Combustible Cladding update: The Association of British Insurers

In the wake of the Grenfell Tower disaster, the role of the insurance industry will be critical in assessing the effectiveness of current and future building regulations – and also how some of the costs in achieving safety standards will be met.

The Association of British Insurers recently provided evidence to the Independent Review on Building Regulations and Fire Safety.

The ABI stressed that insurers have an integral interest in “fit-for-purpose” building regulations that effectively protect lives and property from the risk of fire.

It said:

“The review marks a seminal opportunity to recommend substantial change that will fundamentally improve fire safety in England’s buildings, but also and as a consequence, improving the risk profile of these buildings, increasing competitiveness amongst insurers in this market and benefiting customers through associated effects on premiums”.

The ABI has long called for a comprehensive review of building regulations to ensure robust procedures are in place that enable a competitive property insurance market to continue.

The key areas in which the ABI suggests action is required are:

1. Counteracting the increased level of combustible material in building design and construction and improving the robustness of the building control’s testing regime on the performance of building materials, to include:

• An end to the use of materials of ‘limited combustibility’ on the envelope of buildings, requiring only ‘non-combustible’ materials
• A reformed testing regime that finds proof of non-combustibility, rather than accepting the use of ‘limited combustibility’ in certain circumstances
• A reformed testing regime that replicates ‘real-world’ build conditions rather than ‘perfect build’ scenarios, so that the non-combustibility of materials is considered fit for purpose
• A reformed testing regime that eliminates the use of construction and material that are so susceptible to minor deviation that they can only be demonstrated to be safe and compliant ‘on-plan’. This only serves to create uncertainty about the fire performance of a building 

• The apparent incongruous nature of energy performance / sustainability and fire safety within current regulations with a view to considering an overall resilience score for buildings that includes performance against fire 

• A whole of building fire performance test evaluation, where major refurbishments take place, to ensure that the overall fire performance of the building is not reduced


2. Improving mandatory passive and active fire protection measures, to include:

• Mandatory installation of sprinklers for all new build schools, new build care 
homes and warehouses over 2000m2
• A review of sprinkler protection for other buildings, including a suitable 
performance standard for sprinklers in high-rise or multi-occupancy buildings 
that takes into account wider risks to property 

• Consideration of the link between current, commonly used fire alarm systems, 
the extent of false alarms and the effect on fire service response, detection and 
evacuation procedures 

• Close consideration of the implications of the repeal of the Local Building Acts 
on passive and active fire protections, and the re-introduction of provisions from these Acts that are not currently incorporated within Building Regulations

3. A detailed review and assessment of the understanding and clarification of roles and responsibilities of all those involved in the fire safety of a building, to include:

• Explicit guidance that ensures in the light of reviewed regulations all responsibilities are clearly understood 

• Recommendations to ensure effective enforcement at all levels of fire safety, including design, implementation, supervision, control and authorisation 

• Clarity within the regulatory framework of a ‘Responsible Person’ including relevant qualifications and training that is expected to ensure competency 

• Improving understanding of the purpose of fire safety provisions in Building 
Regulations across persons and sectors who are impacted 

• Close consideration of the role and qualifications of fire engineers in relation to the fire safety of buildings, including the levels to which buildings can be ‘value- engineered’ down to a level that may significantly reduce the overall resilience 
of a building 


Bevan Brittan Pre-Consultation Survey

The consultation asks some wide-ranging questions, and - with the process closing on 14 August - there is not a lot of time to respond. Bevan Brittan is undertaking a pre-consultation survey in order to gain input from our clients and colleagues. Please could you take 5 minutes to complete the questions in our survey. The closing date for the survey to be completed is 30 July.