Fire safety in high rise domestic buildings: analysis of consultation responses

7. Impact Assessments

7.1 Business and Regulatory Impact Assessment (BRIA)

Question 46. Please give information and views on any business impacts you consider the Fire Safety in Existing High-Rise Domestic Buildings guidance might have.

There were 19 responses to this question; 2 individual and 17 from organisations.

From the comments there we two main business impacts highlighted;

• Cost
• Resource

Cost was raised multiple times due to the new guidance requiring checks, assessments, training, staff. One organisation highlighted however that the benefit would be fewer fires which in turn would result in cost savings.

Resource wise, organisations mentioned that there may be additional resource required to manage enforcing the guidance for local authorities and to help with landlords tightening up their training and guidance for their tenants.

Timescales to satisfy the guidance had one or two mentions also.

A couple of organisations stated that the guidelines would mean there would be a higher standard of fire safety due to various stakeholders being more engaged and raised levels of competence.

A couple of organisations stated there would be no significant impact due to it just being an update of current guidance.

"I would question whether Housing Associations and Local authorities are allocated sufficient resources to enable them to police HRRB properly and to ensure that they are properly maintained. Given current skills shortages in the construction industry generally are there sufficient numbers of qualified professional / competent persons that can undertake fire risk assessment to the required standard in Scotland?"
Organisation

"Given that the guidance does not introduce any additional requirements and seeks to clarify existing legal obligations and guidance, it should not have a significant financial impact on housing organisations. The emphasis on risk assessment and prevention of fire should help to minimise the risk of damage caused by fires."
Chartered Institute of Housing Scotland

7.2 Equality Impact Assessment (EQIA)

Question 47. Please give information and your views on impacts on groups with protected characteristics as noted above, that implementation of the Fire Safety in High Rise Domestic Buildings guidance might have.

There were 15 responses to this question; 2 individual and 13 from organisations.

Some organisations felt that these measures would not negatively impact these protected groups, especially if applied and administered correctly and provision built into the guidance to cover them.

One organisation highlighted that everyone should be treated equally unless their disability impairs their use of fire prevention measures.

Another organisation mentioned that high rise blocks attract a range of people from differing backgrounds and that provision of support should be available for all within the policy document. It was raised that those whose first language is not English should be included in this.

One organisation went into detail about how the proposals could potentially negatively impact each of the following protected characteristics: race, age, disability/mobility, pregnancy and maternity and specific comments for each group. Their main concerns were that those with protected characteristics may be given irrelevant information or excluded from fire safety measures and provisions proposed to be implemented as a result of using the guidance document. There was also concern that the document would be used in defence of negligence of protected groups.

One individual suggested that owners should be subject to tighter regulation of their properties and should provide information for their tenants e.g. including fire safety, building insurance, gas servicing, waste disposal, dealing with fires.

With regards to creating the policy document, one organisation raised the importance of contacting vulnerable and minority groups to get their input to ensure the guidance is correctly framed and in an accessible format.

Two other organisations also raised the accessibility of the guidance to ensure those who speak other languages can understand it. Concern was raised over those with age related conditions such as Dementia which may inhibit their understanding of the policy. It was also suggested that the document should be available in multiple formats and supported by infographics, video and other media.

A suggestion was raised to phase out the term 'high rise building' and replace it with 'sheltered housing accommodation'.

"Groups representing disabled people should be expressly canvassed so that the guidance is correctly framed and in an accessible format. It would also be useful to do the same from other minority groups to take into account the need for communications across differing languages and cultures."
Fire Projection Association

"Consideration, and amendments to communication methods, should be given to those individuals with disabilities or conditions e.g. age-related conditions such as Dementia that may inhibit their ability to understand and implement the Fire Safety in High Rise Domestic Buildings guidance. Records of individuals with disabilities and conditions that may inhibit their ability to follow the guidance should be maintained by the building owner and communicated to the Scottish Fire and Rescue Service to assist with the information provided to emergency services on the ground. In addition, as there may be many residents who do not have English as their first language, consideration must be given to the delivery of advice by various languages, infographics, video and animation to ensure information is accessible to all."
AXA UK

Question 48. Please provide any further comments you have on the Guidance below.

A further 6 comments were left on the guidance.

It was suggested that it might be useful to have a vulnerable groups register for residents within buildings who may require additional support e.g. mobility issues.

One respondent commended the Scottish Government for making Fire Safety a priority in Scotland especially within densely populated areas.

One of the Local Authorities highlighted that attention should also be paid to the repair and maintenance of 'common parts' of tenemental/ blocks in relation to fire safety measures.

One Federation welcomed strengthening fire safety for high rise domestic buildings however they would like it to also include other housing types such as; low rise domestic buildings, sheltered housing, maisonettes all of which may also be at risk. They suggest for the approach to be used cross country. They also firmly stated that tenant involvement and empowerment is key to strengthening fire safety in high rise domestic buildings

"I'm pleased the Government has addressed this issue and although it might have arisen from the Grenfell tragedy aftermath and we don't have the same incidence of cladding in Scotland, we still have to ensure that Fire Safety is addressed in these densely populated properties - well done and may the good work so far bring good outcomes for all in the future."
Individual tenant

"We would suggest a register be kept for those people within the protected groups who have additional needs eg a register kept of all residents within buildings who have a mobility issue
Local Authority