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

3. Research findings: Existing high rise domestic buildings

This chapter addresses the objectives of the evaluation of the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings: to establish the level of awareness and use of fire safety guidance; the benefits of the guidance for effective fire safety; and any gaps or weaknesses in it and potential areas for improvement. It draws both on the qualitative and quantitative data.

Chapter 3 – Key points

Research participants were almost all aware of the guidance, typically 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.

Most had carried out fire safety risk assessments prior to the publication of the guidance. However, the guidance has prompted a number of organisations to start conducting fire safety risk assessments.

The template provided in the guidance is helpful. Typically respondents use the PAS 79 template or their consultants’ template. However, most either have, or intend to, review these in light of the guidance.

Some minor modifications to the templates were suggested, for example, including the ability to add photographs to aid identification and assist prioritisation, and provision to undertake the risk assessment floor by floor.

There was a high level of support for the guidance. Users found it clear and concise, and described it as a valuable reference document.

Potential barriers to using the guidance were securing funding for major works identified as being needed by the risk assessments for social landlords; and securing buy-in from private owners/landlords for works in mixed/private sector blocks.

3.1 Awareness

The research participants were, on the whole, aware of the guidance for existing high rise domestic buildings.

All of those responding to the survey were aware of the guidance, and all but one had read at least some of it. However, we might expect those that responded have had greater interest and awareness in the subject, than the general population.

Table 3.1: Awareness of the guidance

Q1. Before taking part in this survey today, were you aware of the Practical Fire Safety Guidance For Existing High Rise Domestic Buildings?
	Total
Aware of and read it (some, most or all)	12
Aware of, but not read it	1
Not aware of it	-
Base: All high rise respondents	13

Most survey respondents became aware of the guidance through formal channels at work, with other sources of awareness including fire risk assessment consultants, colleagues, industry bodies, trade press, and Scottish Government. Around half of the survey respondents had attended a workshop, meeting or seminar about the guidance. These were organised by the respondent's organisation, industry bodies and by Scottish Government.

Table 3.2: How respondents became aware of the guidance

Q2. How did you become aware of the Fire Safety Guidance For High Rise Domestic Buildings? Please select all that apply
	Mentions
Through formal channels at work:	9
From the consultant or fire officer (SFRS) who inspects our buildings:	4
Told about it by a colleague	3
From an industry body	3
In the media, trade press:	3
From a Scottish Government communication	3
Someone in my organisation who was involved in the development of the guidance	3
I was involved in the development of the guidance	1
Searching Scottish Government website	1
Base: All high rise respondents	13

The depth interviews provided more detail. The largest housing providers and umbrella organisations were aware that the guidance was being prepared, either through involvement with the Ministerial Working Group (participation in or providing evidence to) or responding to the consultation on the draft of the guidance. The Grenfell tragedy had raised awareness of fire safety issues, and actioning fire safety in high rise buildings was a live issue across the sector.

"One of our Fire Safety team was on the Ministerial Working Group, so we had quite close contact during the development of the guidance. We provided quite a lot of evidence through the Ministerial Working Group on our operating model." - Depth interview, High Rise

Consultants engaged to undertake fire risk assessments raised their clients' awareness of how the emerging English guidance was already being used to inform fire risk assessment methodology, and discussed the possibility/timescale for the publication of Scottish guidance.

"We had been waiting for it. We had had a fire risk assessment done by an English consultant in the summer of 2019 who had mentioned that there wasn't anything specific to Scotland, but it was coming. His risk assessment was done on the basis of the English guidance, which I think was more prescriptive than the Scottish guidance. So when the Scottish guidance came out we'd obviously been watching out for this coming." - Depth interview, High Rise

The other key source of information and advice was networking and professional bodies; circulars from organisations such as Scottish Federation of Housing Associations (SFHA), Chartered Institute of Housing (CIH), Coalition of Care and Support Providers in Scotland (CCPS), and the Institute of Fire Safety Managers (IFSM).

