Fire strategy for change of use applications, explained

A change of use can alter a building’s fire-safety requirements, even when its structure remains unchanged. A fire strategy for change of use applications records the proposed fire-safety design and the reasoning behind it, including escape arrangements, measures to limit fire and smoke spread, and fire-service access. For a UK Building Regulations application, it supports Building Control approval and safe operation after handover. Building control generally expects a written strategy explaining how the design meets Part B, except for simple houses.

It’s understandable to focus first on whether planning permission is needed, but planning and building regulations address different parts of a proposed change. In England, some qualifying planning applications also require a fire statement, while Approved Document B is commonly used to demonstrate compliance with the Building Regulations. This article explains what a fire strategy covers, how planning requirements differ from building control, and when a fire-engineered approach may be relevant. It also explains why a building’s existing fire arrangements may need review when its use changes.

What Is a Fire Strategy?

A fire strategy records a building’s fire-safety design and explains how its features work together. For a change of use, it helps establish whether existing arrangements remain suitable for the premises and its occupants.

Compartmentation and Fire Resistance

Compartmentation uses fire-resisting walls, floors and doors to restrict fire and smoke spread between areas. Its purpose is to protect escape routes and give people time to reach safety. A strategy records the required performance of these barriers, with fire-resistance examples including 30, 60 and 120 minutes. Gaps around services, damaged doors or unsealed joints can undermine that protection. The assessment therefore considers both the barrier and how openings through it are protected.

Changes to Escape Routes and Compartmentation

Alterations can change how people reach an exit and whether fire-resisting boundaries remain continuous. For example, a new doorway through a protected corridor wall may require a suitable fire door and careful detailing around its frame. Changes to room layouts can also affect travel paths, exit access and separation between different uses. The strategy should show how escape arrangements and compartmentation will work together after the changes, including where services pass through protected construction.

Occupancy and Fire Protection Systems

Occupancy and building use influence the fire alarm, emergency lighting and sprinkler provisions needed to support safe evacuation. The expected number of occupants, their familiarity with the premises, the layout and the activities all inform how these systems support warning, escape and fire control. A change from offices to sleeping accommodation, for example, changes the context for assessing warning and evacuation arrangements. System selection should align with the fire strategy, rather than being considered separately from escape routes and compartmentation.

Preparing and Signing Off a Fire Strategy

A competent fire engineer or fire-safety professional prepares the report, while Building Control considers whether the design demonstrates compliance. For a fully fire-engineered approach, a chartered fire engineer can assist with the technical analysis. There isn’t a single professional signature that replaces regulatory review: the report’s author explains the design, and Building Control assesses it through the application process. In England, UK Parliament describes a higher-risk building as 18 metres or seven storeys high and containing two or more residential units.

Planning fire safety strategies and Fire Statements

A fire strategy may support a planning proposal, a Building Regulations application, or both, but these processes address different matters. In England, planning applications made on or after 1 August 2021 are subject to the fire-safety planning gateway requirements described in the guidance, according to the Ministry of Housing, Communities and Local Government. A fire statement applies to qualifying development involving a relevant building, development of one, or development within its curtilage, unless an exemption applies.

A fire statement addresses fire-safety matters relevant to land-use planning. It should cover the whole development site shown on the application plan, including how the layout supports fire-service access and safe movement. It does not replace Building Regulations compliance or the operational duties that apply once premises are occupied. Outline planning applications and some other cases are exempt, so the type of application and development matter.

A fire strategy is commonly needed where a building’s design must demonstrate compliance with Part B, including for a material change of use. Under Regulation 38, UK Parliament says fire-safety information must be assembled and given to the responsible person when a building is erected or extended, or undergoes a material change of use. This handover information helps the responsible person understand the building’s fire precautions and maintain them in operation.

Once occupied, the Regulatory Reform (Fire Safety) Order 2005 forms part of the fire-safety framework. The responsible person manages ongoing fire safety, using suitable records and a fire risk assessor where appropriate. A building’s site plan should make access, routes and relevant fire-safety features clear, while maintenance arrangements should keep doors and compartmentation effective. National Fire Ltd’s fire door maintenance can help address defects identified in existing fire doors.

Remedial deadlines depend on the applicable building-management plan, not a single UK-wide timetable. For example, Havering Council’s strategy sets Category A work within 2 weeks, Category B within 6 months, Category C within 24 months and Category D within 5 years. These are that council’s specified timescales, not general deadlines for every premises.

Approved Document B and fire-engineered approaches

Approved Document B provides a recognised route for addressing fire-safety requirements in building design. If its guidance does not fit a building or proposed use, a fire-engineered approach can assess alternative measures.

Approved Document B Guidance

In England, Approved Document B explains ways to meet Building Regulations requirements for fire safety. Volume 1 covers dwellinghouses; Volume 2 covers buildings other than dwellinghouses. A strategy uses the relevant volume to assess warning and escape, internal fire spread, external fire spread, and fire-service access and facilities. For a converted office becoming flats, the design must consider how these provisions work together, including compartmentation, detection and firefighting access.

Requirements vary across the UK because building regulations and technical guidance are devolved. Approved Document B is the England guidance, not a universal UK document. In Wales, the Domestic Fire Safety (Wales) Measure 2011 requires automatic fire suppression in new and converted homes. The requirement for new houses and flats has applied since 1 January 2016; care homes, HMOs and similar premises have been subject to it since 2014. Scotland and Northern Ireland use their own building regulations and guidance, so the relevant national framework must inform the design.

