Episode 219 - Approved Document B Consulation

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

Resources from today's episode:

Websites:

• https://www.riba.org/work/insights-and-resources/professional-features/approved-document-b-how-can-architects-shape-the-future-of-building-safety/
• https://consultations.hse.gov.uk/bsr/review-of-approved-document-b-fire-safety/

Thank you for listening! Please follow me on Instagram @part3withme for weekly content and updates or contact me via email me at part3withme@outlook.com or on LinkedIn. 

Website: www.part3withme.com

Join me next week for more Part3 With Me time.

If you liked this episode please give it a rating to help reach more fellow Part3er's!

Transcript

Episode 219:

Hello and Welcome to the Part3 with me podcast. 

The show designed to help Part 3 students kick-start their careers as qualified architects, while offering valuable refresher episodes for practising professionals.

If you’d like to support the podcast and help us keep creating great content, check out the link in the episode notes to subscribe. We also provide one-to-one mentoring to help you prepare for your submissions, exams, and interview, visit our website to learn more, connect with us on LinkedIn via the Part 3 With Me page, find us on Instagram at @part3withme, or email at part3withme@outlook.com.

I am your host Maria Skoutari and this week we will be talking about the latest consultation proposal on changes and updates to Approved Document B. Todays’ episode meets PC3 of the Part 3 Criteria. 

This is not just another regulatory update. Approved Document B is one of the core statutory guidance documents under the Building Regulations, and the current consultation signals a continued shift toward clearer, more technically specific fire safety guidance. The updates to the Approved Document follows as one of the core recommendations relating to fire safety made in the Phase 2 report of the Grenfell Inquiry, which recommended that the document should be placed under “continuous review”, and concluded that the statutory guidance was expressed in an unsatisfactory way, or failed to provide the information needed to design buildings that are genuinely safe in a fire.

So before we get into the detail, it is worth saying what this consultation specifically is about. It is a consultation on proposed changes to Approved Document B, not a final published amendment that has already taken effect. The consultation is being run by the Building Safety Regulator, the Health and Safety Executive, and the Ministry of Housing, Communities and Local Government, and it applies to England only. It was launched on 25th of March 2026 and runs until the 1st of July 2026, so at this stage the important thing is understanding the direction of travel and how architects may want to engage with it.

If you work in practice, you will already know that fire safety guidance is not static. It changes through clarifications, technical revisions, and broader policy shifts, often in response to lessons learned from practice, regulation, and incident review.

So why does this matter for architects:

For architects, this matters because it sits right at the intersection of design responsibility, compliance, risk management, and professional judgment. So the significance of this consultation goes beyond fire engineering. Approved Document B is one of the documents that directly shapes how we translate regulation into form, layout, material selection, and detailing. When that document is revised, the impact is not limited to fire consultants or contractors, it reaches concept design, planning coordination, technical design, and even how we explain our decisions to clients and statutory bodies.

There is also a very practical reason to pay attention. Fire safety guidance affects coordination across disciplines, and Approved Document B revisions can alter the assumptions behind plans, facades, structure, services, and escape strategy. In other words, these are not abstract policy tweaks. They can change the questions asked at design team meetings and the evidence needed to support a compliant scheme.

So what is being proposed under the consultation:

What is notable under the consultation, it touches on eight key area of change: 

• Undertaking small but important clarifications and technical changes to the guidance within Approved Document B.
• Consolidating guidance for designing building work on existing buildings.
• Introducing a threshold whereby the guidance within Approved Document B should not be applied when combustible elements of structure are used.
• Revising and updating guidance on external wall systems and balconies, and reviewing the scope of the ban on combustible materials in and on external walls.
• Recommending the provision of evacuation lifts in residential buildings above 18m and clarifying the guidance for non-residential buildings.
• Updating terminology on ‘sheltered housing’, introducing the new term ‘specialised housing’ in its place, and including provisions for alarm coverage in these building types to be a minimum of Category LD1.
• Introducing updated guidance on roofs, including new provisions for the incorporation of photovoltaic, or PV, panels.
• Increasing the fire resistance rating of open-sided car parks. 

That breadth tells us a lot about where the regulators see current gaps or pressure points in the guidance. The list may sound technical, but the underlying pattern is clear. The regulator appears to be trying to make Approved Document B more explicit, more usable, and better aligned with current building types and current safety expectations. For practitioners, that usually means one thing, fewer assumptions, more defined thresholds, and greater emphasis on early design decisions being justified against current guidance.

Now lets expand on each of the eight key areas:

1. Starting with work on Existing Buildings:

One of the most interesting parts of the consultation is the proposed consolidation of guidance for designing work on existing buildings. That is significant because much of architectural practice is not about new-build work alone it is about retrofit, refurbishment, extensions, change of use, and partial interventions in occupied or complex existing stock.

A more consolidated approach could help reduce uncertainty, especially where architects are navigating older building fabric, legacy conditions, and varying levels of fire protection. It may also help align expectations across projects where the work is less than a full rebuild but still substantial enough to trigger serious fire safety considerations. This is a useful reminder that compliance often depends not only on what the rules say, but on how we interpret them in the context of the existing building.

This part of the consultation also speaks to a wider profession-wide challenge. Existing buildings are often where judgment is hardest, because the design team is balancing heritage, reuse, commercial pressure, buildability, and safety. A clearer Approved Document B framework for existing buildings would not remove professional judgment, but it could make that judgment easier to defend and explain.

