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

Costs, Timescale and Compliance

Estimate of the Cost of Alarms

169. In the consultation paper the Scottish Government proposed that owner occupiers should pay for fire and smoke alarms in their own homes, and that social landlords should fund additional alarms from their own resources.

Q10a: Do you think that it is reasonable for home owners to pay for the work needed to comply with a new minimum standard for fire and smoke alarms? If not, who do you think should meet these costs?

Table 18: Question 10a

	Yes	No	Don't know	No reply
Housing Association (17)	14	1	1	1
Local Authority (13)	13	-	-	-
Lettings / residential lettings / property management (7)	5	1	-	1
Residents association / tenant participation (7)	4	3	-	-
Fire risk / Safety consultant (6)	6	-	-	-
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	10	1	-	2
Individuals (59)	43	12	2	2
Total (122)	95	18	3	6

170. As Table 18 shows, there was majority agreement (95) across all sub-groups that it is reasonable for home owners to pay for the work needed to comply with a new minimum standard for fire and smoke alarms, although the views of residents associations / tenant participation organisations were polarised. Eighteen respondents disagreed with this proposal.

171. While there was general support for this proposal, a number of respondents across all sub-groups raised concerns over the costs. Some respondents suggested that the Scottish Government should take responsibility for installation costs, while some others thought that the Scottish Government should offer grants, subsidies or loans to help cover the costs of installation. A number of these respondents referred specifically to those on low incomes or who are vulnerable as needing financial support and some suggested carrying out means testing. A small number of these respondents referred to the possibility of extending care and repair or handyman schemes or utilising funding from other sources such as energy efficiency schemes.

172. There was also some reference to the potential of grants from the SFRS who have provision to fit smoke alarms free of charge if they are required after a home fire safety visit. A local authority suggested that there would be potential for utility companies to contribute to the costs or for community benefits to be paid for by manufacturers.

173. One individual suggested a trade in or recycling scheme to help alleviate costs.

174. Of the small number who disagreed with this proposal, it was felt that the home owner should be able to decide whether to go ahead or not, although some of these noted that private landlords, those who offer self-catering or short term lets should have to comply with the new minimum standard.

175. Some themes emerging to this question echoed those seen at earlier questions. These included:

• Concerns over how this would be enforced.
• A need for education campaigns to increase understanding of the importance of fire safety.
• A need for risk assessment to ascertain requirements.
• A preference for sealed battery alarms.

176. A small number of respondents referred to the estimates of the cost of alarms provided in the consultation paper, with comments that the cost of hard wired alarms was underestimated and that this is more likely to be around £200 (the consultation paper suggested £50 installation costs for mains wired alarms). A local authority respondent also felt that installing smoke detectors is likely to need professional installation and this will increase the costs. A respondent in the lettings / residential lettings / property management group said:

"Current PRS requirements leave properties with surface mounted trunked cabling which is unsightly. If owners want them concealed you require plaster chasing, making good and redecorating rooms. This cost can be considerably more than the fittings" (lettings / residential lettings / property management).

177. While some were critical of the costs outlined in the consultation paper, others felt that costs associated with this would be manageable, particularly if compared with savings in terms of fatalities, damage to property and use of the SFRS.

Q10b: Do you think that it is reasonable for social landlords to pay for the work needed for their properties to comply with a new minimum standard for fire and smoke alarms? If not, who do you think should meet these costs?

Table 19: Question 10b

	Yes	No	Don't know	No reply
Housing Association (17)	11	3	2	1
Local Authority (13)	10	-	2	1
Lettings / residential lettings / property management (7)	6	-	-	1
Residents association / tenant participation (7)	5	2	-	-
Fire risk / Safety consultant (6)	6	-	-	-
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	11	-	-	2
Individuals (59)	51	4	1	3
Total (122)	100	9	5	8

178. As Table 19 demonstrates, a large majority of respondents (100) agreed that it is reasonable for social landlords to pay for the work needed for their properties to comply with a new minimum standard for fire and smoke alarms; nine respondents disagreed. Many of these respondents reiterated points made to the previous question.

179. A number of those who agreed noted that it would mean parity across the different sectors, that landlords have a duty of care or that it is fair and reasonable that all landlords should bear the cost of implementation. An additional advantage, cited by a small number, is the longer term advantage of protecting property.

180. However, qualifying comments were made by a number of respondents, most notably in relation to the need for adequate resources, a reasonable timescale for implementation, a need to ensure that rents are kept affordable for tenants or for some form of grant / subsidy to be provided. Typical comments included:

"A longer time frame around compliance with a new standard could potentially allow social landlords greater flexibility around planning investments, we recognise there is balance around adequate time to plan and the need to introduce any minimum standard and the benefits it may bring" (local authority).

