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RIBA formal response to Grenfell Tower Inquiry Phase 2 report recommendations

Read our formal response to the Grenfell Tower Inquiry Phase 2 report recommendations.

16 January 2025

Executive Summary

The Grenfell Tower Inquiry Phase 2 report is a thorough examination of the causes of the tragedy at Grenfell Tower and RIBA accepts the report’s findings. 

The report makes clear that people’s safety requires reform of structures and regulations. This includes systemic change within the construction industry, and a fundamental shift in culture and behaviours. RIBA is committed to working with all parties to ensure a competent construction sector.

We have reviewed the report and recommendations in detail, and have set out our response to those recommendations that our members are qualified to comment on and are within our sphere of influence to improve.

These regulatory, structural and operational improvements need to be accompanied by a significant programme of cultural change, as clients and industry move away from a culture of doing the minimum necessary to one where professional expertise is valued, cherished and supported.

As the Inquiry notes, RIBA has taken steps since June 2017 to improve education and training in our profession. With the benefit of the comprehensive findings in the report, and as recommended, we have conducted a stocktake of the measures already introduced, are committed to reviewing them, and have identified further work to be undertaken. This is laid out in detail below.

We have also identified some areas that the report does not touch on, which we believe are important to review and change. These include procurement processes and client decision making.

In summary, RIBA recommends that:

Regulatory:

  • The idea of a single statutory body, like that of the Engineering Council, to ensure a comprehensive competence system for construction professionals is explored.
  • The definition of a higher-risk building is reviewed and extended to include assembly buildings and temporary leisure establishments.
  • A holistic review of Approved Document B – as we have long called for – is urgently undertaken.
  • Both staircases in new residential buildings over 18 metres should be required to function as fire-fighting staircases.
  • Existing single staircase residential buildings over 18 metres are refurbished with appropriate safety measures as ‘consequential improvements’ where a building is subject to 'material alterations'.
  • A broader use of sprinklers across new and converted buildings where there is a higher risk to vulnerable occupants is required.

Structural:

  • The responsibility for the functions relating to fire safety are brought under a single Secretary of State.
  • The proposed Chief Construction Advisor is a suitably qualified person, for example, a chartered professional.
  • An organisational level licencing scheme for principal contractors is created.

Operational:

  • Independent research and development in construction product testing standards is required.
  • The role of contracts and procurement processes in defining the obligations and agency of the different members of the client, design, and construction teams are reviewed.
  • Any safety critical guidance should be freely available.
  • Residential Personal Emergency Evacuation Plans (PEEPs) are developed, for all people who identify as or are identified as having the need for one, in all residential buildings of 11 metres or higher.

Full response  

The regulatory arrangements

The inquiry report recommends that the government draw together under a single regulator all the functions relating to the construction industry to which they referred in the report. RIBA supports the creation of a single regulator for the following activities:

  • the regulation of construction products;
  • the development of suitable methods for testing the reaction to fire of materials and products intended for use in construction;
  • the testing and certification of such products;
  • the issue of certificates of compliance of construction products with the requirements of legislation, statutory guidance and industry standards;
  • the regulation and oversight of building control;
  • the licensing of contractors to work on higher-risk buildings;
  • monitoring the operation of the Building Regulations and the statutory guidance and advising the Secretary of State on the need for change;
  • carrying out research on matters affecting fire safety in the built environment;
  • collecting information, both in this country and abroad, on matters affecting fire safety;
  • exchanging information with the fire and rescue services on matters affecting fire safety;
  • accrediting fire risk assessors;
  • maintaining a publicly available library of test data and publications.

For construction industry professionals, we would be interested in exploring a model similar to that of the current Engineering Council. This could take the form of a single statutory body for all construction professional bodies, which should set processes that all professional bodies certifying the competence of individuals must meet, including architects.

We agree that the definition of higher-risk buildings should be reviewed and extended. We would welcome working with the government to formulate the new definition. As a starting point temporary leisure establishments and assembly buildings should be included in the definition.

