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The Regs: complying with rules on listed buildings

Large cranes and scaffolding on the exterior of clandon park, surrey
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Geoff Wilkinson looks at the rules relating to energy efficiency, disabled access and fire safety in works on listed buildings

Listed buildings can present a great many challenges for anyone undertaking building works, and balancing the competing requirements can be a minefield for the unwary.

Building Regulations for new works and extensions should comply with current standards, but material alterations or replacement of thermal elements often allow a series of ‘get-out clauses’, so that works can be to a lesser standard of compliance, provided they are no worse than the existing. 

The main areas where issues arise are with Parts L and M of the Building Regulations and, following the Grenfell Tower disaster, Part B is relevant too. 

Part L

Part L still applies to historic buildings, but replacement thermal elements and alterations or conversions don’t necessarily need to meet current standards. There is some excellent guidance in Energy Efficiency and Historic Buildings – The Application of Part L of the Building Regulations to historic and traditionally constructed buildings, published by English Heritage in 2011 prior to its rebranding as Historic England. This guide sets out the correct strategy regarding energy efficiency in listed buildings. Often simple upgrades to things like draught proofing are all that is necessary.  

It is often assumed that because a building is listed disabled access is not possible

Part M

It is often assumed that, simply because a building is listed, it is acceptable that disabled access is not possible. On the contrary: good-quality access can enhance our understanding of the historic environment and ensure its sustainability.

With the right kind of thought and discussion a way can be found around almost any barrier with persistence. With this in mind, Historic England published further guides in 2015 – Easy Access to Historic Buildings and Easy Access to Historic Landscapes – to showcase exemplar projects demonstrating how this vision of access for all can be turned into practical reality.

The guidance in Part M can often be seen as too restrictive, yet departure from the guidance can still help to improve access and be explained by an access statement supporting the application. Early involvement of an access consultant and building control prior to making a planning application can help scope out those areas that are impossible and those which can be included. In many cases the same desired result can be achieved by providing alternative routes or reorganising the use of spaces, without any need for physical alterations.

To avoid making the wrong decisions, organisations and professionals should ideally consult disabled people themselves to understand which solutions would actually meet their needs, rather than making assumptions or hiding behind Part M as an excuse to do nothing.  

Part B

In the wake of the Grenfell Tower tragedy architects will need to consider whether it is acceptable to hide behind the ‘no worse than existing’ wording set out in the Building Regulations or whether they should go further to meet the ‘as low [fire risk] as reasonably practical’ wording set out in Construction Design Management regulations and the Regulatory Reform (Fire Safety) Order (RRO). 

I have previously written on the subject of sprinklers and mist systems so I won’t cover that again here but there are a number of other improvements that can be designed in to offset areas of non-compliance with current regulations. Examples of things to consider include: 

Specifying beam detectors rather than point detectors, as these can cover large areas, thus reducing disruption to the fabric of the building. Wireless systems are also available that can be used in areas of a historic building where the installation of wires is not practical.

Voids are a major issue and, where these cannot be fire-stopped, ‘hidden’ aspirating detectors can be used. These can be concealed and continually sample air, decreasing the time it takes to detect a smoke signal and give early warning.

Existing doors in listed buildings cannot be replaced with modern, tested fire door sets but they can often be upgraded by use of paint, varnish or papers if the core is thick enough. If the core isn’t, then careful joinery can replace panels with fire-rated ones, keeping the look, if not the original materials intact. Although no longer in general circulation, English Heritage’s guide Timber panelled doors and fire provides excellent guidance on ways to improve fire doors while recognising the need to minimise intervention and maintain reversibility. Those principles remain and the document, though 20 years old, can still be used as a resource where alternatives are impossible.

Geoff Wilkinson is managing director of Wilkinson Construction Consultants www.thebuildinginspector.org

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