Episode 180 - BS9991:2024

This week we will be talking about the updates made to BS 9991:2024 relating to Fire Safety in the design, management and use of residential buildings. This episode content meets PC3 - Legal Framework & Processes of the Part 3 Criteria.

Resources from today's episode:

Websites:

• https://www.constructionleadershipcouncil.co.uk/wp-content/uploads/2025/03/CLC-BS-9991-Advisory-Note-17.03.2025.pdf
• https://knowledge.bsigroup.com/products/fire-safety-in-the-design-management-and-use-of-residential-buildings-code-of-practice-2
• https://www.constructionleadershipcouncil.co.uk/wp-content/uploads/2025/03/Letter-to-CLC-BS-9991_2024-14.03.2025.pdf

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Transcript

Episode 180:

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I am your host Maria Skoutari and this week we will be talking about the updates made to BS 9991:2024 relating to Fire Safety in the design, management and use of residential buildings. Todays’ episode meets PC3 of the Part 3 Criteria.

Before we look at the updates, what is the BS 9991:2024 - Fire safety in the design, management and use of residential buildings about:

This British Standard is one of the UK’s most widely used fire safety standard and gives guidance on ensuring an adequate degree of life safety is achieved in the event of fire in residential buildings and provides a level of protection for property and businesses in proximity to residential buildings. 

It is mainly aimed to be used by anyone involved in buildings fire protection, including architects, fire risk assessors, fire safety engineers, builders, fire and rescue services and regulators.

The update to the standard was released in November 2024 superseding the 2015 version capturing changes to be aligned with new legislation relating to the Building Safety Act. 

A key item to note is that this Standard is not mandatory but voluntary as it is considered the industry’s good practice guidance. The Building Safety Regulator has been clear that it is not statutory guidance and so design teams can choose to adopt it or not. 

So what does the BS 9991:2024 cover and why should it be used:

The standard provides recommendations and guidance on the design, management and use of dwellings, flats, residential accommodation blocks with individual bedrooms and the provision of kitchens and/or sanitary facilities, specialised housing and care homes to achieve reasonable standards of fire safety for all people in and around such buildings. 

The standard provides comprehensive guidance and detailed recommendations on fire safety tailored specifically to residential buildings, addressing various building types and fire safety scenarios. This is to ensure that fire protection measures are appropriate and effective for residential environments.

The standard also ensures that fire safety measures are designed to protect everyone in and around residential buildings, including vulnerable groups such as children, the elderly, and individuals with disabilities. It helps ensure equitable protection across the board.

In addition to occupant safety, the standard includes provisions for assisting fire and rescue services and providing environmental protection. As well as providing clear principles for the design and ongoing management of residential buildings, making it easier for professionals to implement fire safety systems that meet national expectations and adapt to the building's unique needs.

The 2024 standard reflects the latest legislation as well as emerging trends in fire protection, ensuring that professionals are using the most up-to-date methods and technologies in fire safety planning. As residential buildings present unique fire safety challenges the addresses these in its guidance, ensuring a more effective fire safety approach for such environments.

By following the standard, professionals can design buildings that proactively mitigate fire risks, from construction materials to building layouts, ensuring that potential fire hazards are addressed early in the design phase. The standard helps standardise fire safety practices across different residential projects, ensuring consistent application of safety principles and reducing variability that could lead to higher fire risks. It also encourages innovative approaches to fire safety in modern residential architecture, such as in high-density urban living or sustainable building design, while maintaining safety as a priority. 

So what changed in the 2024 version compared to the 2015 standard:

• Alongside aligning with the latest legislation updates, the standard also updates changes in respect of fixed firefighting systems, and in view of the lack of evidence in support of the efficacy of other systems at this time, the standard has been updated to refer solely to sprinkler systems for all buildings above 11 metres,
• The 2024 version no longer makes any explicit exclusions on timber,
• The scope of the standard has been limited in terms of reaction-to-fire classifications of load-bearing elements of structure to better reflect the available evidence on the use of mass timber in medium and high residential buildings, though this applies to all materials, not just timber,
• This change also removes the link between reaction-to-fire classification and number of stairs,
• The limit on building height is capped at 100m in the scope, based on the general principles given in the SFPE guide on very tall buildings. Additional considerations for buildings over 50m are detailed in the text where appropriate, and residential care is now included in the scope,
• Mechanical smoke control is now required for buildings whose top storey exceeds 30 meters. Natural smoke shafts are only allowed below this threshold,
• Improved requirements have been included for smoke control in protected lobbies and adjacent corridors, aiming to minimize smoke exposure and maintain safe evacuation routes,
• Automatic Opening Vents must now be classified by aerodynamic free area rather than minimum free area.
• Every new building with a lift for access must have at least one lift suitable for evacuation—this can be a circulation lift with appropriate protection, not necessarily a dedicated additional lift and every evacuation lift must be accessed from a protected waiting space either within a stair or lobby. Evacuation lifts default should also be set to driver-assisted mode, with the option for automatic mode where staff are not always present.

