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

7. Conclusions

High rise buildings and Specialised housing: General

Overall, research participants were very welcoming of the both sets of guidance. They considered it helpful, clear and user-friendly; and found the supporting materials comprehensive and extremely useful.

Some had been using English guidance with respect to fire safety in high rise buildings, and welcomed the brevity and clarity of the Scottish document; some had been using the draft guidance in anticipation, and were grateful for formal publication. While the high rise guidance does not, in itself, provide added powers, it is felt to provide clear guidance on good practice, and is consequently a very valuable reference resource.

Suggestions for change that are made across both sets of guidance, and especially those relating to premises-based risk assessments, tend to be minor and designed to clarify and improve rather than correct.

High rise buildings and Specialised housing: Timing

The guidance documents were published at the turn of the year 2019/2020, around three months before the national pandemic restrictions were imposed. These restrictions had significant implications for the implementation for some parts of the guidance.

Premises-based fire safety risk assessments for both high-rise and specialised housing draw on a core of trained, competent staff to undertake the inspections, working with housing and property managers to ensure actions are followed through. Most organisations appear to have fairly well established processes for undertaking these risk assessments, while others were prompted by the launch of the guidance to set them up. There were some interruptions as a result of the Covid restrictions, initially as organisations adapted to new working arrangements and responded to new priorities, and there were some examples of fire-safety work being wrongly classed as non-essential work. However, on the whole, fire safety risk assessment and, especially management of actions, has continued over the course of the last year.

Person-centred fire safety risk assessment (part of the specialised housing guidance) tended to be have been incorporated into care planning. As the profile of social housing specialised housing stock has shifted to lower dependency housing (for example away from care homes and very sheltered housing, and towards retirement housing), the need for/resourcing for such activities is reduced. Many organisations were therefore looking to introduce person-centred risk assessments afresh, without an existing system to continue or adapt. Work had often started to build teams to undertake the risk assessments, when the Covid restrictions hit, and other priorities took over. These organisations are typically only starting now to think again about progressing person-centred risk assessments.

High rise buildings and Specialised housing: Awareness

Almost all those responding to the online survey and depth interviews were aware of the relevant guidance (high rise and/or specialised housing). However, it is important to bear in mind the response to the survey element of the research was disappointing, despite support from the key umbrella organisations working with social housing and care providers. We certainly know that one of the high rise property managers who participated in the research, had not been aware of the guidance before our call; and we were also informed that umbrella groups have been generally struggling to engage care providers.

More work may be required to further improve awareness of both sets of guidance across the industry, both within the social housing sector, and with partners in private housing management (factors/property managers), health and care.

Recommendation: To further improve awareness and use, promote the guidance across social housing, housing management, and care and health sectors, drawing on opportunities to work with/through key partners, and to take part in conferences/seminars.

High rise housing: barriers to carrying out the FSRA

A number of barriers were identified to conducting the risk assessments in high rise properties: the cost of conducting the risk assessments, the cost of carrying out the actions and compliance from owner/private landlords in private/mixed tenure blocks.

The guidance provides a useful resource for social landlords, assisting in specifying actions required and the timeframe for implementation; and provides the policy framework where required for budget/investment proposals to senior management. It also provides a resource and back-up for discussions with owners and landlords in private/mixed tenure blocks who may be reluctant to comply with actions (for example to get agreement from owners to remove items from common areas or to fund actions). However, some research participants were concerned that some grey areas remain, especially around implementing actions when owners refuse, and progressing investment in common areas when there are sufficient missing/non-compliant owners that a majority approval for works cannot be secured.

Recommendation: 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 on common areas in mixed tenure/private sector blocks within the document.

Specialised housing: barriers to carrying out the premises based FSRA

A number of barriers were identified to conducting the premises-based risk assessments in specialised housing, which were largely similar to those identified for high rise domestic properties. The key barriers, therefore, were the cost of conducting the risk assessments on what could be a large number of premises, the cost of carrying out the actions and securing compliance from owners in private/mixed tenure blocks.

As was the case for high rise properties, the guidance provides a useful resource for landlords. It also provides resource and back-up for discussions with owners and landlords in private/mixed tenure blocks who may be reluctant to comply with actions (for example to get agreement from owners to remove items such as mobility scooters from common areas, or to fund actions).

Recommendation: As above, Scottish Government to progress work on improving fire safety in common areas in mixed/private sector blocks. Include further guidance on managing works on common areas in mixed tenure/private sector blocks within the document

Specialised housing: Person-centred risk assessment

A person-centered fire safety risk assessment, for high risk individuals is critically important. However, a number of key features are not included which could improve the effectiveness of the risk assessment in practice.

It identifies who may be able to carry out person-centred risk assessments but does not specify who is responsible for carrying out the assessment. This reflects the flexibility required to respond the variety of housing/care provision models. However, it also means that in some cases, no-one will be identified as being responsible.

It does not identify who is responsible for ensuring the consequent actions are implemented and monitored, but does advise that the housing provider take the lead role.

There is no process for reporting/collating completed risk assessments at the premises/organisation level, so that organisations are aware of any relevant risks, and can action as appropriate

The guidance is designed for professionals; a more concise and easy to read version would be useful for unpaid carers⁶.

Recommendation: 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.

Specialised housing: training and resources:

Several organisations raised concerns about managing the quality and consistency of approach when person-centred risk assessments are being undertaken by a variety of organisations and people. Further guidance and support to complete the templates would go a considerable way to addressing some of these concerns. In particular, inclusion of some worked examples based on frequently encountered scenarios would be very useful. This would show people how to complete the template, the types of issues to look out for, the types of actions that can be taken, and how risks are assessed.

Recommendation: Consider developing a pack of key worked example templates

Unpaid carers:

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.