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

4. Research findings: Existing specialised housing and similar premises

The guidance is primarily for those who are responsible for specialised housing and similar premises and for those who provide care and support services in such premises. It may also be useful for people living in general needs housing who receive a "care at home" service and for anyone involved with their care and well-being.

This chapter addresses the objectives of the evaluation of the Practical Fire Safety Guidance for Existing Specialised Housing and Similar Premises: 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 on the qualitative interviews conducted with housing providers, care providers and representative bodies; and the survey undertaken with housing and care providers; as well as the recommendations from the Housing Support Enabling Unit fire safety roundtable event.

Chapter 4 – Key points

Research participants were almost all aware of the guidance, typically survey respondents became aware of the guidance through formal channels at work or from a Scottish Government communication.

Most had used the guidance, mainly to ensure a satisfactory standard of fire safety, update policies and procedures, and when conducting fire safety risk assessments. Several participants noted that the national lockdown, which had occurred just a few weeks after the guidance launch, interrupted their progress on rolling out the person-centred fire safety risk assessments.

Almost all of the survey respondents had been carrying out premises-based fire safety risk assessments prior to the publication of the Scottish Government guidance in 2020. For most, these are carried out by in-house staff or a mix of in-house staff and external consultants. Almost all have reviewed the risk assessment template provided in the guidance, and some have adopted it in full or in part for their own organisation. Most continue to use either the PAS 79 template or their consultants' template.

Almost all use personal emergency evacuation plans (PEEPs), and it was suggested that reference to the PEEPs should be included more prominently in the guidance and added to the checklist in Appendix 6.

Around half of the survey respondents currently carry out a person-centred FSRA for at least some of their residents. Typically the person-centred FSRAs are carried out in-house, either by a welfare officer, a housing officer, or in some cases an external care provider.

Concerns were raised by participants as to how the responsibility for undertaking each of the risk assessments would be determined; how the information from a range of organisations could be collated and kept updated; and how the actions would be resourced.

There was a high level of support for the guidance. Users found it clear and comprehensive, and the supporting tools user-friendly. More information on how the person-centred FSRA should be used would be welcomed.

Potential barriers to using the guidance were largely around the person-centred FSRA, in terms of having the resources to undertake the risk assessments, limited relationships with residents (which impacts on identifying potentially high risk residents), and the need to obtain consent prior to carrying out an assessment.

4.1 Awareness

The research participants were, on the whole, aware of the Practical Fire Safety Guidance for Existing Specialised Housing and Similar Premises.

All of those responding to the survey were aware of the guidance, and all but two had read at least some of it. As was the case with the guidance for high rise buildings, we might expect those that responded to have had greater interest and awareness in the subject, than the the total population of providers/stakeholders in this sector.

Table 4.1: Awareness of the Practical Fire Safety Guidance for Existing Specialised Housing and Similar Premises

Q27, Q28. Before taking part in this survey today, were you aware of the Practical Fire Safety Guidance For Specialised Housing?
	Total
Aware of and read it (some, most or all)	15
Aware of, but not read it	2
Not aware of it	-
Base: All specialised providers*	17

* Providers comprise 15 housing providers and 2 care providers

Most survey respondents became aware of the guidance through formal channels at work or from a Scottish Government communication. Other sources of awareness included colleagues, trade press, fire officers and industry bodies. Only 5 of the 17 survey respondents had attended a workshop, meeting or seminar about the guidance. Two were in-house sessions and 3 were roundtable sessions organised by SFHA / Scottish Government.

Table 4.2: How respondents became aware of the guidance for specialised housing

Q29. How did you become aware of the Fire Safety Guidance for Specialised Housing?
	Mentions
Through formal channels at work:	10
From a Scottish Government communication	8
Told about it by a colleague	4
In the media or trade press	4
On the advice of a fire officer (SFRS)	3
From an industry body	3
Base: All specialised providers	17

The depth interviews supported these quantitative findings. All participants had been aware of the guidance before the interview. Some were aware that the guidance was being prepared, either through involvement with the Scottish Government policy team, or by responding to the consultation on the draft of the guidance. Those with a mix of high rise and specialised stock were especially alert to forthcoming guidance, given the measures being put in place in response to the Grenfell tragedy. But those with a focus on specialised stock were also aware: information was circulated by in-house health and safety teams, the Scottish Fire and Rescue Service, and professional and trade bodies.