However, this level of awareness may not have been the norm across the housing sector. One participant, a building manager, had not heard of the guidance, nor had his manager:

"I became aware of it [the guidance] when I was approached by you guys to take part in the research. I took it to my manager… She's the operations manager for Scotland, very experienced in factoring and she didn't know about this either. The message hasn't got out." - Depth interview, High Rise

Another participant, despite being engaged during the development of the guidance, including responding to the consultation, only found out that the guidance had been launched 'by chance'.

"I stumbled across it on Twitter, there was no formal presentation that I was aware of." - Depth interview, High Rise

As will be discussed more fully below (Section 3.6) several participants suggested that increased communications and publicity of the guidance would enhance its profile among housing sector professionals and among residents living in high rise buildings.

3.2 Use of the guidance

Most (9) of the high rise survey respondents had used the guidance. The main uses were 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.

Table 3.3: Use of the guidance

Q5. Have you or are you currently using the fire safety guidance for high rise domestic buildings in any way? For example, this could be to review current procedures and policies, training of staff, implementing new procedures, or to undertake risk assessments.
	Total
Yes	9
No	2
Unsure	2
Base: All high rise respondents	13

Table 3.4: Use being made of the guidance

Q6. How are you using the guidance? Please select all that apply
	Mentions
To ensure we achieve a satisfactory standard of fire safety	9
To update policies and procedures	7
When undertaking action in response to risk assessments	7
When conducting fire safety risk assessments on our buildings	6
To create new policies or procedures	5
To train staff and make staff aware of fire safety issues	5
Planning servicing & maintenance activities and upgrade works	1
To support engagement with residents	1
Base: All using high rise guidance	9

The depth interviews allow us to see how this works in practice. For example, some of the organisations had taken the launch of the guidance as an opportunity to review of policies and practice, to ensure they were in line with the best practice set out in the guidance, and make best use of the resource contained within the guidance.

"One of the first things I had been asked to do was to review that documentation for the multi-storeys. And look at what impact that [the guidance] had, and what changes we needed to put in place. So I put together a report for that. I ran through that at one of our housing management team meetings." - Depth interview, High Rise

"I think it's really just been an evolution of working together with the Scottish Fire and Rescue Service. The higher overview of anything that's come out of that, then going on to the health and safety action plan and being addressed from there." - Depth interview, High Rise

One participant was a full member of the Employers in Voluntary Housing (EVH) group of housing associations. One of EVH's members' services is the landlord health and safety control manual, which covers fire safety, gas safety, electrical, etc. Their usual practice is to review this from the local perspective. They have undertaken a further review following the publication of the guidance:

"We take the view that although the manual is written, it's generic, so we have to look at it and make it relevant to us. We review all our key health and safety policies annually, even if it's just having a quick glance over and making sure we're comfortable with them. When we have been reviewing the policy within the manual this time, we've used the guidance documents to make sure that we're doing what we should be doing." - Depth interview, High Rise

Others were reasonably comfortable with the approach that is in place within their organisation. They had reviewed the guidance and were using it to support their existing policy, and operational and investment approaches.

"We have not used it very much. Our fire risk assessments have been in place for several years now. Each time we do them again, it's a case of picking up a few new things that may have changed, or been missed, or where the legislation has changed. The guidance can be really helpful for supporting us to make these changes." - Depth interview, High Rise

The main benefits of the guidance for participants were:

A reference tool for staff: The guidance stores the key documentation they will need to refer to, both on a daily basis and on an ad hoc basis, in a single document.

Information to support investment decisions and funding bids: Generally, the guidance provided the rationale for investment proposals. It also supported the case for proposals when taken to management committees or funders.

