Part 2A: competence is now a duty, not a slogan

The FIA has published a useful reminder of the significance of Part 2A of the Building Regulations, introduced following the Building Safety Act 2022. Its central point is simple, but important: the dutyholder and competence requirements are not confined to higher-risk buildings. They apply much more widely to building work.

For the fire sector, that matters.

Designers of fire precautions, including fire alarm systems, suppression systems and passive fire protection, may fall within the definition of a Designer. Installers will commonly be Contractors, and in some circumstances may have wider project responsibilities. These are not just labels. They carry legal duties.

The most important shift is around competence. Part 2A does not treat competence as a marketing claim, a training certificate or a line in a tender return. It creates duties around appointment, capability and refusing work that sits outside competence. That applies to organisations as well as individuals.

This distinction is often missed.

An individual may be competent for a defined task, but that does not automatically mean the organisation has the systems, supervision, quality assurance and technical governance needed to deliver the work reliably. Equally, a company may hold a certification or employ competent people, but still allocate work poorly or fail to control changes during design and installation.

Competence is therefore not a static status. It is contextual. It depends on the task, the building, the system, the complexity of the work, and the role being performed.

This is especially important in fire safety because the work is often fragmented. A fire strategy may be prepared by one party. Detection and alarm design may be developed by another. Passive fire protection may be specified, procured, substituted and installed through several layers of responsibility. Smoke control, sprinklers, fire doors, façade interfaces and evacuation arrangements may each sit with different specialists.

Part 2A does not remove that complexity. It makes it harder to ignore.

The practical question for the fire sector is no longer simply, “Can we do this work?” It is:

Can we demonstrate that we are competent for this specific role, on this specific project, with these specific risks?

That requires more than confidence. It requires evidence. Clear scopes. Defined responsibilities. Competent appointment. Records of design assumptions. Change control. Suitable supervision. Coordination with adjacent disciplines. A willingness to say no, or to seek specialist input, where the work exceeds the competence available.

This should not be seen as a threat to competent organisations. It is an opportunity to distinguish genuine capability from superficial claims. The firms that already invest in training, third-party certification, technical review and quality management should be well placed. But even they will need to ensure that competence is mapped to roles and tasks, not assumed generically.

The message from Part 2A is clear. Fire safety work is building work. Those who design it, specify it, install it or coordinate it are part of the dutyholder system.

Competence is no longer something the industry can simply assert. It must be understood, demonstrated and managed.

Pyrology Insight note: This article is provided for general professional commentary only. It is not legal advice, project-specific fire safety advice, or a substitute for reviewing the relevant legislation and official guidance for a particular project.