Fire safety guidance - existing high rise domestic buildings and specialised housing and similar premises: impact and effectiveness

Executive summary

Introduction

Policy context

A Scottish Government Ministerial Working Group on Building and Fire Safety (MWG) was set-up in June following the Grenfell tragedy in 2017, to ensure that Scottish buildings were safe. The MWG's established a fire safety regime review for high-rise domestic buildings (those over 18m) in Scotland. In line with the MWG's recommendations the guidance document Practical Fire Safety Guidance for Existing High Rise Domestic Buildings was produced in December 2019 to provide practical fire safety advice on how to prevent fires and reduce the risks from fires. This did not introduce any new statutory requirements but brought together best practice in a single guidance document.

In addition, to ensure that fire safety guidance for those responsible for managing specialised housing and similar premises was easily accessible, Practical Fire Safety Guidance for Existing Specialised Housing and Simliar Premises was published in January 2020. This guidance aims to strengthen fire safety for people who receive care or support by providing advice on how to prevent fires and reduce the risk from fires. The guidance is designed to support owners, managers and staff in sheltered housing, extra care housing, supported housing and small care homes to minimise fire risk. The guidance may also be of interest to individuals who provide care to people in 'general needs' housing, such as friends, families and in-home carers.

Research aims and objectives

The Scottish Government commissioned an independent evaluation of this fire safety guidance in 2021, to determine whether the guidance in its current form is used by those it is intended for; is helpful; and what may be needed to strengthen it. The key objectives of the research were to:

measure awareness of the guidance and establish the extent to which it is being used;

explore how the guidance is being used, and its effectiveness in supporting implementation of fire safety measures/procedures; and

determine improvements that could be made to the guidance, in terms of format, delivery, content and more generally to strengthen the effectiveness of the fire safety support it provides.

Approach

A mixed method approach was used to collect the evaluation data: depth interviews were conducted and an online survey was undertaken.

Qualitative research: A total of 23 depth interviews were carried out in January to April 2021. These were undertaken online using Zoom/Teams and each lasted up to 90 minutes. The interviews were carried out with a range of housing providers and care providers across Scotland, as well as with representative organisations. A number of the depth interviews were also undertaken with unpaid carers to assess views on the Existing Specialised Housing guidance amongst this secondary audience. The sample of housing and care providers was designed to produce a mix of tenure (local authority, housing association and private sector), provider size (including some of the larger housing providers), and type of housing (high rise housing, specialised).

In addition to the interviews, the research took account of the findings and recommendations from the Housing Support Enabling Unit's fire safety roundtable event held on 10^th March 2021. This event hosted delegates from a broad range of organisations from across the country and the discussion focussed on the Practical Fire Safety Guidance for Existing Specialised Housing.

Quantitative research: An online survey with housing providers and care providers was conducted during March 2021. The questionnaire was designed to address the research objectives and was informed by the ongoing programme of qualitative research. The survey length was estimated at around 15 minutes. A total of 24 responses were received to the survey, a response rate of 24%.

Limitations of the research: The overall samples achieved were smaller than anticipated. This was in part a consequence of the sampling frame being considerably smaller than expected as it contained a large number of duplicates (this reduced the number of high rise contacts from 280 to 70), and in part because a substantial proportion of the contacts were unnamed/generic, which made it difficult to access the right person, especially as during the pandemic people were less likely to have been office-based. Because the base size in the quantitative stage was low, the research findings cannot be extrapolated to the wider population. However, the findings across the study were highly consistent and a clear picture did emerge. The research therefore does facilitate valid and valuable insights and understanding.

Research findings

High rise buildings: fire safety guidance

Awareness: The high rise research participants were almost all aware of the guidance, typically finding out about it from their manager, or from publicity produced by other organisations, such as the Scottish Government, professional organisations and trade bodies. Some senior staff were aware as a consequence of participation in the development of the guidance. This high of level of awareness may not be the norm across the housing sector: one research participant said they had not heard of the guidance prior to the research, another was unaware it had been launched.

Use of the guidance: Most of the high rise research participants were using the guidance. It was mainly being used to ensure a satisfactory standard of fire safety, to update policies and procedures, when undertaking fire safety risk assessments and when undertaking actions in response to fire safety risk assessments. It was also being used to support development of new policies and procedures and to train staff. It was especially valued as a reference resource for staff, as it contained all the key information they need to refer to. For example, some participants said the guidance document plays a useful role during discussions with owners and tenants about the actions required by the fire safety risk assessment, as they are able to easily reference the relevant sections should any query be raised.

Guidance not used: Very few of the high rise research participants had not used the guidance; and those that had not generally expected to use the guidance in the future. The main reasons for not having used the guidance to date were lack of staff resources, lack of awareness, and a concern that the guidance was not relevant to the organisation.

Fire safety risk assessments – approach: All the high rise research participants had a current fire safety risk assessment (FSRA) for at least some of their properties. Indeed, most organisations had been carrying out FSRAs prior to the publication of the Guidance in 2019. The main reasons for carrying out fire safety risk assessments across their high rise properties were: it is good practice in building management/health and safety; to comply with fire reduction strategy/performance indicator; and in response to publication of the Scottish Government guidance.