"There's nothing better for us than being able to reflect the Scottish Government guidance to reports to the management board. They talk about a blue light journey; a fire engine costs £3000 every time it leaves the station to come to a fire. Here we can almost look at a cost-benefit analysis of reducing accidental dwelling fires, cheaper insurance. It's good when we're trying to encourage partners or investment vehicles to provide funding if we can show that we adhere to and exceed government guidance and the outcome of that is reduced accidental dwelling fires, reduced fatalities, reduced near misses and reduced accidents." - Depth interview, High Rise

Information to support housing management: Some participants stressed the useful role the guidance plays in supporting the actions required by the fire safety risk assessment; in particular, being able to easily reference the guidance pre-emptively in discussions with residents or owners. Issues mentioned most often were combustible materials in common areas and obstructions in common areas (ranging from bookcases and plant pots, to bikes and rubbish). For example, for one organisation the guidance is providing a really useful reference when reviewing the fire risk assessments, and when explaining processes or decisions to staff or residents:

"It will help with owner occupiers if it's something they are reluctant to change – or they need to spend money on – having the guidance to demonstrate why it needs to be done is really helpful. The same with tenants, if a behaviour needs to change, having the guidance to back us up when we are explaining why, for instance, they can't park their bikes in the hallway, even if there is no room in their flat." - Depth interview, High Rise

3.3 Guidance not used

Very few of the organisations in the research had not used the guidance; only two of those surveyed online had not used it yet. Both said they expected to use the guidance in the future (that they 'possibly would'). The reasons given for not having used the guidance thus far were that they did not have the staff resource to put the guidance into place and the guidance is not relevant to the organisation.

One of the organisations interviewed for the qualitative phase of the research had not used the guidance yet. This was the organisation unaware of the guidance until contacted for interview. It would be fair to say the participant was an enthusiastic convert to the guidance. They felt it sets out exactly why the fire safety risk assessments are undertaken and why residents should comply with the actions.

"I would love to send this to all my high-rise owners and tenants. And I probably will - to say this is what we're working for, this is why we're doing a health and safety review. I'm giving that [the guidance] to each individual, or quoting some of these elements and giving them the webpage, so I can say I'd like to draw your attention to this, this, this…" - Depth interview, High Rise

3.4 Fire Safety Risk Assessment - approach

All survey respondents had Fire Safety Risk Assessments (FSRAs) in place for at least some of their relevant properties, and most had FSRAs in place for all relevant properties.

Almost all (11) of the survey respondents had been carrying out premises-based fire safety risk assessments prior to the publication of the Scottish Government guidance in 2019. Just two respondents started carrying out premises-based fire safety risk assessments following the publication of the Scottish Government guidance.

Table 3.5: Fire Safety Risk Assessments

Q9. Do you have current Fire Safety Risk Assessments which have been undertaken or reviewed in the last year for your high rise properties?
	Total
For all properties	10
For the majority of properties	-
For some properties	3
For no properties	-
Base: All high rise respondents	13

The main reasons that survey respondents gave for carrying out fire safety risk assessments across their high rise properties were:

Good practice in building management/H&S : 10 mentions

Fire reduction strategy/performance indicator : 5 mentions

Publication of the Scottish Government guidance : 2 mentions

Fire (Scotland) Act 2005 : 1 mention

Grenfell Tower fire : 1 mention

The depth interviews support these findings, with participants generally having been undertaking regular fire safety risk assessments in their high rise stock prior to the introduction of the guidance.

"We do our fire risk assessments for the high rise blocks annually, and we do refer back to it because there are a number of actions come out of that fire risk assessment each year." - Depth interview, High Rise

"We have been carrying out FSRAs across our properties for several years." - Depth interview, High Rise

"Within a month of Grenfell back in June 17, we effectively created our first fire prevention mitigation framework, which was in the process of being renewed, so it was an initial three-year document. It worked on four different areas - it looked at partnerships, it looked at prevention, it looked at products and services and performance….We adopt PAS 79 in terms of a methodology for fire risk assessment….And we've got something called a fire precaution logbook as well. So, within the guidance where you've got recommendations for daily checks, testing of your risers and alarm systems, we put that into a logbook, a fire safety logbook. So, all our premises have what we call a fire precaution logbook. So, daily checks, weekly checks, testing of alarms, the maintenance from contractors, all of that is recorded in the fire precaution logbook." - Depth interview, High Rise

One participant, who worked in a management company, which was a subsidiary of a large RSL, commented they had only recently been providing fire safety risk assessments across the stock. Previously, the RSL had undertaken the risk assessments in-house, however, in order to improve the quality and standard of service, a specialist division had been established to be responsible for all health and safety work, including fire safety risk assessments.

