Who is competent to author a fire statement
A fire statement is a statutory submission with no licensed author. Here is how competence is evidenced, what membership grades and certification actually cover, and what to ask before appointing.
There is no licence to be a fire engineer in England. Nobody signs a register that makes you legally entitled to author a fire statement, in the way a licensed ecologist is entitled to disturb a bat roost. What exists instead is a competence expectation: the person preparing the statement must have the fire engineering knowledge, skill and experience appropriate to the building, and the applicant carries the risk of choosing badly.
That matters because the fire statement is a statutory submission. Where a development involves a relevant building, Article 9A of the Development Management Procedure Order 2015 requires a fire statement on the published form, and the Health and Safety Executive is consulted on it at Planning Gateway One under the Building Safety Act 2022 framework.
Why competence is assessed rather than licensed
Fire engineering covers everything from a straightforward residential block designed to a published standard to a performance-based analysis justifying a departure from one. A licence would either have to be so broad it meant nothing, or so narrow it excluded most competent practitioners.
The Building Safety Act framework took a different route. It sets out competence requirements for dutyholders and relies on published competence frameworks covering the built environment generally and particular roles within it, with assessment against those frameworks by professional bodies and certification schemes.
The practical consequence for an applicant is that you are buying a judgement about a person rather than checking a number on a register. So ask questions that a competent person can answer easily and an incompetent one cannot.
Institute membership and the grades that mean something
Membership of the professional body for fire engineers is the first filter, and the grade matters more than the letters.
Graduate and associate grades indicate a qualification and an early career. Member grade indicates assessed competence at a professional level. Fellow grade indicates seniority and contribution. For a relevant building at Gateway One, member grade or above is the sensible floor, and the assessing body's own register of fire engineers is a reasonable cross-check.
A membership grade is evidence of general competence, not of competence for this building. A practitioner whose entire experience is industrial warehousing is not the right author for an 11-storey residential block with a single stair, whatever the letters after their name.
Chartered and incorporated engineer routes
Registration as a Chartered Engineer or an Incorporated Engineer, through a licensed institution, adds an independent assessment of engineering competence against national standards, together with a commitment to continuing professional development and a code of conduct.
Chartered status in a related discipline is not the same thing. A chartered building services engineer with fire experience may be entirely competent, and a chartered fire engineer with no residential experience may not be. Read the experience, not the title.
Where the building is complex or the design departs from a published standard, expect a chartered fire engineer and a fire engineering analysis rather than a compliance narrative. That is also the point at which a full Fire Safety Strategy becomes the governing document rather than the planning-stage statement.
Third party certification and what it covers
Certification schemes exist for fire risk assessors and for various fire safety services. They are useful and they are frequently misapplied.
A scheme certifying competence to carry out fire risk assessments of existing premises under the fire safety order is assessing a different activity from designing a new high-rise residential building. Check the scope of the certification and the specific scheme category, not simply that a logo appears on the letterhead.
Where a scheme does cover the relevant activity, it gives you an independently assessed, periodically reviewed position, which is stronger evidence than a membership grade alone.
Ask for the certificate itself rather than a claim. Scheme registers are public and take a minute to search.
What to ask at appointment
Six questions, and the answers should arrive without hesitation.
- What is your membership grade and registration, and with which body.
- Name three buildings of comparable height, use and evacuation strategy that you have taken through Gateway One.
- Which standard or approach will you design to, and will any part be a fire engineered departure.
- Who will actually write the statement, and what is their grade.
- What does your professional indemnity policy cover for this work, and what is excluded.
- What will you need from the design team, and by when.
Question five is not a formality. Professional indemnity cover in fire engineering has been constrained for several years, with exclusions that vary between insurers. A statement authored by someone without effective cover leaves the applicant exposed if the design is later found wanting.
Question four catches the practice that signs off work produced by someone far more junior. That is normal and acceptable in a supervised environment, and unacceptable where the supervision is nominal.
Question six is the one applicants skip, and it costs the most time. A fire statement cannot be written from a site plan. The author needs stair and core layouts, storey heights measured consistently, the intended evacuation strategy, an outline of the facade build-up and the access arrangements for appliances. Commissioning the statement a fortnight before the target submission date, with none of that settled, produces a document full of assumptions that the Health and Safety Executive will query.
Reviewing a statement written by someone else
Reviewers coming to a fire statement from a planning background can do more than they think, because many failures are not technical.
Check the form is the current published one and that every section is completed rather than cross-referenced to a document not submitted. Check the building described matches the planning drawings, including storey heights, stair numbers and the height measurement used to establish whether the building is a relevant building at all. Check the site access arrangements for fire appliances against the site plan, and the water supply position against the utilities information.
Check the height measurement in particular. The threshold that brings a building into the regime is measured in a defined way, and a building described as 17.9 metres on one drawing and 18.2 metres on another has a problem that is better found by a reviewer than by a consultee.
Then check the assumptions. A statement that assumes a sprinkler system, an evacuation lift or a particular facade build-up is making commitments that must appear in the rest of the application. Where those assumptions are not carried through to the drawings, the statement will unravel at the next gateway.
The Fire Statement is a report type where a competent professional is legally required, and an AI-assisted draft is a starting point for that professional rather than a substitute for them. The same applies to anything structural, where the design class and the disproportionate collapse requirements interact with the fire strategy, a relationship covered in our note on disproportionate collapse and building class in design.
Where a reviewer is needed and the design team has nobody suitable, the professional directory is the route to someone who can review and sign off the draft.
This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.
PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
Is there a legal licence to author a fire statement?
No. Unlike an ecologist handling protected species, a fire engineer holds no statutory licence. The requirement is that the author has fire engineering competence appropriate to the building, evidenced through professional body membership, engineering registration, certification scheme scope and relevant project experience. The applicant carries the risk of appointing someone whose competence does not match the building.
Which buildings need a fire statement with the planning application?
Relevant buildings as defined in the Development Management Procedure Order, broadly those meeting the height or storey threshold and containing dwellings or educational accommodation. Where the requirement applies, the statement must be on the published form and the Health and Safety Executive is consulted at Planning Gateway One. Check the current wording of the Order, because the definition has been amended.
Does chartered status in another discipline count?
Not by itself. A chartered building services or structural engineer with substantial fire experience may be entirely competent, and a chartered fire engineer without residential experience may not be. Read the project history rather than the title, and ask for comparable buildings by height, use and evacuation strategy rather than a general statement of capability.
What should I check in a third party certification?
The scope and the scheme category. A certification covering fire risk assessment of existing premises under the fire safety order assesses a different activity from designing a new high-rise residential building. Where the scheme does cover the relevant work, it provides independently assessed and periodically reviewed evidence, which is stronger than a membership grade on its own.
Why does professional indemnity insurance matter here?
Cover in fire engineering has been constrained for several years and exclusions vary between insurers, particularly around external wall construction. A statement prepared by someone whose policy excludes the relevant work leaves the applicant exposed if the design is later found wanting. Ask for the position in writing at appointment rather than after a problem emerges.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.