FPA Chief Executive Dr Gavin Dunn reflects on the outcomes of the Grenfell Tower Inquiry Phase 2 report and presents a roadmap of the recommendations that industry can take forward
Amidst an evolving political climate and the release of a long-awaited inquiry report on collective failings at Grenfell Tower, we find ourselves on the brink of substantial, fundamental, and complex change.
The fire safety and construction sectors have been inundated with masses of information, from ambitious government targets for new housing to proposed changes to existing building regulations and construction standards.
Without a doubt, the road to get here has been a challenging one, and there is much to still do and achieve. We are seven years on from the deadly blaze that engulfed Grenfell Tower and took the lives of scores of people including children, and the subsequent public inquiry into the tragedy has exposed many of our sector’s shortcomings. While Phase 1 of the Grenfell Tower Inquiry examined the events of that fatal night, the Phase 2 report sought a comprehensive analysis of the decisions made during the refurbishment of the high-rise residential building and underline the regulatory failures that later emerged. Much of this second and final report will be uncomfortable reading for many in the sector – as it should be.
At 1,700 pages long, with more than 30,000 documents reviewed and over 500 witnesses providing evidence – from survivors to emergency responders to industry experts – the report also includes over 60 recommendations aimed at improving fire safety and building safety. Even if only some of these recommendations are implemented, it will signify the most significant generation of change the industry and the UK built environment have ever seen.
Led by Sir Martin Moore-Bick, the Inquiry team had a straightforward objective: to understand systemic failures that led to the tragic deaths of 72 people on 14 June 2027 and prevent future tragedies like Grenfell Tower from happening again. While some individuals in the sector may not agree with everything the final Phase 2 report concludes, from my perspective, the report at its core offers a fair judgement of the current state of our industry. For the FPA and the wider fire safety sector, several themes deserve close attention.
Who was at fault?
The report’s condemnation is severe, but it does not single out fault: no one party is directly attributable to the fire, rather it was the result of a collective failure by all. The report notes the significant failure of the design team, with the Inquiry pointing towards deficiencies in the design of the building and its use of combustible cladding, which contributed to the rapid spread of the fire. In addition to this, testing standards were inappropriate or, more importantly, misunderstood. The certifications based on some of those tests were incorrect, and even those that were correct were often incorrectly relied upon by the design team. Underlying all this was a significant misunderstanding of the building regulatory system; thus, a weak core system led to a series of mistakes. Commercial actors, particularly manufacturers and several other parties, allegedly took advantage of those mistakes to further their commercial interests.
In Sir Martin’s report, the response of the emergency services was also scrutinised, with issues in the communication of the fire services, evacuation procedures, and their overall management of the emergency. There were also failures in the management and maintenance of the Grenfell Tower, including inadequate fire safety measures by the owners and operators and insufficient training for staff regarding residents’ needs.
Regulatory shortcomings are also criticised, with the existing regulations and oversight mechanisms found inadequate for ensuring fire safety. However we interpret these findings, they signify major changes and, invariably, great obstacles that our sector must now overcome.
Regulation of construction products and product testing
One of the key findings highlighted was that inadequate oversight meant that the regulation of construction products, particularly cladding, was poorly enforced. Manufacturers gave out misleading fire performance data, and their safety tests did not reflect real-world conditions. Certification bodies also failed to scrutinise materials sufficiently, allowing unsafe products to be marketed, and the regulatory framework lacked a single body within the government responsible for overseeing construction product safety.
In response to these failings, Sir Martin and his team made the following recommendations:
- New regulatory body: establish an independent authority to regulate construction product safety.
- Accurate labelling: ensure clear and transparent labelling about fire performance.
- Regular recertification: regularly review and recertify materials used in high-risk buildings.
- Manufacturer accountability: Hold manufacturers legally accountable for inaccurate product information.
- Public database: create a public database of construction products, including fire performance details.
- Clearer guidance for use: provide clear instructions on suitable materials for specific building types.