On the whole, high rise research participants commissioned contractors to undertake all or most of the FSRAs on their behalf. They were especially likely to buy-in specialists skills in assessing complex buildings, such as large multi-storeys, and to draw on consultants when they are short-handed. Those carrying out the assessments were either 3^rd party certified or registered with a professional body.

Fire safety risk assessments – template: High rise research participants generally found the FSRA template provided in the guidance to be helpful. While few had adopted the template – they currently used either a PAS 79 template or their consultants' template – they either had or intended to review their own templates to ensure they cover everything contained within the guidance template.

Some minor modifications to the guidance template were suggested: for example, to include photographs of where action is required, so it is clear where and what the issue is; and provision to undertake the risk assessments floor by floor in multi-storey blocks.

Assessment of the guidance: Most of the high rise research participants considered the guidance for high rise domestic properties and the template for fire safety risk assessments to be valuable. The research participants who had used the guidance considered it to be clear and concise. The aspects of the guidance they were most likely to rate as very good were the guidance having comprehensive coverage of relevant aspects of fire safety, clarity as to which organisations and buildings the guidance applies, and provision of tools to support the guidance. They were less likely to rate guidance on who should complete the risk assessments, and on how to complete the risk assessments as very good.

Barriers to using the guidance: Few barriers to using or implementing the guidance were reported. Where barriers were encountered, they included implementing the guidance during the pandemic; lack of time; lack of staff resources; securing funding for any major works identified by the risk assessments for social landlords; and securing buy-in from private owners/landlords for works in mixed/private sector blocks.

Improvements to the guidance: Generally high rise research participants stressed that the guidance was valuable and helpful; suggested changes were intended to make the guidance more useful. Suggested improvements included increased communication of the guidance and updates to social landlords and building managers/factors; an information leaflet for residents about the guidance and residents' responsibilities; and a fully searchable version of the guidance, e.g. an app or a version that would work on an iPad.

Specialised housing and similar properties: fire safety guidance

Awareness: The specialised housing participants were almost all aware of the Practical Fire Safety Guidance for Existing Specialised Housing and Similar Premises, typically finding out through formal channels at work or from a Scottish Government communication.

Use of the guidance: Most of the specialised housing participants had used the guidance. It was mainly being used to ensure a satisfactory standard of fire safety, to update policies and procedures, when conducting fire safety risk assessments, and when conducting person-centred risk assessments. It was also being used when undertaking actions in response to fire safety risk assessments, to support development of new policies and procedures, and to train staff.

Guidance not used: A small proportion of the specialised housing participants were aware of the guidance but were not using it. Most did expect to use it at some point in the future. The main reasons for not having implemented the guidance were largely time-related: lack of time to read the guidance and being focused on dealing with the coronavirus pandemic. Some also mentioned that their existing fire safety measures are robust, and some that the guidance was not sufficiently clear as to who should be conducting the person-centred FSRA.

Fire safety risk assessments: The specialised housing guidance contains two risk assessments: a premises-based fire safety risk assessment and a person-centred fire safety risk assessment.

Premises-based fire safety risk assessments – approach: All the specialised housing research participants had a current fire safety risk assessment (FSRA) for at least some of their relevant properties. Almost all had been carrying out FSRAs prior to the publication of the guidance in 2020. The main reasons for carrying out fire safety risk assessments across their properties were: it is good practice in building management/health and safety; to comply with fire reduction strategy/performance indicator; and in response to publication of the Scottish Government guidance.

The premises-based FSRAs were carried out by external consultants and in-house staff. The depth interviews suggest that in-house health and safety teams play an important role in ensuring risks are assessed robustly, required actions are identified and recorded clearly, and follow-through activities are monitored. Consultants may be brought in to undertake risk assessments to supplement in-house resources and skills, to audit key developments, and/or to provide external validation.

Premises-based fire safety risk assessments – template: Almost all the specialised housing research participants had reviewed the premises-based risk assessment template provided in the guidance. A small number were using it, in whole or in part, to conduct their risk assessments. The others continued to use other approaches, typically a PAS 79 template or their consultant's template.

Person-centred fire safety risk assessments – approach: Around half of the specialised housing research participants currently carry out person-centred FSRAs. However, it is appreciated that the guidance was published just a few weeks before Scotland went into lockdown, and most housing and care providers have not operated normally since that time.

The person-centred FSRAs were generally carried out in-house, either by a welfare officer or by a housing officer. In some teams, the health and safety officer was also involved. No-one mentioned risk assessments being undertaken by informal carers or by friends and family who provide care and support.

Person-centred fire safety risk assessments – template: Many of the specialised housing research participants had reviewed the person-centred FSRA template provided in the guidance. A few had already adopted it for their risk assessments, while others used a different approach, either their own templates or personal emergency evacuation plans (PEEPs).