Government

Currently, a range of government departments have responsibility for building safety. The report recommends that the government bring responsibility for the functions relating to fire safety into one department under a single Secretary of State. We welcome this approach, which would help coordination and accountability.

Chief Construction Advisor

The report notes that the Minister will require expertise and knowledge to help them fulfil this role and recommends that the Secretary of State appoint a Chief Construction Adviser with a sufficient budget and staff to provide advice on all matters affecting the construction industry.

We welcome this recommendation. However, for this role to be a success, it will require the Chief Construction Advisor to be a suitably qualified person. This could be, for example, a chartered professional who is likely to come from the private sector. To ensure the right person with the relevant experience is selected, this must be reflected in the renumeration. It is also vital that succession arrangements for this post are set up to ensure that the experience of the post holder remains current.

Legislation and guidance

RIBA has been advocating for a holistic review of Approved Document B (ADB), with specific provision for those buildings that now fall within the definition of higher-risk buildings. Therefore, the recommendation that the statutory guidance generally, and ADB in particular, be reviewed accordingly and a revised version published as soon as possible, is very welcome. In particular, we support the recommendation that ADB ‘should be drafted conservatively to ensure, as far as possible, that compliance with it will provide a high degree of confidence that on completion of the work the building will comply with the Building Regulations’.

Following ADB updates made in 2024 and previous years, it would also be beneficial to have a clearer amendment tracking system under each piece of guidance – ADB now has a lot of documents listed.

We therefore welcome the announcement that the Deputy Prime Minister has asked the Building Safety Regulator to undertake a fundamental review of how building regulation guidance is produced, updated and communicated to the construction industry.

The report goes on to recommend that a revised version of the guidance contain a clear warning in each section that the legal requirements are contained in the Building Regulations and that compliance with the guidance will not necessarily result in compliance with them.

While we support the inclusion of such a warning, we also support the development of mandatory technical guidance that sets definitive boundaries for certain key issues (such as travel distances, evacuation lifts and numbers of staircases). This guidance should result in compliance with the relevant functional requirements of the regulations.

RIBA would also support an initiative to develop this additional statutory guidance to clarify expectations regarding routes to compliance and designers’ options for determining and demonstrating compliance, including the ability to rely on expert advice.

The report outlines that the use of new materials and methods of construction and the practice of overcladding existing buildings make the existence of effective compartmentation a questionable assumption and subsequently recommend that it be reconsidered when ADB is revised.

The report also suggests that those who design high-rise buildings need to be aware of the relationship between the rate at which fire is likely to spread through the external walls and the time required to evacuate the building or the relevant parts of it. It also highlights that a stay put strategy in response to a compartment fire will be acceptable only if there is negligible risk of fire escaping into and spreading through the external wall. Calculating the likely rate of fire spread and the time required for evacuation, including the evacuation of those with physical or mental impairments, are matters for a qualified fire engineer. The report recommends that the guidance draw attention to the need to make a calculation of this kind as it is one that ought to form an essential part of any fire safety strategy.

We believe a stay put strategy is safe when a building is designed, built and maintained appropriately. However, given compartmentation may not be effective in every case, there is a need for alternative means of escape in both new and existing buildings and we do not support a stay put strategy which is reliant on the above and not guaranteed over time.

Following a successful campaign by RIBA and other experts, in July 2023 the previous government announced it would adopt an 18 metre height threshold for second staircases in all new residential buildings. However, the guidance stops short of requiring the second staircase to be a fire-fighting shaft, or provide evacuation lifts, both of which are vital for emergency evacuation and fire-fighting operations.

For existing single staircases in residential buildings over 18 metres, we recommend they should be refurbished with appropriate fire safety measures as ‘consequential improvements’ where a building is subject to 'material alterations'.

