Fire and smoke alarms in Scottish homes consultation: analysis of responses

Changes to the Minimum Standard

Common Alarms

Q4: Do you think that any new standards should require fire and smoke alarms to be interlinked in different flats in the same building?

Table 11: Question 4

	Yes	No	Don't know	No reply
Housing Association (17)	-	16	1	-
Local Authority (13)	-	11	2	-
Lettings / residential lettings / property management (7)	-	5	-	2
Residents association / tenant participation (7)	2	3	1	1
Fire risk / Safety consultant (6)	1	5	-	-
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	3	6	2	2
Individuals (59)	15	29	12	3
Total (122)	21	75	18	8

83. As Table 11 shows, a majority of those who responded did not agree that any new standards should require fire and smoke alarms to be interlinked in different flats in the same building (75 disagreed compared to 21 – mainly individuals – who agreed).

84. Respondents were invited to explain their answer and 100 did so.

85. Looking first at those who said 'no', the main point raised by almost all of the 66 who commented, was the issue noted in the consultation document; the potential for recurring false alarms.

86. Respondents, from across respondent groups, pointed out that this can lead to a range of problems. The main issues mentioned were:

• That this could lead to complacency; with people assuming every alarm is a false alarm.
• That this would lead to increased call-outs and wasted time for the SFRS; one local authority respondent said that the "fire service has previously requested decommissioning of linked systems".
• That people may remove, disable or damage their alarms to avoid false alarms and thus put themselves and others at risk.
• That each false alarm would mean the need for all to evacuate.
• That this could lead to panic, or to distress for particular groups of people such as elderly people, disabled people, or those with sound sensitivity.
• That this could lead to issues between neighbours particularly if there is one flat that causes recurring alarms, whether through something simple like burnt toast, or by setting off the alarm maliciously.
• That testing would disturb the whole building.

87. Another issue, raised by several organisations and a small number of individuals, was that of connecting, monitoring and testing. One housing association respondent said it would be "difficult to implement and manage to ensure that the system is maintained and fully functional". A respondent from the lettings / residential lettings / property management group explained: "This is likely to be difficult to set up and maintain, due to problems with connectivity of radio interlinking through structural walls and between alarms which may not be compatible with each other".

88. Several respondents, mainly organisations, pointed out that the 'stay put' strategy is recommended and should remain in place ( SFRS advise that when a fire breaks out within a multi-storey building, if a flat is not affected by heat and smoke, then the safest course of action is to remain in the flat and allow the fire service to deal with the emergency); these respondents said that interlinked alarms may cause all residents to try to evacuate.

89. There were also comments that if there were a fire in one area, then evacuating the whole building might pose more risk for those in the affected areas as their exit may be hampered by all other residents evacuating.

90. A small number of respondents mentioned the cost and/or enforcement of maintaining, fitting or retrofitting and how these would be agreed between different owners or landlords.

91. A small number of organisations, from various groups, commented that linking alarms is not required so long as there is proper fire and smoke separation between each flat.

92. Another theme to emerge in a small number of responses, but particularly from local authorities, was that while these respondents do not see the need for interlinked alarms in most blocks of flats, there are some instances where they would recommend this. For example:

• Where there is historical evidence that a particular type of building poses more risk without interlinked alarms or where there is evidence that a particular type of building would benefit.
• Where there are vulnerable residents, such as in sheltered housing.

93. Other comments, from smaller numbers of respondents, are outlined below.

• That there should be a main alarm perhaps linked to the landlord or concierge.
• That while interlinked alarms within individual flats are not necessary, there should be alarms in common areas such as corridors and refuse rooms.
• That in buildings with linked alarms there would need to be very clear guidance for residents on evacuation procedures.
• That interlinked alarms should be used in high rise buildings only.

94. This issue of false alarms was also raised as a concern in responses from a small number of the 15 who said 'yes' and commented further.

95. Looking at the other respondents who said 'yes', new standards should require fire and smoke alarms to be interlinked in different flats in the same building, the main theme to emerge was that this would alert as many people as possible and/or provide more time for evacuation.

