PAS 911 has been withdrawn: what governs a fire strategy now
PAS 911:2007, the Publicly Available Specification that set out a framework for formulating fire strategies, has been withdrawn by BSI. It is no longer a current document and should not be specified in new briefs. There is no like-for-like successor. Fire strategy documents are now governed by the Building Regulations, statutory guidance and British Standards.
If you have arrived here because PAS 911 appears in a specification you have been sent, that is the answer you needed, and it is not the one most sources will give you. The rest of this page explains what the document was, why the reference keeps circulating years after withdrawal, what actually applies now, and how to handle a live tender that still names it.
What PAS 911 was, and what withdrawal means
A Publicly Available Specification is a fast-track standardisation document published by BSI. It is developed with a sponsor and a steering group, goes through consultation, and is then reviewed and either revised, converted into a full British Standard, or withdrawn.
PAS 911:2007 was titled “Fire strategies. Guidance and framework for their formulation”, and the BSI publication index now carries it with the status “Withdrawn”. It set out what a fire strategy document should contain, how it should be structured, how it should be developed through the design process, and how it should be maintained across the life of the building. At the time it was a reasonable attempt to bring order to documents that varied wildly in scope and quality.
It has since been withdrawn. Withdrawal in BSI terms means the document is no longer maintained, no longer reviewed and no longer part of the current catalogue. It can still be bought as a historic record in some places, which is part of why the confusion persists, but it is not a live specification.
Withdrawal is not the same as a standard being superseded. When a standard is superseded there is a named replacement to move to. PAS 911 was not replaced by a successor PAS carrying the same scope. That gap is exactly why people keep reaching for the old reference.
Why people are still referencing it
Four reasons, all of them mundane.
Specifications get copied. A client standard or an employer’s requirements document written years ago gets reused on the next project, and the standards schedule is the section nobody rereads. PAS 911 travels forward inside documents that were never re-checked.
Search results have not caught up. Articles, consultancy pages and forum threads written while the specification was live are still indexed and still rank. Several read as though the document is current. Nothing corrects them.
The problem it addressed is still real. Fire strategies still vary in scope and structure between authors. People who remember a framework that tried to fix that reach for it again, without checking its status.
Nobody was told. A withdrawal is a quiet administrative act. There is no notification to everyone who ever cited the document in a contract.
None of those reasons make it current. If you are writing a brief now, naming a withdrawn specification creates a contractual obligation to a document that nobody maintains, and it will surface as a dispute at handover when somebody asks what conformity was actually assessed against.
What actually governs a fire strategy document now
There is no single replacement framework. The obligations are spread across legislation, statutory guidance, British Standards and competence requirements. This is the set that matters in England and Wales.
The documents that govern fire strategy work in England and Wales, and what each one actually does.
The practical point is that the useful parts of what PAS 911 tried to do have been absorbed elsewhere. Structure and content expectations now come from the standard you are designing to. Lifecycle and maintenance expectations come from the golden thread duties for higher-risk buildings and from Regulation 38 handover for everything else. Author competence, which the specification never addressed properly, now sits under BS 8670-1:2024, which superseded BSI Flex 8670 v3.0:2021.
If a brief or tender still specifies PAS 911
Do not simply ignore it, and do not silently price for it either. Handle it in writing, before you commit.
Raise it as a query, not a criticism. Send a short note stating that PAS 911:2007 has been withdrawn by BSI and asking the client what they want to happen. Most clients do not know, and most are grateful.
Offer a substitute wording. The usual replacement is a clause naming the design standard the strategy will follow, meaning Approved Document B, BS 9991:2024, BS 9999:2017 or a BS 7974:2019 performance-based approach, plus the competence framework the author works to, plus an explicit statement of the review and update arrangement after handover. That covers everything the old specification was reaching for.
Never write conformity you cannot evidence. A statement that a document is “PAS 911 compliant” is not assessable against a withdrawn specification. If a client insists on the phrase, record in the appointment exactly what it is taken to mean.
Get the answer in the contract, not the email chain. Standards schedules are read at handover and in disputes. That is when a withdrawn reference becomes expensive.
If you are on the receiving end, and the tender is already out, the same three questions apply that would have applied when the specification was live: which edition or standard, what conformity actually means here, and who maintains the document afterwards.
What this means for your appointment
The removal of PAS 911 does not lower the bar. In practice it has risen, because the Building Safety Act 2022 regime and the competence framework are considerably more demanding than a voluntary specification ever was.
When you appoint, ask three things. Which design standard the strategy will be written to, and why that route suits this building. What the author’s competence position is under BS 8670-1:2024. And what happens to the document after handover, meaning who updates it and on what trigger.
A fire strategy consultant should answer all three without hesitation. For the deliverable itself and what each section covers, see the fire strategy report page. Where an existing building has no documentation to update, the starting point is a retrospective fire strategy. Reports are arranged across England and Wales through a network of chartered fire engineers.
Frequently asked questions
Is PAS 911 still current?
No. PAS 911:2007 has been withdrawn by BSI and is no longer a maintained document. It can still be found for sale as a historic record in some catalogues, which is a common source of confusion, but it should not be specified in a new brief, tender or appointment.
Was PAS 911 ever a legal requirement?
No, and it never was. It was a Publicly Available Specification, not legislation and not statutory guidance. It only ever bound anyone through a contract, a client standard or an appointment. Legal obligations sit in the Building Regulations, fire safety law and, for higher-risk buildings, the Building Safety Act 2022.
What replaced PAS 911?
Nothing directly. There is no successor specification with the same scope. What it was attempting is now covered across several documents: the design standard for content, the golden thread and regulation 38 of the Building Regulations 2010 for lifecycle and handover, and BS 8670-1:2024 for author competence.
Our client’s specification names PAS 911. What do we do?
Raise it in writing before pricing. State that the specification is withdrawn, propose replacement wording naming the design standard, the competence framework and the update arrangement, and get the agreed position into the contract rather than leaving it in an email chain.
Does a fire strategy written to PAS 911 have to be redone?
Not automatically. A document is judged on whether its technical content still holds for the building as it stands today, not on which framework its structure followed. What triggers a review is a change to the building, a change of use, or a change in the guidance the design relied on.
Which standard should a fire strategy be written to instead?
It depends on the building. Residential work usually follows BS 9991:2024, non-residential work usually follows BS 9999:2017, and both sit alongside Approved Document B. Where the design leaves the prescriptive guidance, BS 7974:2019 and the PD 7974 series set out the performance-based engineering route.
Does any of this differ between England and Wales?
In places, yes. Approved Document B is published separately for England and for Wales, and the two are now a long way apart: England works to the 2019 edition incorporating the 2020, 2022 and 2025 amendments, while Wales works to 2006-edition documents last amended with effect from 20 December 2025. The higher-risk building criteria are also set separately, and they differ: England requires at least 2 residential units alongside the 18 metre or 7 storey trigger, whereas the Welsh design and construction criteria are met by one residential unit, or by a hospital with an overnight bed, a care home or a children’s home. The British Standards themselves are common. Always confirm which nation’s guidance applies before writing the design basis section.
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