Approved Document B

Our response to the Review of Approved Document B consultation

Approved Document B is the building regulation in England that covers fire safety matters within and around buildings. The Grenfell Inquiry Phase 2 report, published in September 2024, recommended a comprehensive review of statutory guidance relating to fire safety, particularly Approved Document B. 

As part of this review, the government is consulting on proposals to amend Approved Document B to:  

• Undertake small but important clarifications and technical changes to the guidance within Approved Document B.
• Consolidate guidance for designing building work on existing buildings.
• Introduce a threshold whereby the guidance within Approved Document B should not be applied when combustible elements of structure are used.
• Revise and update guidance on external wall systems and balconies and review the scope of the ban on combustible materials in and on external walls.
• Recommend the provision of evacuation lifts in residential buildings above 18m and clarify the guidance for non-residential buildings.
• Update terminology on 'sheltered housing', introducing the new term 'specialised housing' in its place and include provisions for alarm coverage in these building types to be a minimum of Category LD1.  
• Introduce updated guidance on roofs, including new provisions for the incorporation of photovoltaic (PV) panels.
• Increase the fire resistance rating of open-sided car parks.

We welcome this consultation and have provided our response on behalf of our members. In particular:

• We support the aim of strengthening and clarifying Approved Document B. New guidance should be proportionate, risk-based, evidence-led and practical to apply across new and existing residential buildings to raise standards and improve resident safety.
• We support clearer guidance on existing buildings, external walls and modern roofs, while recommending further clarity on how requirements interact with fire strategies, fire risk assessments, and refurbishment or retrofit works.
• We also support a threshold for combustible structural elements, provided the final approach is evidence-based and considers safety, buildability, cost and sustainability together.
• We support evacuation lifts in taller residential buildings and the move from ‘sheltered housing’ to ‘specialised housing’, but highlight the need for clear definitions, funding, and a flexible, risk-based approach that reflects resident needs, building type, evacuation strategy and feasibility.
• We also raise concern that proposed roof guidance could restrict solar PV on smaller homes and affect social housing retrofit and decarbonisation.