96. Other points raised included one respondent from the fire risk / safety consultant group who commented that residents in flats should be alerted to any developing fire, rather than simply an initial smoke alarm, and suggested that "Elements of the Type B Dependency systems sometimes installed in Student accommodation may be appropriate". This respondent pointed out that the mandatory standard implies all occupants have the right to a timely warning of fire and also commented that not to do so would give them a lesser standard of protection than those in commercial or industrial properties where "a Category L3 system would normally be applied as a minimum".

97. A respondent from the 'other' organisation group said that "the Common Housing Quality Standard Forum has noted that the impact of a large fire in a tenement flat is likely to affect other flats in the same building".

98. The main points raised in responses from the 19 who said 'don't know' or did not specify their opinion included:

• That there are both advantages and disadvantages (and those mentioned are similar to the main themes from the yes/no respondents).
• That it would depend on the type of property (including escape routes) and/or level of risk and/or the type and reliability of the alarm system, for example:

"Fire detection systems should form part of a properly planned and understood fire safety regime. That may, in some circumstances included linking detectors across a number of homes but there won't be a one size fits all solution" (local authority).

Common Area Alarms

Q5: If we introduce a new minimum cross-tenure standard, do you think that it should require fire and smoke detectors in common areas?

Table 12: Question 5

	Yes	No	Don't know	No reply
Housing Association (17)	4	11	2	-
Local Authority (13)	3	7	2	1
Lettings / residential lettings / property management (7)	2	4	-	1
Residents association / tenant participation (7)	7	-	-	-
Fire risk / Safety consultant (6)	3	3	-	-
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	6	2	3	2
Individuals (59)	28	12	15	4
Total (122)	53	39	22	8

99. Table 12 shows that 53 respondents agreed while 39 disagreed.

100. Respondents were invited to explain their answer and 94 took the opportunity to comment.

101. A wide range of points were raised by the 37 respondents who said 'yes' with no particularly significant themes emerging. Many of the points reflect comments made by those who answered 'no' to question 4.

102. The main points, all from small numbers of respondents who said yes (from various groups unless stated), included:

• That this would provide additional protection or that it will prove safer as more people will be alerted.
• That alarms may only be required in high risk areas such as refuse stores or escape routes.
• The need to ensure that buildings are up to standard and/or the need for clear fire regulations (individuals).
• That residents will be alerted of any areas where their exit might be hampered (residents association / tenant participation).

103. Some respondents, again small numbers, also raised a number of provisos or concerns; these mainly related to:

• Suggestions that while there should be, and in many cases already are, common area alarms, these should not be linked to individual flats; a small number suggested links to a concierge or similar.
• Suggestions that the alarms should only be linked to flats close by to the common areas that may be at most risk. This included a respondent from the other organisation group who, while supporting the need for linked alarms, included this as a possible alternative:

"Fire and smoke alarms in common areas can offer additional safety in relation to fires within closes, stairways and bin stores or chutes. According to national fire statistics, dwelling fires, where smoke alarms are triggered, are discovered more rapidly (less than 5 minutes) after ignition, and are associated with lower fatalities…… A potential alternative approach would be to have common alarms within zoned areas i.e. flats close to bin stores".

104. A small number also raised the possibility of vandalism or malicious triggering.

105. A small number disagreed with or queried the 'stay put' advice with a respondent from the other organisation groups asking "Does stay put happen or do people panic?"

106. Almost all (38) of the 39 who said 'no', also commented. The main themes from these responses were as follows.

107. Over a third of these respondents, from across respondent groups, commented again on the issue of false alarms with many comments similar to those seen at the previous question. One additional point made by these respondents, however, related to the possibility of vandalism as these areas are accessible to all and so alarms could be tampered with or set off maliciously.

108. Around a third, again from across respondents groups, commented that the 'stay put' advice is correct and that these alarms would cause whole buildings to be evacuated; in instances where only a small part needs to be evacuated this would mean those at greatest risk being hampered by others who do not need to evacuate. There were also comments that installing these alarms could jeopardise the 'stay put' advice as people would evacuate on hearing the alarm.

109. Several respondents said there would need to be someone in charge of checking and enforcing safety in common areas and either of checking or turning off the alarm in the case of a false alarm, or to supervise any evacuation should there be a fire. For example, a respondent from the fire risk / safety consultant group said: "It has been recognised for decades that such communal fire alarm systems should only be installed where a responsible person can take charge of the alarm system and any evacuation".

