Key takeaways
- Gateway 2 applies to higher-risk buildings in England, not Wales
- Work cannot start until the Building Safety Regulator approves the application
- The fire strategy must be detailed and specific to the building, not an outline
- Late or incomplete information is the main cause of delay
- Changes after approval need to go through change control
Which buildings go through Gateway 2
The higher-risk building regime under the Building Safety Act 2022 applies in England to buildings at least 18 metres high or with at least seven storeys that contain at least two residential units, and to care homes and hospitals that meet the same height threshold during design and construction. For these buildings, building control is carried out by the Building Safety Regulator rather than a local authority or registered building control approver.
There are three gateways. Gateway 1 is a fire statement at planning stage. Gateway 2 is the building control approval application before work starts. Gateway 3 is the completion certificate application before the building can be occupied.
What the regulator is looking for
At Gateway 2 the regulator needs enough information to be satisfied that the building, as designed, will comply with the Building Regulations. For fire safety, that means a strategy written for this building, with the reasoning behind each decision visible. It should not read as a template with the project name changed.
A Gateway 2 fire strategy typically needs to set out clearly:
- The guidance followed, such as Approved Document B or BS 9991, and every departure from it, with the engineering justification
- The evacuation strategy and how the design supports it, including any evacuation lift
- Means of escape, including stairs, travel distances and protected lobbies
- Compartmentation, fire stopping and cavity barriers, with the fire resistance periods
- External walls, including materials and how they meet the restrictions on combustibility
- Structural fire resistance
- Firefighting access and facilities: firefighting shafts, lifts, dry or wet risers and smoke control
- Active systems: detection, alarm, sprinklers and smoke ventilation, and how they interact
- Management assumptions the building relies on once occupied
New residential buildings of 18 metres or more are now expected to have a second staircase under Approved Document B, and the strategy should show how that has been addressed.
Why applications are sent back
From what design teams report, the most common problems are not exotic engineering questions but missing or inconsistent information:
- Key design decisions left "to be confirmed by the contractor"
- Drawings that do not match the fire strategy text
- Departures from guidance with no clear justification
- Product choices, especially for external walls and fire stopping, not identified
- Fire strategy written late, after the layout has been fixed around the wrong assumptions
Each round of questions adds weeks to a programme. Getting the strategy complete and consistent before submission is the single most effective way to protect the start date.
After approval: change control
Gateway 2 approval is for the design as submitted. If the design changes during construction, for example a different cladding product, a revised layout or a substituted fire-stopping system, the change has to be managed through the change control process, and some changes need the regulator's approval before the work is done. The fire strategy should be kept current as part of the golden thread of building information that carries through to Gateway 3 and occupation.
What about Wales?
In Wales
The Gateway process and the Building Safety Regulator's higher-risk building regime do not apply. Building control follows the Welsh regulations and Approved Document B (Wales), and new and converted homes generally need sprinklers. The Welsh Government is reforming building safety law, and we advise on the current Welsh position for each project.
How we help
We write fire strategies in-house for higher-risk and other buildings, from RIBA Stage 2 through to handover. Managing Director Paul Chamberlain spent more than 30 years in Fire and Rescue, so we write with the fire service's view of the building in mind, and we respond to regulator and fire service comments directly. Send us your drawings for a fixed-price quote.