Remediation Position Statement

1. Issue Identification

The Grenfell Tower fire in June 2017 was a national tragedy that resulted in the greatest loss of life in a residential fire since the Second World War. The resulting response efforts and inquiries have highlighted the scale of systemic fire and building safety issues in the built environment.

Fire and rescue services (FRSs) have played a pivotal role in making buildings safe since the Grenfell Tower fire, conducting thousands of inspections, identifying dangerous fire safety defects, and working to safeguard residents. These efforts have provided critical insights into the scale and complexity of the challenge of remediating dangerous safety defects in our built environment.

In particular, they have underscored the limitations of current enforcement and regulatory approaches in addressing deeply rooted issues in building safety compliance, funding, accountability, and construction practice. These insights have highlighted the scale of broader issues preventing duty holders from meeting their obligations to make buildings safe. There is an urgent need for further action, including strategic workforce planning, funding, and data transparency, which are necessary steps to ensure that remediation is delivered effectively, equitably, and at pace so that people can feel safe in their homes.

The National Fire Chiefs Council (NFCC) welcomes the Government’s renewed focus on accelerating building remediation, reflected in the Remediation Acceleration Plan (December 2024 and July 2025), and recent calls to action. To support efforts, NFCC has identified persistent barriers to progress, including major data gaps, unregistered buildings, fragmented funding, regulatory complexity, workforce shortages, and the lack of a unified, risk-based approach, all of which continue to hinder the sector’s ability to meet national targets.

While progress has been made on the highest-risk buildings, many residential blocks still require work, posing ongoing risks and undermining public confidence. The building industry and its regulators remain fragmented, under-resourced, and lack the coordination needed for large-scale remediation. To complicate matters, current funding only focuses on cladding, but many buildings also contain serious internal fire safety defects in addition to dangerous combustible cladding.

Medium-rise buildings (defined as 11–18m), which are far more common than high-rise buildings (18m+), face greater uncertainty due to data gaps, limited records, funding exclusions, and the absence of a consistent, risk-based approach. Additionally, much of the Building Regulations 2010’s statutory building safety design guidance (Approved Document B) is triggered by an 18m height threshold. This is also the trigger height for enhanced safety requirements within Part 4 of the Building Safety Act, including mandatory registration with the Building Safety Regulator.

NFCC’s members are therefore aware that some parts of the sector build to a height just below this threshold, to avoid introducing various safety features. This suggests that there could be a number of buildings as high as six storeys that have been built in recent years without critical firefighting facilities and features such as firefighting shafts.

2. NFCC position

NFCC is concerned that enforcement powers and capacity alone are not sufficient to address the building safety crisis, and many duty holders still face systemic challenges in meeting their legal obligations. The time taken to remediate the external walls of a single building can be extensive, and this will be dependent on a range of factors outside the desire or willingness of the relevant duty holder to carry out the work; time-bound obligations can only be effective if people are in a position to comply.

The remediation of England’s residential building stock must be supported by a risk-based, collaborative, and programmatic approach that ensures unsafe buildings are identified, prioritised, and made safe in a timely manner. Without targeted investment, clear guidance, and a skilled workforce, the sector will continue to struggle to meet the Government’s remediation targets and, more importantly, protect lives.

3. Recommendations

NFCC calls on the UK Government to:

Create a centrally-coordinated risk-based remediation programme, which should be backed by an industry-wide action plan that clarifies roles, responsibilities, and realistic timelines for the remediation of residential buildings, supported by a shared data solution for all parties.

Urgently undertake long-term strategic workforce planning through a cross-departmental Construction Skills Strategy. This should include programmes of work to identify critical professions that require further regulation, monitor capacity, and fill critical shortages in fire engineering, fire risk assessment, regulatory staff, building control, and related trades.

Keep all remediation funding schemes under regular review to ensure they cover relevant fire-safety defects (both internal and external) and that leaseholders are not bearing undue costs.

Urgently review Approved Document B, making clear that the guidance does not facilitate compliance with the Building Regulations 2010, and review the Building Regulations 2010’s non-worsening provisions to close loopholes that allow buildings to be refurbished without reasonable improvements.

Clarify how the Building Safety Act 2022’s enforcement powers should be used in tandem with existing fire safety legislation and enable the Building Safety Regulator to take a strategic leading role in the central coordination of enforcement powers, including the production of new learning, guidance, or precedents that arise.

Implement the Grenfell Tower Inquiry’s Phase 2 recommendations through occupational regulation, a large-scale product testing regime, and publicly available compliance data.

4. Supporting evidence

In February 2025, NFCC published an Industry White Paper on Remediation. This position statement should be read alongside the Industry White Paper, which goes into much greater depth on all of the issues below.

Scale of remediation challenge

A 2024 National Audit Office report estimated that up to 12,000 residential buildings above 11m in England could require remediation.

MHCLG (via Homes England) then began to collect data regarding how many residential buildings of 11m+ require remediation. This data has formed a new ‘National Remediation System’.

MHCLG’s current best estimates are that there are between 5,900 and 9,000 residential buildings over 11m that will require remedial work in England. This equates to an estimated 12-13% of the residential building stock over 11m in England.

5,554 of these buildings are currently in the Government’s public remediation portfolio.

MHCLG statistics show that work is not complete on nearly two-thirds of these buildings (3,627).

Remediation is, to date, only complete in 1,927 buildings.

