Building standards (fire safety) - external wall systems: consultation

Part 3: Large scale fire test, BS 8414

Overview

Following the ministerial working group on building and fire safety in March 2021, a need was identified to take precautionary action on both the highest risk cladding material and the use of large scale fire test results in new development. Accordingly, as an interim measure, changes were made to the technical handbooks from 1 April 2021 to identify the need to avoid use of category 3 MCM cladding in new building work and to remove reference to BS 8414 (and associated BR 135) as alternative guidance.

The Scottish Government Building Standards Division (BSD) have requested notification from local authority verifiers under section 34 of the Building (Scotland) Act 2003 where BS 8414 (and associated BR 135) and extended field of application assessments (BS 9414) have been used to demonstrate compliance with the mandatory building standards.

Interpretation of options tables

Any reference to storey height means the height of the topmost storey above the adjoining ground.

For the purposes of this consultation ignore rules of measurement around sloping sites and topmost storeys consisting solely of plant rooms.

Reference to european classification A1, A2, B, C, D and E means reaction to fire classification as set out in BS EN 13501-1.

Supplementary guidance on the competence of designers, installers and verifiers of cladding systems as well as interpretation and use of fire test results will form part of a future consultation on compliance and contained within a new compliance handbook.

The following tables excludes proposals for the ban on MCM (Category 3) as this is covered in Part 2 of this consultation:

Options tables

Please consider the following 4 options and confirm your preferred option in question 3 which follows.

Option 1 – April 2021 addendum

This option re-affirms the decision to remove reference to BS 8414/BR135 from technical handbook and to notify BSD when used as an alternative approach;

Domestic buildings [1]
	Performance [2]	Commentary
Any storey at a height of not more than 11m	B, C, D or E	Status quo
Any storey at a height of more than 11m	A1 or A2 or Fire safety engineered (FSE) approach [3]	Supplementary guidance in compliance handbook
Entertainment and assembly buildings, residential care buildings and hospitals [1]
	Performance [2]	Commentary
All buildings regardless of height [4]	A1 or A2 or FSE approach [3]	Supplementary guidance in compliance handbook
All non-domestic buildings (other than entertainment, assembly and residential care buildings and hospitals [1]
	Performance [2]	Commentary
Any storey at a height of not more than 11m	B, C, D or E	Status quo
Any storey at a height of more than 11m [2]	A1 or A2 or FSE approach [3]	Supplementary guidance in compliance handbook

Notes

[1] Assume building more than 1m from boundary i.e. if < 1m to boundary cladding should achieve european classification A1 or A2 in accordance with BS EN 13501-1.

[2] Any reference to A1 or A2 or FSE approach assumes that supplementary guidance will be provided in the new compliance handbook (to be developed).

[3] Alternative FSE approach from first principles using BS 7974 or International fire engineering guidelines (IFEG). guidance in compliance handbook to restrict use of this approach to chartered / incorporated engineer registered with engineering council having skills, knowledge and [experience/expertise] of façade fire testing and construction.

[4] Excludes small buildings as defined in non-domestic technical handbook (NDTH) provided no storey more than 11m.

Option 2 – Managed use of BS 8414 to address risk

This option will cite reference to BS 8414/BR135 in the technical handbooks with tighter controls depending on the use and height of the building;

Domestic buildings [1]
	Performance [2]	Commentary
Any storey at a height of not more than 11m	B, C, D and E	Status quo
Any storey at a height of more than 11m and not more than 18m [2]	A1 or A2 or BS 8414/BR135 or FSE approach [3]	Supplementary guidance in compliance handbook
Any storey at a height of more than 18m	A1 or A2 or FSE approach [3]	Supplementary guidance in compliance handbook
Entertainment and assembly buildings, residential care buildings and hospitals [1]
	Performance [2]	Commentary
All buildings regardless of height [4]	A1 or A2 or FSE approach [3]	Supplementary guidance in compliance handbook
All non-domestic buildings (other than entertainment, assembly and residential care buildings and hospitals [1]
	Performance [2]	Commentary
Any storey at a height of not more than 11m	B, C, D and E	Status Quo
Any storey at a height of more than 11m and not more than 18m [2]	A1 or A2 or BS 8414/BR135 or FSE approach	Supplementary guidance in compliance handbook
Any storey at a height of more than 18m	A1 or A2 or FSE approach	Supplementary guidance in compliance handbook

Notes

[1] Assume building more than 1m from boundary i.e. if < 1m to boundary cladding should achieve european classification A1 or A2 in accordance with BS EN 13501-1.

[2] Any reference to A1 or A2 or BS 8414/BR 135 assumes that supplementary guidance will be provided in the new compliance handbook (to be developed).

[3] Alternative FSE approach from first principles using BS 7974 or IFEG. guidance in compliance handbook to restrict use of this approach to chartered / incorporated engineer registered with engineering council having skills, knowledge and [experience/expertise] of façade fire testing and construction.

[4] Excludes small buildings as defined in NDTH provided no storey more than 11m.

Option 3 – Regulatory ban

This option proposes a regulatory ban i.e. A1 or A2 only in regulation for residential buildings with any storey more than 18m

Domestic buildings [1]
	Performance [2]	Commentary
Any storey at a height of not more than 11m	B, C, D or E	Status quo
Any storey at a height of more than 11m and not more than 18m [2]	A1 or A2 or BS 8414/BR135 or FSE approach [3]	Supplementary guidance in compliance handbook
Any storey at a height of more than 18m	A1 or A2 only [in regulation]	Supplementary guidance in compliance handbook. No assessments in lieu of tests (AILOT) and / or FSE approach [3]
Entertainment and assembly buildings, residential care buildings and hospitals [1]
	Performance [2]	Commentary
Any storey at height of not more than 18m	A1 or A2 or BS 8414/BR135 or FSE approach [3]	Supplementary guidance in compliance handbook
Any storey at a height of more than 18m [5]	A1 or A2 only [in regulation] [5]	Supplementary guidance in compliance handbook No assessments in lieu of tests (AILOT) and / or FSE approach [3]
All non-domestic buildings (other than entertainment, assembly, residential care buildings and hospitals) [1]
	Performance [2]	Commentary
Any storey at a height of not more than 11m	B, C, D or E	Status quo
Any storey at a height of more than 11m and not more than 18m [2]	A1 or A2 or BS 8414/BR135 or FSE approach [3]	Supplementary guidance in compliance handbook
Any storey more than 18m [2]	A1 or A2 or FSE approach	Supplementary guidance in compliance handbook

Notes

[1] Assume building more than 1m from boundary i.e. if < 1m to boundary cladding should achieve european classification A1 or A2 in accordance with BS EN 13501-1.

[2] Any reference to A1 or A2 or BS 8414/BR 135 assumes that supplementary guidance will be provided in the new compliance handbook (to be developed).

[3] Alternative FSE approach from first principles using BS 7974 or IFEG. guidance in compliance handbook to restrict use of this approach to chartered / incorporated engineer registered with engineering council having skills, knowledge and [experience/expertise] of façade fire testing and constfruction.

[4] Excludes small buildings as defined in NDTH provided no storey more than 11m.

[5] May be extended to other residential buildings including hotels

Option 4 – Any alternative proposal

This provides opportunity for suggesting alternative proposals the Scottish Government should consider.

Question 3: Which of the four options is your preferred choice?

Option 1 - April 2021 addendum ☐

Option 2 - Managed use of BS 8414 ☐

Option 3 - Regulatory ban ☐

Option 4 - Any alternative proposal ☐

Please select only one answer and provide any reasoning in the box below.

Comments: