Since the devastating fire at Grenfell Tower in 2017, the Royal Institute of British Architects has been advocating for stronger regulation to make the built environment as safe as it can be. We have been clear that consistency and clarity are needed on a height threshold at which two or more staircases are necessary to provide adequate access for firefighters and evacuation of residents from their homes.
In December 2022, the Department for Levelling Up, Housing and Communities (DLUHC) launched a consultation which sought views on the maximum height threshold for the provision of a single staircase in new residential buildings – the consultation proposed a 30 metre height threshold.
RIBA responded to the consultation outlining that, from the best available evidence and guidance from our Expert Advisory Group on Fire Safety, we believe that the appropriate threshold for a second staircase in new residential buildings is 18 metres.
Positively, we have a commitment from the Secretary of State for Levelling Up, Housing and Communities, the Rt Hon Michael Gove MP, that new residential buildings over 18 metres will be required to have second staircases.
Responding to the announcement, RIBA President Simon Allford said:
“This is a significant moment. Over six years on from the Grenfell Tower tragedy, it is hugely positive and reassuring to see the Government listening to the united call of experts on fire safety, bringing greater coherence and certainty for industry.
Mandating second staircases in new homes over 18 metres is a vital step towards a safer built environment for all. We are pleased to have played our part in this.”
As part of our call to Government we wrote a letter to Levelling Up, Housing and Communities Secretary of State, Rt Hon Michael Gove MP, outlining the reasons for our 18 metre position, and why we believe the government must adopt this. The letter is also signed by organisations representing multiple sectors - the built environment, fire safety and disability rights groups, including:
- Royal Institute of Chartered Surveyors (RICS)
- Chartered Institute of Building (CIOB)
- National Fire Chiefs Council (NFCC)
- Housing Learning and Improvement Network (Housing LIN)
- Disability Rights UK
- Inclusion London
- Claddag (Leaseholder Disability Action Group)
Hear more from Clive Betts MP, Chair of the Levelling Up, Housing and Communities (LUHC) Committee.
Why 18 metres?
While arguments exist for a range of thresholds, both higher and lower, an 18 metre threshold would bring the greatest harmonisation with the wider regulatory environment, and therefore the greatest simplicity and certainty for industry at this time.
An 18 metre threshold would align with definitions in the Building Safety Act, as well as thresholds for certain provisions in the Fire Safety (England) Regulations, and the amendments to fire safety provisions within Approved Document B in relation to fire alert systems in blocks of flats with storeys over 18 metres.
This would also help to synchronise standards across the United Kingdom by aligning to rules in Scotland, which has required two staircases in new residential buildings over 18 metres for four years.
Better reflect a post-Grenfell world
Research has found that post-Grenfell, more people are choosing to evacuate their building when there is a fire. Between 1 April 2019 and 31 March 2022, there were 154 cases where 10 or more people evacuated from a block of flats of a minimum of six storeys in London. This amounted to nearly 8,500 people choosing to evacuate buildings rather than ‘stay put’ before the arrival of the London Fire Brigade during an incident.
This demonstrates the importance of occupants having access to a safe, smoke-free evacuation route in buildings over 18 metres, helping to remove the risk of a single point of failure.
Better align non-domestic and domestic buildings
In England, there is currently no maximum height for residential buildings with a single staircase. In contrast ‘Buildings other than dwellings’ are only permitted a single stair up to 11 metres, under Approved Document B, Volume 2.
Following the COVID-19 pandemic, increased hybrid working patterns mean that occupants are spending more time in their homes. Therefore, an 18 metre height threshold for requiring a second staircase in residential buildings would better align with non-residential requirements.
What further action is needed from government?
While we believe 18 metres is the correct height for a second staircase for new residential buildings, it is not a panacea for fire safety. We also urge the government to undertake a full review of Approved Document B. We must ensure that regulations and guidance are consistent, clear, unambiguous and actually deliver safe buildings.
What does this mean for existing single staircase buildings over 18 metres?
Critically, it is important to note that there is an extensive existing single staircase housing stock. An 18 metre height threshold for a second staircase in new residential buildings does not make existing single staircase residential buildings inherently unsafe.
However, to ensure existing buildings are as safe as possible, we recommend that the government require existing single staircase residential buildings over 18 metres be refurbished with evacuation lifts, sprinklers and centrally addressable fire alarm systems as ‘consequential improvements’ where a building is subject to 'material alterations'. This was included in our consultation response to government.
What does this position mean for RIBA Members?
These policy recommendations are to government. RIBA Chartered Members and RIBA Chartered Practices are required to adhere to current Building Regulations. Members engaged in work on blocks of flats over 18 metres are recommended to discuss these policy recommendations with their clients.
How can I support the call for second staircases over 18 metres?
If you would like to support our call for second staircases in new residential buildings over 18 metres, please like and share our posts on social media tagging the Department for Levelling Up, Housing and Communities.
Campaign developments
Clive Betts, Chair of the Levelling Up, Housing and Communities (LUHC) Committee, said:
“Building safety and the remediation of historic defects have been a major area of scrutiny for the Levelling-Up Committee since the Grenfell fire. It’s crucial the government acts to ensure the law helps to deliver a built environment which is as safe as it can be. I urge the government to seriously examine the case, put forward by RIBA and a coalition of organisations, for second staircases for new residential buildings over 18 metres. I hope the government will respond by taking the opportunity to look again at how to ensure adequate access for firefighters and to enable the evacuation of residents from their homes.”
Chair of RIBA Expert Advisory Group on Fire Safety and RIBA Past President, Jane Duncan, writes about why this campaign to improve fire safety standards matters so much.
Read Jane Duncan's fire safety blog on why the implementation of mandatory second staircases in high-rise buildings above 18 meters is crucial for ensuring adequate evacuation options and alignment with existing fire safety measures across the built environment.
Published: 23 March 2023
Updated: 5 March 2024