"I first saw it through the media. I'm part of a number of groups of health and safety advisers, and we meet regularly, and we discuss all things fire related." – Depth interview, Specialised provider

"I worked closely with this guy, who is the Scottish Fire and Rescue Service Fire Enforcement Officer. He has been absolutely brilliant, keeping us up to date with any of the new legislation going through." – Depth interview, Specialised provider

This high level of awareness among housing providers was in part be due to Scottish Government working in partnership with key representative organisations. One such body was interviewed for the evaluation. This organisation made information available to a wide range of specialised housing bodies, including sheltered housing providers, providers of supported housing more generally, and care providers. They noted that good engagement was achieved with housing associations, but less so with care providers.

"It was more challenging, it's fair to say, to get engagement with care providers who perhaps didn't see fire safety as such a key part of their role because they'll be working with landlords rather than being the landlord. However, they obviously have a role to play, via safety guidance. The role of care providers is really helpfully highlighted and all of that co-ordination between landlords, care providers and other professionals working with individuals is very much key to it." – Depth interview, Specialised provider

4.2 Use of the guidance

Most (11) of the specialised housing survey respondents had used the guidance. The main uses were 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.

Table 4.3: Use of the specialised guidance

Q32. Have you or are you currently using the fire safety guidance for specialised housing in any way? This may be simply using it to review current procedures and policies, training of staff, implementing new procedures, to undertake risk assessments, etc.
	Total
Yes	11
No	5
Unsure	1
Base: All specialised providers	17

Table 4.4: Use being made of the guidance

Q33. How are you using the guidance? Please select all that apply
	Mentions
To ensure we achieve a satisfactory standard of fire safety	8
To update policies and procedures	7
When conducting fire safety risk assessments on our buildings	6
To conduct person-centred risk assessments for our residents	6
When undertaking action in response to risk assessments	5
To create new policies or procedures	5
To train staff and make staff aware of fire safety issues	5
Base: All using all specialised guidance	11

The depth interviews provide a more nuanced picture of how organisations are using the guidance on the ground. For some, who already have established effective policies and procedures in place, the guidance is being used as a reference resource. For example, it is being reviewed to ensure local policies and procedures meet the standards and best practice set out in the guidance, and to provide a robust justification for actioning risk assessments. This can range from wholescale review to minor tweaks.

"When it first came in we sat down and read through it and then we discussed it with some of our health and safety reps and especially the housing and highlighted areas where we thought we need improvement, and then it's an ongoing point. I will be reading it again in March, if we're coming out of the lockdown, because we'll then be doing the fire risk assessments again." - Depth interview, Specialised provider

"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, Specialised provider

Some organisations have had less time to make substantive changes. They have read the guidance, and have set targets to incorporate revisions to current policies and procedures as required when risk assessments are due to be updated. One organisation, which has both high rise and specialised housing, commented that implementing the high rise guidance had taken precedence, given competing resource pressures during the pandemic year.

"We focused on our high rises as that was the priority after Grenfell. Perhaps it's a slightly naïve view, given that in the specialised housing it's elderly and vulnerable tenants, but I think we're confident that our specialised housing schemes are actually okay in terms of fire safety…They're quite small [low rise flats and houses], so we don't have the same height issues there. And we have on-site staff, albeit that they're not sheltered housing wardens…" - Depth interview, Specialised provider

4.3 Guidance not used

A small proporion of the survey respondents were aware of the guidance for specialised housing but had not yet used it; five of those surveyed online^[2]. Four of these said they expected to use the guidance at some time in the future, while the other was unsure. The main reasons for not having implemented the guidance were largely time-related: lack of time to read the guidance (2 mentions), being focused on dealing with the coronavirus pandemic (2), lack of time to implement guidance, (1) and lack of staff resources to conduct the person-centred risk assesments (1). Two organisations mentioned already having robust fire safety measures in place, and two mentioned the guidance was not clear who is responsible for carrying out the person-centred risk assessment.

One of the organisations interviewed for the qualitative phase of the research had not used the guidance. This organisation currently uses the PAS 79 document for care home fire safety risk assessments, and considered this similar to the healthy working lives template but much more detailed.

4.4 Premises-based Fire Safety Risk Assessment

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

All survey respondents had premises-based fire safety risk assessments (FSRAs) in place for at least some of their relevant properties, although only around half had FSRAs for most of their properties.

Table 4.5: Fire Safety Risk Assessments

Q36. Do you have current Fire Safety Risk Assessments which have been undertaken or reviewed in the last year for your specialised housing or similar properties?
	Total
For all properties	6
For the majority of properties	1
For some properties	8
For no properties	-
Base: All specialised housing providers	15

Almost all (14) of the survey respondents had been carrying out premises-based fire safety risk assessments prior to the publication of the Scottish Government guidance in 2020. Just one of the respondents started carrying out premises-based fire safety risk assessments following the publication of the Scottish Government guidance in 2020.

