School of Specification – Fire Safety for Principal Designers

Simón Santamaria, Technical Development Director at Stantec, has produced a School of Specification module on fire safety for principal designers. Here he explores the distinction between compliance and conformity, as well as the tools for evaluating competence and quality in fire safety design.

What core knowledge and competencies do principal designers need in order to discharge their fire safety duties effectively?
Principal designers play a critical role in upholding fire safety under the UK dutyholder regime. While they are not fire specialists, they must demonstrate due diligence by engaging meaningfully with experts, tracking decisions, and supporting compliance – not just conformity with guidance. This requires a working understanding of their legal responsibilities, the outcomes-based nature of the Building Regulations, and how fire safety decisions evolve through design and construction. Principal designers should be able to discuss hazards, risk, and mitigation at a strategic level; understand how different systems interact; and recognise when assumptions create risk. Equally important is their role in setting up processes to record decisions, competence, and design intent. This enables them to confidently challenge advice where needed and demonstrate that fire safety has been actively coordinated rather than passively delegated.

What’s the difference between compliance and conformity – and why does it matter?
Conformity is following guidance, while compliance is meeting the functional requirements of the law. Conformity may lead to compliance, but that outcome is not guaranteed. This distinction matters and, for principal designers, this means recognising that fire safety cannot be reduced to box-ticking exercises. Demonstrating compliance requires judgment, justification, and an understanding of why particular guidance is appropriate for a given design. Language drives behaviour: when teams focus solely on ‘meeting guidance’, they risk overlooking performance, context, and unintended consequences that only become apparent when solutions are properly interrogated.

Compliance is embedded in the golden thread: clear, traceable information, recorded decisions, and competence evidence”

How can principal designers assess whether a fire safety strategy is robust?
A robust fire safety strategy is clear, consistent and transparent about its objectives and assumptions. It should explain not only what measures are proposed, but why they are appropriate and how they contribute to the building performance in a fire. Principal designers should look for a clear narrative that links hazards to mitigation, guidance to intent, and design decisions to outcomes. A strong strategy demonstrates an understanding of first principles, rather than simply restating benchmark solutions. Where complexity exists, it should be acknowledged and managed, not obscured. This allows principal designers to understand the implications of design changes and maintain control of risk as the project evolves.

What are the key elements of demonstrating compliance?
Compliance is embedded in the golden thread: clear, traceable information, recorded decisions, and competence evidence. In practice, this means showing that guidance is appropriate for the project, that design provisions meet fire safety objectives, and that these objectives align with the functional requirements of the Building Regulations, all documented in a coherent, accessible report.

What practical lessons can principal designers apply in their own projects?
Principal designers can add immediate value by asking fire engineers to explain their reasoning and link solutions to physical principles, not just standards or precedents. Questions such as “What problem is this addressing?” or “What assumptions does this rely on?” help reveal whether a solution is robust and proportionate. Recording decisions, interfaces, and competence is equally important. By encouraging open dialogue, early challenge, and clear documentation, principal designers move beyond simple conformity checks and help ensure that compliance is demonstrable, defensible, and aligned with the overall design intent of the building.