110. In relation to this point, a respondent from the housing association group said:

"A focus should be on enforcing safe common areas. To achieve this , new powers need to be given to a regulated body to allow action to be taken. This should include the ability to forcible [sic] remove items of a fire hazard and where items are likely to impinge access and egress. It should be criminal to ignore the advice of the statutory body".

111. A local authority respondent suggested that:

"consideration should be given to establishing standards and guidance for undertaking assessments of particular buildings in this regard, as required".

112. Several respondents also mentioned the need for risk assessments for each building, ensuring that proper preventative measures, including security checks, fire rated doors and bans on combustible materials from common areas, as well as standards to ensure building construction is designed to contain fire, are in place.

113. Another local authority respondent felt that: "Consideration should be given to the historic sources of fires within such properties and whether there is evidence which indicates fires within common areas are of significant numbers to support this proposal".

114. Another theme, from a smaller number of respondents, was again the question of who would pay for and maintain any system.

115. Once again, a main theme in responses from the 19 who said 'don't know' or did not specify their opinion was that there are both advantages and disadvantages. And, again, those advantages and disadvantages mentioned match the themes from the yes/no respondents.

116. Another main theme was that the decision should be based on expert advice, risk assessment and/or evidence.

117. A small number felt there should be common area alarms but these should be linked to the Fire Service or landlord / concierge rather than to individual flats.

118. A very small number felt that the 'stay put' advice may change following the Grenfell Tragedy.

Battery Powered Alarms

119. The Scottish Government propose the following minimum criteria for battery alarms:

• Sealed battery units, designed to last the lifetime of the unit (at least 10 years);
• Interlinking between alarms (including radio, Bluetooth etc.); and
• A warning device to alert occupiers at the expiry of the lifetime of the unit.

Q6: Do you think that it would be acceptable to specify battery alarms in new standards, provided these meet the minimum criteria?

Table 13: Question 6

	Yes	No	Don't know	No reply
Housing Association (17)	15	2	-	-
Local Authority (13)	9	4	-	-
Lettings / residential lettings / property management (7)	2	4	-	1
Residents association / tenant participation (7)	5	2	-	-
Fire risk / Safety consultant (6)	-	3	2	1
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	9	4	-	-
Individuals (59)	35	20	2	2
Total (122)	75	39	4	4

120. Table 13 shows that 75 respondents agreed that it would be acceptable to specify battery alarms in new standards, provided these meet the minimum criteria; 39 respondents, including many individuals, disagreed.

121. Respondents were invited to explain their answer and 121 commented further. The main themes in comments from those agreeing with the proposal are that this offers a simpler and more economical route to safety. A small number of respondents suggested that this, in turn, increases the likelihood of compliance. One residents' association / tenant participation organisation commented: " Installation would be quicker, cheaper and less disruptive to internal decoration. The disruption (from mains installation) might be a dis-incentive to meeting the new standard, particularly in the owner occupied sector where the onus will be on the owner to pay for/organise the works".

122. There were mixed views from a small number of respondents on the relative effectiveness and safety of the suggested criteria for battery alarms. There were a small number of comments on the ways in which technology has progressed and advanced and this was occasionally directly linked to confidence in sealed battery units. In contrast, a respondent in the fire risk / safety consultant group of organisations commented: " While battery operated units with long term batteries are better than the old style, it still requires someone to change a battery in 10 years, and results in a system that is not inspected or maintained during that period".

123. Many respondents – regardless of whether they agreed or disagreed - queried how this would be monitored and enforced. A small number also expressed concerns that entire units might be removed, for example by tenants.

124. A number of respondents, predominantly those who disagreed with the proposal, suggested mains powered units are the safest and therefore the best option.

125. System stipulations were suggested by a number of respondents and these included those detailed in the consultation. In addition, a number of respondents suggested that different requirements are appropriate according to tenure and that owner occupiers should have greater flexibility of choice.

126. Linked to the next question in the consultation, there were a small number of comments that this change would be unfair on landlords in the private rented sector. One individual respondent commented: "…. you have forced private landlords to reach a standard in a very short space of time and at great cost but now you want everyone else to have an easy ride".