Given the number of variables involved to calculate the likely rate of fire spread and the time required for evacuation, including the evacuation of those with physical or mental impairments, there must be sufficient information, guidance and an agreed methodology to ensure that these calculations can be done in a standardised and reliable way. Any use of technology must also not replace basic fire safety principles such as alternative routes of escape.

The report calls for ‘fresh minds’ when reviewing and revising the Building Regulations. It recommends that membership of bodies advising on changes to the statutory guidance should include representatives of the academic community as well as those with practical experience in the industry (including fire engineers) chosen for their experience and skill and should extend beyond those who have served on similar bodies in the past. We welcome this approach, with the caveat that expert architectural representation is also included.

The understanding of the need for fire safety strategy was highlighted in the report. With this in mind, the Inquiry suggests it be made a statutory requirement that a fire safety strategy produced by a registered fire engineer to be submitted with building control applications (at Gateway 2) for the construction or refurbishment of any higher-risk building and for it to be reviewed and re-submitted at the stage of completion (Gateway 3). We agree with this approach and would also like to see this for higher-risk buildings that have been included in the new, wider definition as recommended above.

Fire performance tests

To do their job effectively, architects rely on accurate data for construction materials. The trust in testing that we had relied upon in the past has been undermined. Therefore we agree with the recommendation for steps to be taken in conjunction with the professional and academic community to develop new test methods that will provide the information needed for such assessments to be carried out reliably.

RIBA agrees that the government should make it clear that BS 9414 should not replace the role of a suitably qualified fire engineer. However, there may be cases where carrying out an assessment of a material, product or system that is within the same manufacturer’s range could be assessed by a ‘suitably competent person’.

Certification of products and publication of test data

We have been advocating for any fire safety testing of new materials and construction methods to investigate real world application and use of materials rather than laboratory conditions and be independent. Therefore, we welcome the recommendation that the construction regulator should be responsible for assessing the conformity of construction products with the requirements of legislation, statutory guidance, and industry standards and issuing certificates as appropriate.

The report also recommends that copies of all test results supporting any certificate issued by the construction regulator be included in the certificate; that manufacturers be required to provide the construction regulator with the full testing history of the product or material to which the certificate relates and inform the regulator of any material circumstances that may affect its performance; and manufacturers be required by law to provide on request copies of all test results that support claims about fire performance made for their products. The Code for Construction Product Information (CCPI) is working to support this recommendation with industry, of which RIBA is supportive. We will work with our members to promote the work of the CCPI.

Fire engineers

RIBA agrees that the government, working in collaboration with industry and professional bodies, should encourage the development of courses in the principles of fire engineering for construction professionals and members of the fire and rescue services as part of their continuing professional development.

Architects

As the Inquiry notes, RIBA has taken steps since June 2017 to improve education and training in our profession. With the benefit of these comprehensive findings, and as recommended, we have conducted a stocktake of the measures already introduced, are committed to reviewing them and have identified further work to be undertaken.

RIBA work undertaken since the Grenfell Tower fire

1. RIBA Code of Conduct and Code of Practice

RIBA’s Code of Professional Conduct and Disciplinary Procedures were reviewed and overhauled during 2018. The new code came into effect on 1 May 2019. Since then, the Code and Disciplinary Rules have been updated to align with RIBA's updated Constitution. These amended documents were launched on 1 April 2021.

Following the Grenfell Tower fire, the codes had an additional focus on health and life safety. The changes included new guidance on health and safety and building performance to ensure RIBA members can be informed leaders and have the relevant expertise.

The codes are deliberately more detailed and specific than the previous iterations and include more guidance for members so practitioners can use them as a resource when dealing with day-to-day questions and dilemmas.

RIBA commits to reviewing our Code of Conduct and Code of Practice in light of the Grenfell Tower Inquiry report.

2. A revised Education and Professional Development FrameworkThe Way Ahead

The Way Ahead outlines RIBA’s new Education and Professional Development Framework. The framework signifies a new direction for architectural education and continuing professional development, with a greater emphasis on health and life safety, the climate emergency and professional ethics.

