In June 2017 – on the day after the Grenfell Tower fire – a Scottish government ministerial working group (MWG) on building and fire safety was set up to review regulatory frameworks and other relevant issues. The initial focus of the group was on high rise domestic buildings but it has also considered other buildings including housing, the NHS estate, schools and prisons.
- a Building Standards review of compliance and enforcement
- a Building Standards review of fire safety
- a review of the fire safety regime and regulatory framework for high-rise domestic buildings
- an inventory of high-rise domestic buildings in Scotland
- a fire safety campaign for high-rise domestic properties
- gathering information on the presence of aluminium composite materials on high-rise domestic buildings and those with sleeping accommodation
- collecting information on the presence of external-wall insulation systems.
A review panel on fire safety building standards in Scotland established by the MWG brought together an experienced group of fire safety engineers and specialists, along with representatives of the major construction bodies in Scotland and the various regulators. It was supported by a small international group of fire safety regulators, who ensured that there was an appropriate degree of reflection and benchmarking after each meeting.
Following the publication of the review panel's report in 2018, ministers have taken steps to implement the recommendations for increasing safety in high-rise buildings, in particular residential premises.
These recommendations included: introducing a better mechanism for verifying fire safety engineering on complex buildings; changes to guidance on external cladding, cavities, fire spread on external walls, and escape routes; and extending the requirement for automatic fire suppression systems to additional building groups. This article details the different measures being taken.
External wall guidance
A draft Scottish advice note, Determining the fire risk posed by external wall systems in existing multi-storey residential buildings, was subject to a 3-month targeted consultation that ended on 25 October last year, and the responses are currently under review.
The note has been drafted to help building owners and managers and risk assessors determine fire risk, and also explains how more detailed wall appraisals by specialists such as chartered fire engineers or surveyors can support risk assessments, where required.
The document therefore uses the same benchmark methodology as such risk assessments, with criteria including fire compartmentation and separation, internal and external fire spread, means of escape, fire detection and warning systems, and ensuring access for fire service vehicles.
Ultimately, the decision on whether any element – including cladding – poses an unacceptable risk to life is down to the professional judgement of the risk assessor. The guidance can only offer benchmarks and information to help that decision, as each assessment is building-specific.
In light of the Grenfell Tower tragedy and evidence from subsequent UK government fire tests the guidance recommends the removal of Category 3 metal composite materials (MCMs) – including aluminium composites – from all residential buildings, regardless of height.
The categories of MCM panels adopted as part of the BRE screening tests sponsored by MHCLG post Grenfell have been indicated as Category 1 (limited combustibility Calorific Value ≤ 3 MJ/Kg), Category 2 (fire resistant – FR >3 and ≤ 35 MJ/Kg) and Category 3 (non-FR > 35 MJ/Kg.)
Partially clad buildings with category 3 MCMs should be risk-assessed, and the document offers more detailed guidance on this process.
Alarm systems
Following consultation, the Scottish government announced in March 2018 that the requirement for smoke, heat and carbon monoxide alarms, which previously applied to private rented property and new buildings alone, would be extended to all homes. This was agreed by Holyrood in January 2019.
Under this new requirement, every home in Scotland must have a smoke alarm fitted in the living room or lounge, and in circulation spaces such as hallways and landings.
Every kitchen will also be required to have a heat alarm, which must be interlinked with the smoke alarms so they can be heard throughout the property. Furthermore, there must also be a carbon monoxide alarm where there are fixed combustion appliances.
However, the Scottish government has listened to public concerns about the impact of the COVID-19 pandemic and asked Holyrood to delay implementation of these changes from February 2021 to February 2022, to give people more time to carry out this important safety work.
Automatic fire suppression
In January 2018, shortly after the inception of the fire safety building standards expert review panel, MSP David Stewart proposed a bill to require Scottish social housing to be fitted with fire suppression systems. Initially intended to apply to all new-build and existing high-rise social housing, the proposals were amended in May that year to cover only the former. The bill received cross-party support from 60 MSPs, and the Scottish government agreed to take over the legislation to give the proposals full effect.
