Building standards - (fire safety) external wall systems: consultation analysis

1. Introduction

1.1 Introduction

1.1.1 Following the fire at Grenfell Tower in June 2017, a Ministerial Working Group (MWG) was established to oversee a review of building and regulatory frameworks (and other matters) to help ensure that people are safe in Scotland's buildings. In 2018 the Building Standards (Fire Safety) Review Panel recommended strengthening the guidance in the Technical Handbooks. These changes were introduced in October 2019 and included:

• Lowering the height at which combustible cladding can be used from 18 metres to 11 metres to align with fire-fighting from the ground; and
• Tighter controls over the combustibility of cladding systems on hospitals, residential care buildings, entertainment and assembly buildings regardless of building height.

1.1.2 The Scottish building regulations set national, mandatory standards and these standards are supported by guidance in the Technical Handbooks on how the standards may be met. In September 2020 a panel of fire experts was convened to consider a ban on the highest risk cladding materials through building regulations and to review the role of the large-scale fire test (BS 8414) in supporting guidance.

1.1.3 Concerns have been raised about the use of BS 8414 in the Technical Handbooks, particularly the lack of control over the competence of designers, installers and verifiers when using and interpreting the results of BS 8414. The MWG adopted a cautionary approach in March 2021 on the highest risk cladding material and the use of large scale fire test results in new development. This resulted in interim changes to the Technical Handbooks in April 2021 including the need to avoid using category 3 metal composite material (MCM) cladding in new building work and the removal of reference to BS 8414^[1] as alternative guidance.

1.2 The Consultation

1.2.1 A consultation ran between 16^th July 2021 and 11^th October 2021 to obtain the views and opinions of stakeholders on a review of building standards relating to the fire safety of cladding to help ensure the safety of people in and around Scotland's buildings. The consultation covered five main areas:

• Part 1: Mandatory Standard 2.7 relating to fire spread on external walls.
• Part 2: Definition and ban of category 3 MCM.
• Part 3: Large scale fire test, BS 8414.
• Part 4: Consequential matters – combustible exemptions.
• Part 5: Impact assessments.

1.2.2 The proposed changes outlined in the consultation aim to improve fire safety for the design and construction of all buildings, in relation to external wall cladding systems, making them safer for those in and around buildings in the event of an outbreak of fire.

1.3 Methodology

1.3.1 The approach to the analysis is shown in Figure 1. The first stage of the review was to validate the responses to determine that they are relevant to the analysis and whether there were any duplicate responses or campaign responses. There were some responses to some questions where the comments were very similar to the comments of another organisation, but as there were slight differences, they are not being treated as campaign responses.

Figure 1: Methodology

Validation

• Validate Responses
• Typology

Review

• Review
• Coding

Analysis & Reprorting

• Analysis
• Reprorting

1.3.2 The validation stage also developed a typology to reflect the respondent and their relationship to the building regulations. This is set out in paragraph 1.4.1 below.

1.3.3 Stage 2 was focused on establishing an appropriate framework for the analysis. The consultation combined quantitative and qualitative methods of data collection and while the quantitative responses provided a good overview of opinion, it was the qualitative comments that provided a far greater depth of response.

1.3.4 A coding framework was established of the main themes arising from the open-ended questions. The framework was kept under continuous review to ensure it was fit-for-purpose and that the responses mapped effectively on to it.

1.3.5 Stage 3 was the analysis of all questions and reporting of results which took account of client feedback at all stages of the reporting process. All "closed" questions are analysed by category of respondent.

1.3.6 All responses to the "open" questions have been given an equal weighting, allowing every idea presented to be considered equally. Where possible we have used a number of simple bands to provide an indication of the frequency of an idea, although it is noted that this treats the response from an individual with the same weight as the response from a professional body which may have many members. Nevertheless, the following bands have been used to indicate the frequency with which a point was raised:

• Few: up to 3 responses.
• Several: 4 to 9 responses.
• Many: 10 and over responses.

1.4 Overview of Responses

1.4.1 At the close of the consultation period there were 76 responses which were categorised into the following groups:

• Construction Industry: organisations involved in the construction of homes and buildings.
• Consultancy: organisations who offer consultancy services and advice.
• Individuals: individual members of the public.
• Local Authorities: local authorities who undertake the verification role in Scotland.
• Manufacturers: manufacturers of products used in the construction of buildings.
• Research Establishments/Fire Test Houses: organisations undertaking research and fire testing of products and systems.
• Trade Associations: organisations representing contractors and companies involved in the manufacture, supply and installation of products used in the construction of buildings.
• Other: organisations which did not fit readily into the categories above, including professional bodies.

1.4.2 A summary of the number of responses by category is shown in the Table 1 below with a list of respondents by category included in Appendix A.

Table 1: Summary of Responses by Category

	No.	%
Construction Industry	6	7.9
Consultancy	7	9.3
Individuals	22	28.9
Local Authorities	8	10.5
Manufacturers	7	9.3
Other	9	11.8
Research Est./Fire Test Houses	2	2.6
Trade Associations	15	19.7
Total	76	100.0

1.5 Report Structure

1.5.1 The remainder of the report is organised as follows:

• Section 2 presents the analysis for Part 1 of the consultation relating to Mandatory Standard 2.7.
• Section 3 sets out the analysis for Part 2 of the consultation covering the definition and ban of category 3 MCM.
• Section 4 analyses the results relating to Part 3 of the consultation on BS 8414 (large scale fire tests).
• Section 5 considers the results for Part 4 of the consultation on consequential matters.
• Section 6 sets out the analysis of the impact assessment (not included in this draft).