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

Good practice in building management/H&S: 12 mentions

Fire reduction strategy/performance indicator: 5 mentions

Publication of the Scottish Government guidance: 4 mentions

The findings from the depth interviews supported these findings, with participants generally having been undertaking regular fire safety risk assessments in their specialised housing prior to the introduction of the guidance.

"The health and safety team carry out the risk assessments in our established properties." - Depth interview, Specialised provider

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

Some organisations that currently, or previously, managed care homes had found the care homes fire safety guidance^[3] helpful in managing their specialised housing.

"We used to have care homes. So we were doing fire risk assessments back in 2008 when the first guidance came out for care homes. Sadly we closed our care homes in 2018. And once we had finished with care homes, I went back to the board and said could we just continue for sheltered housing and very sheltered housing developments? And it was actually a very progressive board who just said, 'Yes, let's go for it. Whether it's a legal requirement or not, we'll go ahead and we'll do it'." - Depth interview, Specialised provider

Who carries out the premises-based FSRA?

The FSRAs in specialised housing are carried out by a mix of external consultants and in-house staff. Four of the organisations undertook the FSRAs using their own staff, while five employed consultants, and the remaining six used a mix of their own staff and external consultants.

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

Table 4.6: Who carries out the FSRA?

Q39. Who carries out the Fire Safety Risk Assessment in your specialised housing or similar properties?
	Total
External consultant	5
In-house	4
Mix of in-house and external consultants	6
Base: All specialised housing providers	15

This was supported by the depth interviews. 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.

"Mainly done in-house although we will bring in an external assessor for new properties or properties they've taken over as it will involve intrusive inspections e.g. going into loft spaces. Usually only for the initial inspection." - Depth interview, Specialised provider

For those using external contractors, the cost of undertaking regular premises-based risk assessments may be considerable. One large housing association commented that the cost of moving to three-yearly assessments would eat into the budget available to implement actions identified.

"It states in the guidance it's every three years for a full risk assessment. So that's a cost that you're going to have to continue to build in in the future. Because let's say it's £700, £800… Even if you're doing 100 a year, it's quite a cost. That would come outwith the £3,000 budget that we have. So then that reduces the amount of money we have to implement actions… They're probably better, actually, trying to get [the consultant] and try to employ him, but I think he probably makes a lot more money through being self-employed!" Depth interview, Specialised provider

Premises-based FSRA template

Almost all of the survey respondents had looked at the risk assessment template within the guidance. One was using the template from the guidance to conduct risk assessments, and 2 others had adapted it to create templates that better suited their organisation. Others used a different approach, typically PAS 79 or their consultants' template.

Table 4.7: The premises-based FSRA template

Q41. Have you read through the fire safety risk assessment template in the fire safety guidance for specialised housing?
Read the premises-based FSRA template	Total
Yes	12
No	1
Unsure	1
Base: Specialised housing providers aware of guidance	14
Q42. Have you used the fire safety risk assessment template for high rise buildings in any way within your organisation?
Used the premises-based FSRA template
No – we currently use PAS 79 instead	3
No – we use a different template (not PAS 79 or SG)	3
Yes – we have used the template from the guidance to conduct risk assessments	1
Yes - we have used the template as a basis to create a risk assessment approach for our organisation	1
Yes – Other (blended it with PAS 79)	1
Unsure	2
No – we do not currently use a template	1
Base: All read the template	12

This was supported by the depth interviews. Participants had been drawing on advice from consultants and from the SFRS. In-house risk assessment templates, checklists and procedures had been established by management teams and Health and Safety teams. These provided clear and reliable reporting frameworks, and identified items requiring action and investment. As with the high rise guidance, there was a general view that the templates in use are fairly similar to that provided in the guidance.

"If we'd started from nothing, yes the template would have been useful, but most of it was already there, we had it before… we were basing our own template on the fire brigade's…" - Depth interview, Specialised provider

Actions

As with the high rise guidance, the participants sought to prioritise the actions identified in the risk assessment, and were familiar with the approach set out in the guidance. The guidance was considered systematic and helpful.

"I think it's really good. I think it's really clear, very useful for people who don't really understand the fire risk assessment procedure. It's a great check list to start with.." - Depth interview, Specialised provider

One small amendment was suggested: that referencing is included so that it is clear who has responsibility for addressing each action.

4.5 Person-centred Fire Safety Risk Assessment

As noted above (section 4.4), the fire safety guidance for specialised housing and similar premises also includes guidance for person-centred fire safety risk assessments. This FSRA is designed to protect people at high risk from fire due to specific vulnerabilities, and aims to identify whether additional fire safety measures may be required to reduce risk. Unlike the premises-based FSRA, the person-centred FSRA can be carried out by a 'lay person', typically someone who engages frequently with the vulnerable person, such as a sheltered housing scheme manager, a care provider or an informal care provider such as a family member.