Regarding product testing, the Inquiry team concluded BS 476 did not adequately assess the fire risks posed by modern materials, such as the combustible cladding used at Grenfell Tower. In particular, the Class 0 rating gave a false sense of security, as it did not reflect a material’s true combustibility. BS 476 tests also did not assess the fire performance of entire cladding systems, focusing instead on individual materials, and current methods including BS 8414 offered insufficient guidance for complex systems, leading to widespread misinterpretation.
The recommendations offered were as follows:
- Replace with modern standards: replace BS 476 with modern, comprehensive testing standards for fire safety.
- System testing: emphasise large-scale testing of entire wall systems to reflect real-world conditions.
- Clearer combustibility classification: ensure clearer distinctions between non-combustible and combustible materials.
- Align with international standards: adopt international testing standards such as the Euroclass system.
- More rigorous testing: require real-world testing of products, assessing how they perform in full systems.
A more rigorous testing approach is, of course, a welcome one, and there is much in the report to suggest that test certification houses should be given the freedom to report directly to the regulator, independent of the manufacturer. If interpreted correctly, this could mark a significant shift in the nature of the testing body/manufacturer relationship, where the inappropriate imbalance – with the power, money, and resources sitting with just one body, the manufacturers – that allows people to do things they should not will no longer exist.
Building control
Moving on to building control, the report concluded that the Royal Borough of Kensington and Chelsea’s (RBKC) Building Control department did not fulfil its responsibility to ensure building regulations were met. Officers failed to properly examine the design and installation of critical elements, missing clear indications of fire hazards posed by combustible cladding. Additionally, Building Control depended too much on certificates and assurances from contractors and manufacturers, and there was insufficient expertise within the department to assess complex high-rise projects. Communication failures with contractors and fire safety consultants also led to misunderstandings and mismanagement of fire safety risks.
In his recommendations, Sir Martin called for significant reform of the building control market, including a greater push for improved competency:
- Strengthening oversight: reform Building Control departments to enforce stricter oversight of construction projects.
- Improved competency: enhance training and regular competency assessments for Building Control officers.
- Mandatory inspections: increase the frequency and thoroughness of inspections during construction, especially for critical fire safety elements like cladding systems, fire doors, and compartmentation.
- Independent certification: Building Control should ensure independent and robust assessments of materials and systems rather than relying solely on manufacturer certifications or test results.
Fire engineers and fire risk assessors
The report highlighted that fire engineers had inadequate involvement in the Grenfell Tower refurbishment, resulting in critical fire safety risks being overlooked. A lack of comprehensive risk analysis meant they did not conduct thorough risk assessments for fire safety and failed to assess the cladding system adequately. There was also an over-reliance on prescriptive guidance, where fire engineers adhered strictly to prescriptive regulations without fully considering the unique risks posed by the materials and design. They also did not clearly communicate fire safety concerns effectively to the architects and contractors.
The recommendations for fire engineers include:
- Greater involvement: fire engineers should be engaged throughout the design, construction, and completion phases of high-rise projects.
- Independent oversight: fire engineers should act independently to provide unbiased advice on fire risks.
- Higher professional standards: introduce mandatory accreditation for fire engineers to ensure competency including CPD and make ‘Fire Engineer’ a protected title with support from regulators.
- Clearer accountability: fire engineers should be held accountable for fire safety advice through clearer guidance and documented reports.
The report also suggests that the fire risk assessors involved in assessing the residential block failed to identify significant risks, including the dangerous cladding of the building. Arguably, this risk assessment is the fundamental underpinning document of the safety and risks within a building. However, the assessors were found to have lacked the expertise needed to assess complex fire safety risks in high-rise buildings. Risk assessors made assumptions about fire safety features without verifying their adequacy, and their assessments often did not prioritise critical fire risks such as external cladding. Ultimately, a generic and routine risk assessment approach was taken for a unique building that had a unique set of risks.
The recommendations for fire risk assessors include:
- Mandatory qualifications: introduce a standardised accreditation system for fire risk assessors ensuring assessors are independent and accountable.
