5 Critical Moments When a Fire Strategy Becomes Essential for Full Compliance

Fire strategy planning is a fundamental requirement for safe and legally compliant buildings across the UK. Fire safety remains a critical aspect of building design, maintenance and day-to-day operation. For businesses, developers and property owners, understanding exactly when a fire strategy is needed can make the difference between robust protection and serious non-compliance. In this guide we examine the key scenarios that trigger the need for a fire strategy, with particular focus on the obligations set out under Regulation 38 of the Building Regulations.

1. New Buildings: Establishing the Foundation of Your Fire Strategy

A comprehensive fire strategy is integral to the design of every new building. It must be prepared and submitted to Building Control to demonstrate compliance with the functional requirements of Approved Document B and related legislation. A well-developed fire strategy sets out the active and passive measures that will be used to prevent fire, limit its spread, provide safe means of escape and support firefighting operations.

At AL23 Safety our consultants specialise in producing clear, practical fire strategies for new construction projects of all sizes. We work closely with design teams from the earliest stages to ensure that fire safety is fully integrated rather than treated as an afterthought. The resulting fire strategy provides Building Control with the evidence they need and gives the future Responsible Person a solid foundation for ongoing management.

2. Major Refurbishments: Updating the Fire Strategy for Changing Layouts

Substantial alterations to a building’s structure-such as the removal or relocation of walls, changes to escape routes, the introduction of new staircases or significant modifications to floor layouts-almost always require a revised fire strategy. These works can introduce new risks or invalidate assumptions made in the original design.

A fresh assessment ensures that compartmentation remains effective, travel distances stay within acceptable limits and any new materials or systems meet current standards. AL23 Safety has extensive experience supporting refurbishment projects. Our team reviews the existing arrangements, identifies the impact of proposed changes and produces an updated fire strategy that restores full compliance while minimising disruption to the programme.

3. Change of Use: Aligning the Fire Strategy with New Occupancy Risks

Converting a building from one use to another-for example turning offices into residential flats, a retail unit into a restaurant or a warehouse into a mixed-use development-fundamentally alters the fire risks present. Different occupancy profiles, sleeping risks, cooking processes or higher occupant numbers all demand a tailored response.

In these situations a new or significantly revised fire strategy is essential. It must address the specific hazards of the new use, the expected behaviour of occupants and any additional protection measures required by the regulations. AL23 Safety evaluates the changed risk profile and develops a fire strategy that satisfies both Building Regulations and the ongoing duties under the Fire Safety Order.

4. Complex or Higher-Risk Buildings: The Need for a Bespoke Fire Strategy

Large, unusual or higher-risk buildings frequently fall outside the scope of standard guidance and require a fire-engineered solution. Examples include high-rise residential blocks, deep basement structures, buildings with complex atrium designs or premises storing significant quantities of hazardous materials.

In these cases a conventional code-compliant approach may not be sufficient or appropriate. A performance-based fire strategy, supported by specialist analysis, is needed to demonstrate that an equivalent or higher level of safety is achieved. AL23 Safety’s consultants possess the technical expertise to design and document these sophisticated fire strategies, ensuring that innovative designs can proceed while still delivering the required standard of protection.

5. Retrospective Documentation: Creating a Fire Strategy Where None Exists

Regulation 38 places a clear duty on the person carrying out the work to provide the Responsible Person with comprehensive fire safety information no later than the date the building is first occupied. Unfortunately, many existing buildings were never issued with a formal fire strategy or the original documentation has been lost.

Where this gap exists, a retrospective fire strategy must be prepared. AL23 Safety undertakes a detailed survey of the as-built condition, reviews available drawings and management arrangements and produces a clear, defensible fire strategy that brings the building into line with current expectations. This document not only satisfies regulatory requirements but also provides the Responsible Person with the information needed to manage the premises safely going forward.

The Legal Importance of a Robust Fire Strategy Under Regulation 38

Having a suitable fire strategy is not merely good practice, it is a legal obligation under Regulation 38. Failure to produce or maintain appropriate documentation can leave building owners, developers and Responsible Persons exposed to enforcement action, civil liability and, in the worst cases, criminal proceedings. More importantly, the absence of a coherent fire strategy increases the likelihood that occupants will be placed at unnecessary risk should a fire occur.

AL23 Safety is committed to helping clients navigate these requirements with clarity and confidence. Whether you are planning a new development, undertaking a major refurbishment, changing the use of a building, dealing with a complex design or simply need to fill a documentation gap, our team can deliver a tailored fire strategy that meets both regulatory and practical needs.

Do not leave fire safety documentation to chance. Contact AL23 Safety today to discuss your project and ensure that your fire strategy is robust, compliant and ready to protect the people who occupy your building.