The Impact of the NFCC’s Opinion Paper on High-Rise Building Design and Fire Safety Standards

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On 12th February 2024, the National Fire Chiefs Council (NFCC) released an opinion paper addressing the design of high-rise residential buildings, outlining three primary objectives: ensuring the independence of multiple stairways for evacuation, guaranteeing safe evacuation for all building occupants, and enhancing resilience for firefighting provisions. While claiming to bridge a gap in fire safety standards, it presents a paradigm shift in the design of residential buildings, potentially surpassing existing guidelines.

Following release, discussions have been ignited regarding the implications for building design and safety protocols. It is imperative for architects, designers and stakeholders within the construction industry to grasp the far-reaching consequences outlined in the NFCC’s opinion paper.

The NFCC’s paper is described as advice to Fire and Rescue Services (FRS), filling the gap left by outdated guidance that fails to address impending changes such as the integration of evacuation lifts and multiple stair designs. However, questions loom regarding the paper’s longevity and its alignment with forthcoming revisions to key regulatory documents.

In this article, James Lane, Wintech’s Director of Fire Engineering, shares his insights into the key objectives outlined by the NFCC and analyses their potential impacts on building design, safety measures and regulatory compliance. By shedding light on these aspects, James aims to provide clarity for those affected by it and raise questions about the fundamental advice the paper gives.

On 12th February 2024, the NFCC issued an opinion paper on the design of high-rise residential buildings and set three principal objectives:

• Independence of multiple stairs for evacuation
• Safe evacuation for all building users
• Resilience for firefighting provisions

This document has potentially far-reaching consequences for the design of residential buildings that exceed the current, and possibly planned, guidance in published codes of practice on fire safety. It is important that designers and those involved with advising designers are aware of the implications.

The opinion paper is presented as advice to Fire and Rescue Services (FRS) on considerations for high-rise blocks of flats [1.5/1.7]. This is “necessary” because current published guidance is outdated and does not address pending changes such as evacuation lifts or multiple stairs designs.

The Secretary of State for Housing, Leveling Up and Communities, the Rt Hon Michael Gove, wrote on 19th February 2024:

“The Building Safety Regulator will publish the new guidance on second staircases before the end of March, making clear the need for a second staircase in new multi-occupancy residential buildings that have a top occupied storey above 18 metres, and confirming that evacuation lifts will not be called for as a matter of course, providing housebuilders with the clarity they need to progress developments.”

Revision to Approved Document B (ADB) is therefore anticipated for the end of March and BS9991 in June 2024. The Department of Levelling Up, Housing and Communities (DLUHC) set transitional period of 30 months following revision of ADB. Imposing additional requirements ahead of guidance publication is ignoring this transitional period.

As the paper states:

“Until such time that guidance is published, this paper outlines the NFCC opinion on…” [1.3].

Does this mean that when such guidance is published, this advice from the FRS becomes redundant? That would give it a lifespan until the end of March, in which case, should we assume that advice from the FRS will ignore the publication of new guidance at the end of the month?

A significant change is that passing through the lobby of one stair to reach an alternative stair is not permitted, in direct contradiction to ADB volume 1 paragraph 3.33:

For reasons of resilience, the opinion paper stipulates that there should be more than one evacuation lift per stair core, meaning if one lift is unavailable owing to maintenance or breakdown, there will still be one lift for evacuation.

In [4.5] a lobby provided with access to an evacuation lift should be safeguarded against the ingress of smoke. Criteria for design is given as [5.2 c)/5.17]:

“…the smoke control system… should not extract from the firefighting or evacuation lobby itself…”.

The lobby protecting the stair and lift would therefore not be provided with smoke control, but to achieve the protection to the lobby, smoke control is required in the adjacent corridors.

This part of the paper includes a number of inter-related matters:

• Fire main outlets to be in a stair lobby, not within the stair
• More firefighting lifts in addition to evacuation lifts
• Residents should have the option to leave the building unaffected by firefighting operations
• Dual use of lobbies for firefighting and evacuation lift waiting space

Because we are repeatedly told that the standard procedure is to fight a fire from one or two floors below, placing the riser outlet in the lobby could result in all doors being kept open between two floors.

Resilience in provision is again cited as a reason to increase the number of firefighting lifts. To give flexibility for occupants to leave the building at any time, three lifts for each stair core would be necessary:

• One dedicated evacuation lift
• One dedicated firefighting lift
• One dual purpose evacuation and firefighting lift

Two dual purpose lifts would not be adequate because if one is unavailable for maintenance and the other is being used for firefighting then there would not be a lift available for evacuation.

Even though the paper states it is “predicated on residential designs based on a stay put strategy” [1.11], they see a need to provide this flexibility of choice.

Although it should be possible to leave, if residents are not on a floor affected by fire, it is not critical they have a normal lift service. Design guidance recommends provision of Emergency Voice Communication (EVC) systems to use in conjunction with evacuation lifts. Should these not then be used by occupants to give and receive information about their whereabouts and requirements for evacuation, otherwise what is the point in providing them?

Furthermore, [6.10] lists protection to firefighting lobbies additional to evacuation lobbies, such as increased fire resistance, rising mains, firefighting lifts and smoke control. [6.13] and [6.14] advocate the dual use of lobbies for evacuation and firefighting . However, [5.2 c)] states there should not be smoke extract from an evacuation lobby. Will it therefore be acceptable to have a lobby designated as a firefighting lobby but without smoke control that removes heat and smoke from the lobby? Seems contrary to the requirements of firefighting lobby protection.

The objectives of this opinion paper will have a significant impact on building design, place limitations on layout options and require additional protections and provisions beyond any current guidance document. Although it is billed as advice to FRS on dealing with new consultation applications, it is likely to be adopted as “policy” by many and could lead to updated guidance being disregarded, which then only serves to further confuse the situation, rather than clarify it, as stated to be the aim of the paper.

– James Lane, Director of Fire Engineering

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Related Resources:

Glass Risk Assessment →

The Run-Up to Gateway 3 →