The survey showed that approximately half of the organisations (8 out of 17) currently carry out person-centred FSRAs, with 3 saying they carry out them out for all residents regardless of perceived risk; 1 reporting conducting person-centred FSRAs for all residents at increased risk; and 4 carrying them out for just some residents at increased risk.

However, it is appreciated that the guidance was published just a few weeks before Scotland went into lockdown last year, and most housing and care providers have not operated normally since that time. As one of the depth interviewees said:

"[Before the guidance came out I had] concentrated on the person-centred approach and what we would have to do. Who's going to do it? When's it going to get done? Unfortunately when the document come out I had a meeting with the team in February 2020, and three weeks later we were in lockdown which was really annoying!" - Depth interview, Specialist provider

Table 4.8: Person-centred FSRAs

Q44. Does your organisation currently carry out person-centred fire safety risk assessments for residents in specialised housing or similar premises?
	Total
Yes - for all residents regardless of perceived risk	3
Yes – for all residents identified as being at increased risk in specialised housing	1
Yes – for the majority of residents identified as being at increased risk in specialised housing	-
Yes – for some residents identified as being at increased risk in specialised housing	4
No – for none of the residents in specialised housing	4
Unsure	5
Base: All specialised providers	17

Who carries out the Person-centred FSRA?

Typically the person-centred FSRAs are carried out in-house, either by a welfare officer or a housing officer. In some organisations, the health and safety team are involved as well. Two respondents mentioned external care providers undertaking the assessment. No-one mentioned risk assessments being undertaken by informal carers or by friends and family who provide care and support.

This was supported by the depth interviews. Almost all of the person-centred FSRAs were undertaken by in-house staff.

Table 4.9: Who carries out the person-centred FSRA?

Q47. Who carries out the Person-centred Fire Safety Risk Assessments?
	Total
A welfare officer, carer (or similar) employed by my organisation	4
A housing officer (or similar) employed by my organisation	3
External care provider who delivers the care package to the resident	2
An external assessor who is 3rd party certified or registered with a professional body appointed by my organisation	1
Relatives or friends of the residents	-
Other (in-house H&S, team leader)	3
Base: All carrying out person-centred FSRAs	8

Two broad questions were raised with respect to the person–centred FSRA in the qualitative depth interviews: how should the risk assessments be resourced, especially in large organisations; and how should the organisation collate the information if the assessments were (increasingly) undertaken by different people/agencies.

Resources: Undertaking risk assessments for a large number of residents may be daunting for some organisations, especially large, specialist organisations. The resource implications of funding any actions identified as a consequence of undertaking the assessment was raised as a further concern.

"If you have 7,000 tenants, even if you come up that 50 percent were vulnerable, you're talking 3,500 people that will have to be assessed. And again, who's doing the actions? If you actually look at their fire blankets, people who are smoking and burning their settee, who's providing those? Large ash trays?… Because some of these people don't actually have family. I shouldn't go on too much about the person-centred assessments, because I'll just come back to the same thing. It is going to be so difficult to implement." - Depth interview, specialised provider

Different assessors: Some participants commented that they would face challenges collating risk assessments that had been completed by a number of different of different agencies/people; and that they had no mechanism for identifying when a risk assessment had been completed on one of their residents, for systematically obtaining copies of said assessments, or for inputting the information from assessments into their database. One participant further commented that it would be difficult to develop to a consistent assessment of risk if a large number of people had been involved. Some participants noted that, given they have the resources to carry out the assessments in-house, they will do so, as this enables them to bypass many of the logistical and quality issues highlighted.

"The challenge is having a consistent approach to assigning a risk level across staff and housing complexes. It's important to try and get it as standard, because if you've got a housing officer in one complex puts somebody as a high level and then the next complex you would get exactly the same results and believe they're a medium level, it sort of undermines what we're actually trying to achieve." - Depth interview, specialised provider

Person-centred FSRA template

Many of the survey respondents had looked at the person-centred FSRA template provided in the guidance. Two were using the template from the guidance to conduct risk assessments, and two others had adapted it to create templates that better suited their organisation. Others used a different approach, either their own templates or PEEPs.