"Given the number of homes housing associations own, the cost of upgrading alarms will be significant – estimates from members vary between £200,000 and £300,000 for medium sized housing associations. Costs will be significantly higher where associations have large number of homes or where the majority of their homes are from a stock transfer." (Housing Association)

181. There were a small number of suggestions that financial support may be needed for specific groups. A small number of respondents had concerns that this could result in a rent increase for tenants.

182. As at the previous question, there were a number of suggestions for the Scottish Government to make funding available, in the form of grants, loans or subsidies.

Timescales

Q11a: Do you think that the timescale we have proposed for installing additional alarms is reasonable: One year for battery alarms?

Table 20: Question 11a

	Yes	No	Don't know	No reply
Housing Association (17)	5	11	-	1
Local Authority (13)	6	5	2	-
Lettings / residential lettings / property management (7)	3	2	1	1
Residents association / tenant participation (7)	5	2	-	-
Fire risk / Safety consultant (6)	5	1	-	-
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	5	4	3	1
Individuals (59)	35	14	8	2
Total (122)	64	39	14	5

183. As shown in Table 20, a majority (64) of respondents agreed that a one year timescale for installing additional battery alarms is reasonable. This compares to 39 who disagreed; highest levels of disagreement came from housing associations.

184. Respondents were invited to expand on their answer and 75 took the opportunity to comment. The key comments from those who agreed with the proposal was that this would be an adequate timescale, that it would be relatively easy to install additional battery alarms or that fire safety should be a priority. A small number of respondents suggested that this could be completed in a shorter timescale than that suggested by the Scottish Government. That said, a small number of these respondents noted it would be dependent on the availability of the necessary battery alarm units. A small number of respondents also noted that this requirement should be acceptable to social landlords who will be aware of this issue but that other sectors might need a longer period of time.

185. Of the respondents who disagreed with this proposal, a key comment, primarily from housing associations and local authorities, was in relation to the logistical and financial challenges that would be presented by such a short timescale. Some of these respondents noted that there could be problems with installation and connection; others that this would need to be part of the planned maintenance cycle, which would also help to spread the costs over a longer period of time. A small number of these also noted that this could result in significant costs that have not yet been budgeted for. One housing association identified a number of key issues including budgeting, timescales, the need to keep rents as low as possible, availability of products as well as other pressures upon social landlords.

186. A number of respondents suggested alternative timescales, with a small number suggesting that this could be completed in as little as three or six months. However, most of those providing an alternative timescale – primarily housing associations – suggested five years as this would allow for planning, procurement and the budgeting of costs over a more realistic time period. A small number of respondents felt that a timescale of ten years would fit better with planned maintenance cycles. However, there were also a small number of comments that social landlords would not require a longer timescale given that they will have some form of provision in place already.

187. There were some suggestions that the implementation of this proposal should be staggered and prioritise at-risk households.

188. Some respondents, mainly individuals, who disagreed with this proposal did so on the basis of a dislike of using battery alarms and a preference for linked mains alarms instead.

189. One concern raised by some respondents was whether or not manufacturers and suppliers have sufficient capacity to be able to cope with an increased demand over a short period of time. Additionally, that a sudden increase in demand could result in increased costs of battery alarms at a time when many organisations are under considerable financial pressure.

190. A very small number of respondents made other suggestions and these included:

• Insurance companies insisting upon battery fitted alarms in owner occupied properties as this would help with enforcement in this sector.
• The Scottish Government should not support battery alarms as this would be promoting one supply sector at the expense of another.

Q11b: Do you think that the timescale we have proposed for installing additional alarms is reasonable: Two years for mains wired alarms?

Table 21: Question 11b

	Yes	No	Don't know	No reply
Housing Association (17)	4	12	-	1
Local Authority (13)	5	5	3	-
Lettings / residential lettings / property management (7)	3	3	-	1
Residents association / tenant participation (7)	4	3	-	-
Fire risk / Safety consultant (6)	3	2	1	-
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	6	3	2	2
Individuals (59)	36	15	6	2
Total (122)	61	43	12	6

191. As Table 21 shows, a majority of respondents (61) felt the proposal that a two year timescale for installing additional mains wired alarms is reasonable. This compares to 43 respondents who disagreed. As at the previous question, the highest level of disagreement came from housing associations, with views mixed across other types of organisation.

