MHCLG consultation on banning the use of combustible materials in the external walls of high-rise residential buildings

14 August 2018

The National Housing Federation supports the overall proposal put forward in the consultation to ban the use of combustible materials in cladding systems on high-rise buildings. However, we recognise that such a ban will not be simple to implement and careful consideration of unintended consequences is required.

The tragic events at Grenfell Tower have called into question the effectiveness of the legislative and regulatory regime for high-rise and multi-occupancy residential buildings.

The quality of homes, places and services, based on a founding principle of safety, is integral to our vision for the future. We believe the Hackitt Review, and policy implementation arising from that process, must act as a catalyst for transformative change across construction and building management. We are committed to working with Government and industry partners to support meaningful and long-term change in the safety and quality of higher risk residential buildings.

The National Housing Federation’s position on a ban of combustible materials

Following consultation with members, the Federation supports the overall proposal to ban the use of combustible materials in cladding systems for buildings 18m or over in height through a change in the law.

We believe the use of combustible materials on the external walls of high-rise buildings introduces an unacceptably high risk in the event of fire. Regulating the use of these materials requires a complex and technical testing regime, and is overly reliant upon perfect construction and installation.

However, such a ban will not be simple to implement. Prior to legislative changes coming forward, the Government must assess the impact such a ban could have on the rates of construction for high-rise buildings and consider appropriate timeframes for transitioning to the new regime.

Our consultation response draws on the technical expertise of our members and partners to propose solutions and options to Government. We are mindful of the policy detail, scope and associated guidance needed to mitigate any unintended consequences of implementing this proposal.

Our response covers:

• Options for managing the limited use of combustible materials where no alternative is available or appropriate, either through a more targeted ban and/or the introduction of a registered supplier scheme and approved details
• The need to adopt a risk-based approach for existing buildings in line with the recommendations of the Hackitt Review.
• The early adoption of relevant recommendations from the Hackitt Review for projects where building work is already underway and the materials being used would not satisfy the European Class A2 or better requirement.
• Recognition that the proposed changes are likely to increase project timescales, and therefore costs, at least in the short term while industry and the supply chain adapts.