Independent scrutiny of fire strategies, UK wide
Independent Fire Safety Peer Review
A performance based fire strategy has no tabulated answer to check it against, which means the whole case rests on assumptions somebody chose. AL23 Safety carries out independent peer review of fire strategies, fire engineering analyses and fire risk assessments, for clients UK wide.
What is a fire safety peer review?
A second qualified opinion, written down and gradeable
A peer review is an independent technical examination of somebody else's fire safety work. The reviewer takes the strategy, the calculations, the modelling and the supporting drawings, then tests whether the conclusions actually follow from the evidence. It is not a rewrite and it is not a second design. It is an opinion on whether the case presented is coherent, complete and defensible.
The output is a written report listing findings, each graded by significance, with a route to closing every one of them. On a live project the review is normally iterative. Findings are issued, the design team responds, the reviewer accepts or maintains the point. The register closes before submission rather than during determination.
Who needs one
The five reasons a review gets commissioned
Performance based design under BS 7974
Where the acceptance criteria, the fire scenarios, the input assumptions and the modelling all rest on engineering judgment, there is no code table to check against. Review is the only meaningful check.
Higher-risk buildings at Gateway 2
The Building Safety Regulator is the building control authority and construction cannot start until approval is granted. A rejected or stalled application is expensive.
Major development in London
London Plan Policy D12(B) requires the planning fire statement to be an independent fire strategy produced by a third party suitably qualified assessor.
Insurer, funder and warranty conditions
Professional indemnity insurers commonly attach conditions to fire engineering work and lenders increasingly ask for independent comfort before drawdown.
Post-Grenfell risk position
Regulation 7(2) of the Building Regulations 2010 on combustible materials in external walls and the dutyholder regime under the Building Safety Act 2022 have made an unchallenged single author fire strategy a poor position to defend.
The regulations that apply
Your legal framework, in plain terms
Start with what the law does not say. There is no general legal requirement for peer review of a fire strategy in England. What the law does require is competence. The Building Regulations etc. (Amendment) (England) Regulations 2023 inserted Part 2A, regulations 11A to 11Q, into the Building Regulations 2010 with effect from 1 October 2023, applying to all building work. Regulations 11F to 11I define competence as skills, knowledge, experience and behaviours for an individual and organisational capability for an organisation, require verification before appointment and prohibit accepting work beyond your competence. Peer review is one of the practical ways a client evidences that it took those duties seriously.
Regulations 11F to 11I of the Building Regulations 2010
Competence must be verified before appointment. A reviewer's own competence evidence is part of the record, not an afterthought.
The Building (Higher-Risk Buildings Procedures) (England) Regulations 2023
Set the Gateway 2 and Gateway 3 procedures. Gateway 2 is a hard stop before construction. Gateway 3 is a hard stop before occupation.
London Plan Policy D12(B)
Development plan policy requiring an independent third party author for the fire statement on major development in London.
Regulation 7(2) of the Building Regulations 2010
The combustible materials restriction for external walls, which is one of the most reviewed provisions in the current market.
Section 156(4) of the Building Safety Act 2022
Would insert a competence duty for persons appointed to assist with a fire risk assessment into the Fire Safety Order. It has not been commenced.
We will not overstate the regulator's position
No published Building Safety Regulator or gov.uk guidance mandates an independent third party fire strategy review as part of a Gateway 2 application. The gov.uk guidance on building control approval for higher-risk buildings, last updated on 1 April 2026, does not set out such a requirement. What is true is that the regulator applies its own multidisciplinary scrutiny and that independent review before submission is market practice because it reduces the chance of rejection. Anyone who tells you the regulator requires a peer review is selling something.
The commercial argument is in the regulator's own numbers. The Building Safety Regulator strategic plan published on 31 March 2026 targets responses to non-complex Gateway 2 applications within 18 weeks and remediation applications within 12 weeks by March 2027, alongside a 65 per cent Gateway 2 approval rate. A 65 per cent approval target means roughly one application in three is still expected to fail. Twelve weeks of programme is usually worth more than the cost of a review.
What the review covers
Specific and stated in advance
- The fire strategy narrative, tested for internal consistency against the architectural, structural and services drawings at the revisions actually issued.