Who carries out the FSRA?

Typically the FSRAs are carried out by external consultants. Survey respondents indicated that external consultants were responsible for conducting all the FSRAs in seven organisations, and undertook some of the assessments in a further four organisations. Just two organisations said they were fully responsible for conducting all the FSRAs.

Table 3.6: Who carries out the FSRA?

Q12. Who carries out the Fire Safety Risk Assessment in your high rise properties?
	Total
External consultant	7
Mix of in-house and external consultants	4
In-house	2
Base: All high rise respondents	13

In all but one case (where the respondent indicated they were unsure) external assessors engaged in undertaking FSRAs are either 3^rd party certified or registered with a professional body.

This was supported by the depth interviews. Almost all used external consultants to undertake the fire safety risk assessments. This enables them to buy in skills from a range of specialists, such as ex-fire officers and architects, to undertake the assessments on their different types of properties – for example, mid-rise, multi-storey and specialist housing. Even organisations that are competent to undertake some/most of the risk assessments themselves by having the necessary knowledge, skills, experience and behaviours in-house, may consider there are some building types where they require the services of consultants.

"The consultants we use include an ex-fire officer who undertakes the risk assessment in the high rise buildings as he is familiar with issues related to stairwells, smoke corridors, ladder access, and so on." - Depth interview, High Rise

"Risk assessments are carried out under contract by a licenced contractor, with required actions passed to the technical team/investment team for action. The approach draws on best practice within the industry across the UK." - Depth interview, High Rise

Two of the large organisations we spoke with had the resources to establish (as well as the estate to warrant) an in-house specialist team to conduct the fire safety risk assessments. The staff within these teams were typically ex-fire officers, who were trained in line with current guidance and legislation (English and Scottish).

"By and large, the majority of risk assessments are done by our own staff who are trained to PAS 79 standard. So, they use the PAS 79 methodology, which is a recognised standard certainly among Scottish Fire and Rescue colleagues and some of the enforcement teams within Scottish Fire and Rescue. There may be occasions when we may use consultants just because of capacity issues." - Depth interview, High Rise

Fire safety risk assessment - template

Almost all of the survey respondents had looked at the risk assessment template within the guidance, and two had used the template to adapt or update their existing in-house/consultant's risk assessment approach. Others used a different approach, typically PAS 79 or say they do not do not use a template-based approach at all.

This was supported by the depth interviews. Participants have been content to use their consultant's reporting template for the risk assessment; these have provided a clear reporting framework, and have identified items requiring action and investment. There was a general view that the templates in use are fairly similar to the one contained in the guidance. However, there was often an intention to review the templates being used to ensure they do cover everything that is contained within the guidance template.

Table 3.7: The FSRA template

Q14. Have you read through the fire safety risk assessment template in the fire safety guidance for high rise domestic buildings?
Read the template	Total
Yes	11
No	1
Base: All aware of high rise guidance	12
Q15. Have you used the fire safety risk assessment template for high rise buildings in any way within your organisation?
Used the template
No – we currently use PAS 79 instead	4
No – we use a different template (not PAS 79 or SG)	2
No – we do not currently use a template	2
Yes - we have used the template to adapt or update our existing in-house/consultant's risk assessment approach	2
Unsure	1
Base: All who have read the high rise template	11

"We don't have a risk assessment template. We've had an external company in to do our risk assessments. So they have a template that they utilise and they fill in. Their template is very similar (to the guidance template). But that's one of the things on my action plan. To review the template and see how that compares with what we've done in the past to see if there's anything that we're missing." - Depth interview, High Rise

In some cases the participants used PAS 79 (either in-house or through their consultants). This was considered similar to the template provided in the guidance, but has the benefit of being a recognised standard, which is well known to Scottish Fire and Rescue Service (SFRS) enforcement officers.

