Amendments to the Building Regulations made on the 28 November 2018 and coming into force on 21 December 2018 will see a ban of COMBUSTIBLE MATERIALS in certain “relevant” high rise residential buildings. These changes are in the main a response to the government consultation on the ban of the use of combustible materials in cladding systems on high-rise residential buildings following the Grenfell Tower Fire on the 14 June 2017.
Please note for now these changes apply only to buildings and building work in England. We will keep you updated with further amendments applicable to building work in Wales.
It is important to understand that the ban of combustible materials in respect to compliance extends to residential buildings with a floor over 18m (not including any storey consisting exclusively of plant) and falls under the definition of a “Relevant Building” as follows:
The above definitions, although not explicitly stated in the changes, generally relate to buildings where a stay put or a managed phased evacuation strategy is to be implemented. Please note by implementing a simultaneous evacuation policy the ban of combustible materials on the above buildings will still be required.
Stroma Building Control has a duty of care and responsibility to provide you with the best counsel in particular in relation to fire safety matters. Therefore it follows that we would recommend that consideration is given to the limitations of external wall materials where a stay put or phased evacuation policy is provided to any building including buildings under 18m.
In practice to the above requirements, materials used on relevant buildings described above will be limited to the following European Classifications, classified in accordance with BS EN 13501-1:
There are a number components within the construction of the wall that maybe excluded from this requirement given in Regulation 7(3). Notable exclusions are as follows:
There remains the option to use a wall system that has been tested to BS 8414 and classified to BRE Report BR 135 Fire performance for buildings over 18m not described as a Relevant Building.
Specified attachments include balconies, solar panels and brise soleil.
Significantly where there is a change of use to a relevant building as described above, the construction of the external walls and specified attachments must be investigated and where necessary work must be carried out to ensure they only contain materials achieving the European class A2-s1,d0 or class A1, other than those components exempted. Apart from the cost of these changes there is the real possibility that the thermal performance of the fabric of the building will be reduced by replacing an insulation board with a non combustible material that does not have similar thermal insulation properties, the replacement of thermal elements dependant on the extent could also be considered as a thermal renovation and have additional requirements in regards to the overall thermal performance of the element being renovated, which would also have a cost implication.
The drive to ensure relevant buildings only contain materials achieving the European class A2-s1,d0 or class A1, other than those components exempted is further highlighted by that Regulation 7(2) relating to relevant buildings that is your buildings over 18m and are either a dwelling, institution, or a room for residential purposes as discussed above will prevail over the provisions for external wall surfaces described in diagram 40 of approved document B.
The announcement and changes coming into effect have happened very quickly and the government have allowed a short transition period.
The Amendment Regulations come into force on 21 December 2018. However the Amendment Regulations will not apply where a building notice or an initial notice has been given to, or full plans deposited with, a local authority before 21 December 2018 and either the building work to which it relates:
There is a lot to consider in a very short period of time. We are here to help you understand the changes and give you the surety of compliance. Please do not hesitate to call or email your contact at Stroma Building Control for any existing projects or future developments.
Martin Watton, Technical Director