Table 4.10 Person-centred FSRA template

Q48. Have you read through the person-centred Fire Safety Risk Assessment template in the Fire Safety Guidance for Specialised Housing?
Read the template	Total
Yes	9
No	5
Unsure	1
Base: Specialised housing providers aware of guidance	15
Q49. Have you used the fire safety risk assessment template for high rise buildings in any way within your organisation?
Used the template
Yes - we have used the person-centred fire safety risk assessment template provided in the Guidance to conduct risk assessments	2
Yes - we have used the template as a basis to create a risk assessment approach for our organisation	1
Yes – the H&S team support local teams	1
No – we use a different template	2
No – but we do have PEEPs in place	1
No – we do not have PEEPs or use a person-centred fire safety risk assessment template	1
Unsure	1
Base: All who have read the person-centred FSRA template	9

The depth interviews confirmed that organisations are aware of the template, and are generally comfortable with this approach to collecting information about their residents'/clients' risks and requirements.

"Housing associations do risk assessments across so many issues. So, I think they're pretty confident about carrying out risk assessments and I think they're always really pleased to see a new template and to look at it like, 'does that enhance what we're already doing?' And they're very keen to introduce things to their own processes, like that. Certainly, from thinking about managing the COVID pandemic, there's been a great willingness to share good practices about risk assessments around infection, prevention and control. These networks really do assist organisations to reflect on their own practice generally, in terms of risk assessments and share good ideas and stuff. I'm sure it's the same with the fire risk assessments, fire safety." - Depth interview, specialist providers

However, the depth interviews also indicated that the person-centred FSRA was not a straightforward issue. Some organisations currently collect similar information as part of care plans/personal support plans – detailed, active plans that are maintained by staff providing support and care for vulnerable residents/clients. Some others noted they had previously collected this information but no longer did so, because either staffing resources had been reduced or the profile of housing had changed – typically care homes, very sheltered housing and sheltered housing had been replaced with retirement housing.

A number of issues were raised about determining who to risk assess. Some participants commented that the guidance implied they should be risk assessing people at risk of fires in mainstream tenancies in their general needs stock should they become aware of increased risk. There was some ambiguity as to whether or not this was the intention of the guidance. One participant noted their familiarity and knowledge of residents has deteriorated substantially over the last year as a consequence of pandemic restrictions, and they doubted their capacity to identify which residents required a risk assessment. Some participants commented that they did not have any 'right' to undertake a full risk assessment: given they had no right of access to the residents' homes. This case was most often made with respect to residents in private sector accommodation, but equally applies to those social rented housing.

"I got the impression that it puts on landlords more of a requirement than should be there, if that's the right word. We wouldn't do this for a normal tenant in one of our houses unless we've identified that there was an issue with them. We teach our housing officers to look out for domestic fires when they're in a property - they look to see if there are cigarette burn marks on the carpet? Is there evidence that they've had minor fires in the kitchen? Things like that. And that's when we might involve this." - Depth interview, specialised provider

"Up until this point in our sheltered housing complexes they were more like part of the family. Now with what's happened with COVID and how we're having to step back our services… there is a possibility that a gap will widen in our knowledge." - Depth interview, specialised provider

"When it's in domestic premises that are in mainstream housing, somebody who, whilst they might have some degree of vulnerability, might live quite independently. To what extent do your responsibilities extend as opposed to a sheltered premise or an ex-sheltered premise and a supported living accommodation. It's trying to find the balance in terms of your priority there." - Depth interview, specialised provider

Most of the participants had personal emergency evacuation plans (PEEPs), which they considered key to assisting the speedy safe evacuation of premises in the event of fire. It was suggested that reference to the PEEPs should be included more prominantly in the guidance, and added to the checklist in Appendix 6^[4].

Actions

As with the premises-based risk assessment, the depth interview participants were familiar with the approach to prioritisation of actions set out in the guidance. Some commented they were more used to a RAG classification, rather than the red, orange and yellow classification in the guidance, but presumed it would be the same in practice.

A small number of specific points were raised:

Consistency of interpretation when a number of different people are involved in conducting the assessment (see above)

Resourcing the actions, especially in cases when the funding required is substantial and/or the residents are in the private sector/are privately funded (see above)

The need for a multi-agency approach to address risks for very vulnerable residents

"If someone is in medium to high risk, then we would certainly quickly have a team approach, and we would look at how we mitigate that risk. But it's not just an in-house discussion. It would involve anybody else as required, and that would allow us to have a plan of action to mitigate the risk as far as possible." - Depth interview, specialised provider

"Over the last five years, we've visited over 1,000 vulnerable customers. We will go and assess a customer in their own home and provide everything from fire retardant bedding to metal ash trays, metal buckets with lids that would suppress fires and dropped cigarettes. Air fryers, replacing open chip pans which are still the cause of a lot of accidental fires." - Depth interview, Specialised provider

4.6 Assessment of the guidance for Specialised housing

Overall views on the guidance

Overall all, or almost all, of the survey respondents considered the guidance for Specialised housing and the templates for fire safety risk assessments to be valuable, with around a third considering these to be very valuable.