- Compliance route selection, including whether Approved Document B, BS 9991:2024 or BS 9999:2017 has been followed and whether departures are identified and justified. Neither British Standard is statutory guidance so choosing one is a decision that needs stating.
- Means of escape provisions, travel distances, stair capacity, evacuation strategy and the assumptions behind any phased or stay put approach.
- Compartmentation, cavity barriers, protected shafts and the coordination of penetrations with the services design.
- External wall construction against regulation 7(2), plus the fire risk appraisal underlying it where the building already exists.
- Smoke control and detection design, including the basis of any modelling and the tenability criteria adopted.
- Structural fire engineering assumptions, including the fire curve used, the thermal actions, the acceptance criteria and the sensitivity of the answer to the inputs.
- Firefighting provision, access, water supplies, risers and firefighting shaft arrangements.
- The qualitative design review record where a BS 7974 approach has been taken and whether the approving body actually agreed the criteria at the time.
- The competence declarations and the golden thread information supporting the package.
- Fire risk assessments in occupied buildings, reviewed for methodology, scope, significant findings and the realism of the action plan.
What a peer review does not do
The limits, stated plainly
A peer review is an opinion on the evidence submitted to the reviewer. It is not a warranty, an approval or a design check of every calculation. Four limits matter.
It does not transfer liability. The original designer remains responsible for the design. A favourable review does not move that responsibility and no reviewer's report can. If a design fails, the designer's professional indemnity insurers will be the first port of call, not the reviewer's.
It does not extend to what was not disclosed. If a drawing revision, a modelling input file or a fire test report is withheld, the review cannot speak to it. We list what we were given and what we asked for and did not receive.
It is not intrusive survey work. Peer review is a desktop discipline. Where the question is what is actually built rather than what is drawn, that is a fire compartmentation survey or a site inspection, which we scope separately.
It does not replace the approving body. Building control and the Building Safety Regulator make their own decisions. A cleared review register improves your odds. It does not bind anybody.
Independence, conflict of interest and insurance
Independence is a structural fact, not a promise
There is no statutory definition of "independent" for this purpose in England. London Plan D12(B) supplies the only policy wording, with the words "independent" and "third party". Even the Greater London Authority's competency criteria for it sit in unadopted draft guidance. That leaves the test to be applied honestly rather than technically.
Our position is that a reviewer must not be the original designer, must not sit in the same organisation as the original designer and must not be under the commercial control of the party whose design is being reviewed. Where a reviewer is appointed by the contractor or the developer rather than by the client, the scope and the reporting line should be documented at the outset so that adverse findings cannot be quietly suppressed. And a reviewer who then takes on design responsibility for the fix has stopped being independent for that element, which we will tell you before it happens rather than afterwards.
Insurance matters as much. Since 2019 the professional indemnity market has commonly applied fire safety and cladding exclusions or aggregate sub-limits to construction consultants. Ask any reviewer to confirm in writing that their policy responds to review work on your specific building type. We expect to be asked.
Competence, registers and BS 8674:2025
How to check the person, not just the letterhead
The Institution of Fire Engineers offers Engineering Council registration at EngTech, IEng and CEng, assessed against UK-SPEC, with interim registration available for candidates who meet the academic requirement but not yet the experience requirement. Continuing professional development is a condition of registration. The IFE also operates a higher-risk buildings registration for professionals working on fire safety compliance in higher-risk buildings and publishes a public directory of registered professionals.
For fire risk assessors specifically, the IFE Fire Risk Register is aligned to BS 8674:2025, the framework for competence of individual fire risk assessors published on 15 August 2025. BS 8674 sets three tiers, Foundation for simple low-risk buildings, Intermediate for buildings of moderate complexity and Advanced for high-risk complex environments such as large residential blocks, care facilities and public venues. The IFE register admits only at Advanced, requiring evidence across education, training and experience plus work samples assessed by an IFE Professional Review Panel.
Two caveats we think you should know. BS 8674 is a voluntary code of practice rather than law. Section 156(4) of the Building Safety Act 2022, which would create a statutory competence duty for persons assisting with a fire risk assessment, has not been commenced. BS 8674 also expressly excludes fire engineering activities, invasive inspection, organisational competence and appraisal of external wall construction, which sits with PAS 9980:2022. It is the right benchmark for a fire risk assessor. It is not the benchmark for a fire engineering peer review and anyone citing it as though it were has misread the scope. We also hold BAFE SP205 third-party certified fire risk assessments, independently certificated by SSAIB, which is relevant where the thing under review is a fire risk assessment rather than a design.
