While the Labour government's ambition to accelerate housebuilding is welcome, this goal must not come at the expense of safety – which needs to be central to design, construction, remediation and conversion.
But an August fire in a high-rise building in Dagenham, east London, and the publication of the Grenfell Tower Inquiry phase 2 report the following month, together serve as stark reminders of the catastrophic consequences of letting safety take a back seat.
Occupant safety should be critical to industry thinking
One of the crucial reforms that the Hackitt review called for was culture change in the construction industry.
At the heart of this change is ensuring honesty and integrity. Individuals and organisations need to make the right decisions, act ethically and do their duty, without exploiting opportunities to benefit from unclear lines of responsibility.
Only with such change and better regulation will building safety be improved.
It must be at the forefront of developers' minds that these buildings will become homes where families will reside, and do so assuming they are safe.
Guidance seems at odds with legislation
Whether the statutory guidance underpinning the Building Regulations is fit for purpose must also be considered.
In 2019, the previous government committed to a full technical review of Approved Document B of the Building Regulations within five years, but this review is still ongoing with some areas still to be started.
The Grenfell Tower Inquiry phase 2 report reiterated that the Approved Documents needed reviewing 'as a matter of urgency', citing in particular Fire safety: Approved Document B.
At the National Fire Chiefs Council (NFCC), we have long been concerned about this guidance and its treatment within industry. As we see it, the Labour government has inherited a Building Regulations regime that has been amended but not fixed.
For example, the requirements of Fire Safety: Approved Document B were updated in March 2024 to building design guidance to include the need for secondary stairs for residential buildings of 18m and above from September 2026. However, the changes did not extend to making provision for those occupants who are less mobile.
Neither did the changes reflect the need to meet the functional requirements, which are the foundation for whether or not a building is compliant. The guidance is, in NFCC's view, not capable of enabling compliance with the regulations. Even if one follows Fire Safety: Approved Document B or other guidance, this doesn't ensure compliance; however, people still often assume that it does.
This only serves to create the level of ambiguity we see heavily criticised by the Grenfell Inquiry phase 2 report. NFCC firmly believes that the regulations cannot be separated from, or less than, the principles of the functional requirements.
Building Safety Act 2022 recognised the intrinsic relationship between construction and occupation. This is emphasised by the requirement it introduced at gateway two of the regulatory process, which a project must pass if construction is to proceed: namely, to identify the measures, strategies and policies that ensure anyone in the building can evacuate safely in an emergency.
However, the failure of the revised Fire Safety: Approved Document B to include requirements for lifts to enable such evacuation by everyone means that the guidance is seemingly at odds with the legislation.
Grenfell Inquiry phase 2 report also criticised the lack of fire safety consideration in the planning process, and the need for competent fire engineering advice not only to be sought but heeded.
Support on access and egressibility lacking
The inadequacy of the Building Regulations is further exposed in relation to accessibility. Although Access to and use of buildings: Approved Document M provides for this, there is no provision yet for ensuring the equivalent level of so-called egressibility; that is, making a means of evacuation accessible.
When it comes to the construction of buildings, the industry must address any implicit bias in terms of ableism, especially when the Grenfell Tower fire drew attention to the need to accommodate those with limits to their mobility.
Construction needs to ensure the safety of firefighters responding to incidents in high-rise buildings as well. Many of the features that provide safe egress and refuge for those evacuating are also vital to support the efforts of emergency services.
Unfortunately, we have learned since the Grenfell Tower fire and subsequent reviews that a number of buildings have not been built or refurbished to appropriate standards.
NFCC does not believe that the principle of installing high levels of compartmentation, which by default supports stay-put strategies, should obviate the need for measures that enable people to leave a building safely should they wish to.
The current law requires that all residents and lawful visitors are able to evacuate to a safe place outside the building without needing external assistance. There should always be a plan B to enable evacuation in an emergency, and paramount in doing so is providing a safe means of escape for people with disabilities.
Although Fire Safety: Approved Document B does not make provision for evacuation lifts, this is a requirement in the London Plan 2021. There will be local plans in other places enforcing similar requirements for the safe egress of those with mobility limitations – but some living elsewhere in the country will have no such protection, in effect creating a safety lottery.
The Building Regulations require that 'All people can escape to a place of safety without external assistance'.
'All people' includes people with disabilities, so the fact that Fire Safety: Approved Document B does not include specific guidance in that regard reflects that many of the assumptions are still based on pre-war research on evacuation times, and other historical studies that studied only able-bodied participants.
A rapid evidence review, published by the Home Office in February 2024, considered international research, which found that evacuation lifts have the potential to be used effectively during an emergency, reducing the overall time taken to escape high-rise buildings, and enabling egress by residents, such as wheelchair users with severe movement impairments, who might otherwise have to remain in the building.
'When it comes to the construction of buildings, the industry must address any implicit bias in terms of ableism'
Safety must be built into process
Ultimately, whatever the type of building, safety must not take a back seat as it has done and must instead be built into the process.
A lack of research, standards, regulations or benchmarks for competence may threaten the safety of building occupants – or require the industry to provide costly mitigation, due to a lack of understanding about what good looks like – something set out so clearly in the Hackitt review.
Government and industry must have serious intent to learn the lessons of the past, which is why NFCC welcomes the Grenfell Tower Inquiry phase 2 report finding that the implementation of the review's formal recommendations should be tracked and monitored.
These are the challenges the government must address to meet its housing targets, and to also ensure buildings are designed and constructed to be suitable for those who will call them home.