Survey respondents were also asked to rate key aspects of the guidance. Most rated each of these good (that is either quite or very good), with between 3 and 5 respondents out of 15 rating each of the aspects very good. As the table below shows, the aspects of the guidance most often considered very good were clarity of the buildings and organisations to which the guidance applies, comprehensive coverage, provision of tools to support the guidance and being user-friendly.

Table 4.11: Overall assessment of guidance for specialised housing

Q58. Thinking now about the fire safety guidance for specialised housing, how valuable would you say each of these aspects has been for your organisation?
	Premises-based FSRA Template	Person-centred FSRA Template	Guidance
Very valuable	5	5	5
Quite valuable	10	8	9
Not very valuable	-	1	-
Not at all valuable	-	-	-
Unsure	-	1	1
Base: All aware of the Specialised guidance	15

Table 4.12: Assessment of aspects of the guidance

Q34. How would you rate the fire safety guidance for specialised housing on the following aspects?
	Very good	Total good
Clarity of the organisations and buildings to which the guidance applies	5	12
Provision of practical tools to improve fire safety (e.g. checklists, risk assessment templates)	4	13
Comprehensive coverage of relevant aspects of fire safety	4	12
Being user-friendly – the language and layout are easy to follow	4	12
Signposting to further sources of information and advice	3	13
Guidance on how to complete risk assessments	3	13
Advice on how to use/implement the guidance	3	11
Guidance on who should complete risk assessments	1	9
Base: All aware of the specialised guidance	15

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.

"I think it has helped bring a structure to what we do well outside our team's influence. It will probably be really helpful when dealing with customers." - Depth interview, Specialised provider

"I thought it was quite accessible. The first half is excellent, and it does mirror a lot of our thoughts. The sections… I'd need to look, but the later sections (Ch5) which become very technical on the building environment and the safety in the building environment, they're very accurate, and they're very relevant, but I think they'd be a hard read for a lot of people." - Depth interview, Specialised provider

"I'd say pretty helpful, maybe eight out of ten, if I was giving it a score like that. All of it's in one place. Because it's also applicable to normal housing, it's a useful guide. It's not just for specialised housing. We don't now have any shelter housing, we don't call them that anymore, they're all just normal tenancies, and the guidance was quite clear that it doesn't matter what you call it, you still have responsibilities." - Depth interview, Specialised provider

Just one survey respondent rated the guidance as very good on 'who should complete the risk assessments'. This lack of enthusiasm was echoed in the depth interviews, indeed one participant commented that the guidance was unhelpful in this regard:

"The main thing is you've got numerous parties involved, and then you're saying someone should take the lead. The practicality of that is that nobody will take the lead." - Depth interview, Specialised provider

Barriers to using the guidance

Just 3 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, finding 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.

Table 4.13: Barriers to using the guidance for specialised housing

Q53. Have you experienced any difficulties or barriers in using or implementing the fire safety guidance for specialised housing? Please select all that apply?
	Mentions
Organisational focus has been on dealing with coronavirus pandemic for the last year	6
Finding the staff resources to undertake the person-centred risk assessments	5
For low dependency housing: do not have the authority to enter people homes to conduct the risk assessments/ unclear who is responsible for conducting the risk assessments	5
Do not have the authority to purchase items/make changes to people homes in response to the risk assessments	2
Finding time to put the guidance into practice	2
Do not have the financial resources to implement actions that might be identified from the risk assessments	2
The guidance is not clear or easy to follow	1
Senior management don't see person-centred fire-risk assessment as a priority at the current time – they are just good practice	1
Finding time to read it	-
Not experienced any barriers or problems	3
Base: All using the specialised housing guidance	11

The depth interview participants expanded on these issues. Some commented that the timing of the launch, just a few weeks before the pandemic restrictions were introduced, meant that they were unable to put in place new/revised systems in response to the guidance. This especially impacted on their capacity to introduce systems to undertake the person-centred FSRAs.

"We've already started with the premises fire risk assessments, but because of Covid, that type of work's [person-centred risk assessments] had to be suspended." - Depth interview, Specialised provider

Funding of any actions within the specialised sector has the potential to be complex. People who are responsible for funding their own care may not be able to/wish to pay for actions themselves. For vulnerable residents, eligible for financial support, first identifying the appropriate budget, then gaining approval may be fraught with difficulties.