Our process
Graded findings, closed out in writing
- 01
Conflict check and scope
We confirm we are independent of the design team, agree the review boundary in writing and record what is excluded.
- 02
Document control
We log every document by title, revision and date. The review speaks only to that set. The set is printed in the report.
- 03
Review and grading
We grade every finding. Critical means the design cannot proceed as drawn. Major means a substantive change or a written justification is required. Minor means a clarification or a correction is needed. Observation means good practice worth considering.
- 04
Response and close out
The design team responds to each finding. We accept, partially accept or maintain each point. The register records the outcome with a date and a named responder.
- 05
Closing statement
We issue a final statement recording which findings closed, which remain open and what the residual position is. Open findings stay visible rather than disappearing.
What you get
A register somebody can audit, not a letter of comfort
- A peer review report with an executive summary written for the client rather than for the engineer.
- A numbered findings register with grading, the clause or standard relied on and the evidence examined for each point.
- A document control schedule listing every drawing and report reviewed by revision and date, plus anything requested and not supplied.
- A close out log showing each response, the reviewer's acceptance position and the date.
- A final closing statement stating the residual open findings in plain terms.
- Our competence and independence declaration, with professional indemnity confirmation for the building type.
What we need from you
The whole package, at the revisions in use
- The fire strategy and all supporting analysis, including modelling input files where CFD or evacuation modelling has been used.
- The architectural, structural and services drawings at the revisions the strategy relies on.
- The qualitative design review record where a BS 7974 approach has been adopted.
- Correspondence with building control, the Building Safety Regulator or the fire and rescue service to date.
- A clear statement of who appointed us and who the report goes to, agreed before we start.
Why AL23 Safety
Independent and structured so that it stays that way
Accountable
When something is non-compliant, we say so clearly and set out the fix. We do not soften a finding to keep a design team comfortable.
Genuinely third party
We take review appointments on projects where we hold no design role. Where we already act as designer, we say so and decline rather than reviewing our own work.
One team, three disciplines
Fire engineering, fire safety and health and safety in-house so a review can cover the structural fire case, the evacuation case and the management case without three separate appointments.
UK wide
We review fire strategies and fire risk assessments for clients across the UK from our Manchester base.
Before the submission goes to the regulator
A fortnight of review beats twelve weeks of resubmission
Send us the package as it stands. We will tell you within days whether it is ready or where the exposure sits.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usNo. No published regulator or gov.uk guidance mandates an independent third party review as part of a Gateway 2 application. The regulator applies its own multidisciplinary scrutiny. Independent review before submission is market practice rather than a legal requirement and its value is in reducing the chance of a rejection.
No. You should be suspicious of anyone who implies otherwise. The design responsibility stays with the designer. A peer review is an opinion on the evidence given to the reviewer at a point in time. It improves the quality of the submission. It does not change who is liable if the design turns out to be wrong.
A single block with a settled strategy and a complete document set can be reviewed in a small number of weeks, with a close out cycle after that. A phased scheme with performance based structural analysis and CFD modelling takes longer, mostly because the close out cycle involves several rounds. The delay is almost never the review itself. It is waiting for missing documents.
It is driven by the size and complexity of the building, how many disciplines the review has to span, whether modelling files need interrogating and how many rounds of close out you expect. A review of a fire risk assessment on an occupied block is a very different job from reviewing a travelling fire analysis. We look at the document schedule before pricing because the honest answer depends on what is actually in it.
We can. There is a boundary. Once we take design responsibility for an element, we are no longer independent for that element and the review no longer covers it. On London Plan D12(B) work in particular, that distinction matters. We will set out which parts we can carry and which need a different appointment.
Yes. That is a common instruction from landlords, managing agents and insurers, especially where an assessment has produced findings the client does not understand or does not believe. We check the methodology, the scope, the significant findings and whether the action plan is deliverable. Where a fire strategy is missing entirely, we will say so because that is usually the real problem.
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