PAS 9980 was introduced by the British Standards Institution as a code of practice for carrying out Fire Risk Appraisals of External Walls. It followed the withdrawal of earlier government advice notes and was intended to create consistency in how external wall fire risk is assessed.
It certainly created consistency. Whether it created confidence is another matter.
At the centre of the continuing debate is a single word: tolerable.
PAS 9980 does not require automatic removal of combustible materials. Instead, it allows assessors to determine whether the overall fire risk posed by an external wall system is tolerable when factors such as building height, fire strategy, mitigation measures and occupancy profile are taken into account.
For some professionals, that is proportionate and pragmatic. For others, it represents a serious compromise.
Risk-Based or Safety-Led?
Supporters argue that PAS 9980 was designed to prevent unnecessary, blanket remediation. They say a risk-based approach allows competent fire engineers to distinguish between genuine life-critical danger and lower levels of risk that can be managed.
In a system already under pressure from funding constraints, insurance challenges and workforce shortages, proportionality matters.
Critics see a different picture. They argue that retaining combustible materials in situ, even under a managed risk model, conflicts with the post-Grenfell expectation that unsafe materials would be removed. In their view, tolerating risk is not the same as resolving it.
The Mandation Question
A fresh layer of tension has emerged around whether PAS 9980 should be mandated. Recent industry commentary has questioned whether embedding the framework into law would bring clarity or simply formalise its perceived weaknesses.
Those in favour of mandation suggest that it would reduce disputes and provide a single recognised pathway for assessments. Those against argue that turning a risk-tolerance model into statute risks locking in compromise rather than strengthening life safety.
Legal and Regulatory Context
PAS 9980 sits alongside the post-Building Safety Act regime, with the Building Safety Regulator now operating as the building control authority for higher-risk buildings.
Although PAS 9980 is guidance rather than legislation, it carries practical force. Funding applications, lending decisions and remediation strategies frequently rely on Fire Risk Appraisals carried out using its methodology.
Where an assessment concludes that risk is tolerable, remediation may not proceed. That conclusion has financial, legal and emotional consequences for residents living behind those façades.
Consultation and Revision
PAS 9980 is under revision, following a consultation process that attracted strong and sometimes conflicting responses. A revised edition is expected in 2026.
Observers will be watching closely to see whether definitions of risk are tightened, thresholds clarified and alignment with life-safety expectations strengthened.
Why the Temperature Stays High
This is not simply a technical disagreement between engineers. It reflects a broader question about what safe was meant to mean after Grenfell Tower.
For some, PAS 9980 introduces realism and proportionality. For others, it introduces uncertainty and residual danger.
Stephen Day will again bring the lived experience perspective from Royal Artillery Quays. Gareth Wax will chair the discussion, with Hamish McLay contributing from the conveyancing and regulatory side.
We will also be joined by James Allen of AITCo Consulting, bringing additional professional insight into how PAS 9980 is being interpreted in practice and what its retention means on the ground.
Cladding Matters exists to hold space for serious conversations when policy, practice and lived experience do not sit comfortably together.
Join us live on Friday 13th February at 1pm.
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