Episode 162 - *Bonus* Approved Document B Further Updates

This week we will be talking about the current legislation changes to Approved Document B and changes to follow. This episode content meets PC3 - Legal Framework & Processes of the Part 3 Criteria.

Resources from today's episode:

• https://www.architecture.com/knowledge-and-resources/knowledge-landing-page/what-architects-need-to-know-about-changes-to-approved-document-b
• https://www.architecture.com/knowledge-and-resources/knowledge-landing-page/how-can-architects-access-printed-versions-of-approved-document-b?utm_campaign=Member Update 030425&utm_content=Read more&utm_term=&utm_medium=email&utm_source=Adestra
• https://www.gov.uk/government/publications/fire-safety-approved-document-b

2025 Updates:

https://assets.publishing.service.gov.uk/media/67c1ac3d16dc9038974dbcfe/2025_Amendments_to_Approved_Document_B_volume_1_and_volume_2.pdf

2026 Updates:

https://assets.publishing.service.gov.uk/media/66d57a94d107658faec7e448/AD_B_2026_amendments.pdf

2029 Updates:

https://assets.publishing.service.gov.uk/media/66d57aaabdecebe01a18341b/AD_B_2029_amendments.pdf

Combined Updated Approved Document B:

https://assets.publishing.service.gov.uk/media/67d2bb074702aacd2251cb94/Approved_Document_B_volume_1_Dwellings_2019_edition_incorporating_2020_2022_and_2025_amendments_collated_with_2026_and_2029_amendments.pdf

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Transcript

Episode 162:

Hello and Welcome to the Part3 with me podcast. 

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I am your host Maria Skoutari and this week we will be talking about further legislation changes to Approved Document B and changes to follow. Todays episode meets PC3 of the Part 3 Criteria.

Make sure to stay until the end for todays scenario. 

Back in episode 111, we spoke about amendments that were made to Approved Document B Volumes 1 and 2 to capture the second staircase requirements within tall residential buildings, updates to interlocking stairs, evacuation shafts and changes to the provisions for fire doorsets.

Now, as of March 2025, a number of other updates have been made to Approved Document B. These updates signify the end of a cycle that began in 2022, when the Department for Levelling Up, Homes, and Communities launched the Fire Safety in Buildings consultation for sprinklers in care homes, removal of national classes, and staircases in residential buildings.

The government published three amendment booklets on 2nd September 2024 to the guidance to the building regulations on fire safety which consisted of:

• The first amendment booklet, coming into force on 2 March 2025, contains Regulation 38 and fire safety information, the removal of references to BS 476 in relation to reaction to fire and roofs and introduce new guidance around the provision of sprinklers in care homes. This change ends the dual system for classification in favour of the European Standard (BS EN 13501 series) alone.
• The second booklet, coming into force 30th September 2026, included the re-issue of the previous guidance on second staircases in 18m+ residential buildings for procedural reasons and also includes design provisions to support the use of evacuation lifts in blocks of flats under volume 1.
• The third booklet, coming into force 2nd September 2029, contains the removal of references to BS 476 in relation to fire resistance ending the situation where there are two alternative ways of demonstrating compliance, and remove confusion surrounding potential “equivalence”, simplifying the system for specifying architects. There will be a transition period relating to this ending in 2029. 

All three updates have now been consolidated into one document and can be accessed from the website and its officially titled Approved Document B: Fire Safety - Volume 1: Dwellings (2019 edition incorporating 2020, 2022 and 2025 amendments and forthcoming 2026 and 2029 changes).

The amendments stated within booklet one, as of March 2025 have come into force and as mentioned relate to the provision of sprinklers for all new care homes irrespective of height. New care homes will be expected to limit compartment sizes to 10 beds while ensuring self-closing devices are fitted to doors. These changes also remove all previous allowances when sprinklers are provided, which previously allowed increased number of beds per compartment and the removal of self-closing devices for doors, these updates are provided under Volume 2 for buildings other than dwellings. 

In terms of the Regulation 38 updates, it aims at enhancing fire safety practices focusing on improving the clarity, accountability, and transfer of fire safety information. The key updates under Regulation 38 in Volume 1 and 2 includes detailed obligations for duty holders in providing comprehensive fire safety information to the responsible person which the responsible person is then required to formally acknowledge receipt of such information and its adequacy. Additionally, third-party certification schemes are mandated to ensure that fire safety information is accurately communicated to authorities, creating a clear and accountable documentation trail. 

