Building and Fire Safety Expert Working Group minutes: May 2024

Attendees and apologies

Chair

• Peter Wilkinson, Pyrology Ltd - online

Members

• Craig Donnelly, Local Authority Building Standards Scotland (LABSS)
• Lila Angelaka, Historic Environment Scotland (HES) - online
• Simon Montgomery, HES - online.
• Angus Law, Edinburgh University
• Stewart Kidd, British Automatic Fire Sprinkler Association (BAFSA) - online
• Fionnuala McKinney, Building Regulations, Northern Ireland Government - online
• Charles-Elie Romeyer, Building Safety Regulator, HSE - online
• Gavin Hammond, Scottish Fire and Rescue Service (SFRS) – online
• Chris Getty, Scottish Fire and Rescue Service (SFRS) – online
• Peter Drummond, Royal Incorporation of Architects in Scotland (RIAS)
• Jim McGonigal, Scotland Branch of the Institution of Fire Engineers (SIFE)
• Colin Todd, CS Todd and Associates
• Edith McDowall – Optimal Economics
• Sharon McLure, Association for Specialist Fire Protection (ASFP) - online
• Samantha MacCuish, Federation of Master Builders - online

Scottish Government Officials

• Stephen Garvin, Deputy Director, Building Standards Division
• Lisel Porch, Safer Communities Division - online
• Chris Booth, Safer Communities Division - online
• Scott Young, Building Standards Division
• Steven Scott, Building Standards Division
• Colin Hird, Building Standards Division

Apologies

• Benny Rooney, Building Standards Division
• Andrew Nicholson, The Fire Surgery
• Neil McDougall, NLM Consultancy
• Alastair Perry BAFSA
• James Clark, Safer Communities Division
• Paul Keepins, Building regulations, Welsh Government
• Sean Cairns, Thistle Trade Group
• Damien Fairley, Northern Ireland Government
• Andrew Watters, Safer Communities Division

Items and actions

Welcome

The chair welcomed everyone to the third meeting of the Building and Fire Safety Expert Working Group (EWG) and covered the agenda for the meeting.

Meeting business

Apologies were noted.

Minutes of the last meeting were discussed.

Title of HES document referred to in paragraphs 20 and 21 (fire safety in traditional buildings) to be amended to include ‘short guide’, but noted this title may still change in future.  

AP4 – Supporting analysis of hotel stock – thanks to members who contributed. Consensus view added to final report.

AP5 – BAFSA reaching out to EU contacts – links to various journals and reports shared. Can be circulated to WG members. Does demonstrate paucity of published sources on hotels as a topic.

AP6 – SG to consider type of lift identification. Will cover under misc. items this afternoon. Links into PIP which shows two stairs. SFRS to consider and advise on PIP. It was noted by SG Officials that the amended/updated information signage template referred to within AP6 is required for going to consultation.

The minutes of the last meeting were then agreed.

SG officials noted that pre-election period restrictions should not affect the work of the group.

The Grenfell Phase 2 Report is due to be published on 4 September. Recommendations are not expected to impinge on Cameron House work but there will be a broader response to the recommendations made following analysis.

Action Point 1: AP1 The minutes of Meeting 2 to be amended by SG officials as noted above and published.

Action Point 2: AP2 SFRS and FRU to work on producing an updated signage template to show lift identification and two stairs, for inclusion in consultation.       

Recommendation 4 of the Cameron House Hotel FAI

Update on cost benefit analysis
(Paper 3)      

SFRS data has been analysed, with buildings assigned to traditional or non-traditional construction. The likelihood of hotel fires in traditional buildings is less probable than for non-traditional but the likelihood of fatality is greater in traditional hotel buildings. Problems experienced with getting cost information from industry with only one return to date where the company has offered indicative figures for BS EN 12845 and BS 9251 installations, with the former being more expensive. Suggested that listed buildings incur a premium. Question and discussion on average size of rooms, generally accepted as circa. 20 m² for typical rooms and 25 m² for luxury. Applied costs to 10 & 40 room scenarios – differential in costs. Initial results, comparison – positive cost benefit for BS 9251 solutions, BS EN 12845 costs not always positive for larger hotels.

Question – if refurbishing and budgeting, £35-55 per m² is relatively minor part of a spend of around £2,000 per m². Perhaps better to look at average increase of development costs by introducing AFSS. Cautious about introducing costs in isolation.