Fire-Engineered Approaches and BS 9999

A fire-engineered approach uses analysis to demonstrate how a building can achieve suitable fire safety through a coordinated package of measures. It may be appropriate where a building’s geometry, existing construction or proposed use does not fit prescriptive guidance. BS 9999 is an alternative framework used to develop strategies for buildings other than dwellinghouses; BS 9991 is also relevant to residential design. The selected method should explain its assumptions and how escape, detection, compartmentation and firefighting provisions work together.

For certain permitted-development prior-approval applications in England, a fire-safety design statement is required from 1 August 2021 where buildings contain at least 2 dwellinghouses and meet the Planning Gateway One height condition. This planning statement addresses design principles, concepts and standards; it does not replace Building Regulations compliance. A chartered fire engineer can assist where a change of use requires a fully engineered assessment.

Fire strategies for change-of-use applications

A change of use can alter evacuation assumptions, occupancy and the building’s fire-safety design. A project-specific assessment should connect those changes to planning and building regulations.

Consulting Local Authorities and Fire Services

Consultation identifies which authorities need to consider the fire-safety implications of a proposed use. In England, local planning authorities must consult the Health and Safety Executive before granting permission for qualifying development involving a relevant building. Other proposals follow their applicable planning route. The local authority determines the relevant consultees, while fire and rescue authority input may relate to access and firefighting provisions. The consultation route depends on the proposal; there is no single process for every change of use.

Contents of a Change-of-Use Fire Strategy

A change-of-use strategy explains how the proposed premises can manage fire risk and support safe evacuation. It should identify the existing building and proposed use, then assess occupancy, escape routes, warning arrangements, compartmentation and fire-service access. It should also explain design assumptions and how relevant measures demonstrate compliance. Compare existing plans with the proposed layout to identify altered routes, new openings or changes affecting protected areas. Clear drawings connect the written assessment to the building itself.

Risks of an Inadequate Fire Strategy

An inadequate report can leave key design decisions unexplained, such as whether escape routes remain suitable for the proposed occupancy. Planning or building control may need further information before assessing the relevant fire-safety issues, affecting the application’s progress. More importantly, overlooked weaknesses in compartmentation or evacuation arrangements can leave building users exposed to unmanaged fire risk. A strategy should address the proposed use, not simply reproduce the building’s existing arrangements.

For a change-of-use project, review the fire strategy requirements alongside proposed plans, evacuation assumptions and building-safety measures.

National Fire: Fire Stopping

National Fire supports building projects where a change-of-use strategy identifies passive fire protection work. Its Fire Stopping work can help maintain compartmentation at service openings, while Fire Door Installation and Fire Door Maintenance address fire-resisting doors. Injectable Cavity Barriers are another option for specified cavity-barrier requirements.

Turn to National Fire when the project’s fire strategy identifies passive fire protection work, or when surveys reveal issues with compartmentation or fire doors. Aligning this work with the building’s design helps keep the intended fire-safety measures clear throughout the project.

Visit National Fire’s website to discuss your project.

Turn the fire strategy into a coordinated next step

A change of use is an opportunity to build fire-safety decisions into the project’s working brief. Keep the strategy aligned with design updates, construction details and handover information, so the intended protections remain clear as the building moves towards its new purpose. This gives the project team a practical reference for carrying decisions through, rather than treating the fire strategy as a document that ends at approval.

Where the strategy identifies passive fire protection work, National Fire provides Fire Stopping, Fire Door Installation and Injectable Cavity Barriers. These services support delivery of the measures identified for the building. A fire strategy for change of use applications is most useful when its design intent informs the work that follows.

To discuss the fire-safety work identified for your project, contact National Fire about your project. A clear next step can help keep your plans focused on a safer, well-prepared building.

Frequently Asked Questions

What Is a Fire Statement?

A fire statement is a planning document addressing fire-safety matters relevant to land-use decisions in England. It applies to qualifying development involving a relevant building, subject to exemptions, and covers the whole development site shown on the application plan. For example, it can explain how the proposed site layout supports fire-service access. It does not replace Building Regulations compliance or the fire-safety arrangements needed once the building is occupied.

Approved Document B, BS 9999 or BS 9991?

The appropriate reference depends on the building’s use and the design approach. Approved Document B provides guidance for Building Regulations compliance in England, with separate volumes for dwellinghouses and other buildings. BS 9999 is a framework for buildings other than dwellinghouses, while BS 9991 relates to residential design. A fire strategy should make its chosen basis clear, particularly where a mixed-use building includes homes and commercial space.

How Often Should a Strategy Be Updated?

Update a fire strategy when a change means its existing assumptions no longer describe the building accurately. Triggers can include a new use, an altered internal layout, changed escape arrangements or building work affecting fire-resisting construction. For example, converting storage space into occupied rooms may change how the layout and fire precautions need to be assessed. Keep the current drawings and written strategy aligned with completed work.

When does an existing building need a retrospective strategy?

A retrospective strategy can be useful when an existing building has no clear record of its fire-safety design, or its use has changed since earlier plans were prepared. It records current arrangements and explains them against current guidance. This can give the building owner, fire risk assessor, insurer and enforcing authority a shared account of the premises, particularly when older drawings do not show later alterations.

Which guidance do you design to?

The design basis depends on the building’s location, use and proposed works. In England, Approved Document B is commonly used; BS 9991 or BS 9999 may inform a suitable alternative approach. National Fire provides fire strategy drawings. For associated door maintenance, choose a service suited to the doors and their fire-safety role.

What is a fire strategy for a change of use application in the UK?

A fire strategy for change of use applications explains how a building’s fire-safety design relates to its proposed purpose. It considers whether existing arrangements remain appropriate and identifies design measures or changes needed to support safe use. For instance, a conversion into sleeping accommodation may require a fresh assessment of the assumptions behind warning and evacuation. The strategy provides a reasoned design record for the project and its handover.