"I think it's about looking at responsibilities in terms of HSCPs, landlord/care providers, and at individuals themselves. Where is it fair to apportion that financial responsibility? What do you do when there isn't that agreement between parties? Or an HSCP perhaps thinks that their contract with a care provider covers adaptations to some extent? Or a care provider feels that their landlord, in a situation, is leaving the care provider to have to pick up those costs? …There might be scope for saying a bit more about where the responsibility for financing some of these things should lie." - Depth interview, Specialised provider

As noted above, a number of social housing providers have shifted away from providing care homes and very/sheltered housing over recent years, and towards housing such as retirement housing, which accommodates less vulnerable tenants. As a consequence, they may no longer routinely produce care plans/housing support plans for residents. Therefore, they may not know which tenants require a person-centred FSRA. They may also lack the staff resources to conduct the risk assessments in-house.

"The housing association changed the terminology of its buildings about seven years ago. So we don't actually provide sheltered housing, we actually provide retirement housing. We're deregistered by the care inspectorate, so we don't actually do any housing support plans, which will be problematic doing the person-centred fire risk assessment approach." - Depth interview, Specialised provider

One association commented that there have been government reductions in finance for welfare officers, which means that associations are no longer resourced to produce individual care plans for each tenant, including an assessment of their fire safety risk. Their welfare officers have been replaced by staff who are effectively providing a janitorial role. They don't have time to undertake the risk assessment, nor are they well placed to undertake one, as they don't have the 'authority' or a reason to enter the resident's home.

"When we asked who should be undertaking the risk assessment it was suggested that carers or district nurses could do it as part of their role. Which is just not feasible, they don't have time; it's not something they would think of to do." - Depth interview, Specialised provider

4.7 Improvements to the guidance

Six of the survey respondents said they thought the Scottish Government could provide greater support or guidance around the specialised housing guidance. Suggested actions included more training and workshops, provision of a training template so that organisations have a clearer idea of what is required, and external audit of the completed template to provide reassurance to organisations that they are following good practice.

Table 4.14: Additional support

Q54. Is there anything the Scottish Government could do to support you implement the guidance?
	Yes
Specialised housing guidance	6
Premises-based FSRA	4
Person-centred FSRA	8
Base: All aware of Specialised guidance	17

Four survey respondents said they thought the Scottish Government could provide greater support or guidance on the premises-based FSRA. One organisation commented that a training programme to support the implementation of this guidance would be helpful. Staff would be especially motivated to participate if such a programme were accredited and/or recognised for personal development. It was also suggested external funding be made available to support this training.

Eight survey respondents said they thought the Scottish Government could provide greater support or guidance on the person-centred FSRA. Suggestions for further support included:

Clear guidance on who is responsible for completing the templates (5 mentions), with respondents requesting greater clarity on the role of social work teams, and how they should be dealing with vulnerable people who do not have care/support, who live in owner occupied housing, etc. One respondent commented: "It needs to be really clear who should be responsible for doing them (person-centred FSRAs). Saying that several people/organisations may have responsibility and then ask them to work together to complete the template or for one of them to take the lead, just will not happen." - Survey respondent, Specialised housing

Greater clarity on what is required (2 mentions) for example by way of FAQs or a sample completed template

Survey respondents made a small number of suggestions for improving the guidance.

One respondent suggested that the premises-based FSRA become mandatory.

"I would like this to be mandatory as this removes the option to comply or not. Formal reporting or validation of the templates would provide reassurance to Boards and tenants alike." – Survey respondent (This issue is discussed in more detail in section 5 below)

One respondent suggested that there could be more detail on the types of premises to which the guidance applied.

One respondent suggested there could be clearer definitions throughout the guidance.

"… e.g. better reference on understanding how individuals with dementia/ autism/ cognitive problems can be affected and be at greater risk; and is a care home defined as small because of the number of occupants or physical size of the property." – Survey respondent^[5]

One asked for further guidance on how to complete the person-centred risk assessments.

The depth interview respondents reflected these findings. Participants found the guidance helpful, and did not think substantive changes were required. Where improvements were suggested, they related to the person-centred risk assessment, which many of the participants did anticipate presenting some challenges.

"I don't think there's any need for improvement in there. The templates are pretty well structured, and the relevant information that you need to put in … I think everything's relevant. I wouldn't see any further need for improvement in there." - Depth interview, Specialised provider

General improvements

Length: Most thought the guidance for specialised housing was about the right length, and certainly none could think of anything that could be lost from the document. Participants had typically read through it to get a feel for the contents, and expected in future they would use it as a reference document. However, one respondent commented that the length of guidance was "quite daunting", although the content was all relevant and useful. They suggested that it could perhaps be broken down into clearer sections, with greater use made of hyperlinks in the templates, to guide users to the relevant section of the guidance.