127. A respondent in the fire risk / safety consultant group of organisations commented that the environmental cost of using lithium battery devices should be considered.

Q6a: This would involve a change to the current Private Rented Sector guidance which requires mains wired smoke alarms. Please let us know your views about this.

128. One hundred and twenty-one respondents made comments at this question, a number of whom referenced their earlier answers. For example, those who had said that mains powered units should be mandatory reiterated this belief. A number of those who supported the proposed change commented again here on technological advances that have been made and the need for guidance to be updated in line with those developments.

129. Many supported a change to PRS guidance and, once again, a number suggested that the change would encourage compliance among landlords or even encourage new landlords to enter the market.

130. A small number of respondents commented that they felt the guidance for PRS should not be revised regardless of proposals relating to other tenures. A small number also suggested that the PRS guidance should be extended to encompass social housing.

Maximum Age for Alarms

Q7: Do you think that a minimum standard should specify a maximum age for alarms?

Table 14: Question 7

	Yes	No	Don't know	No reply
Housing Association (17)	16	1	-	-
Local Authority (13)	10	2	1	-
Lettings / residential lettings / property management (7)	3	3	-	1
Residents association / tenant participation (7)	7	-	-	-
Fire risk / Safety consultant (6)	3	3	-	-
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	8	3	1	1
Individuals (59)	42	10	4	3
Total (122)	89	22	6	5

131. As shown in Table 14, there was majority support, across most sub-groups, for a minimum standard to specify a maximum age for alarms (89 respondents supported this proposition, compared to 22 who did not). Views were polarised among organisations in the fire risk / safety consultant and lettings / residential lettings / property management sub-groups.

132. Respondents were invited to explain their answer and 91 took the opportunity to comment, some of whom simply noted that there is a need for a common standard so as to remove any confusion, that this is common sense, or that the introduction of a maximum age will ensure alarms are replaced regularly and remain effective.

133. Some respondents specified certain lifespans for alarms, with the highest level of consensus being for 10 years, although there were also a small number of suggestions that this would need to be reviewed periodically as technology develops and the lifespan of an alarm is extended. A small number of respondents suggested replacement every:

• 3 years (1 respondent).
• 5 years (3 respondents).
• 8 years (2 respondents).

134. While some respondents specified a maximum age for alarms, a similar number suggested that the lifetime of any alarm should be in line with manufacturers' guidance / advice or warranty. A small number of respondents also simply referred to an alarm being replaced at the end of its lifespan.

135. A small number of respondents within local authorities and housing associations suggested the need for a minimum lifespan rather than a maximum.

136. Some respondents referred to specific technology, with requests for some form of audible warning that a battery alarm is coming to an end of its life. A small number of respondents also noted that mains powered alarms do not need to have a maximum age, with one respondent in the lettings / residential lettings / property management sub-group noting that introducing a legislative timeframe for mains powered alarms would be an unnecessary financial burden.

137. Some respondents, rather than suggesting a maximum age for alarms, noted that good levels of maintenance can be a deciding factor on the lifespan of an alarm. There were also some comments that there should be regular monitoring and testing so as to avoid unnecessary alarm replacement. A small number of respondents suggested that alarms could be tested in the same way as other electrical goods, similar to PAT ^[4] testing.

138. As at previous questions, a small number of respondents queried how this would be enforced or noted the difficulties of implementing this proposal, with some commenting that this could not be enforced in the owner occupied sector. Two individuals also noted that the introduction of these changes will need to be communicated effectively to landlords and homeowners so as to ensure any required changes take place, with a suggestion from a local authority for an information campaign to ensure awareness of this.

Q7a: If yes, do you agree that the maximum age should be 10 years?

139. Eighty-two respondents opted to provide commentary to this question, although over half of these simply agreed that the maximum age should be 10 years, while a small number of respondents thought that a five year minimum should be applied.

140. Some respondents provided qualifying commentary, with the largest single comment being that the maximum age should be dependent upon the manufacturer's guidance, or dependent upon what is available. A small number, while agreeing with the maximum age of 10 years, also noted that this should be kept under review to allow for changes in technology in the future. Two individuals commented that the maximum age is irrelevant providing an alarm is well maintained.

