Fire and smoke alarms in Scottish homes: consultation

Part Three: Options to Extend Standards

28. The Scottish Government’s view is that the standard currently applied to private rented housing represents the current best practice. We therefore consider that the most appropriate option to improve standards for fire and smoke alarms is to extend this standard to all tenures.

29. In this part we consider the following options:

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

30. Some sections in this part of the consultation seek views on making changes to standards only for some housing. It would be helpful to have your views on these changes even if you support the application of a new standard to all housing.

Social Housing (Option A)

31. The SHQS could be amended to include a more demanding standard for fire and smoke alarms in place of the existing element 44. Changes to the standard for social housing could have a much bigger impact on some landlords than others, depending on previous improvements.

Question 1: Do you think that there should be a new minimum standard for fire and smoke detectors in social rented housing? Yes/no/don’t know - Please explain your answer.

1 (a) If yes, do you think this should be based on the standard currently applying to private rented property? (see paragraph 19)

1 (b) Alternatively, do you think that some other standard should apply to social rented housing? If so, please give details.

Tenements and Flats ^[24]

32. In this section we are seeking views on whether there should be a new minimum standard in:

• All tenements and flats (option B); or
• Flats in high rise buildings (option C).

33. The Common Housing Quality Standard Forum noted that the impact of a large fire in a tenement flat is likely to affect other flats in the same building, and therefore it may be appropriate to introduce a standard for smoke alarms for owners in tenements, because of the potential to harm other occupiers in a building if a fire is not detected promptly. ^[25]

34. A new standard for flats could also be limited in scope to cover only high-rise housing. We define this as housing blocks that are higher than 18 metres. ^[26]

Question 2: Do you think that individual flats should all be subject to the same minimum standards, regardless of tenure, in all tenements and blocks, regardless of height? Yes/no/don’t know - Please explain your answer.

2 (a) Alternatively, do you think that individual flats should all be subject to the same minimum standards, regardless of tenure, only within tenements and blocks higher than 18 metres? Yes/no/don’t know. Please explain your answer.

2 (b) If you are in favour of a standard for flats, whether in all buildings or only those over 18 metres tall, do you think this should be based on the standard currently applying to private rented property?

2 (c) Alternatively, do you think that some other standard should apply? If so, please give details.

All Housing (option D)

35. We are also seeking views on the option to apply a minimum standard for fire and smoke alarms to all housing. This could be done, for example, by amending the statutory tolerable standard. ^[27] This is a condemnatory standard – any house that is below tolerable standard is not acceptable as living accommodation.

Question 3: Do you think that there should be a common new minimum standard for fire and smoke detectors in all housing, regardless of tenure? Yes/no/don’t know - Please explain your answer.

3 (a) If yes, do you think this should be based on the standard currently applying to private rented property?

3 (b) Alternatively, do you think that some other standard should apply? If so, please give details.