Training: Training for staff and for residents/carers, so everyone understands what the guidance is for, and how the actions affect them.

"Quite a lot of our residential managers that I deal with think that fire safety doesn't really belong to them, while in actual fact, fire safety does belong to them. So, they don't know that they're actually in charge of that side. And, I think, some sort of training, when these documents come out, should be included for residential managers, to make them aware of changes." - Depth interview, Specialised provider

Integrating the allocations process: One respondent commented that it may be worth starting the person-centred FSRA during the housing application stage, with a view to increasing the suitability of the housing allocation from a fire safety perspective.

Guidance for person-centred risk assessment

The main suggestion made by participants was to improve the clarity of the guidance, in terms of who is responsible for conducting them, the scope of the assessment and the method used for the assessment. More detail on each of these potential areas of improvement is provided below.

Responsibility: Greater clarity is required around who is responsible for undertaking the assessments, and who is then responsible for implementing/funding any resulting actions. The HSEU roundtable report notes this was one of the main issues of discussion, and requests a mechanism for clarifying who is responsible for carrying out the assessment to remove the ambiguity that currently exists. It also suggests that a mechanism for identifying lead funding and implementation agencies should also be included, to ensure actions are progressed.

The HSEU further suggests that it may be helpful to appoint an 'independent neutral voice' to provide the final decision in cases where different agencies have conflicting views of risk priorities. They suggest that the SFRS may be the appropriate organisation to take on this role.

Scope: Some respondents were looking for more clarity on who the guidance applies to. For example, they asked if the person-centred FRSAs were aimed at all/some people within specialised housing, at people receiving care in general needs housing, at other vulnerable people living in general needs housing?

"You could interpret it that everybody that's receiving care in general needs housing should have a personalised or property fire risk assessment, I personally think it's a bit vague." - Depth interview, Specialised provider

"For example we have a customer with addiction issues within our high rise block who just within the last week or two has set off smoke alarms 3 times. They're not falling within specialised housing, so we haven't done a person-centred fire safety risk assessment with that person, however it's quite clear that that's the sort of person that probably needs that level of risk assessment." - Depth interview, Specialised provider

Method: Premises-based risk assessments for each provider tend to be undertaken by a small number of (or even a single) accredited or properly qualified assessors. Conversely, the person-centred risk assessments are likely to be undertaken by several people for each provider. In some cases these staff – housing managers, welfare officers, residential managers and supervisors, etc. – may be trained in the organisation's risk assessment approach and template. In other cases, a number of organisations may be involved in the risk assessment, and there may be several different variations of the template in use. Participants suggested that given this, clearer direction on the completion of the template was required, to provide consistency of completion, and to standardise the quality of the risk assessment.

"We have a health and safety section, and we've got a health and safety officer. She will liaise with support staff and support managers to work through fire risk assessments, fire evacuation plans, and personal emergency evacuation plans …

But what we cannot really do is ask other the agencies providing support to someone in our properties what they're doing about fire safety. They may ask us for our generic risk assessment for the building, which they will incorporate into their risk assessments. But they do not provide us with that, and it's not really practical for us to ask, because we would need to ask for updates every change that occurred." - Depth interview, Specialised provider

The HSEU report includes a series of recommendations designed to support practitioners deliver high quality person-centred risk assessments. These include:

Fire safety training to cover the person-centred risk assessment

Package of best practice templates, set out on a step by step basis for common scenarios, such as a resident with an oxygen tank, or a high level of emollient creams being stored on the premises. This could include a checklist of tasks where appropriate.

Additional information on the level and content of monitoring data required, together with clarity on who is responsible for maintaining these records.

Specific issues

Evacuation policies: Some participants, including those from specialist organisations, commented that the term 'stay put' may be inappropriate for people with cognitive difficulties. They tend to use much clearer, and less dogmatic terminology, which will not cause problems should the person need to leave their property.

"Stay put doesn't work for people with cognitive difficulties who are less able to use their judgement - to them it may reinforce they should stay put in bed when in fact the building is on fire and they should be leaving." - Depth interview, Specialised provider

The HSEU report also raised the issue of evacuation policies. It was appreciated that the document provides guidance on how evacuation strategies should be responsive to the structure of the premises. Roundtable delegates stressed that the capacity of residents must also be taken into account, noting that residents may have fluctuating ability, depending on support, and/or may have low levels of mobility. It was suggested that this area would benefit from some best practice around frequently found scenarios, or there may be a need for specific evacuation planning training or advice.

Appendix A provides a note of additional specific issues raised.