- Comprehensive risk assessments: conduct thorough, site-specific assessments that go beyond prescriptive guidance.
- Improved competency standards: provide rigorous training for assessors, particularly in evaluating external wall systems.
- Detailed and comprehensive assessments: risk assessments should cover all fire safety aspects, including compartmentation and cladding.
- Regular reviews: fire risk assessments should be reviewed regularly, especially after building alterations.
Definition of high-risk buildings
One of my final reflections on Sir Martin’s report relates to the definition of ‘high-risk buildings’. The report notes that the regulatory framework's current definition is too narrow and unclear. Categorising buildings based solely on height does not fully account for fire risk complexities, as mid-rise buildings below the 18-metre threshold can still pose significant dangers. Additionally, the current definition neglects the presence of vulnerable individuals, such as elderly or disabled residents, who may need more protection and tailored evacuation strategies.
Sir Martin offers the following recommendations:
- Broaden the definition: the definition of ‘high-risk buildings’ should be expanded beyond height to include factors such as:
- The presence of vulnerable residents
- Building use (e.g. residential, care homes, hospitals) occupancy levels and density
- The presence or absence of fire safety features.
- Risk-based approach: a more nuanced, risk-based approach is needed, considering factors like construction materials, occupancy, and fire safety measures, instead of relying solely on height.
- Tailored safety measures: buildings classified as high-risk should have customised fire safety protocols, including enhanced systems, evacuation plans, and regular inspections.
Currently, the Building Safety Act (2022), which is less than two years old, uses a very specific definition for ‘high-risk buildings’, using height and sleeping as a proxy for risk. The Inquiry has suggested that such a definition is inadequate and has instead called for something not height-related, or at least not predominantly based upon height. Their new definition offers a broader scope based on the presence of vulnerable residents, the occupancy density of the building, and the presence of any fire safety features. While allowing for a more tailored assessment of risk and a refined approach to fire safety is something to be welcomed, changing the definition poses a real risk of jeopardising and undermining the good work that has already been done. The building safety regime is not equipped to handle the wider range of buildings that this change of definition would entail.
Where do we go from here?
Sir Martin’s report exposes systemic failures that led to the tragedy of Grenfell Tower. As I mentioned above, the problem with systemic and cultural failures is that everyone and no one is at fault. The real danger is that we simply wait to be told the crux of the problem. Instead, the report’s findings require all of us, as a sector, to reflect on what we have done and what we need to do differently to enable the change the built environment requires. Ultimately, we will only succeed if enough of the sector is willing to be part of that change.
There is one statement from Sir Martin that will sit uneasily with many of us in the industry for years to come:
“…The simple truth is that the deaths that occurred were all avoidable and that those who lived in the tower were badly failed over a number of years and in a number of different ways by those who were responsible for ensuring the safety of the building and its occupants.”
Looking ahead, there are significant challenges not just for industry but for government too. The new government is on a mission to drive change in the built environment, improve building safety, and be seen to act on building safety. They see it through the eyes of social justice, and they have an impulse and a mandate to act. Certain commitments were promised in a ministerial statement released just two days before the publication of the Phase 2 report and included proposals for residential personal emergency evacuation plans (PEEPS) for vulnerable and disabled residents, sprinklers in all new care homes, the disbanding of outdated national classes, and a reform of the construction product testing regime. These are not insignificant actions, and it is imperative that as an industry we do not let them get lost in the noise of other housebuilding targets and construction-related news.
There is now even more opportunity for industry and government to come together and share knowledge and expertise, with the FPA’s Policy Manifesto and its six key policies a fundamental part of this. Collectively, we can welcome a genuine convergence of life safety and property protection that prioritises the safety of residents and celebrates innovation in construction.
The biggest takeaway from the Inquiry report is that it has finally removed the barrier that says, ‘Why wait?’ and industry has now reached a much-needed milestone. No longer can we sit on our laurels and let the failings within the built environment pass us by. Fire safety should be at the centre stage of both building protection and life safety. The time for change is now.