CIH submission to the Review of Approved Document B: Fire Safety consultation

Questions 3, 4, 5, 6, 7 and 8

We support the consultation’s clarifications of Approved Document B to improve understanding of the requirements. The social housing sector has seen increased regulatory and legislative oversight in building safety in recent years, and it is important that all parties understand their duties and responsibilities in keeping residents safe. The regulations and policy requirements in this area can be complex to manage, and it is vital that the government is clear where and how overlapping policies and processes work together in a joined-up, coherent approach (such as with the Housing Health and Safety Rating System and Awaab’s Law hazards).

In our response to the Industry and Regulators Committee inquiry into the BSR in 2025, we highlighted serious concerns in the fragmented guidance, gaps in technical capacity, and lack of feedback in the building safety environment. Whilst we recognise the improvements from the BSR in recent months to tackle these issues and delays, it continues to be a complicated system with a lack of transparency or understanding of expectations. CIH collaborated with the Building Safety Alliance to produce guidance on the ‘golden thread’ of building safety, as required in the Building Safety Act. This is part of our ongoing commitment to improving implementation throughout the sector regarding building safety, and we are particularly clear on the role of residents, culture and stigma in learning the lessons from the Grenfell Tower fire.

The proposed text makes it clear that safety is ongoing and not set at one point-in-time, which CIH has always argued. Safety cannot be treated as a tick box exercise that is never reviewed or improved upon, as it can leave residents living in vastly different standards of housing, with inconsistent approaches to building safety. All parties must be encouraged to regularly review their building safety approach and listen to residents about what is and what is not working, to improve their service delivery and processes. This requires holistic culture change in the building safety sector, for housing providers, construction companies and manufacturers to work together to listen, learn, and improve.

We also welcome the move back to performance-based guidance. In our response to the BSR inquiry, we argued that this performance-based approach is necessary for overall improvement in building safety. We outlined where this is working well in European contexts, where the system shows what ‘good’ looks like across the lifecycle of the building, not just at the construction stage, with clear expectations in applications and designs. In particular, Denmark and the Netherlands have performance-based approaches to building safety, which we believe can provide key lessons for the approach in this country.

However, Approved Document B must include more explicit guidance on communicating and working with residents when building safety works are planned. Residents must be informed beforehand, particularly when fire safety measures and evacuation procedures will be temporarily affected. This includes changes to sprinklers, fire prevention measures, and evacuation routes. Residents must be at the heart of all decisions, with the impact clearly communicated to all residents, including through accessible communication methods.

Questions 17, 18, 19, 20, 21 and 22

We support the guidance outlined on evacuation lifts. It can be argued that the ‘stay-put’ policy for fire evacuation has largely failed disabled and mobility-impaired residents, as they are often excluded within this framework. Research has shown that often accessibility is treated as secondary, as residents must overcome daily barriers regarding safety, which reinforces stigma. We agree that the introduction of a requirement for two evacuation lifts in buildings over 18m will have a positive impact on society, especially for protected groups characterised under the equalities act for age, disability and pregnancy and maternity.

We have therefore supported the Resident Personal Emergency Evacuation Plans (RPEEPs) as this ensures that residents with mobility issues restricting evacuation remain high priority, and that this is regularly reviewed and updated. Residents and their needs must be central to all decisions and designs of new homes, including in the evacuation and lift procedures.

It is also crucial that evacuation lifts are not only thought of in the design phase, but throughout the management of the building throughout its life. Engagement is crucial, as residents must know how the lift works and what their evacuation plan is. We would recommend that the guidance includes more explicit requirements for resident communication of evacuation procedures, as well as regularly updating staff training to support responses to residents’ questions and concerns.

We believe the 18m threshold is clear and aligns with the High-Rise Buildings (HRB) regime and second staircase requirement. This alignment is necessary to avoid additional complexity and confusion within the building safety regulatory and legislative environment, to ensure all providers and parties are clear on their responsibilities and duties to keep residents safe.

Questions 23, 24, 24a, 25, 26, 27, 28 and 29

We support the terminology change to ‘specialised housing’, which allows for a greater understanding of the different types of housing within this area, including for specialised housing with or without care. However, we think it is important to note that care needs can and do evolve over time, so there should be guidance provided on how to review this distinction on an ongoing basis for providers.

We also support the enhanced alarms as the preferred approach. Audio alarms alone are often not enough and exclude groups of people who also need access to emergency alerts. This is part of a wider piece required within the guidance on accessible resident communication of building safety requirements and procedures, particularly for residents with hearing impairments, cognitive difficulties or sensory differences who may not respond as expected. Providers must consider all these different resident needs in building safety design and management, and guidance for consistency and best practice would be helpful in this area, with input from sector experts and residents.

Additionally, Responsible Persons obligations (testing, maintenance, and communication) should be more explicit within the guidance, linked to the fire risk assessment alignment in Section 4. Installing alarms is crucial as part of the design process but ensuring these are working and engaging regularly with residents to check that they know the response process is a longer-term housing management area. The guidance must cover management, not just design, to ensure it is effective in practice, and may be helpful to link to the Responsible Persons Toolkit under RPEEPs.

Questions 37, 38 and 39

The impact assessment for the consultation only considers the quantifiable costs and benefits of the proposals. Yet, there are real and tangible benefits that are not counted within the impact assessment that we believe it would be helpful to highlight. This includes resident feelings of safety and trust, which are essential to understanding if the changes are successful and effective. Whilst these are less easy to quantify, it is possible to achieve.

The Tenant Satisfaction Measures are a key method for this, as well as surveys, resident engagement, and feedback. The impact assessment should not only focus on the cost, but the impact, particularly on residents. Research has demonstrated that learning from resident experiences, and the practical reality of how they live within their homes, is crucial in responding to changes needed in the building safety regime, as there is a profound emotional and financial toll on residents living in unsafe buildings. Delays in remediation exacerbate stress, financial insecurity, and mistrust, are all costly to the relationships between residents and providers, as well as resident health and wellbeing.

Whilst we believe that the proposals in this consultation will make a positive impact upon protected groups, it is important that social housing residents in protected characteristics are not excluded from decision-making or improving the building safety regime. The consultation could and should go further in making communication obligations clear and mandatory for providers, to ensure fairness and equality within all design and management decisions, and engagement with residents.

It is important that the costs and benefits of the proposals are seen holistically within the social housing context. There must be clear alignment within government for policy areas to interconnect and align, to ensure joined up working between building safety, development, net zero, and housing management policies. This will enforce the importance of building safety at the centre of all housing decision-making and avoid siloed ways of working or inconsistent and complex operating systems for providers to navigate, ultimately impacting upon residents.

For more information on this response, please contact: policy@cih.org