141. Of the small number of respondents disagreeing, the maximum age of 10 years was felt to be too long.

142. Other comments, each from a very small number of respondents, included the concern that imposing a maximum age of 10 years will limit the potential for innovation in the industry and will not incentivise manufacturers to improve upon their products if legislation requires an alarm to be changed every 10 years.

143. A small number of respondents also noted that alarms should be regularly checked, perhaps by fire service personnel or as part of regular electrical ( PAT) checks.

Q7b: If not, what alternative?

144. Thirty respondents chose to provide commentary at this question, with many echoing the response they had given in the two previous questions.

145. A small number of respondents opted to provide an alternative lifespan for alarms. There was no consistency in response, with suggestions ranging from as few as three years to a minimum of ten years, or fifteen years. However, many respondents providing an answer suggested that the alternative should be based upon the manufacturers' recommended lifespan.

146. A small number of respondents suggested that alarms should only be changed when they stop functioning.

147. Other comments made by one or two respondents included:

• Manufacturers should improve alarm products to offer a longer lifespan.
• Alarms should be subject to the British Standard specification.
• Alarms should be regularly checked and maintained; for example as part of a regular electrical check.
• There is a need for more research to ascertain a sensible maximum age for alarms.

Location of Alarms

Q8: Do you think that there should be any change to the rules on the location of alarms in the minimum standard? If so, what?

Table 15: Question 8

	Yes	No	Don't know	No reply
Housing Association (17)	2	13	1	1
Local Authority (13)	2	7	3	1
Lettings / residential lettings / property management (7)	1	4	1	1
Residents association / tenant participation (7)	4	3	-	-
Fire risk / Safety consultant (6)	2	-	4	-
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	5	5	2	1
Individuals (59)	27	28	3	1
Total (122)	43	60	14	5

148. As Table 15 shows, views were relatively split as to whether there should be any change to the location of alarms in the minimum standard, with 43 in support of this proposal compared to 60 who were opposed. The organisations least likely to support this proposal were housing associations, local authorities and those in lettings / residential lettings / property management.

149. Eighty respondents provided further commentary to back up their response. A number of respondents made suggestions for additional rooms into which an alarm should be placed, with bedrooms receiving the most suggestions, although some respondents noted that alarms should be placed in all rooms, hallways, common areas and / or kitchens. There were also a small number of suggestions that alarms should be interlinked.

150. A number of respondents noted that there was a need for specialist advice, with advice from the SFRS cited by many of these respondents. While one respondent in the lettings / residential lettings / property management sub-group noted that the current guidance means that electricians must be clear on what should be provided by way of alarms, another in the 'other' sub-group noted that many electricians do not follow this guidance or have the required knowledge to advise property owners on what alarms need to be installed.

151. A small number of respondents, rather than making suggestions for specific rooms into which alarms should be placed, noted that a risk-based approach should be adopted, that the placement and number of alarms should be dependent on property layout or the size of the property or that there needs to be consideration on the wider fire protection system in place, how a property is occupied and by whom.

152. Of the respondents disagreeing with this proposal, many noted that the present rules on the location of alarms are suitable and do not need to be changed. A small number of respondents referred specifically to the standard for new build which sets out a need for one alarm per level of a house.

153. A small number of respondents requested clear guidance so that landlords and property owners understand what alarms they need to provide, with some referring to the BS 5839-6:2013 Fire Detection and Fire Alarm Systems for Buildings.

154. A number of respondents disagreeing with this proposal also called for more research or evidence, for example, to identify the most at risk rooms or to ascertain the reasons behind alarm failure to activate.

Other Changes

Q9: Do you think there should be any other changes considered for (i) any new standard for social landlords and owner occupiers or (ii) the existing standard for private rented housing?

Table 16: Question 9i

	Yes	No	Don't know	No reply
Housing Association (17)	4	9	2	2
Local Authority (13)	6	5	2	-
Lettings / residential lettings / property management (7)	1	1	4	1
Residents association / tenant participation (7)	3	3	-	1
Fire risk / Safety consultant (6)	1	3	1	1
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	2	6	3	2
Individuals (59)	23	19	12	5
Total (122)	40	46	24	12

155. As Table 16 shows, views were polarised as to whether there should be any other changes considered for any new standard for social landlords and owner occupiers, with 40 in agreement with the proposal and 46 not in agreement, although 24 respondents gave a response of 'don't know' and 12 did not reply.