So when it comes to Reaction to fire, as mentioned, the update to guidance removes the national classification system (BS476) for reaction to fire and roofs from Approved Document B, which provides statutory guidance for fire safety in new building work. The European Standard (BS EN), deemed more current and robust than the National Classes, will be the sole route of specification within Approved Document B for reaction to fire and roofs classifications.

In relation to the second booklet which republishes the amendments in relation to second staircases in 18m-plus residential buildings first issued in March 2024. As previously announced these amendments will still come into force on the 30th of September 2026 with a further 18 months for these projects to start and sufficiently progress on site within that timeframe. Meaning that designers working on potential projects affected should advise their clients that building control approvals received before this date must have started and sufficiently progressed within the period of 18 months beginning on that day. Otherwise, any approval will lapse and a new application, in line with the current regulations at the time of submission, will apply. This could incur significant redesign and reprogramming in respect of a second stair being accommodated. The second staircase requirements are stated within Volume 1 for dwellings which also provides updates to fire Dorset requirements. Volume 2 provides clarification notes regarding evacuation lifts, shaft and exit passageway as well as inner room and storey exit.

In support of the changes under the second updated, similar guidance in BS9991:2024 is in effect already to support the Part B changes and was updated in November 2024. BS9991:2024 relates to ‘Fire safety in the design, management and use of residential buildings’, the previous version was updated in 2015. BS 9991 is commonly used during the design of residential buildings, and particularly higher-risk buildings, as an alternative to statutory guidance, the BSR reminds designers that they will still need to demonstrate a level of safety at least equivalent to that provided by Approved document B. The reason why this standard was also updated was due to the fact that the 2015 version pre-dated the Grenfell Tower fire and given it is most commonly used during the design of residential buildings, and particularly higher-risk buildings an update was required to capture the new regime requirements. The key changes made to the standard include:

• The height limitation on buildings with a single stair
• Where a building has lifts they should be provided with a means of using lifts for escape.
• It also provides expanded guidance on residential care homes, evacuation lifts, revised height limits for sprinkler installation and a recommendation that buildings over 18m should have at least two stairs
• Some previous exclusions of load-bearing timber elements in structures, based on their reaction-to-fire classifications, have now been removed from the updated standard.

The advisory note provides some clarity if you are choosing to adopt recommendations within BS 9991 as a route to compliance under the Building Regulations:

• Planning applications made from the date of the advisory note (17 March 2025) should adopt BS 9991:2024.
• Building control applications made at Gateway 2 where designs have been progressed using BS 9991:2015 are required to clearly state how building work remains compliant to Part B of Schedule One of the Building Regulations (some parts of BS 9991:2015 are no longer compliant) and why. Applicants are encouraged to demonstrate that relevant recommendations from BS 9991:2024 have been assessed and adopted where reasonably practicable to do so.
• From 30 Sept 2026, Gateway 2 applications that have adopted BS 9991 should use BS 9991:2024.

Now as mentioned there is a third booklet under the Approved Document Updates, which as of 2nd September 2029, changes focus on fire safety provisions following the removal of national classes for fire resistance in both Volumes 1 and 2. The European Standard (BS EN), deemed more current and robust than the National Classes, will be the sole route of specification within Approved Document B for fire resistance classifications. References to BS476 in relation to broader fire resistance testing of products and materials will be removed following a transition period that ends on this date.

The aim of this phased approach to the amendments to be made to Approved Document B is to enable designers and other industry professionals to be aware of the changes and schedule them in accordingly. 

To sum up what I discussed today:

• New updates have been made mandatory under Approved Document B as of March 2025 with further updates to follow in 2026 and 2029. 
• As of March 2025, new guidance includes removal of references to BS 476 in relation to reaction to fire and roofs and introduce new guidance around the provision of sprinklers in care homes.
• As of September 2026, new guidance will be implemented where a building has lifts at least one should be an evacuation lift and for more than one common stair to be provided in blocks of flats with a storey 18m or more in height.
• As of September 2029, new guidance will be implemented removing national classes of references to BS476 in relation to fire resistance. 
• Architects must plan ahead and advise clients early to align with changing standards and avoid costly redesigns.