The Way Ahead is a single standard covering pre- and post-registration education and professional development. Key components of the new framework include education themes and values, mandatory competences, career role levels, core continued professional development (CPD) curriculum, specialisms and accreditation.

a.      Education Themes and Values

RIBA-validated architectural education is widely regarded as a highly successful model creating generations of world-renowned practitioners, teachers, critics and writers.

Post-Grenfell, we undertook a significant review of the curriculum and developed the Themes and Values for Architectural Education, which form the basis of our requirements for the validation of schools of architecture both in the UK and internationally. These revised themes and values place importance on the social purpose of architecture and put increased focus on the protection of the end user and responsible specification.

RIBA will review the changes made to the curriculum following the Grenfell Tower Inquiry report.

We remain confident in the decisions made concerning Parts 1 and 2, and we have plans to undertake a significant piece of work to develop the professional attributes required for chartered membership of the profession (Part 3). This will include further detail on how to understand, interpret, and make sound judgements on the Building Regulations, including how to meet the functional requirements.

RIBA commits to working with schools of architecture to help them deliver the new requirements once implemented.

RIBA also owns the Professional Experience Development Record (PEDR) which allows Part 3 students to log their practical experience. Currently, the PEDR refers to the previously shared RIBA/Architects Registration Board (ARB) professional criteria.

RIBA commits to updating this to align with the forthcoming Part 3 revisions to develop professional graduate attributes and the ARB’s new academic and practice-based outcomes.

b.       Mandatory Health and Life Safety

As part of The Way Ahead, RIBA has determined that the core competency for architects must encompass a fundamental level of awareness and understanding of priority subjects for them to be competent to practice and to provide public assurance.

One of the mandatory competences is Health and Life Safety. Laid out in RIBA's Health and Life Safety Knowledge Schedule, UK Chartered Members will need to demonstrate an understanding of seven core areas, including personal safety, design risk management and fire safety.

In May 2024, we relaunched our Health and Safety Test which replaces the voluntary pilot test that has been available since 2021. It is updated to include new legislative duties and competence requirements introduced by the Building Safety Act 2022 and 2023’s amendments to the Building Regulations relating to design risk management.

Alongside the test, we have expanded and updated RIBA Health and Safety Guide which is designed to improve industry understanding of issues in accordance with Construction (Design and Management) Regulations 2015 (CDM Regulations) and prepare architects for the health and safety test. It provides practitioners with the required knowledge regarding site safety, hazards and design risk management to discharge their professional services and legal duties competently and safely. To date over 2,500 books have been sold.

From 1 January 2025, practising RIBA Chartered Members must take and pass RIBA Health and Safety test if their work requires them (and their organisations) to carry out ‘designer’s duties’ under the CDM Regulations and the Building Regulations (in England). The test is free for all RIBA Chartered Members and must be passed every five years. Failure to pass the test can lead to suspension and ultimately expulsion from RIBA.

RIBA commits to reviewing the Health and Life Safety test to ensure it remains up to date and relevant for our members.

c.      RIBA Core Curriculum CPD

CPD is an effective, tried and tested and widely adopted means of maintaining and demonstrating competence for qualified professionals. Maintenance of competence and upskilling through regular CPD is a membership requirement for most professional bodies, especially when work has a direct impact on public safety and welfare. All RIBA Chartered Members are therefore required to undertake and record at least 35 hours of CPD on our platform each year.

As part of The Way Ahead, RIBA’s mandatory ten-topic CPD Core Curriculum – with a minimum of two hours of CPD required annually under each topic – underlines the key technical, regulatory, design, business and client competencies required. Health, Safety and Wellbeing, and Legal, Regulatory and Statutory Compliance, are two of the ten mandatory topics.

While this structure was in place before the Grenfell Tower fire, the content covered in the core CPD has been updated to reflect all relevant regulatory and strategic change.