156. A total of 60 respondents, across all sub-groups, opted to provide additional commentary in support of their response.

157. A small number of respondents noted that the same standard should apply to all types of tenure, including the private rented sector and the social sector. There were also a small number of mentions for other sectors such as holiday homes or serviced apartments. A small number of respondents noted that the current standard is adequate. However, a small number of respondents also commented on the need for a timescale to allow owners and landlords to carry out any required changes in the light of a new standard.

158. As at some previous questions, some respondents made suggestions for technology that could or should be adopted under a new standard and this included mentions of carbon monoxide detectors (housing associations) and interlinked alarms with carbon monoxide detectors. Other suggestions included:

• Fire extinguishers in common areas or in each home.
• Retrofitting of sprinklers in existing homes and in all new build.
• Smoke detectors in the master bedroom.
• Fire doors.
• Smart smoke detectors that can self-test and upload results to a portal.

159. As at a number of previous questions, there were some references to the difficulties of enforcing a new standard, particularly among owner occupiers. A small number of respondents suggested that owner occupiers should not have to comply with the same standard, or that the new minimum standard should focus on the areas of highest risk such as flatted properties. One individual stressed that social landlords should be held accountable for the safety of their tenants.

160. A small number of respondents focused on the need to give consideration to groups of people who might have additional needs, such as disabled tenants.

161. Some respondents noted responsibilities that should lie with property owners. These included informing tenants about fire safety, providing confirmation that fire and smoke detection equipment has been installed in line with the standard or being responsible for testing smoke alarms in accordance with British Standard or fire safety guidance.

162. Once again, some issues seen at earlier questions were highlighted by small numbers of respondents. These included

• The need for more research.
• The need to adopt a risk-based approach.
• Using the SFRS to carry out checks.
• The need to educate the public, owners, landlords and tenants on the importance of fire safety.
• Consistency in the language used.

Q9: Do you think there should be any other changes considered for (i) any new standard for social landlords and owner occupiers or (ii) the existing standard for private rented housing?

Table 17: Question 9ii

	Yes	No	Don't know	No reply
Housing Association (17)	8	5	2	2
Local Authority (13)	1	8	3	1
Lettings / residential lettings / property management (7)	1	4	1	1
Residents association / tenant participation (7)	2	4	-	1
Fire risk / Safety consultant (6)	2	2	2	-
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	2	6	3	2
Individuals (59)	17	27	11	4
Total (122)	33	56	22	11

163. As shown in Table 17, more respondents disagreed (56) that there should be any other changes considered for the existing standard for private rented housing than agreed (33), although some provided an answer of either 'don't know' (22) or did not reply (11). Highest levels of disagreement came from local authorities and respondents in lettings / residential lettings / property management. Highest levels of agreement came from housing associations.

164. Forty-seven respondents, across all sub-groups, opted to provide additional commentary in response to this question.

165. Some respondents noted the need for the same standard across all types of tenure or felt the existing standards are adequate for the private rented sector, although a small number of individuals noted that the standard should be the same as for new build.

166. Some respondents opted to outline suggestions for technology requirements that should be included in the standard and these included:

• Battery technology.
• Fire extinguishers.
• Sprinklers (retrofitted to existing properties and installed in new build properties).
• Interlinked alarm systems to include bedrooms / detectors in bedrooms.
• Fire rated entry doors in flatted properties to minimise the fire risk to others.
• Carbon monoxide detectors.
• Easy access to fire escapes.
• Emergency lighting in communal areas.

167. Once again, the issue of enforcement was raised by some respondents, with most of these noting the need for some form of monitoring for compliance and maintenance of equipment. There were suggestions for penalties to be imposed on those not complying.

168. Other issues raised by respondents at this question included a need for:

• Fire safety education.
• Research.
• Consideration of risk management rather than a focus on fire and smoke alarms per se.
• Time to implement and apply any required changes.