The regulatory change will require automatic fire suppression systems to be installed in all new flats and maisonettes, social housing and multi-occupancy dwellings with more than 6 residents from 1 March 2021 applying to buildings of any height in those categories.
High-rise inventory report
In March 2020, the Scottish government published the High rise inventory: summary report. This provides information on the construction and fire safety of high-rise domestic buildings with any storey at a height of more than 18m above the ground. It includes data for larger tenement-style buildings as well as those that might be more commonly understood as traditional high-rise flats.
The inventory has been developed as a central source of information, providing an overview of the key aspects of high-rise domestic buildings in Scotland, including their fire safety features.
The data has been gathered by the Scottish government's Scottish Exchange of Data, and continues a project commissioned from professional services company Capita in 2018. Local authority building standards departments completed the inventory for all relevant buildings, with data provided or verified to the best of the respondents' knowledge at the time of completing the inventory, and it should therefore be treated as a snapshot in time.
This marks the first inventory of 774 high-rise domestic buildings in Scotland, and the intention is to update the report on an annual basis. The data gathered may be developed over time to ensure that it provides an accurate picture of fire safety in high-rise buildings and can be used to direct future policy, legislation and guidance.
Future standards board
The Scottish government set up the Building Standards Futures Board early in 2019 to provide guidance and direction on the development and implementation of the review recommendations.
- Workforce strategy: Facing an ageing workforce as well as lack of re-investment in staff and innovation, this strategy will focus on identifying what is required to support a verification service for the future.
- Compliance plan: Large, complex projects often change during the construction process. Recent failures have highlighted the need to ensure that designs receiving a building warrant are constructed in accordance with that design, especially the safety-critical features. The use of compliance plans is being explored for complex and high-value public buildings.
- Certification strategy: Re-appointment of current certification bodies is ongoing and due to be completed by March this year. A strategy for the future development of certification is being prepared alongside this to identify priorities and a range of short-, medium- and long-term measures.
- Digital transformation: A national online portal for building standards, Getting started on eBuilding standards Scotland, was introduced in 2016, enabling electronic submission of applications for building warrants and other forms such as completion certificates. The digital transformation project will explore how technology can support and enhance building standards.
- Technical strategy: Technical guidance is used to ensure that projects fulfil building regulations, and to support compliance with the mandatory functional standards. A review on the way the technical handbooks are developed and communicated is being undertaken, and the technical strategy will direct the Scottish government's provision of updates and guidance in future. The technical strategy may encompass more digital options as well, to improve compliance
- Verification standards: A review of the operating and performance frameworks to help verifiers assess the service they provide against regulatory requirements is being carried out. Standards will focus on the quality with which verification work is undertaken and link the skills and experience of verifiers and applicants.
- Delivery models: The current model has Scotland's 32 local authorities appointed as verifiers for their respective geographical areas. The need for a potentially improved and reshaped model has been identified, including a review of the need for central hubs of expertise.
The board is considering taking further measures in implementing the recommendations. Officials will also assess what legislative changes are required, with any reforms subject to public consultation.
Further review
Local government, housing and planning minister Kevin Stewart has instructed officials to convene a fire safety review panel to examine how to ban the highest-risk cladding from buildings.
It will also consider: whether changes are required in the technical handbooks to mandatory standard 2.7, concerning fire spread on external walls; the role of the large-scale facade fire test BS 8414; and the question of competency in designing, installing and verifying cladding systems.
This review, which is envisaged to last 12 months, will be advised by appropriate experts using the most up-to-date evidence to recommend further changes to building standards, if required.
- other cladding types, notably high-pressure laminate cladding
- the recommendations of phase 1 of the Grenfell Tower fire inquiry
- progress made by the Building Standards Futures Board, which is implementing recommendations from the building standards reviews.
The safety of people in the built environment continues to be a priority for the Scottish government, and although we are confident in our building standards we are not complacent. This is why we undertook reviews, sought expert advice, and have implemented the recommendations made. We will also consider any evidence emerging from or recommendations made by the ongoing Grenfell Tower fire inquiry.