RIBA commits to ensuring that our CPD content and requirements remain to a high and pertinent standard and is updated as regulatory and other changes occur.

Following our own review of the Part 3 curriculum, we will review our Core CPD to ensure it is aligned and make any changes necessary. 

d.     Compliance with RIBA and ARB’s CPD policy

We have enhanced our policy for compliance with our CPD requirements. From January 2024, we have signalled our intention that every member must maintain an up-to date online record on our CPD recording system. We will apply sanctions for non-compliance. Members could be suspended and ultimately expelled if they fail to respond to RIBA requests and reminders within subsequent warning cycles.

Following the introduction of ARB’s CPD requirements, we have worked collaboratively to ensure that our CPD scheme is compatible with ARB requirements, and that online records submitted to RIBA can be used to demonstrate annual compliance with ARB obligations.

RIBA will continue to work with the ARB to ensure that architects are undertaking CPD and will sanction those members who do not.

3.       RIBA Principal Designer CPD

RIBA's accredited Principal Designer course defines and provides the skills, knowledge and experience to a professionally agreed standard.

To show awareness and capability to deliver this role, there is an industry expectation for professionals to demonstrate attendance and knowledge attained. Following completion, an attendance certificate is issued showing completion of RIBA’s accredited course.

Since the updated Building Regulations were published in August 2023, RIBA has trained over 2,500 multi-disciplinary individuals in the Principal Designer role under CDM and the Building Regulations.

4.       New RIBA guidance and tools

In addition to the above, RIBA has produced a swathe of resources, guidance and tools for members post-Grenfell. Some of these include:

RIBA commits to reviewing this work to ensure that the findings of the Grenfell Tower Inquiry report are addressed in this work.

Proactive work RIBA has undertaken since the Grenfell Tower fire

5.      RIBA Principal Designer Register

RIBA Principal Designer Register allows individual RIBA Chartered Members in the UK to demonstrate that they meet the competence criteria to serve as principal designers as defined under the CDM Regulations and the Building Safety Act.

RIBA Principal Designer competence criteria covers the competences necessary to perform the principal designer role effectively.

Registrants will have demonstrated knowledge, skills, experience and behaviours to support the duty holder role under CDM and the new principal designer role under the amended Building Regulations. RIBA is naturally keen to support its members to acquire, attest and maintain their competence to perform the role’s duties.

RIBA is confident that architects can demonstrate the competences of PAS 8671 and RIBA Principal Designer Register has been established to support clients in respect of their duty to take all reasonable steps to satisfy themselves that they are appointing a competent principal designer.

A designer intending on carrying out the principal designer role may choose to demonstrate their competence via an alternative method, but the register is the approach that RIBA is taking to support Chartered Members in proving their competence as a third-party certification.

As of December 2024, 318 Chartered Members have enrolled on the application process for RIBA Principal Designer Register and 80 have passed all stages.

RIBA commits to ensuring that RIBA Principal Designer Register continues to meet the competences of PAS 8671.

Further areas of work needed post-inquiry report

Reading the detail of the report, and having conversations with our members, we have identified the following areas that we believe our members could benefit from further information or guidance on.

We commit to updating our guidance and professional or educational standards to cover the following:

