Housing Forum highlights potentially negative impact of second staircase rules

The Housing Forum has highlighted its concerns over the government’s requirements for a second staircase in new residential buildings over 18m in height and the unintended negative impact it could potentially have for fire safety.

In a letter sent to the Secretary of State for the Department for Levelling Up, Housing and Communities (DLUHC) on 14 August, the forum’s Director of Policy and Public Affairs Anna Clarke said the sector was "struggling with the lack of a clear roadmap" that sets out the how the proposals for a second staircase fit with other building safety changes.

The DLUHC had announced a requirement for a second staircase in new residential buildings over 30m in height in December. However, last month the Secretary of State the Rt Hon Michael Gove MP announced that this would now apply to new residential buildings over 18m in height.

In its letter, the cross-sector body, which represents member organisations that include architects, manufacturers, housing associations and local authorities, welcomed the clarification over the height limit but warned that "this means that a large number of additional buildings at different stages of development are now falling within scope".

The Housing Forum has outlined three main concerns. The first is the lack of clarity from government regarding the core purpose of a second staircase.

Even before the government’s decision to change the requirement for a second staircase from buildings over 30m to over 18m, the cross-sector body has argued there had been little progress in providing much-needed technical clarity on the purpose or design requirements for a second staircase.

Because a staircase’s design depends on its intended use, the Housing Forum argues decision makers need to know what the core purpose of a second staircase is so they can design accordingly. It outlines five questions designed to clarify the government’s position on this issue.

For example, the cross-sector body asks whether both staircases are intended to be potentially available for fire-fighting. If this is the case, this will impact on the design of the shafts.

"If the people making decisions over the fire safety are not clear on these questions, they cannot make sensible judgements or design for intended purpose," Clarke warned in the letter.

The Housing Forum’s second area of concern covers transitional arrangements, particularly in light of the new requirement for a second staircase in buildings over 18m in height. It is calling for clear and urgent clarification on this matter.

"It takes a lot more than two staircases for a building to be safe and – conversely – existing tall buildings with a single staircase can be safe, and are going to continue providing homes for people for the foreseeable future"

"The government needs to provide leadership to all stakeholders, including developers, planners, lenders and landlords, to ensure transitional schemes are delivered," said Clarke.

"Stakeholders need to be encouraged to remain committed to transitional schemes to prevent important homes and places being significantly delayed or, worse, made unviable."

One of the areas the cross-sector body highlights is large-scale affordable housing projects that have already been through the design process and will now be subject to additional design changes to accommodate the government’s revised requirements for a second staircase.

The Housing Forum adds that beyond the question of a second staircase, there is currently a lack of clarity, coordination and agreement between industry stakeholders for a ‘raft of fire and safety regulation’. It warned this is now impacting on projects at all work stages.

The cross-sector body’s third concern relates to clarity on the technical specifications.

In particular, it said that, in the absence of clear guidance for designers, it is "unclear whether the provision of a second protected staircase integrated into an existing core arrangement will be sufficient to meet the emerging fire safety standards".

The Housing Forum has called for urgent responses to a list of 13 questions it has presented to the Secretary of State. These cover critical design considerations, including "Do both staircases need to be constructed to the same specification of compartmentation?" and "Is it the intention that the second stair is just a 'stair', or a 'core', which includes lifts?"

If it is the latter, the cross-sector body adds that the government needs to provide clarity on what type of lifts they need to be i.e. for firefighting, evacuation or passengers and also specify how many.

The Housing Forum has called on the government to provide sight of the secondary legislation that governs the Building Safety Act and to do this urgently because the scheme is due to start in only two months’ time.

The cross-sector body has also voiced its concern about the narrow focus on one or two staircases.

"It takes a lot more than two staircases for a building to be safe and – conversely – existing tall buildings with a single staircase can be safe, and are going to continue providing homes for people for the foreseeable future," stated the letter.

"It is critical that the government leads the way to a balanced and evidence-based approach to fire safety, and ensures that the second staircase issue does not become emotional or detract from wider building safety issues."