To assist with the industry’s shift to the updated version, in March this year, the Construction Leadership Council published a very useful guide in respect to the adoption of BS 9991:2024 for those preparing building control approval applications for higher risk buildings. 

This guidance provides some clarity if the BS 9991:2024 is chosen to be adopted by design teams as a route to compliance under the Building Regulations. These include that:

• Planning applications made from the date of the advisory note, which was the 17th 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, as some parts of BS 9991:2015 are no longer compliant. 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, when the scheme involves a higher risk building and BS9991:2024 is chosen to be adopted, there are certain steps that need to be followed under the Gateways. 

• Under Gateway 1, where applicants are required to submit a Fire Statement alongside their Planning Application, attention should be given to the requirements to record through the Fire Statement which fire safety design guidance will be adopted during the design phase following confirmation of planning approval. Meaning if BS 9991:2024 or any other guidance is chosen to be followed, this needs to be stated within the Fire Statement. This commitment should be referencable throughout the design, including addressing any amendments to building regulation functional requirements and or updates to design codes. The commitment and or amendment to the fire safety design approach taken should be captured as part of the golden thread.
• Under Gateway 2, if the BS9991:2024 is the chosen guidance stated under Gateway 1, applicants submitting the Gateway 2 application should demonstrate how the design remains compliant with the relevant functional requirements of the building regulations. In addition, a conclusion of the assessment of the standard should be presented by the applicant, with an affirmative statement of compliance to Part B of Schedule One of the Building Regulations 2010 (as amended).

What is the Building Safety Regulators position with the updated standard:

Generally, the Building Safety Regulators position on the standard for higher risk buildings is that applicants are expected as mentioned to set out their approach taken to each element of the higher risk building work. The Regulator expects applications to give clear reasons for adopting the approach taken and explain how and why the approach ensures compliance with the functional requirements. 

The Regulator therefore expects that building work must be able to demonstrate, for common buildings (i.e. including “common” Higher Risk Buildings), a level of safety at least comparable to the one provided in the relevant version of Approved Document B (i.e. version applicable when the building regulation application is deposited). Through this approach designers will need to ensure that an at least equivalent level of safety is provided in new developments where there have been changes to the guidance, code or standard followed in the design, taking into consideration any relevant transitional arrangements of the statutory guidance. In all cases, the Regulator will remain pragmatic when considering Higher Risk Building regulations applications.

To sum up what I discussed today:

• As of November 2024, BS 9991:2024 superseded the previous 2015 version and provides detailed, up-to-date recommendations for fire safety in various types of residential buildings, aligning with recent legislation such as the Building Safety Act. It aims to address unique fire safety challenges in residential environments and ensure consistent, effective practices across the industry.
• The standard is voluntary and serves as the industry’s good practice guidance rather than legal requirement. Adoption is at the discretion of the design team, but it is treated as a benchmark by professionals and regulators.
• Key changes include, exclusive reference to sprinklers in buildings above 11m. No specific exclusions for timber and a redefined scope regarding structural fire classifications for all materials. Height limits set at 100m, with specific provisions for buildings above 50m and care homes now included. Mandatory mechanical smoke control for buildings over 30m and improvements in smoke control for lobbies/corridors. Introduction of enhanced requirements for evacuation lifts and protected waiting areas.
• The Regulators view of the standard are that while BS 9991:2024 is not statutory, applicants for higher risk buildings must clearly justify their choice of guidance and demonstrate compliance with building regulations. New planning and control applications after March 17, 2025, and Gateway 2 submissions after September 30, 2026, are expected to use BS 9991:2024, with transitional arrangements clarified for in-progress projects. The Building Safety Regulator requires a level of safety at least equivalent to current Approved Document B and expects clear, documented rationale for chosen approaches.