The government has published an international review on approaches to fire safety and property protection, comparing the building safety regulations of several countries
Dated November 2022 and published on 26 February 2025, the research offers literature review findings and evidence on the international approaches used to reduce property damage in the event of a fire. It follows the government’s commitment to carrying a “full-scale technical review” of Approved Document B (ADB) in response to the findings of Dame Judith Hackitt’s independent review of building regulations and fire safety in 2017 and 2018.
As part of its technical review, a call for evidence by the then Department for Levelling Up, Housing, and Communities (now Ministry of Housing, Communities, and Local Government), identified that “insufficient attention [was] given to protection of buildings in fire safety regulations”, with views needed on property protection.
As the report notes, statutory guidance on building regulation in England covering fire safety matters within and around buildings is published in ADB, with provisions for property protection signposted to the 2015 RISCAuthority Design Guide for the Fire Protection of Buildings by the FPA, which offers twelve principles for fire protection in the design and engineering of buildings. and “many insurers use it as a basis for providing guidance to the building designer on what they require”.
“Whilst property protection is not the intent of building regulations or ADB, the RISCAuthority Design Guide is signposted in ADB, as many insurers use it as a basis for providing guidance to the building designer on what they require. Property protection often requires additional requirements and insurers may set higher standards before accepting the insurance risk. However, compliance with the guide is not a requirement of ADB.”
It should be noted that the RISCAuthority Design Guide has now been replaced by BDM01 A to Z of Essential Principles for the protection of buildings, published in 2023, which is available on the FPA website here.
The objective of the report was to “conduct a review of literature and evidence on approaches intended to reduce property damage in the event of a fire including how other countries approach the issue of property protection through building regulations or equivalent, industry guidance, and evidence on the benefits of property protection and different regulatory approaches”.
The countries studied included the UK, the USA, Germany, Sweden, New Zealand, Australia, Japan, and Singapore, analysing their property protection approaches through prescriptive or performance-based Building Regulations. As the report states: “While prescriptive frameworks define the mechanisms by which the final output must be produced, performance-based frameworks – rather than defining the specific ways in which a building must be constructed – set out functional statements about how a building must perform in the event of a fire.”
For high-rise domestic and multi-occupancy buildings, the primary objective of the national building and fire safety regulations for residential buildings in all the countries reviewed was life safety.
“In some countries – such as Australia, Japan, New Zealand, Sweden and the USA – a degree of property protection is achieved through the principle of limiting fire spread, both between and within buildings. This principle is historically rooted in these countries’ building legislation and applies equally to high-rise domestic buildings and to individual dwellinghouses.”
The report also compared international regulatory approaches to fire safety in industrial warehouses, commercial properties, schools, and historic buildings, offering a thematic analysis of the robustness and resilience of buildings; the challenges brought about by new methods of construction; issues around competence particularly in design, specification, and installation; and the societal and environmental impacts of fire.
For instance, several countries had stricter requirements for schools, with the drivers for property protection internationally also varying to some extent, ranging from preserving business continuity to minimising disruption in a community setting.
The report also found an emphasis on active fire protection measures, such as automatic fire sprinkler protection measures, with mandatory sprinklers being common in international fire safety regulations. This was especially the case for buildings deemed to require additional protection, such as warehouses and schools, with sprinklers also featuring heavily in non-statutory guidelines.
“Research into the fire resilience of buildings also tends to emphasise sprinklers as the primary method of protecting buildings from fire and ensuring resilience, a point which is also underlined by numerous stakeholders. However, the rationale for sprinkler use is not always explicitly set out in international building regulations,” the report states.
One exception to this was detailed in Japanese Building Standard Law, where passive fire protection through “fire resistive buildings” held greater emphasis. As the report stated, the findings indicated that “effective fire resilience can also be achieved through higher durations of fire resisting construction”.
Ultimately, a key message from the research found that while property protection was “rarely set out in international fire safety regulations as an overt objective”, the “principle of protecting buildings and property from fire is implicitly embedded in a number of countries’ codes”.
Fire safety measures often served a “dual or overlapping purpose in fire safety legislation”, with the report stating that “while the primary objective of most mandatory measures is to ensure life safety, many also have ancillary property protection impacts”.
You can read the full report here.