"We would recognise the template as been very close to PAS 79 but it doesn't come out and say that. The timescales and risk ratings and things like that are pretty much the same." - Depth interview, High Rise

While the basic structure and elements covered in local templates were broadly the same, there were a few points of difference.

Several of the participants included the use of photographs where action/ investment is required in their templates, and felt these would be a helpful addition to the guidance template. These are especially valuable in large organisations, as an aid to identify which building is being referred to, and in supplementing the description of the fault/issue.

"Photographs, our consultant includes photographs, which are quite helpful to try and identify, or to actually see visually what he's talking about. And also sometimes given the size of the building, just to narrow down where specifically he's looking at. And I think it's also quite good to have the before and after pictures if you like as well." - Depth interview, High Rise

Some participants also noted their templates don't simply note the presence of records/items on the template – for example if testing and maintenance records are complete – they record evidence that this is so (for example, date and reference of certificates which can be checked).

Some participants noted that their approach involved risk assessment floor by floor within the multi storey blocks. This provided more detailed, systematic information from across the stock.

"Our risk assessment feels more structured, if you like. That the risk assessor is going floor by floor and probably answering these questions on each floor that he's looking at in order to be able to report back on specific issues or areas of concern, because I think looking at that it's asking questions which seem general, which if you were to take a 20 storey block, you might have a lot of actions coming out of that. And you might lose actions possibly in the mix of a fairly loose, freehand question." - Depth interview, High Rise

One participant noticed that the guidance template records 'history of fire' within the building. This is not included on the template used by their organisation, and could be extremely relevant.

"I have that situation in one block, which has commercial properties underneath it, including a delivery-only restaurant. It's a purpose-built facility, so it will have been fire rated. But that's quite interesting. Has there been any history of fire? I didn't even think about things like that. That's not a question that's on our health and safety form. There's no column that says has there ever been a fire in this building? That's quite cool." - Depth interview, High Rise

Actions

All the participants sought to prioritise the actions identified in the risk assessment, and were familiar with the approach set out in the guidance. In many cases, the actions that can be addressed in-house by staff or management are normally taken almost immediately, whereas those requiring significant investment, especially when this involves private owners, can take some time to programme through. While risk assessments are undertaken on a property-by-property basis, prioritisation decisions are typically taken across the whole stock or within budget heads (for example for all factored stock/for all specialised housing).

Some participants mentioned that photographs of the issues identified can be helpful in determining relative priorities, as they enabled to staff to have a clearer understanding of the nature and scale of the different issues which need to be resolved across the organisation.

Participants stressed the risk assessment is a snapshot of the situation on the day – things can be different the next day.

"Everything can be fine when the assessment is done, the next day there could be a mattress dumped by the bins!" - Depth interview, High Rise

"So reinforcing that whole structure there is a daily inspection regime from environmental staff. They'll check things like fire door self-closes are working, or bin chutes are operational. External contracts, checking lifts, emergency lighting… there are quarterly checks, annual checks. The fire risk assessment process will be three-yearly. So there are all sorts of safeguards in there." - Depth interview, High Rise

Further guidance or support

None of the survey respondents or the depth interviewees thought that there was anything more that the Scottish Government could do to support them to use the fire safety risk assessment template.

3.5 Assessment of the guidance

Overall views on the guidance

Overall the majority of the survey respondents considered the guidance for high rise domestic properties housing and the template for fire safety risk assessments to be valuable, with the larger proportion considering these to be very valuable.