Comments made that cost could be modified downwards if AFSS is installed along with wider works such as rewiring or plumbing, with costs of water supply a factor of size and number of pumps required. Mains supply still an option. Response from Optimal is that Scottish Water cannot guarantee the pressure supply and therefore designers/installers tend to not go down the route of mains water supply for systems. However, research will provide analysis for systems with and without pumps.

Suggestion to engage a Quantity Surveyor experienced in such work to identify further cost to benchmark against for the research.

A group member offered to engage with sprinkler contractors for possible gains on costs with a request made for a template from Optimal to assist in doing this.

Comment regarding the Highlands and Islands areas and the higher costs associated with converting buildings in these areas. Data required on this prior to consultation.

Query made regarding the inclusion of property damage in the cost/ benefit analysis. Optimal highlighted this is one of the biggest benefits, when including fatalities and injuries. SG officials also advised this is common use in research, since 2005. Although area of damage has been considered it is suggested there are few with large area of damage but will be looked at again within the research. Question regarding using data for England. Response was given that it would not be likely to be able to distinguish the traditional buildings from this data. Published data from SFRS had to be augmented on case by case basis. 11 years of data has 6 fires with sprinklers. Fire Service reports do not go into the detail of residents evacuated as a possible indicator for lives saved. Also some sensitivity analysis around the damage costs can be carried out once we have more costings from suppliers.

Part of the research brief was to identify whether traditional buildings are disproportionately affected by fires. On deaths and injuries, reporting is on incidents in last 11 years. Multiple fatality or injury is quite rare in Scotland.

Some variation in SFRS reporting due to different officers involved but need to avoid assuming AFSS are 100% effective. Can also contact operators who have developed and installed AFSS on the cost point question. Noted it may be difficult to get commercial operators to share this information.

Question raised around how to disentangle actual add-on cost of checking AFSS systems beyond annual checks.

Query raised on how many lives have been saved in hotels by AFSS. Data available only covered 6 fires in buildings where AFSS were installed over the last 11 years. BAFSA data is published but not many fires in sprinklered hotels. Again 6 deaths & 30 injuries in hotels over 11 years.

Action Point 3: AP3 Group members to explore QS option and further sprinkler contractors through different network, supported by required template from Optimal.

Action Point 4: AP4 SG Officials to undertake Highland and Islands impact assessment for data related to paragraph 14.

Recommendation 5 of the Cameron House Hotel FAI

Hidden cavities and voids, workmanship age and variations from current standards. (Paper 4)

Reference to HES guidance and the current guidance for buildings with sleeping risks. WG asked if there is anything to action to strengthen current SG documents? Comments made that Guide for Practitioners 7 is excellent and well used and requires little updating. The managing change documents are higher level and do draw back to GP7 as the technical document. FRU will look to word this as such whilst committed to review all of current fire safety guidance documents. The ‘Managing Change’ guide is for planning, GFP 7 is a detailed technical guide – people need to be aware of this. Intent to promote use of revised GFP 6 once available.

WG was asked for comment on the current functional standard and specifically posed the question in paragraph 14 on paper 4. Consensus was that the current standard 2.4 is fit for purpose. Noting, practical application of the standard to older buildings is more challenging, especially in relation to conversions and application of ‘reasonably practicable’ and reinforcing the intent that developers need to investigate voids and bring up to standard where practicable.

Paragraphs 15 and 16 of paper 4 - Question asked around existing buildings and the application of reasonably practicable (RP) to cases. Suggested that more clarity is required to the process of applying RP to define the expected process and outcome where RP applies. Provide context and set out the tests of reasonableness that apply in a given case for a given standard. General agreement that better clarity on expectation is needed with a structured approach needed. SG officials agreed to provide more guidance on this process, including on level of competency required. SFRS noted provisions are already set out under duties within the FS Act.

Reference to paragraph 20 of paper 4 and cavity barriers - Are members content to go to consultation and align with approach in England (ADB) and have cavity barriers above fire resisting ceilings. Comment made that the 30 m distance cited is based on historic research. Question raised if, for consistency, reference 20 m and 10 m distances. Officials will review. Agreed to take to consultation.

Paragraph 23 of paper 4 - Are we content with 2.0.7? Officials to comment and take off-line with HES and rewrite – invited further comments from others on this.

Paragraph 26 of paper 4 - Too many elements could be picked up on/need addressed here, why just lath and plaster? A comment was made to supplement regulation 8 around degradation of internal linings due to age or lack of maintenance.