192. Respondents were again invited to explain their answer and 73, across all sub-groups, did so. Many of the responses echoed those given at the previous question. Those in support of the proposal felt that two years is a reasonable period of time to comply with the minimum standard.

193. Two different perspectives were demonstrated from those opposed to this proposal. A larger number of those in disagreement with the proposal, mostly in housing associations and local authorities as well as some individuals, felt that two years is not long enough, with some suggestions that a five year period would be more suitable. As at the previous question, the reasoning for this was that time is needed to take into account the number of properties affected and the scale of work to be undertaken, other pressures on budgets such as energy efficiency schemes or other housing condition demands, the availability of installation contractors and skilled trades to undertake this work.

194. There was a preference from some of these respondents that any work is undertaken in line with ongoing planned maintenance. A small number of respondents suggested prioritising households most at risk. There were also a small number of comments about the time it can take to obtain approval under building regulations or the time it would take to legislate for the minimum standard.

195. A smaller number of these respondents, mainly in the lettings / residential lettings / property management sub-group and some individuals felt that one year would be a more suitable time period; a small number of others noted that this should be done as quickly as possible but did not stipulate a specific timescale.

196. Again there were some concerns over the availability of qualified tradespeople or the potential for price increases among tradespeople due to increased demand; and some queries as to whether the market has sufficient capacity to meet increased demand.

Timetable for owner occupiers and social landlords

Q12: Do you think that the timetable should be the same for both owner occupiers and social landlords?

Table 22: Question 12

	Yes	No	Don't know	No reply
Housing Association (17)	12	2	2	1
Local Authority (13)	8	3	2	-
Lettings / residential lettings / property management (7)	5	1	-	1
Residents association / tenant participation (7)	6	1	-	-
Fire risk / Safety consultant (6)	5	-	-	1
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	8	2	-	3
Individuals (59)	38	13	6	2
Total (122)	82	22	10	8

197. As Table 22 demonstrates, a large majority of respondents were in favour of a timetable that is the same for both owner occupiers and social landlords, with 82 in agreement and 22 disagreeing.

198. Respondents were invited to explain their answer and 66, across all sub-groups commented. The key comment emerging from those in agreement with this proposal was that there is a need to ensure the safety of all and that this would provide a level playing field. As an organisation in the 'other' sub-group commented:

"Yes, [we] believe the timetable should be the same for both owner occupiers and social landlords to comply with a new minimum standard, based on the principle that everyone should have the same entitlement and right to a safe home regardless of tenure".

199. A small number of respondents, mostly individuals, suggested that this work should be completed in a shorter timescale.

200. There were concerns from a number of respondents, and these included:

• How this would be implemented / enforced.
• A need for more information as to what type of tenure poses the greatest risk of having domestic fires, or that this should be based on risk assessments.
• The availability of alarms and contractors; if there is a short timescale, this could serve to push up costs.
• A need to consider the risk, investment plans and likely costs in each sector.
• A need for a national information campaign to inform all property owners and social landlords.

201. The relatively small number of respondents in disagreement with this proposal and who felt that a longer timescale would be needed for social landlords, focused on the scale of work that would be required by social landlords, once again with suggestions that any work should be carried out in line with planned maintenance. A small number of these respondents also pointed out that properties owned by social landlords will already comply with the Scottish Social Housing Charter and be monitored by the Scottish Housing Regulator.

202. In relation to the owner occupied sector, some respondents in disagreement with this proposal felt that a two year timescale is suitable given that owner occupiers will not have the same number of properties to comply with a standard, with a small number suggesting a shorter timescale for this sector. Once again, a number of respondents focused on the difficulties of enforcing this among owner occupiers, with some suggestions that this could be enforceable at point of sale.

203. A small number of respondents felt that mixed tenure properties should have the same timescale applied because of the risk to all residents.

Compliance in Social Housing

Q13: Do you think existing enforcement routes are sufficient for the social housing sector?

Table 23: Question 13

	Yes	No	Don't know	No reply
Housing Association (17)	13	3	-	1
Local Authority (13)	10	2	1	-
Lettings / residential lettings / property management (7)	1	1	4	1
Residents association / tenant participation (7)	6	1	-	-
Fire risk / Safety consultant (6)	1	2	3	-
Other ( e.g. charities / health / professional organisations / manufacturer) (13)	4	2	5	2
Individuals (59)	24	12	18	5
Total (122)	59	23	31	9

204. Table 23 shows that while a greater number of respondents agreed (59) than disagreed (23) that existing enforcement routes are sufficient for the social housing sector, a significant number (31) provided an answer of 'don't know' to this question and a further 9 respondents did not reply.