Survey respondents were also asked to rate key aspects of the guidance. Almost all of the survey respondents who had read the guidance rated each of these aspects good or very good. As the table shows, the aspects of the guidance most often considered very good were the comprehensive coverage, clarity as to which buildings the guidance applies, and provision of tools to support the guidance. Fewer respondents rated the guidance on who should complete the risk assessments, and on how to complete the risk assessments, as very good.

Table 3.8: Overall assessment

Q22. Thinking now about the fire safety guidance for high rise domestic buildings, how valuable would you say the risk assessment template and the guidance has been or will be for your organisation?
	FSRA Template	Guidance
Very valuable	5	8
Quite valuable	4	3
Not very valuable	1	-
Not at all valuable	1	-
Unsure	1	1
Base: all aware of the high rise guidance	12	12

Table 3.9: Assessment of aspects of the guidance

Q7. How would you rate the fire safety guidance for high rise domestic buildings on the following aspects?
	Very good	Total good
Comprehensive coverage of the relevant aspects of fire safety	9	10
Clarity of the organisations and buildings to which the guidance applies	8	10
Provision of practical tools to improve fire safety (e.g. checklists, templates)	8	10
Being user-friendly – the language and layout are easy to follow	7	10
Signposting to further sources of information and advice	6	10
Advice on how to use/implement the guidance	5	10
Guidance on how to complete risk assessments	4	9
Guidance on who should complete risk assessments	3	9
Base: All aware of the high rise guidance	12

These findings were supported by the depth interviews. Participants said they found the guidance helpful, clear and concise; and it usefully brings everything together in one place. Furthermore, it is badged as coming from Scottish Government which gives it authority.

"This is very clear. It's like a one-stop shop. Anything that you need to know about that is all found in one place." - Depth interview, High rise

One stakeholder noted that their membership had not raised any issues with them about the guidance over the last year; which can be interpreted positively:

"I've had no traffic on it since it launched, and that I guess is probably a mark of confidence - it's landed and people have taken account of it and got on with it as best they can, particularly given what the last year has been like." - Depth interview, Stakeholder

Barriers to using the guidance

Around half of the survey respondents who were using the guidance commented that they were not experiencing any difficulties or barriers in using or implementing it. Of the others, the main issues that people had encountered were the challenges of implementing the guidance while responding to the pandemic, and a lack of staff resources.

Table 3.10: Barriers to using the guidance

Q19. Have you experienced any difficulties or barriers in using or implementing the fire safety guidance for high rise buildings? Please select all that apply?
	Mentions
Not experiencing any barriers or problems	5
Organisational focus has been on dealing with coronavirus pandemic for the last year	3
Finding time to put the guidance into practice	3
Finding the staff resource to review or put the guidance into practice	2
Finding time to read it	1
Difficult to obtain residents' cooperation for risk assessments or implementing actions	1
Unsure	1
Base: All using the high rise guidance	9

The depth interview participants also reported few barriers to implementing the guidance. The main issue mentioned was resourcing actions identified; either within their own organisations when major programmes of work were identified (for example the replacement of all doors across the stock) or securing owner approval to undertake works required by risk assessments (for example when the cost of the works exceed the authorised 'factoring limit' or where missives require the agreement of a majority of owners).

"It was going to be more than what the factoring agreement said we were able to do. But it was essentially emergency work because it had been highlighted in the safety report when they'd done the annual inspection. So we had no choice but to go ahead and do it. But then the kickback we get back from that from the owners - I had seven of them on the phone complaining. And it's like, you either want your building to comply or you don't. And unfortunately to have it comply you're going to have to pay your share. That is a challenge." - Depth interview, High rise

Generally, however, participants stressed that the guidance has been supportive and helpful.

