HRB Justification Statement Services

A Building Regulations Justification Statement is a supporting document that explains how a proposed design or technical solution complies with the functional requirements of the Building Regulations, particularly where the approach does not follow the standard guidance in an Approved Document or where the guidance does not directly address the proposed solution.

The statement brings together the design rationale, applicable Building Regulations requirements and supporting technical evidence so that the compliance approach can be clearly understood and assessed.

A Justification Statement is not a separately prescribed Gateway 2 document in the same way as the Building Regulations Compliance Statement, Construction Control Plan or Change Control Plan.

However, additional justification can be valuable where a design departs from standard guidance, uses an alternative compliance approach or involves a complex solution that requires further explanation.

The relevant reasoning and evidence should also be reflected in, or clearly linked to, the Building Regulations Compliance Statement submitted as part of the Gateway 2 application.

A Justification Statement may be appropriate where the proposed design does not follow a conventional route set out within the Approved Documents or where standard guidance does not adequately address the circumstances of the project.

Examples can include complex building geometry, unusual fire strategies, mixed-use arrangements, bespoke construction details, alternative technical solutions or other project-specific approaches requiring additional explanation.

The need for justification should be assessed against the particular design, relevant functional requirements and supporting evidence rather than assumed for every higher-risk building project.

Yes. Approved Documents provide guidance on ways of satisfying the Building Regulations, but following an Approved Document is not the only possible route to compliance.

Where an alternative approach is proposed, the project team needs to demonstrate that the design still satisfies the relevant functional requirements of the Building Regulations.

A well-prepared Justification Statement can explain why the alternative approach has been adopted, how compliance is achieved and what technical evidence supports that conclusion.

The Building Regulations Compliance Statement is a required part of the relevant Gateway 2 building control application and sets out the project's overall approach to complying with the Building Regulations.

A Justification Statement is a more focused supporting document that can provide additional explanation for a particular design decision, alternative approach or area of technical complexity.

Where a Justification Statement is used, it should align with the Building Regulations Compliance Statement and the project's drawings, specifications and supporting evidence so that the submission presents a consistent compliance strategy.

No. Although fire and structural safety are particularly important considerations for higher-risk buildings, compliance with the Building Regulations extends across all applicable functional requirements.

A Justification Statement may therefore relate to any relevant part of the Building Regulations where a design decision or alternative approach requires additional explanation.

Depending on the project, this could include matters relating to structure, fire safety, ventilation, accessibility, drainage, acoustics, thermal performance, protection from falling or other applicable requirements.

The appropriate evidence depends on the technical issue and the proposed solution.

Evidence may include engineering calculations, drawings, specifications, fire strategies, test reports, certification, product performance information, assessments, technical reports, recognised standards, design codes and specialist advice.

The evidence should be relevant to the proposed design and clearly linked to the particular Building Regulations requirement being addressed.

The statement should be prepared and coordinated by people with appropriate competence and sufficient understanding of the relevant Building Regulations requirements and technical design issues.

Input may be required from several members of the design team, including architects, structural engineers, fire engineers, building services engineers, façade specialists and other technical designers.

The Building Regulations Principal Designer should also ensure that relevant design information is coordinated and that the overall design compliance strategy is coherent.

Yes, where the issues are related and can be clearly explained within one coordinated document.

For complex projects, however, it may be clearer to use separate justification statements for different design matters or disciplines and then cross-reference them from the overall Building Regulations Compliance Statement.

The most appropriate structure will depend on the complexity of the project and the amount of supporting technical evidence involved.

A clear and well-evidenced statement can make it easier for the Building Safety Regulator to understand the proposed design, the applicable requirements and the reasoning behind an alternative approach.

It can also help identify inconsistencies or gaps in the supporting information before submission.

However, providing a Justification Statement does not guarantee approval or prevent the BSR from requesting additional information. The strength of the application depends on the quality, completeness and coordination of the overall compliance evidence.

Once a Gateway 2 application is approved, the approved information becomes part of the project's agreed documents.

If the design subsequently changes, the project team must assess the effect of that change on Building Regulations compliance and manage it through the applicable change control process.

Where the change affects a design solution covered by a Justification Statement, the statement and supporting evidence may also need to be reviewed or updated. Major changes require BSR approval before the affected work proceeds.

BSAC can review proposed works and identify areas where the Building Regulations compliance route requires further explanation or supporting justification.

Our team can review drawings, specifications and technical reports, identify the applicable functional requirements, assess the proposed compliance approach and prepare a coordinated justification narrative supported by the relevant project evidence.

We can also help ensure that the Justification Statement aligns with the Building Regulations Compliance Statement and wider Gateway 2 submission, providing the Building Safety Regulator with a clear and traceable explanation of the proposed approach.