HES seeking to appoint lead authors for redrafting of GP6 and GP7. GP6 review is carrying out between BSD, HES and RIAS. Seeking to identify what may be out of date or absent to brief specialist writers. Looking for author particularly on fire as a topic. ‘Listed building’ and ‘traditional building’ definitions are progressed but ‘historic building’ still under review, considering the background to these definitions. Noted that the BSD Procedural Handbook references listed, historic and traditional definitions

Action Point 5: AP5 Officials to provide more guidance on the balance and expectation of what reasonably practicable is, including level of competency required.

Action Point 6: AP6 Officials to look at background of 30m cavity barrier spacing related to point above. 

Competency of Fire Risk Assessors

(Oral update)

Fire risk assessors competency. In England, current focus is on HRBs and high rise, there is a different tenure system in Scotland but we are looking at things in a similar way – risk focussed. There is no current requirement for accreditation nor experience of fire risk assessors. Scotland  has been working with the 4 nations, and is part of the Home Office fire group and BSI work to define competency. We are also observers on current work in England, working with UKAS on third-party certification schemes, codes of conduct, what an experienced worker route looks like, enforcement etc. Officials recently outlined options to the Minister and will look to align with UK on risk assessment required with changes to fire legislation. Going to consultation - plan is for stakeholder engagement around proposed changes. Recognise the need for changes in primary legislation. Risk factors and specialisms e.g. FRAEW 9980. 

Comment made on risk factors – Is this matching risks with competency or defining limits on when a competent person is needed based on risk?  It was noted that decision making on this issue was still ongoing work.

Further comment noted that this is potentially hugely impacting work. Not just competency but specialisms needed of assessors. Knock-on effect to competency of verifiers as well as impact on those who already consider themselves competent.

Programme

Update (Paper 5)    

Update by officials. Programme on course and everything achieved as needed to date. Next stage is to develop proposals for consultation and share these with the group for comment. Over the next few months we will post proposals for any feedback on the consultation package. HES guidance document GP6 will not be ready for consultation. Seeking to have further costs from sprinkler contractors and to agree with the group what is put forward to the Minister under recommendation 4. No plan for another face-to-face WG meeting once the package is ready, unless this is needed.

Standard 2.15 Review

Standard 2.15 Automatic Fire Suppression Systems (Paper 6)

Legislation amended on 1/3/21 to apply standard 2.15 to additional building types – all flats & maisonettes, shared multi occupancy residential buildings and social housing dwellings. Verifier feedback suggest some confusion on what to apply in mixed use buildings. Should AFSS be required in both domestic & non-domestic parts. Also partial conversion of a building. Officials noted intention is not to apply provision to other non-domestic buildings but will review internally and feed back.

Purchase of new private sector dwellings as social housing dwellings. Officials noted that an existing dwelling becoming a social housing dwelling does not trigger application of standard 2.15. Topic raised as part of review discussions. SG Housing officials asked to consider and provide advice on whether current provisions remain fit for purpose or if this practice requires a specific response. Question has also been raised by verifiers.

Action Point 7: AP7 SG officials to follow up on social housing question.

Scope of standard 2.15 review - extensions to flats and maisonettes and simple conversions. Significant number of applications to dispense with 2.15 for small scale works are being made and granted. Officials are currently engaging with verifiers and SFRS on a potential Direction to enable decision making for low-risk cases by Verifiers. Seeking to amend scope of standard 2.15 as part of this review, with the Direction as an interim measure, aligned to current research covering buildings to up to 18m high and conversion to form not more than 3 dwellings.

Schedule 6 (conversions) question – option to meet standard as far as is reasonably practicable. Option to move standard 2.15 into this category for conversions but need to know the direction of travel on the broader question of traditional buildings firstly. Topic first discussed at first WG meeting.

Miscellaneous issues

Miscellaneous issues (Paper 7)                     

The purpose of this paper was to seek comments from the Building and Fire Safety Expert Group (BFSEG) on Miscellaneous Issues to be included in the public consultation exercise in Autumn 2024, including the lath and plaster and low-level emergency lighting recommendations for the Cameron House FAI.

Lath and Plaster. Discussed earlier in the meeting. Difficult to determine condition without intrusive inspection. HES has it recognised in their publications. It is well presented in here and the materials and cavities issue is covered in the FRU guidance documents. Existing guidance covers this. Also covered in update to 2.0.7. and the above guides. Agreed covered currently.

