Fire safety compliance isn’t static. A building that was once compliant under UK fire safety law can become non-compliant overnight, not because anything went wrong, but because something changed.
That “something” is often what’s referred to as a material change.
But what does that actually mean in practice? And when do building alterations, refurbishments, or usage shifts trigger a legal duty to revisit your fire risk assessment, alarm system, or escape routes?
In this article, we explain what counts as a material change under UK fire safety regulations, how to recognise one, and what action you’re legally required to take.
What Is a Material Change?
A material change refers to any alteration in the structure, use, or occupancy of a building that could affect the existing fire safety strategy.
This term is recognised under several regulations, including:
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The Building Regulations 2010
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The Regulatory Reform (Fire Safety) Order 2005
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And more recently, the Building Safety Act 2022
When a material change occurs, it can:
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Trigger a need for building control approval
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Require a revised fire risk assessment
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Necessitate upgrades to fire alarms, emergency lighting, or compartmentation
In short, once a material change happens, you may no longer be legally covered by your previous fire precautions.
Examples of Material Changes in a Building
Here are some common examples that count as material changes:
1. Change in Use
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Turning a retail shop into a restaurant or takeaway
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Converting a house into an HMO (House in Multiple Occupation)
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Changing a commercial office into a medical facility or nursery
These affect the building’s fire risk profile, including the type of occupants, the hours of use, and the risk of ignition sources.
2. Change in Occupancy
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Increasing staff numbers in an office
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Adding new tenants to a block of flats
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Using a previously empty floor or space
More people means more complex evacuations, potential congestion in escape routes, and possibly a need for voice alarms, extra signage, or phased evacuation.
3. Structural Alterations
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Moving or removing internal walls
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Installing mezzanine floors
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Adding new staircases or lifts
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Cutting service penetrations through fire-rated walls or ceilings
Any structural work that affects compartmentation, escape times, or access for firefighting is considered a material change.
4. Installing New Systems
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Adding ductwork or ventilation systems
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Installing false ceilings
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Retrofitting air conditioning or data cabling
Even contractors doing electrical or plumbing work can accidentally breach fire-stopping, undermining your fire strategy without realising it.
5. Change in the Vulnerability of Occupants
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Admitting occupants who require assisted evacuation
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Operating a dementia care unit in part of the premises
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Turning a standard flat into sheltered housing
If the people using the building become more vulnerable or less able to evacuate independently, your fire precautions must adapt accordingly.
What the Law Says
The Regulatory Reform (Fire Safety) Order 2005 places a duty on the Responsible Person to “Take general fire precautions as may reasonably be required in the circumstances to ensure that the premises are safe.”
A material change often creates new circumstances, which means the Responsible Person must:
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Review the fire risk assessment
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Update evacuation procedures
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Modify fire safety systems as needed
Failing to do so can result in enforcement notices, insurance issues, or even worse, endangering life.
Do I Need to Notify Building Control?
If the change involves structural work or significantly alters the use of the building, yes, you may need to submit a Building Regulations application or seek approval from a building control body.
This applies to:
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Flats being converted into HMOs
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Commercial units being repurposed
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Fire doors, staircases, or compartment walls being removed or relocated
Failure to get approval can result in legal action or orders to reinstate fire precautions at your own cost.
How to Stay on Top of Material Changes
Fire safety isn’t a one-off task. To remain compliant:
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Review your fire risk assessment regularly, or when changes occur
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Keep communication open between contractors, landlords, and fire risk assessors
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Don’t assume small changes are risk-free. Even something like relocating a kitchen or moving desks can affect escape routes
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Engage a competent person to review new layouts and systems
Final Thoughts
Material changes are part of how buildings evolve, but they also shift the fire risk landscape. Whether you’re a landlord, building manager, or business owner, recognising and responding to these changes is part of your legal duty.
If you’ve recently changed the way a space is used, made structural alterations, or taken on new types of occupants, now is the time to review your fire safety measures.
For expert advice on fire protection and prevention measures, contact Martyn Young Fireproofing Consultancy on 07585 896648