PAS 9980, Combustible Materials and the Truth About Risk
On one side sits a strongly held belief that any combustible material on an external wall is unacceptable, and that PAS 9980 is inherently dangerous because it allows such materials to remain in place. On the other sits a more pragmatic view that existing buildings are imperfect, resources are finite, and fire safety must be addressed through proportionate, risk based decision making, not blanket prescription.
Both positions are understandable. Neither is entirely comfortable.
The Reality PAS 9980 was Written for
PAS 9980 was never intended to be a design standard for new buildings. It exists because the UK has a vast stock of legacy residential buildings, many constructed at a time when today’s expectations, materials, and knowledge simply did not exist.
In that context, the question is not: “Would we design this today?”
It is: “Given what we have, what is the actual level of risk, and what intervention is proportionate?”
That distinction matters. Without it, we risk applying modern, prescriptive thinking to an existing built environment that cannot realistically be rebuilt wholesale.
The Criticism: “PAS 9980 is Opinion-Based”
The criticism most often levelled at PAS 9980 is that it is opinion based. And this criticism is not without merit.
Fire risk assessment by its very nature involves professional judgement. Two competent professionals can review the same building and place different weights on height, façade geometry, cavity configuration, management arrangements, or fire protection measures.
This creates discomfort, particularly when the stakes are high and the consequences of decisions are financial, political, and personal.
But it is also worth stating plainly, there is no such thing as a purely objective fire risk assessment. Even prescriptive standards require interpretation. The danger does not lie in professional judgement itself it lies in poor judgement, weak evidence, or conflicted incentives.
Combustible Materials in a Binary Argument Within a Non Binary World
The argument that all combustible materials must be removed is emotionally compelling, especially in a post Grenfell landscape. However, it assumes a simplicity that does not exist in real buildings.
Risk is not determined by combustibility alone. It is shaped by:
- how materials are configured
- continuity and compartmentation
- cavity barriers including presence, location, and quality
- façade openings and interfaces
- building height and means of escape
- detection, alarm and suppression
- management and maintenance regimes
A combustible product embedded deep within a well protected system does not necessarily present the same risk as a poorly detailed non combustible façade. Fire safety is contextual not absolute.
Can the UK Afford Total Prescription?
This is the uncomfortable question that rarely gets asked openly.
As a nation, can we afford to strip every combustible element from every residential block of flats? Not just financially, but practically and socially?
Even with targeted remediation, the current national programme will take many years. Expanding this to a fully prescriptive, zero combustibles approach across all heights would:
- overwhelm industry capacity
- displace thousands of residents
- introduce new risks through rushed or poorly controlled works
- place extraordinary pressure on contractors, many of whom may not survive the financial exposure
And when contractors fail, the problem does not disappear. The cost simply moves elsewhere to leaseholders, property owners, or ultimately the taxpayer.
Government Safety Nets and their Limits
Government intervention through schemes such as the Cladding Safety Scheme has been essential in protecting leaseholders where no viable route to recovery exists.
However, no safety net is infinite, and long term affordability cannot be assumed. As remediation programmes extend over many years, the cumulative financial burden grows, placing increasing strain on public funding.
Political priorities also play a decisive role. Fire safety funding competes with healthcare, education, defence, and infrastructure, and future allocations will always be shaped by wider economic and social pressures.
Changes in government or shifts in policy direction add further uncertainty. A national fire safety strategy that relies on the state underwriting historic construction decisions indefinitely is inherently fragile and cannot be considered a stable long term solution.
The Ethical Line: Independence and Impartiality
Perhaps the most dangerous aspect of the current environment is not PAS 9980 itself, but how it is sometimes used.
There is a growing perception that some reports are written to suit a particular outcome whether that is to protect a contractor, unlock funding, or minimise scope. When professional judgement becomes aligned with the interests of the paymaster rather than the evidence, trust in the system erodes.
This is perilous from both directions. Reports written to defend the indefensible are as damaging as those written with an unyielding presumption of failure.
Fire engineers and assessors must never fear impartiality. If they do, the system has already failed.
No Easy Answers but a Necessary Conversation
PAS 9980 is neither a silver bullet nor a reckless gamble. It is a tool, one that demands competence, evidence, transparency, and ethical independence.
The uncomfortable truth is there are no perfect solutions. Opinion based assessments can be challenged. Prescriptive approaches can be unaffordable or unachievable. Risk must be managed, not wished away.
The real question for the industry is not whether PAS 9980 is dangerous but whether we are using it honestly, competently, and proportionately.
If we are not prepared to confront that question openly, then no standard, however well intentioned, will protect us from repeating the mistakes of the past.