Fire and smoke alarms in Scottish homes consultation: partial business and regulatory impact assessment

4. Options

Do nothing option

The "do nothing" option would mean failing to take action to improve fire safety in Scotland's housing stock. Prior to the Grenfell Tower tragedy, work was already underway through the Common Housing Quality Standard Forum to harmonise housing standards across tenures, including safety elements such as fire and smoke alarm requirements in houses. This specific element has now been prioritised to help minimise the risk of fire in Scotland's homes.

Other options

Several options are proposed in the consultation paper including:

A. Applying a higher standard to social rented housing
B. Applying a new standard to flats, irrespective of tenure
C. Applying a new standard to flats only in high-rise buildings, irrespective of tenure
D. Applying a new standard to all housing, irrespective of tenure

In each of these options, it is proposed that requirements are in line with the standard currently applicable to the private rented sector.

Current minimum standards in new build and private rented housing require mains wired alarms. This is because of the risk that alarms powered by disposable batteries will fail because batteries have expired or been removed. The consultation also seeks views on the option for types of sealed battery alarms where the battery lasts the lifetime of the unit and is built with a mechanism to alert the user that the alarm should be replaced. Allowing these types of alarms would reduce the cost and disruption associated with retrofitting mains powered alarms.

Views on each option are invited as part of the consultation process.

Sectors and groups affected

Different proposals will affect different groups of people:

• If additional fire and smoke alarm requirements are included in the SHQS, all social housing providers and social tenants will be directly affected.
• If additional fire and smoke alarms are required in all in tenements or blocks of flats, all owners and tenants living in tenements or blocks will be directly affected.
• If additional fire and smoke alarms are required in all tenements and blocks of flats over 18 metres tall, all owners and tenants living in such tenements and flats will be directly affected.
• If additional fire and smoke alarms are required in all houses, all householders, including owners and tenants will be directly affected.

Owners will incur costs if their current alarms fall short of the new regulatory minimum. Occupants (owner-occupiers and tenants) where fire and smoke alarms are installed will benefit from living in homes which are safer and at lower risk of fire than they were before the alarms were installed. Occupants of neighbouring dwellings will also benefit from the reduced risk of fires which spread to their homes.

Benefits

Reduced Number of Fatalities and Serious Injuries
While the number of fatalities varies from year to year, there is statistical evidence of a higher fatality rate for dwelling fires in Scotland where no operational smoke alarm was present. Over the seven years to 2015/16, there were 5.9 fatal causalities per 1,000 dwelling fires where there was no operational alarm, compared with 6.9 where there was an operational alarm. ^[6] This lower fatality rate is in line with the international evidence – a report by BRE Global for the Scottish Government found that a wide range of international literature supports the conclusion that the presence of an operational smoke alarm could reduce the risk of death by 50%. ^[7]

Reduced Costs to Scottish Fire and Rescue Service
The quicker response time associated with an alarm should lead to a fall in the severity of fires to which the Scottish Fire and Rescue Service are called. This is expected to lead to a decrease in the amount of time and resources required from the Scottish Fire and Rescue Service, reducing costs.

However, this must be set against a possible increase in costs due to an increase in the number of false alarms to the Scottish Fire and Rescue Service. Over the period 2009-10 to 2014-15, there was a 29% increase in the number of false alarms due to the apparatus, although this was followed by a small decline in 2015-16. ^[8]

Reduction in Damage to Property
The quicker response time due to an increase in the number of smoke and fire alarms is expected to lead to a reduction in the severity of fires, and, as a result, a decrease in the amount of damage caused to property as a result of fires. A UK Government report in 2004 estimated that the average amount of damage caused in a residential fire in the UK was £7,300. ^[9] If this figure were simply uprated by inflation over the period, this estimate would be approximately £9,000 for 2016 (however, any improvements in fire-fighting technology since 2004 may have served to decrease this figure).

Costs

If the same standard for fire alarms that applies to the private rented sector is extended to other tenures, alarms will need to be installed in properties which do not have any alarm as well as in those which have one or more alarms but which fall short of the required standard in terms of the number and placement of alarms.

Although fire alarms are not mandatory in the owner occupied sector, unless the property was built under the 1993 or subsequent building regulations, only an estimated 7% (110,000) of properties in this tenure do not have any smoke alarm at all. ^[10] One third (490,000) have one alarm, while the remaining 60% (900,000) have more than one alarm. The number of alarms prescribed by the proposed minimum standard implies that the 600,000 owner-occupied properties with no or only one alarm definitely fall below the proposed standard. Furthermore, it is possible that some or most of the remaining 900,000 properties with more than one alarm would also not comply with the proposed standard, although it is not possible to determine the proportion from the available data.

In the social rented sector, although at least one alarm is required by the Scottish Housing Quality Standard, the estimated 48% (280,000) of properties with only one alarm would definitely fall below the proposed standard. Again, it is likely that some or most of the remaining 52% (305,000) of properties with more than one alarm would fall the standard, although it is not possible to determine this proportion.

In addition, most of the estimated 850,000 owner-occupied properties and 140,000 social rented properties where the alarms are only or partly powered by batteries are likely to require replacement to comply with the standard, unless the battery type is in compliance with the standard (a sealed battery unit designed to last the lifetime of the fire alarm, which is at least 10 years).

Market figures indicate that a mid-range mains-powered, inter-linked smoke alarm costs around £65 and that a mid-range, inter-linked sealed battery alarm with a 10-year battery life costs around £80. Installation of a mains-powered alarm is likely to cost around £50, while sealed battery alarms do not require professional installation.

As the proposal is currently for no alarm to be more than ten years old, each property would incur the upfront purchase (and installation costs where applicable) at least once every ten years. Currently existing alarms will have a manufacturer's recommended lifespan and this is usually ten years, but there is no process for identifying or requiring replacement when the recommended lifespan is exceeded.

The total cost to meet the requirements will depend on the final form of the regulations and the built form of individual properties.