Britain’s Fire Protection Association has put the Mass Timber Insurance Playbook before the UK construction sector as the Health and Safety Executive consults on capping structural timber at 11 metres in English buildings. That is according to a new analysis in the FPA’s Fire & Risk Management Journal, which compiled industry response to HSE’s open consultation on Approved Document B (ADB).
Wood Central understands the playbook, produced by the Alliance for Sustainable Building Products (ASBP) and part-funded by Built by Nature, targets insurers and construction teams seeking common ground on mass timber risk.
The proposed ADB revision would force load-bearing elements in buildings above 11 metres to meet a minimum A2-s3, d2 combustibility classification — a bar most cross-laminated timber and glulam products cannot clear. Below that height, the guidance states load-bearing timber that fails the A2 standard “should not be exposed,” with carve-outs only for buildings with occupied storeys up to 4.5 metres and single-storey industrial buildings.
The Building Safety Regulator has confirmed ADB does not apply to tall, large, or complex buildings with combustible structural elements, and the HSE consultation seeks to set the height above which timber-framed buildings cannot use ADB alone for compliance. Above the threshold, an alternative compliance pathway will be expected.
Whitby Wood director Kelly Harrison warned the proposal would be “extremely detrimental for the decarbonisation of the construction industry,” telling the Architects’ Journal that approval routes outside ADB would carry cost, time, and design programme risk most clients would not accept.
Haworth Tompkins director Lucy Picardo, whose practice’s Backstage at the Old Vic and Theatr Clwyd refurbishment both cleared the 11-metre threshold, backed the government’s fire safety review whilst warning the changes would deal a “significant blow” to decarbonisation efforts. The UK risked falling further behind Europe on low-carbon construction unless the guidance is rewritten before adoption, she told the AJ.
Built by Nature European networks lead Joe Giddings, whose 28 March LinkedIn post first publicised the consultation, called the proposal a “massive setback for climate mitigation.” He told the AJ that mass timber remains one of the most effective tools for cutting embodied carbon in new buildings, and that fire safety is achievable at all heights with the right design strategy.
The pushback follows Wood Central’s report earlier this month, in which Waugh Thistleton founder Andrew Waugh, designer of the Black and White Building in Shoreditch, branded the revision “frankly, deeply frustrating and flawed.” Waugh said his practice was already coordinating an industry-wide submission with alternative proposals fit for a low-carbon future.
The HSE consultation closes on 1 July 2026, with the playbook now circulating through fire-industry channels alongside the architectural submissions already in train. The playbook is built around shared language between construction teams and insurers when assessing mass timber risk, the FPA said.
If adopted in current form, the revised ADB would force the Black and White Building, the Backstage extension at the Old Vic, and the Theatr Clwyd refurbishment — each above the 11-metre threshold — onto an alternative compliance pathway, leaving the industry roughly nine weeks to file submissions before the 1 July deadline closes.