  • routes to compliance with Building Regulations – architects are responsible for many key design decisions related to some of the functional requirements of the Building Regulations, and should understand how to prove compliance with these, using the Approved Documents or British Standards. When carrying out the principal designer role they will also have responsibility for coordinating all compliance information so should have a general understanding of all functional requirements. RIBA will support existing and future members in coordinating routes to compliance, including fire engineering, with more detailed CPD, updating RIBA Health and Safety Test and enhancements of our compliance tracking tools.
  • specification writing – architects, as lead designers, will often lead the production of the specification and the Grenfell Tower Inquiry report shows that this was not done to the standard expected of a competent architect. While this is not indicative of the profession, we will update our professional standards and test members to better reflect the importance and complexity of specification writing.
  • testing and certification of construction products – identifying the appropriateness of a particular construction product can be overly complicated, and the Inquiry report clearly shows that dishonest behaviour from manufacturers led to poor product selection for Grenfell Tower and across the industry. We will provide guidance to members and others on appropriate product selection processes, working with the Code for Construction Product Information, RIBA CPD Providers Network, and other industry bodies.
  • whole life carbon assessments – to meet the demands of the UK carbon budget and the UK Net Zero Carbon Buildings Standard (UKNZCBS), architects will need to take a significant role in coordinating whole life carbon design decisions and RIBA will support members in developing their competence in the critical area including how it relates to building safety.
  • challenging poor behaviour – RIBA Members are already held to a high standard of professional integrity and under the new regulations they will be expected to challenge the design work of others they do not believe to be compliant and to question competence where they do not see the same evidenced. We will update our Code of Conduct and guidance to support this in 2025.

RIBA would welcome the opportunity to input into the ARB’s competency outcomes review following the recommendation of the Grenfell Tower Inquiry report.

The Inquiry also recommends that it be made a statutory requirement that an application for building control approval in relation to the construction or refurbishment of a higher-risk building (Gateway 2) be supported by a statement from a senior manager of the principal designer under the Building Safety Act 2022, and, that all reasonable steps have been taken to ensure that on completion the building as designed will be as safe as is required by the Building Regulations.

RIBA agrees with this recommendation on the condition that ‘all reasonable steps’ is the level that is required to be met. There is a foreseeable risk that such a requirement would transfer the liability for the design of a building from the designers to the principal designer.

It may be difficult for any single individual to have sufficient competence or oversight of the holistic design of a higher-risk building to make such a statement, which could also have implications for the individual’s Professional Indemnity Insurance (PII).

Contractors

We agree with the recommendation that a licensing scheme operated by the construction regulator be introduced for principal contractors. However, we believe this should be wider than for higher-risk buildings. There is a concern about competence across many building types. We believe the responsibility should be at an organisation level, rather than individual.

Building Control

RIBA agrees with the recommendation that the government appoint an independent panel to consider whether it is in the public interest for building control functions to be performed by those who have a commercial interest in the process. Recently building control functions have been through significant change – to positive (clarity on roles and responsibilities, new processes and ‘compliance’ requirements) and detrimental (loss of approved inspectors from the profession and changed processes creating actual, or perceived, delays) effect.

Feedback on changes already introduced to regulate Registered Building Inspectors (RBIs) and Registered Building Control Approvers (RBCAs) seem to be having a positive impact on affecting behaviours and sanctions being imposed for breaches of codes of conduct. Therefore, we recommend a period of bedding in of the current regime followed by a review to assess the efficacy of the new system. If failings persist, then it may be pertinent to consider nationalisation as the report suggests.

A construction library

RIBA would welcome the construction regulator sponsoring the development of a cladding materials library. However, it would need to be accessible and not sit behind a paywall. RIBA would support working with the government and wider built environment sector to make wider safety critical standards freely available.

Response to recommendations

We must learn from our mistakes. Select committees and public inquiries play a vital role in uncovering information, and this information should be taken on board by government. If ignored, this must be noted to ensure the government can be held to account. Therefore, we welcome the recommendation for a legal requirement for the government to maintain a publicly accessible record of recommendations made by select committees, coroners and public inquiries together, with a description of the steps taken in response.

Fire Risk Assessors

RIBA members rely on the advice of fire engineers. Assurance that those providing this advice are competent and qualified to do so is important. Currently, however, this is not necessarily that easy to ascertain. Therefore, we welcome the recommendation for the government to establish a system of mandatory accreditation to certify the competence of fire risk assessors by setting standards for qualification and continuing professional development.

Commercial fire risk assessors also have limitations on their PII that would often extend to ‘cladding’.

