Practical fire safety for existing specialised housing and similar premises: BRIA

3. Public Consultation

A public consultation on the draft Guidance document took place between 31 July and 22 October 2019. The consultation included questions requesting information and views on any business impacts that the Guidance may have.

38 respondents provided feedback, which included:

• Housing Associations (and umbrella organisations)
• COSLA
• Local Authorities
• Private Housing Providers
• Care Providers
• Health and Social Care Partnerships
• Care Inspectorate
• SFRS
• Fire Safety / protection / insurance companies
• Individuals

During the public consultation period, 3 engagement events took place:

• Presentation / Workshop with CCPS Housing Support Enabling Unit on 27 August 2019
• Presentation and questions with SFRS on 18 September 2019
• Presentation and questions with Wheatley Group and other care/support agencies on 8 October 2019

3.1 Potential Impacts on Business noted by respondents to the consultation

Section 5 of the consultation asks about potential benefits and costs associated with using the Guidance and requests data on a number of areas. Question 28 asks for information and views on any business impacts the respondent considers the Guidance may have.

The potential cost of having to hire a competent person to carry out a premises-based risk assessment was highlighted. However, the most common business impact identified was additional costs to implement appropriate fire safety measures, as a result of the risk assessment process. Another respondent noted the additional pressures that may be faced by care homes if vulnerable people require residential care and are no longer able to live independently at home.

Information was sought in the consultation on:

• Number of people and premises the Guidance will apply to.
• Proportion of people and premises with adequate fire safety measures in place.
• Proportion of people and premises that will need additional fire safety measures.

Only a minority of respondents gave an answer to these questions. There was a wide variation in responses to the number of people and premises affected by the Guidance: 70 – 8000 people and 3 – 5000 premises, reflecting the range of premises that organisations are responsible for.

A few respondents confirmed that the majority (over 50%) of their premises have adequate fire safety measures, taking into account the Guidance or that there are adequate person-centred measures. This could mean that many respondents have still to carry out premises-based fire safety risk assessments in the near future to improve fire safety. In addition, it is not clear whether the responses relating to people imply that the fire safety measures are appropriate, as determined by a person-centred risk assessment. It is not possible to establish the position overall, given the low number of responses.

There was a low response to the question on the number of people or premises that will need additional fire safety measures, so from this the actual positon cannot be established. It is expected that, in practice, this will be dependent on the fire safety risk assessment findings.

Other potential costs identified by respondents include:

• Increased staff requirements
• Retrofitting of measures
• Alternative accommodation
• Increased insurance premiums
• Building modification, maintenance and management
• Training to familiarise staff with the Guidance

Sixteen respondents highlighted fire safety and the reduction of fires and saving lives as main benefits. Further benefits include a structured approach of fire safety to Specialised Housing, the implementation of best practice and fostering a better understanding of resident/tenant needs.