Barriers to implementing the person-centred FSRAs: A number of issues were raised in relation to the person–centred FSRA. Some specialised housing research participants were concerned about resourcing the risk assessments, especially in large organisations, both in terms of staff to undertake the assessments and funding resultant actions; while some raised concerns about how organisations will collate the information if the assessments were (increasingly) undertaken by different people/agencies. The main concerns related to the process for determining where responsibility lies for undertaking the assessment (and implementing actions) when multiple agencies are involved; and how to resolve cases when agencies have no right of access to a vulnerable person's home to undertake an assessment.

Assessment of the guidance: Most of the specialised housing research participants considered the guidance for existing specialised housing and the templates for the risk assessments to be valuable. The key aspects of the guidance that research participants were most likely to rate as very good were the clarity of the buildings and organisations to which the guidance applies; the provision of practical tools to support the guidance; comprehensive coverage of relevant aspects of fire safety; and the guidance being user-friendly. Almost none of the respondents rated guidance on who should complete the risk assessments as very good.

Barriers to using the guidance: Only a few of the specialised housing research participants mentioned they were not experiencing barriers to using or implementing the guidance. Issues encountered related to implementing the guidance during the pandemic; lack of staff resources to undertake the person-centred risk assessments; and issues around authority/legitimacy of carrying out person-centred risk assessments for people living in low dependency housing.

Improvements to the guidance: General improvements to the guidance suggested included more training and workshops, provision of a training template so that organisations have a clearer idea of what is required, and an external audit of the completed template to provide reassurance to organisations that they are following good practice.

Around half of the specialised housing respondents thought that further support was required to implement the person-centred FSRA. This could include clearer guidance on who is responsible for completing the assessment, and more tools for completing the template – such as FAQs and sample templates.

Unpaid carers: fire safety guidance for existing specialised housing and similar properties:

As well as research with housing and care providers and representative bodies, the research assembled the views of a small sample of unpaid carers.

Awareness: None of the unpaid carers interviewed had been aware of the fire safety guidance for existing specialised housing and similar properties before being contacted for the interview.

Person-centred FSRA – guidance: All found the guidance extremely interesting and informative. Some mentioned that, while they were already alert to potential fire risks, the guidance had either reminded them to check these more thoroughly and/or had identified other risks that they should consider. Such additional issues included risks from emollient creams and the need for evacuation plans. However, many of the unpaid carers did not find the guidance document user-friendly or concise. They concluded – correctly – it was aimed at professionals rather than laypeople.

Person-centred FSRA – template: Most of the unpaid carers interviewed said they felt able to undertake the risk assessment for the person they care for. While they felt the guidance document was a little wordy, the template itself was straightforward and made sense. They considered they would be able to work through most of the sections in the template fairly quickly, as most of the risk factors would not apply to their relative – in each case, only two or three of the sections appeared relevant (these sections differed between respondents).

Some carers raised the issue of who should be responsible for undertaking the assessment for people who do not have a carer. One unpaid carer, whose father lives in sheltered housing, was concerned that his father could be at risk from fire in neighbouring properties.

Legislative requirement

In England and Wales a duty holder is legally required to carry out a premises-based fire safety risk assessment of communal areas in domestic premises, such as common stairs and passageways. New legislation is expected to clarify that flat front doors, building structure and external walls should form part of this. Scotland has different fire safety and housing legislation. It is considered good practice to undertake a fire safety risk assessment at present, but there is no legal requirement.

Almost all the study research participants supported further consideration of a move towards making it a legal requirement to carry out premises-based fire safety risk assessments in common areas, as is the case in England and Wales. Research participants considered this would serve to prioritise fire safety; require housing providers to adopt high standards of fire safety within their buildings; and empower landlords/factors to take action in response to risk assessments.

Some concerns were raised around the cost of carrying out the FSRAs, the cost of implementing the actions identified through the FSRAs, and obtaining permission to carry out work/recovering costs from private owners.

Conclusions

Overall, research participants were very welcoming of the both the high rise and the specialised housing guidance. Housing and care providers considered both to be helpful, clear and user-friendly; and found the supporting materials comprehensive and extremely useful. Suggestions for change that were made, especially those relating to premises-based risk assessments, tended to be minor and designed to improve rather than correct.

Unpaid carers also welcomed the guidance, although they recognised it was aimed at professionals rather than lay-people. They found the content relevant and informative, if rather inaccessible; and the template extremely useful.

Recommendations:

Promote the high rise guidance and the specialised housing guidance across social housing, housing management, care and health sectors and unpaid carers, drawing on opportunities to work with/through key partners, and to take part in conferences/seminars

Scottish Government to progress planned work designed to improve fire safety in common areas. Scottish Government to consider if new fire safety legislation for common areas is required. Include further guidance on managing works in common areas in mixed tenure/private sector blocks within the guidance documents

Consider a review of the person-centred fire safety risk assessment materials, including providing information on who could be responsible (for assessment/ actions/ monitoring), good practice on determining responsibilities, and consideration of whether arrangements for imposing/ arbitrating responsibility are required

Consider developing a pack of key worked example templates