Multi‑storey residential buildings - fire risk posed by external wall systems: consultation analysis

1. Introduction

Introduction

1.1 This report presents the independent analysis of consultation responses to the Draft Scottish Advice Note (SAN): Determining the fire risk posed by external wall systems in existing multi-storey residential buildings.

1.2 Links to the Draft SAN (Version 3.0) and the consultation document are provided in Annex A.

Background

1.3 On 20^th January 2020, the UK Government's Independent Expert Panel published consolidated advice for building owners of multi-storey, multi-occupied residential buildings in England. This brought the Expert Panel's advice together in a single document and superseded the previous Advice Notes 1 to 22 that were published sequentially following the Grenfell Tower fire in June 2017. The key change in the consolidated advice note is the application of the guidance to residential buildings regardless of height. Previously, Advice Note number 14 guidance applied to buildings over 18 metres.

1.4 On 30^th March 2020, Scottish Ministers agreed to set up a Technical Working Group to develop a SAN to determine the fire risk posed by external wall systems in existing multi-storey residential buildings in Scotland. This was with a view to bringing clarity to the different legislative requirements and guidance in Scotland and take account of the key findings from large scale and intermediate scale fire testing of external wall cladding systems carried out by the UK Government.

Draft SAN

1.5 The Technical Working Group have met three times and the third version of the Draft SAN was used as the basis of a three-month targeted consultation.

1.6 The Draft SAN provides advice for those responsible for fire safety in residential buildings including building owners/managers, and residents groups where they exist, who are responsible for determining the fire risk posed by external wall systems on existing multi-storey residential buildings. The advice will also be of interest to fire risk assessors and specialist wall appraisal experts.

1.7 For the purposes of the Draft SAN, external wall systems include: cladding systems (i.e. outer cladding panel, support rails, cavity barriers and any insulation material exposed in the cavity behind the cladding), spandrel panels, window infill panels, balconies, solar shading and any other architectural feature or attachment to the building structure.

1.8 Although not a legal requirement in Scotland, a fire safety risk assessment for blocks of flats is recommended as best practice. Non-domestic residential premises are classed as "relevant premises" under Part 3 of the Fire (Scotland) Act 2005, as amended. A fire safety risk assessment is a legal requirement for all "relevant premises" and must "identify any risks to the safety of relevant persons in respect of harm caused by fire."

1.9 The aim of the fire safety risk assessment and any supporting external wall system appraisal is to ensure that building occupants are not placed at undue risk of harm as a result of fire spread via the external wall system.

1.10 The scope of the Draft SAN applies to existing multi-storey residential buildings, including:

• Blocks of domestic flats, including sheltered housing, extra care housing and supported flats;
• Student accommodation, including boarding schools and halls of residence;
• Hospitals or other premises with overnight patient accommodation;
• Care homes;
• Hotels and boarding houses;
• Hostels; and
• Prisons.

1.11 The Draft SAN's scope is limited to the safety of building occupants only. More stringent measures may be necessary for property protection or business continuity reasons, but are out with the scope of the SAN.

1.12 The findings of the consultation will be used by the Technical Working Group to revise and finalise the SAN prior to its publication.

Report Structure

1.13 Section 2 presents details of the consultation methodology and limitations.

1.14 Section 3 to Section 11 presents the analysis of the responses to each consultation question.

1.15 The following Annexes are attached:

• Annex A: References;
• Annex B: Webinar - Organisation Distribution List;
• Annex C: List of Webinar Questions; and
• Annex D: Consultation Responses to be Published.