2. Now moving to the third and fourth key areeas of change which relates to External Walls and Combustible Materials which come hand in hand:

This change proposes the introduction of a threshold at which Approved Document B guidance should not be applied when combustible elements of structure are used. This is a crucial area because it affects the boundary between permitted design approaches and the point where a scheme may need a different level of fire strategy, scrutiny, or alternative compliance route.

The consultation also proposes to revise and update guidance on external wall systems and balconies, and to review the scope of the ban on combustible materials in and on external walls. For architects, this is one of the most consequential areas because external wall design is often where architecture, fire safety, energy performance, and aesthetics collide. A revision here will likely influence material choices, façade build-ups, and the level of coordination needed before planning and technical submission.

It is worth being careful here in that the consultation is simply proposing changes it is not yet the final rulebook. So the right professional response is not to speculate wildly, but to watch the direction of travel, review existing design assumptions, and be ready to adapt specifications and fire strategies if the final guidance moves in the same direction.

3. Now moving to the fifth and sixth key areas of change which relate to Evacuation and Sheltered Housing:
 The consultation proposes recommending evacuation lifts in residential buildings above 18 metres and clarifying the guidance for non-residential buildings. That is a meaningful development because it reflects the increasing emphasis on inclusive evacuation planning, not just on means of escape in the most traditional sense. For taller residential buildings, the question is no longer only how people exit in an emergency, but how people with mobility impairments can do so safely and with dignity.

The proposal to update terminology from “sheltered housing” to “specialised housing” is also important. Terminology matters in regulation because it shapes interpretation, scope, and design expectations. The inclusion of minimum Category LD1 alarm coverage in those building types suggests a more demanding baseline for alarm provision where vulnerable occupants may be present as LD1 is the highest level of life protection alarm coverage.

For designers, this is another reminder that fire safety is not a one-dimensional issue. It is about the interaction between occupant profile, building height, detection, alarm, evacuation strategy, and operational management. In that sense, the consultation aligns with a broader building safety culture that looks beyond simple compartmentation and escape distance.

4. Next, let’s look at the seventh key area of change relates to Roofs and Photovoltaic panels:

The consultation proposes updated guidance on roofs, including new provisions for incorporating photovoltaic panels. This is particularly relevant at the moment because PV is now routinely part of sustainability-led design, but it brings fire safety considerations that need to be integrated rather than appended later.

This is key because architects are increasingly expected to design buildings that are low carbon and low risk at the same time. If the guidance evolves to more clearly address PV panels, that could help reduce uncertainty in specification and detail design, especially on larger or more complex roofscapes. It also reinforces the need for early coordination with fire engineers and MEP teams, rather than treating roof systems as purely environmental infrastructure.

5. And lastly, the final key area of change is increasing the fire resistance rating of open-sided car parks:

This essentially relates to the introduction of a threshold whereby the guidance within Approved Document B should not apply when combustible elements of structure are used. This acknowledges that certain structural systems, for example, mass timber construction, behave differently in fire conditions and may require an alternative approach to compliance, rather than direct application of Approved Document B guidance.

So what does this mean for architects and what should their next steps be:

• They should engage with this consultation before it closes on 1st of July 2026 as this is a direct opportunity to influence how fire safety guidance is shaped for the profession.
• Any proposed changes to guidance on external wall systems and the combustible materials ban will directly affect how materials are specified and façades are designed, particularly on buildings above 18m, so close attention should be paid to that.
• The proposed provision of evacuation lifts in residential buildings above 18m will have design and cost implications that practicioners will need to factor into projects at feasibility stage.
• The updated guidance on specialised housing and alarm coverage will affect how sheltered or specialised housing schemes are approached. Category LD1 coverage requires a comprehensive detector strategy across the entire dwelling.
• The new guidance on PV panels means that where renewables are incorporated into the roof design, practicioners will need to be alert to updated fire safety requirements.
• The proposal to consolidate guidance for existing buildings is particularly relevant if practices work on refurbishment, heritage, or retrofit projects.
• Across all of these proposals, there is a broader message, Approve Document B is now under “continuous review”, which means keeping up to date with evolving guidance is no longer optional it is a professional responsibility.

The consultation page makes clear that responses are encouraged through the online survey, and written responses are also accepted if clearly labelled with the relevant questions. For a profession that often says it wants to shape regulation, this is one of the moments where that statement can become real.

Let’s sum up what we ran through today:

• Approved Document B is the government guidance covering fire safety under the Building Regulations, and it is fundamental to how architects approach fire safety in design.
• The current consultation has been launched by the Building Safety Regulator, the Health and Safety Executive, and the Ministry of Housing, Communities and Local Government, and runs until 1 July 2026.
• The proposals stem directly from the Phase Two report of the Grenfell Inquiry, published in September 2024, which made 58 recommendations and called for Approved Document B to be placed under continuous review.
• There are eight areas of proposed change, covering external wall systems and the combustible materials ban, evacuation lifts in buildings above 18m, updated terminology and alarm provisions for specialised housing, new guidance on PV panels in roofs, a combustible structure threshold, and an increase in the fire resistance rating of open-sided car parks.
• These proposals relate to England only, and architects should engage with the consultation to ensure the profession’s voice is heard in shaping the final guidance.

For architects, and especially for those preparing for or working through Part 3, the message is clear. Stay informed, read the detail, and think about how fire safety guidance shapes the decisions you make from the first sketch to the last specification note.