Building Safety Act: Why architects now need to consider fire resistance

The introduction of the Building Safety Act in 2022 marked a seismic shift in how safety is embedded in building design and construction across the UK. Developed in response to the Grenfell Tower tragedy and following Dame Judith Hackitt’s independent review recommendations, the Act introduces sweeping reforms to enhance building safety, particularly in high-rise and high-risk residential buildings.

The Act introduces new statutory responsibilities for architects. They are no longer peripheral consultants in the early design stages but now legally accountable duty holders, required to demonstrate that safety, including fire resistance, is prioritised and maintained from concept through to completion.

As fire safety becomes inseparable from architectural design, we explore why architects must now take a proactive role in specifying fire-resistant materials and systems, including mechanical ventilation—where product choice and integration can have significant implications for compliance.

Fire resistance as a core design concern

Fire resistance is no longer a late-stage construction detail but a foundational design parameter. The Building Safety Act explicitly obliges architects to “design out” risk early. This includes ensuring structural elements, materials, and systems resist flame spread, protect escape routes, and allow for safe evacuation.

Under the revised regulatory regime, this means integrating fire resistance into layout, materials, and building services. Crucially, architects must consider how elements like walls, ceilings, and service penetrations perform under fire conditions, ensuring that any breaches (such as those made for ventilation ductwork) do not compromise the integrity of compartmentation.

This change is particularly impactful for projects falling within the Act’s scope, being buildings over 18 metres in height or having at least seven storeys, those containing multiple dwellings, or those classified as higher risk buildings (HRBs).

Dutyholders, gateways, and the Golden Thread: Key elements of the Building Safety Act

The Act introduces a dutyholder framework, aligning closely with CDM 2015 regulations. Architects are now formally recognised as Principal Designers under the Building Regulations, responsible for ensuring that fire safety is demonstrably accounted for at each Gateway:

• Gateway 1 (Planning): At the planning application stage, designers must demonstrate that fire safety has been adequately considered and incorporated into the design. Fire statements are mandatory for relevant developments.
• Gateway 2 (Pre-construction): At the pre-construction phase, full design details must demonstrate compliance before construction begins. This must include a full safety review of the design, materials, and compliance documents by the Building Safety Regulator before construction can commence.
• Gateway 3 (Completion): Upon completion of construction, the Building Safety Regulator must be satisfied that the building complies with all safety standards and that it is fit for occupation.

Throughout the duration of the three gateways, a comprehensive digital record forming part of the “Golden Thread” must prove that what is ultimately built aligns with what was initially designed. The Golden Thread covers all aspects of a building's design, construction, and maintenance throughout its entire lifecycle. 

Failing to fulfil these duties carries legal risk. Therefore, architects must be confident in their specifications, especially where ventilation interacts with fire-resistant elements.

Where ventilation and fire safety intersect

Modern buildings are more airtight and energy-efficient than ever. As a result, mechanical ventilation systems such as MVHR and MEV are no longer optional but a regulatory necessity under Part F and Part L of the Building Regulations in highly air-tight dwellings

However, if poorly specified or installed, these systems can become pathways for smoke and flame spread, undermining compartmentation strategies.

Key intersections include:

• Duct penetrations: Ducts running through walls and ceilings must be fire-stopped, often with intumescent fire sleeves or fire dampers.
• Grilles and valves: Any element breaching a fire-rated barrier must itself be fire-rated. This includes extract valves and terminal grilles.
• Fire dampers: For larger ducted systems and communal areas, these are required in certain ductwork arrangements to automatically close in the event of fire, particularly when ventilation systems cross compartments.
• Product compatibility: Using non-certified components (e.g., plastic grilles in fire-rated walls) can invalidate the overall compartment rating and expose designers to liability.
• External wall penetrations: Meeting approved document B, for all dwellings above 11 metres, all materials penetrating the external facade should be manufactured from a non-combustible material achieving A1 or A2-s1, d0 standard

Architects must collaborate early with M&E consultants and ventilation manufacturers to ensure that systems meet both ventilation performance requirements and fire resistance criteria under Approved Document B.

Balancing fire and air: A practical approach

Architects must now ask: “How does this product or system affect the building’s fire strategy?” This question is especially important when working with increasingly ambitious sustainability and air quality targets.

For example, specifying an MVHR system in a high-rise block may deliver SAP gains and IAQ improvements, but it also introduces fire-stopping challenges that must be mitigated with the correct use of fire-rated ductwork, dampers, and accessories. Oversight at this stage can cause compliance failures, project delays, or post-handover disputes.

The BEAMA Ventilation Group highlights the growing need for competency in specifying whole-house ventilation systems, emphasising that safety and efficiency are not mutually exclusive.

Specifying for compliance with the right supply partner

Given the complexity of regulatory overlap — Parts B, F, L, and increasingly O — it is essential that architects work with trusted suppliers who offer fully tested, compliant, and well-documented solutions.

Seek out a ventilation partner who can support you in meeting the demands of these regulations through:

• Fire-rated product ranges: Including fire-rated grilles and terminal valves that maintain compartmentation integrity.
  
  
• System compatibility advice: To help ensure that every duct, grille, and control system integrates without compromising fire resistance or energy performance.
  
  
• Technical documentation: Supplied in formats suitable for gateway two submissions, including BIM models and test certifications.
  
  
• Design support: Direct consultation during RIBA stages 3–5 to reduce rework and aid smooth Building Control approvals.
  
  
• Regulatory alignment: Products tested to meet Part B and Part L criteria, with SAP Appendix Q listings and ISO 9001 quality assurance.

Critically, this kind of end-to-end support helps architects, designers, and specifiers balance fire safety, buildability, and compliance to achieve project sign-off without project delays.

Conclusion: Early integration, safer outcomes

The Building Safety Act has fundamentally changed how building design is conducted in the UK. Architects are no longer isolated from construction accountability; they are now at its centre. Fire resistance is now a design-stage priority, not just a compliance box to be ticked post-tender.

Incorporating fire-resistant ventilation solutions early can reduce risk, avoid delays, and ensure safer, future-ready buildings. To this end, it is crucial to partner with a ventilation supplier who can confidently support architectural teams with compliant systems, technical guidance, and a track record of reliability.

To ensure your ventilation specifications are safe, compliant, and buildable, contact Titon for expert advice or explore the Titon FireSafe® Range for more information.