ARB Safety and Sustainability Guidelines for Architects: Consultation Response from London Practice Forum

The London Practice Forum has issued a response to the ARB’s consultation on proposed guidance for education institutions on fire and life safety design and sustainability. You can read the consultation papers here.

The content of our consultation response is shown below.

Dear ARB,

I am writing on behalf of the London Practice Forum. We have collectively reviewed the ARB’s latest safety and sustainability guidelines for architects and offer our feedback below.

Broadly speaking the LPF is supportive of the new emphasis these guidelines give to safety and sustainability, two areas that are crucial to the way we design and have already become a key focus for our internal learning programs and continuous professional development.

The fact that the ARB is looking at how these topics can be integrated into the curriculum for students of architecture is also welcomed, though how and at what stage these topics are taught is yet to be detailed and will have an impact on practices if significant upskilling of architectural assistants is required prior to part three.

Generally, we would like to see further guidance from the ARB and the RIBA on how architects can align their fees to incorporate these additional skills and competencies. With growing expectations on architects to increase their scope, to include embodied carbon calculations and post occupancy evaluations for example, coupled with increasing running costs – particularly relating to PI insurance – there is no up-to-date guidance from either industry body to help architects adequately explain fees to clients. This is an issue we feel should be addressed.

Fire and Life Safety Design

The guidelines themselves seem comprehensive and reasonable, and most competent architects will already have a thorough understanding of these issues and implemented procedures to ensure competency is maintained. That said, the introduction to these guidelines state that “clients and users are entitled to expect that all architects will have the competence to prepare and execute designs that will maintain their safety and wellbeing”. This statement does not adequately reflect the complex processes involved in the design and construction of a building. An architect is just one of the parties involved in the design and operation of a building; structural engineers and fire engineers also have responsibilities for ensuring that the building design ensures life safety. The interconnectivity of these responsibilities and how they are defined and agreed is crucial to ensuring safety of life both during construction and occupation.


The London Practice Forum acknowledges that the climate crisis is one of the fundamental challenges facing our industry and society as a whole. The new competency guidelines on sustainability are a significant step towards ensuring the industry collectively embraces the topic and proactively works towards a more sustainable future. However, there are a number of areas within the new guidelines that require further clarification:

  • SA5. The sharing of building performance data is a worthy aspiration, and we can see how this will benefit both our own practices and the wider industry. However, the most useful performance data is collected post occupancy. Clients are not always willing to pay for these evaluations to take place, nor share the data that is collected with the wider team. Our ability to comply with this standard will rely heavily on our clients buy-in.
  • SC3. This requires architects to calculate predicted operational and embodied energy use and carbon emissions. These calculations require specialist expertise and technical software that many architects do not have access to in-house. Whilst some larger practices have the resources to develop tools themselves, some of which are becoming more readily available, most practices will outsource these calculations to services and structural engineers who are better equipped to carry out this work. Our suggested rewording for SC3 is “Understand the principles of predicted operational and embodied energy use and carbon emissions and provide information to those carrying out calculations as required.”
  • SC4. This states architects should “be able to carry out Post Occupancy Evaluations / Building Performance Evaluations to understand performance gaps and inform future projects.” As previously noted above, we acknowledge the benefit of post occupancy evaluations in learning lessons from our completed projects to improve our future work. However, we would like some clarity on the following:
    • What does the ARB expect the scope of these evaluations to be? Building performance data usually relates to mechanical and electrical installations, the POE therefore sitting more comfortably within the MEP engineer or sustainability consultants’ scope.
    • Will the ARB or RIBA be providing guidance on how architects calculate fees for POE? Currently, our fees rarely stretch beyond RIBA Stage 6, and for us to include POE services, a fee structure would need to be in place that extends to RIBA Stage 7, something our clients are rarely engaging with. An obligation to undertake post-occupancy evaluation will place an unreasonable burden on practices if there is no accompanying fee to pay for it.