"I think the guidance has been very helpful. Sometimes it has been helpful from the point of view that it reinforces or gives us the confidence that we were on the right track or we continue to be on the right track. From that perspective, no barriers." - Depth interview, High rise

"Yeah it takes time to go through and to deal with, but it has been helpful. Trying to bring all the different strands together and work out what that actually means for us. I think it's been extremely helpful." - Depth interview, High rise

3.6 Improvements to the guidance

Survey respondents and interview participants made a small number of suggestions for improving the guidance. Participants stressed these were 'tweaks' intended to make the guidance more useful, as opposed to substantive changes.

Two of the survey respondents thought that the Scottish Government could do more to support them to implement the Guidance. Only one of these respondents commented on the type of support that would be helpful:

"The guidance does not say a lot in relation to buildings over 60m - additional information for these buildings would be helpful." – Survey respondent

Two respondents made suggestions that related to particular challenges faced by managers of mixed tenure buildings:

"A subsection on the responsibilities / obligations of mix-tenure private owners to comply with direction / recommendations given by property managers and to promote enhancement to fire safety." – Survey respondent

"More recognition of high rise buildings that have properties with mixed ownerships - we have a number of privately owned properties within our high rise blocks and it's unclear how we can engage fully with some of the requirements as a result of this." – Survey respondent

Finally, one survey respondent specifically asked for more technical information on cladding and fire barriers.

"Specific technical detail on cladding systems, fire barriers, etc." – Survey respondent

The depth interviews support these findings, with most agreeing that overall the guidance is about the right length, and is clear and concise.

The key area for improvement mentioned was better communication of the availability of the guidance and any further updates that are that issued. The audience for the guidance was fairly wide-ranging, including housing providers within the social sector, property managers/factoring companies, SFRS, consultants providing risk assessment services, architects and surveyors, lettings agents, and so on. It was appreciated that the guidance will have been disseminated when launched, but the events of last year had served to shift the focus.

It was suggested that a leaflet for residents and owners be produced (similar to the one produced previously for high rise residents) which would contain some information about the guidance on existing high rise properties, including residents' responsibilities.

"I think it should be advertised. Every factor in Scotland is registered so there's no excuse why the Scottish Government haven't contacted the head operatives of the regional offices of the factors registered in Scotland to say this guidance exists and can you let us know how many staff you've got and how many people have seen it? Why am I only finding out now? I'm not someone who goes onto the government's website to see what's kicking around. Maybe I should. There may be other things out there that I don't know about, but I don't think there's any excuse… Factoring within Scotland is legislated. We've got to follow a code of conduct, so all of our businesses are registered and it wouldn't be difficult for the Scottish Government to contact those offices and say guys, we've got a guideline for high-rise and you may not have one but this is relevant to any factoring because you might get a high-rise or might have a building." - Depth interview, High rise

Some participants also suggested a searchable online version, such as an app or something they could use easily on the ipad when they are out and about, would be extremely useful. This fits with the way most of the participants are using the guidance, as a reference document, that they refer to (or refer others to). Being able to navigate the document easily and quickly would add to its utility.

"One thing for me, would be a searchable facility. With a lot of electronic documents now you can put in compartmentation and it will take you to the specific part of the document. I think that would be really helpful for a range of people that we work with. You've got an electric version, you've got it on your iPad and you suddenly want to know about self-closing doors in common areas, you can type that in, and it takes you there. So, you don't have to spend time and read through the document. It would save time. It's difficult to find lots of comments to make it better than it already is, but that would be one. - Depth interview, High rise

Participants raised issues about the scope of the FSRA, and the implications for resources. Several mentioned the cost of conducting the risk assessment: in the region of £800 - £1,000 per building, which clearly becomes significant for landlords with several buildings and/or who wish to repeat the risk assessment at frequent intervals.

Some landlords questioned whether the risk assessment, and subsequent regular safety checks, should cover flat doors. If so, this would present both resourcing and practical challenges: checking individual dwelling doors to make sure that they are in a good state of repair and fit correctly, they are closing properly, and that the smoke seals are intact and fitted correctly. Critically, checking that each door conforms to safety standards, and has not been replaced by the owner for an alternative.