Low level emergency lighting. View expressed that current non-domestic emergency lighting provision at low level is not needed as occupants will escape before any lighting fails. Solution will generally not be recommended by a risk assessment. SFRS suggested that incidents where lighting fails is low. Question on the use of protected circuits and if needed as a separate circuit, and not necessarily fire resistant. Point for SG Officials to consider and follow up, including FRU to review. Can ask consultation question and set out view of WG on whether necessary or just an alternative or additional practice.

Action Point 8: AP 8 SG Officials to follow up on protected circuit and fire resistance questions.

Regulation 8 (3) Extending the ban to hotels, boarding houses and hostels. SG are working with BRE and seeking data from SFRS on post fire redacted reports which will allow phase 2 of this work to move on with specification and analysis.

Clause 2.7.1 of the Domestic and Non-domestic Technical Handbook. Manufacturers seeking clarity around references on backing boards. SG request feedback from the group on wording in paragraphs 11 and 12 of paper 7. It is proposed to engage with relevant organisations on the revised wording prior to finalising proposed changes to the guidance in clause 2.7.1 as part of the consultation.

Action Point 9: AP 9 WG members to offer feedback on wording in paragraphs 11 and 12 of paper 7

Regulation 8 (4) Exemptions. Members to discuss whether Scotland should align with England on exemption Types 11 (shading) and 14 (balconies) from table to paragraph 14 of paper 7. Relates to exemptions to A1/A2 rating). Agreed to go to consultation on these to seek views. Also noted England testing of glass balustrades and awaiting final conclusions/comments from this research.

Battery Energy Storage Systems (BESS). It is proposed to consult on guidance for BESS. Guidance for domestic buildings will be based on PAS 63100. Whilst the key message will be to locate BESS outdoors, where this is not possible, suitable compartmentation (medium duration fire resistance) and early warning of fire (smoke alarm) within the compartment should be provided. Need to look at definition of ‘place of special fire risk’. England also working on this topic and we are looking at a consistent approach across the UK if possible.

Car Parks and electric vehicles. BSD propose to commission a literature review of current research carried out globally on car park fire safety in relation to electric vehicles to help identify risks and actions. Members views were requested on the interim guidance developed by Arup for the Office for Zero Emission Vehicles (OZEV). WG noted that the Australian government undertook research which Arup’s reflects. Numbers of EV fires is less than for combustion vehicles. Although different fire dynamics (e.g. jets) heat release rate is relatively similar. Lack of data is an issue as is pace of change in manufacturing and innovation. Also noted that EVs are considered in revised IStructE guidance on car park design.

External Premises Information Plates (PIP) to all new high rise above 18m. Suggestion to remove guidance in 2.14.10 on existing premises and highlight PIP for existing buildings in 2.14.0. Look also at conversion of buildings subject to refurbishment. Engage with SFRS to provide new example including 2 stairs, also clarify how different types of lifts are represented.

England - key changes to AD B since 2020 - second staircase in blocks of flats > 18m (March 2024) – Clause 3.29 of ADB, interlocking stairs question - Scotland need to develop guidance around this for the group. It was noted that AD B introduced some definitions, which included interlocking staircases. England’s research of countries that were accepting interlocking staircases revealed they were only being recognised as a single escape stair. Panel members were advised to read England’s equality impact assessment for the two staircases, which DLUCH did not take forward.

Exit width from rooms in non-domestic buildings - members generally agreed with the proposals to amend exit widths. One member offered to provide further comments following the meeting.

Hospitals - Members were asked for comment on the proposal to cite SHTM81 in the Non-domestic Handbook and remove current guidance in Annex 2.B.

BS EN 13637:2015 Electrically controlled exit systems for use on escape routes - requirements and test methods - it is proposed that the principle of citing BS EN 13637 will be included in the consultation.  It is not intention to replace references to BS EN 1125 or BS EN 179 in the Technical Handbooks. Officials will work with industry to amend the guidance on locking mechanisms and consult the working group when the draft guidance has been updated. SG officials to look at this further and come back to the group. No group comment whether we cite or not.

Action Point 9: AP9 SG officials to follow up for group comment on proposals.

Local Authority Building Standards Scotland - Guidance Notes - It was noted that the Scottish Building Standards Hub is taking these notes on as part of its work.

Approved Document B: Fire safety - frequently asked questions – Should Scotland adopt this approach? FAQ seen as a halfway house to any legislative change. Noted that FAQ can be used for things open to interpretation or to confirm intent of the standards and guidance. Not viewed as a positive undertaking by the group.