It’s important for all to understand their limitations (as they are not designers) to also understand any gaps in knowledge.

A College of Fire and Rescue

RIBA agrees with the recommendation that the government establish an independent College of Fire and Rescue immediately with sufficient resources.

Implementing change

We welcome the recommendation that the London Fire Brigade establish effective standing arrangements for collecting, considering, and effectively implementing lessons learned from previous incidents, inquests, and investigations.

Further comments – what’s missing

The Inquiry’s report was thorough and wide-ranging. However, there are further areas of work we have identified that would help improve the safety of the built environment.

Reviewing the role of contracts and procurement processes in defining the obligations and agency of the different members of the design and construction team

The report recognises that the refurbishment of a major building is a complex undertaking which requires the co-operation of many different bodies, often with specialised skills and experience. It is the client who ultimately controls the budget, determines the scope of the work and programme, and needs to ensure that a competent design and construction team is appointed. The client appoints a multi-disciplinary team usually comprising of an architect, cost consultant, project manager/employer’s agent, as well as a range of specialist engineers and other consultants. The construction work is undertaken by a contractor and various specialist sub-contractors.

The narrative sections of the report identify issues and failings relating to the process of appointing the consultant team and procuring the building work, and the management and coordination of design and construction. The report also makes clear that many of those engaged in the project did not properly understand the nature and scope of the obligations they had undertaken. Or, if they did, they failed to pay sufficient attention to them. It also reveals that there was a casual approach to contractual relationships, with a lack of clarity about the responsibility for different decisions and issues as well as the authority of and obligations of the different organisations.

The remit of the Grenfell Tower Inquiry was restricted to the circumstances of the fire and the huge loss of life that ensued. The report is candid that it has not looked at the construction industry at large and its authors do not know whether the shortcomings identified are typical, but they do comment that they think they are likely to have been widespread.

While it is understandable that the main focus of the report’s recommendations is on matters of regulation and competence, it is perhaps surprising that the issues identified in relation to client decision-making and responsibility and the role of contracts and procurement processes in defining the obligations and agency of the different members of the design and construction team have not resulted in any formal recommendations. RIBA believes that these are areas to which the construction industry and those who advise clients on the appointment of designers and contractors and procurement methods should give further thought.

Requiring a broader use of sprinklers across new and converted buildings where there is a higher risk to vulnerable occupants

Life-saving sprinkler protection needs to be extended more widely and enforced across all new and converted buildings where there is a higher risk to vulnerable occupants. The recent announcement requiring sprinklers in all new care homes is a positive step. But we urge the government to mandate this more widely across all settings where vulnerable people may be living. Vulnerable people are not just represented by older people; they may have a physical vulnerability, which might include temporary as well as permanent disabilities, health conditions, or impairments.

Providing Residential Personal Emergency Evacuation Plans (PEEPs) for all people who identify or are identified as having the need for one, in all residential buildings of 11 metres or higher

RIBA welcomes the announcement made on 2 September 2024 that the Home Office will bring forward proposals to improve the fire safety and evacuation of disabled and vulnerable residents in high-rise and higher-risk residential buildings in England, in response to the Grenfell Tower Inquiry’s Phase 1 recommendations relating to PEEPs. These proposals will be called ‘Residential PEEPs’.

RIBA recommends that ‘Residential PEEPs’ should be provided for all people who identify, or have been identified, as having the need for one, in all residential buildings of 11 metres or higher. Where practical and possible, these plans should be reviewed with the individual and the potential to evacuate should be outlined to the individual as well as equipment which may be available. Those who live with relatives or carers, and those responsible for their care need this information to enable the possibility of self-evacuation.

RIBA also recommends that the government should also consider a more holistic approach to the use of General Emergency Evacuation Plans (GEEPs), that can be provided to the Fire and Rescue Services and made available to residents, outlining appropriate emergency evacuation procedures for visitors and unidentified residents who cannot evacuate themselves.

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