205. Respondents were invited to explain their answer and 61 took the opportunity to comment. Many of those agreed that the existing enforcement route is sufficient or that it is established as the primary route for assessing condition and services quality in the social housing sector.

206. A very small number of respondents noted concerns over whether the Scottish Housing Regulator ( SHR) would have the resources to take on additional responsibility.

207. Some respondents, mainly housing associations or those in the residents association / tenant participation sub-group suggested that there needs to be a question on the annual return ( ARC) to show compliance with the standard, although a very small number of respondents felt that the SHR will need to have robust systems to check on the information provided and / or to carry out site visits to verify performance and ensure compliance with the standard.

208. Of the smaller number who disagreed, there were some concerns over how to ensure the robustness of enforcement measures and ensure that all standards are consistently met across the social housing sector.

209. Small numbers of respondents also queried how this would be enforced in the private rented and owner occupied sectors or how mixed tenure blocks would comply with the standard.

210. A very small number of respondents noted, "if we are working towards a common housing standard we consider that there should be a common route of redress i.e. tenants in the social rented sector should also have access to the First-tier Tribunal in the same way that PRS tenants do".

211. There were also a very small number of suggestions that there needs to be better enforcement by the SHR than at present.

Q13a: If not, what else do you think is needed to enforce a new standard in social housing? Please also tell us what additional support is needed, for example training, advice or guidance.

212. Thirty-seven respondents provided commentary at this question, a number of whom reiterated the need for training, advice and guidance to be provided. Guidance was cited most frequently, with respondents acknowledging the importance of consistency of application and enforcement and setting out the requirements for compliance and reporting. There were also very small mentions for:

• More staff or additional inspectorate staff in local authorities.
• A publicity campaign to increase awareness of requirements.

213. A small number of respondents referred in some way to enforcement, with comments that the standard needs to be set and enforced or that the Regulator must enforce the standard.

214. There were very small numbers of suggestions for the new standard to be applied under existing fire legislation and some references to the need for this to be the responsibility of the SFRS.

Compliance in Owner Occupied Housing

Q14: Do you have any views on the most effective approaches to encouraging compliance with a minimum standard for fire and smoke alarms in the owner occupied sector?

215. Ninety-seven respondents opted to provide commentary in response to this question, with some endorsing the measures outlined in the consultation paper.

216. Many of those answering this question offered support for the various measures outlined in the consultation paper, with evidence of compliance at point of sale being the most popular measure. That said, there were some queries over whether this would be binding or that it would take a long time to ensure there are alarms in all owner occupied properties if there is reliance on this approach.

217. There was also support for discounts via insurance policies or for the fitting of alarms to be a condition of an insurance policy, although a small number of respondents queried how willing the insurance companies would be to apply such a condition.

218. There were also suggestions from a small number of respondents for additional measures that could be considered. These included

• When a building warrant is applied for (suggested by local authorities).
• As a condition of mortgage approval.
• To be incorporated in council tax payments.
• During annual gas / electrical checks (suggested primarily by individuals).

219. Some respondents suggested education, marketing or advertising campaigns to increase awareness of the minimum standard. A small number of respondents suggested that there is a need to offer advice or guidance rather than enforcement.

220. There were also suggestions for some form of financial incentive to encourage owner occupiers to adopt a new standard. These included grants, loans, and subsidies. Conversely, there were also a small number of suggestions that financial penalties should be imposed for non-compliance.

221. A number of respondents commented specifically on enforcement of the minimum standard, with many of these noting the challenges of enforcement and the need for an enforcement regime. A small number of respondents felt this should focus on flatted properties where failure to provide alarms could increase the risk of danger to other occupants.

222. There were a few suggestions as to who should be responsible for enforcing the standard, with most respondents focusing on local authorities, although some noted that local authorities would need increased enforcement powers or that they are reluctant to use their enforcement powers. A very small number of respondents suggested this responsibility could lie with the fire service or come under landlord legislation. A small number of respondents also doubted whether owner occupiers would comply with this standard.

223. A small number of respondents felt this minimum standard should not be imposed on owner occupiers.

224. One local authority noted:

"The council agrees that there does not appear to be a single measure that can achieve compliance across all owner occupied homes. Therefore, it will be necessary to work with the Scottish Government, other partners and stakeholders to consider a range of measures that can contribute towards raising the level of compliance. In the meantime, further consideration should be given to awareness raising, information and funding options for private sector housing".