Cost to regulators

Depending on the final number of buildings within scope, NFCC estimates the total cost to FRSs could range from £29.86 million for 5,900 buildings to £61.77 million for 12,000 buildings. Based on the most recent figures provided, the current working estimate is £46.11 million to inspect around 9,000 buildings that may require remedial work, at a time when many FRSs are already facing real-terms budget cuts. These estimates are based on a hypothetical modelled scenario where 25% of inspecting officers with the relevant competencies are ringfenced exclusively for these buildings. It does not include management overheads and monitoring of buildings under interim measures.

This is illustrative only and is based on a hypothetical modelled scenario where 25% of inspecting officers with the relevant competencies are ringfenced exclusively for these buildings. It does not include management overheads and monitoring of buildings under interim measures.

Crucially, this would also have significant implications for FRSs’ capacity to oversee high-risk premises such as hospitals and care homes. This comes at a time of ongoing funding pressures to FRSs, along with skills shortages across the building and fire safety workforce.

Workforce competence and capacity

Regulators

It can take three to five years for FRS fire safety and fire engineering staff to acquire the relevant training and qualifications and apply those skills at a competent level, and many staff move to the private sector, or other competing employers such as local authorities, hospitals, or posts inside of the new Building Safety Regulator upon achieving competency qualifications. The implementation of the Building Safety Regulator has required experienced FRS staff to serve as fire service members of multi-disciplinary teams as part of the new regulator’s assessment processes, and the staff recruited to backfill the corresponding impact on FRS capacity are still in development. These impacts are only just beginning to be felt and mean that FRSs continue to be impacted by the chronic shortage of competent staff across the sector at a national level, despite the implementation of mitigation measures such as market rate supplements, pension abatement, and consideration of fast-track training.

As the extent of the issues has become known, it is clear that the range of technical knowledge, especially with external wall systems, is beyond the standard learning, experience, and competence routes of FRS regulators. Some regulatory staff have not yet had sufficient opportunity to gain relevant expertise and exposure to remediation work or the level of enforcement required to regulate remediation works. Skilled fire engineers are frequently needed for at least part of the process of identifying defects and carrying out remediation work on a building. This further increases pressure on available resources, as they are significantly less common than inspecting officers.

FRS staff who focus entirely on protection and building safety form around 2.7% of the total national workforce across English FRSs, though a proportion of these staff are ringfenced to support the Building Safety Regulator with activity in high-rise buildings. An NFCC data collection from FRSs in October 2024 shows that there are 803 competent fire safety staff in protection departments across England, of which 675 are inspecting officers holding the relevant minimum competency requirements to undertake audits in 11-18m buildings, while also auditing and providing business-as-usual activities in all other regulated premises under the Fire Safety Order.

There were, in the same reporting period, also fewer than 30 competent fire safety engineers in English FRSs who can work on fire safety in complex regulated premises, with many moving to the private sector over recent years, making the retention of competent staff an ongoing challenge.

Industry

NFCC was pleased to be the first organisation to fulfil the recommendations of the Independent Review of Building Regulations and Fire Safety by updating the competency framework for FRSs. But whilst the FRS competency framework now enjoys oversight from HMICFRS, for many parts of the industry, the developed standards rely on voluntary action, with the Industry Competence Committee’s remit appearing to be limited. A report from the earlier formed Industry Competence Steering Group (ICSG) (A Higher Bar) notes that the road to industry competence involves a “challenge of ensuring the work is both recognisable and accessible” and “avoid[ing] gaps”, with the task being “far from complete.” Until this happens, as noted within the ICSG’s reports, there remains a risk that the best in the industry become better, while still being ‘undercut’ by parts of the industry that are able to avoid requirements to be properly competent.

Since the ICSG’s first report in 2020, there has been no movement on a centralised cross-departmental government strategy to identify, monitor, and address key skills shortages in the workforce in terms of demand and supply.

The Chartered Institute of Building conducts research on issues facing the construction industry and has highlighted significant gaps in the skills pipeline, with a predicted shortfall of more than 250,000 workers needed to deliver construction output by 2028. The UK Skills Trade Index 2023 estimates that 35% of the construction and trades workforce is aged over 50, and when driven by high demand for apprenticeships and increased migration finds that the skills shortage has created an acceleration in wages above the average for the economy.

Government and parliamentary research are increasingly highlighting a skills and workforce gap in construction and engineering. In January, results were published following reviews of two Industry Training Boards, which included findings that construction employment is now at its lowest proportion of total UK employment in nearly 100 years, and during the same period, construction labour cost inflation has surpassed background national wage growth by 40% whilst industry productivity has declined. The report recommended the creation of a construction workforce planning and development system. Recent opinions from sector bodies have outlined concerns that there is a long-term issue within construction employment that will take more than a decade to solve, with 300,000 fewer workers in construction in the UK now than in 2019. Occupations in critical demand as measured by Skills England and reported within Department for Education statistics include quantity surveyors, electrical engineers, as well as senior officers in fire services.

Concurrently, the Chair of the House of Lords Science and Technology Committee published a letter to the Home Secretary, Chancellor and Minister for Science, highlighting longstanding concerns about the UK’s ability to attract STEM talent and calling for changes to visa policies.

The Government has since announced investments to ensure more training is available to help ensure the UK has a sufficient bank of skilled construction workers. Whilst these announcements are positive, the UK’s construction workforce is necessary for the delivery of many current government priorities unrelated to the remediation of residential buildings, including the ambitious target to build 1.5 million new homes by the end of the Parliamentary term, as well as the creation of 14,000 new prison places, plans for HS2, and expansion projects of major airports.

The Science Education Tracker 2023, published jointly by the Royal Society and Engineering UK has also raised concerns about the future workforce in STEM (Science, Technology, Engineering, and Mathematics) fields.