Balancing Fire Safety Standards: A Comparative Analysis of European Approaches and Lessons for the UK?
Global attention was drawn to UK fire safety standards in the aftermath of the Grenfell Tower disaster in 2017, and a review by Dame Judith Hackitt found that current fire safety legislation in the UK is inadequate and in need of improvement. One potential solution to this issue is to learn from the approaches of other countries, particularly those in the European Union, while avoiding their shortcomings. While it is important to have proper regulation in place, it is also crucial for those involved in designing and constructing buildings to have a thorough understanding of how fires can affect a building and how to minimize damage and danger.
Different countries across Europe have distinct ways of approaching fire safety regulations. In the United Kingdom, fire regulations are based on a "performance-based" system, that only requires five basic requirements; means of warning and escape, internal and external fire spread, and access for the fire service, and the method used to meet these requirements is left up to the designer and can come from various sources. Similarly, Sweden follows a performance-based approach in their Building and Design Regulations (BBR 94 and BKR 94) and also considers the proximity of surrounding buildings similarly to the way the UK demands external material ratings in relation to boundary conditions.
However, many European Union countries have a "prescriptive-based" approach, which requires a building to meet a pre-determined standard for fire safety. Germany, for instance, follows the National Model Building Code and has prescriptive rules that dictate what designers should and should not do with additional regulations for certain types of buildings or uses. The benefit of this approach is that life safety systems cannot be compromised for cost savings.
Italy, on the other hand, has adopted a flexible hybrid approach, which has both an older prescriptive approach and a newer, more "creative" design-based approach similar to the United Kingdom. Denmark also has a mixed approach, with performance-based requirements for complex buildings, but prescriptive solutions for traditional buildings, which varies depending on the building type. Similarly, Austria also has a mixed approach, with prescriptive fire safety design regulations set by the government of the 9 federal states, but it is also possible to use a performance-based approach if it can be demonstrated that the required level of safety is achieved.
Both performance-based and prescriptive approaches have their own advantages and disadvantages.
A prescriptive approach, which lays out specific rules and regulations for building design and construction, provides a clear and structured framework for ensuring safety. It also makes it easier for building officials to enforce compliance and for builders to understand and follow the regulations. This approach can also help prevent the "race to the bottom", a culture as described by Dame Judith Hackitt in her independent review into UK Building Regulations, in terms of providing the minimum protection for the lowest cost, as compliance is the only way to demonstrate the standard is met.
On the other hand, a performance-based approach, which focuses on the overall safety of the building rather than specific requirements, allows for more flexibility in the design process. It emphasizes engineering, calculation, and modelling, which can lead to more efficient and innovative solutions. This approach can also account for unique or complex buildings that may not fit into prescriptive regulations. Design Teams with the assistance of Fire Safety Consultancies in the UK are therefore urged when adopting this approach to focus all efforts on delivering the best quality building possible in order to ensure resident safety, rather than prioritizing costs over safety.
The key may be to follow neighbouring countries and find a balance between the two approaches, with prescriptive regulations providing a clear structure and performance-based approach providing flexibility and innovation. A combination of both could be considered, with a prescriptive approach for basic requirements, and performance-based approach for specific and unique buildings.