Fire and smoke alarms in Scottish homes consultation: interim equality impact assessment

Stage 1: Framing

Results of framing exercise

Most recent estimates indicate that there are around 600,000 social rented homes, and 1.5 million owner occupied homes, of which 310,000 are flats. ^[2] The new policy has the potential to impact on all of these people.

Some social landlords report that they have made some efforts to work towards the higher standard for fire and smoke alarms required in the private rented sector, and analysis of the available evidence is in the accompanying Business and Regulatory Impact Assessment. However many social landlords who have made this effort will likely be required to do more to fully comply. For those landlords who have not taken such action, the task will be more demanding.

The owner occupied sector has the lowest proportion of homes without any smoke or fire alarms – with 7% of homes owned outright and 8% of mortgaged properties having no alarm in 2015. Furthermore, alarms present in owner occupied properties are more likely to be battery operated than in other tenures.

The Scottish Government Building and Fire Safety Ministerial Working Group is directing progress in proposals for action to reduce the risk of fire in buildings in Scotland (including schools and hospitals). As a first step, this consultation has been prioritised to concentrate solely on fire safety in Scottish homes. This is being led by the Housing Standards and Quality team in the Scottish Government.

A stakeholder working group was established to provide stakeholders the opportunity to help inform and progress development of the draft consultation. It is chaired by the Scottish Government with representatives from COSLA, SFHA, CIH, ALACHO and GWSF attending. The group considered a range of issues and helped make decisions about the consultation’s scope and recommendations contained therein. Views were also invited from Private Rented and Owner Occupier representative bodies.

In this Interim Equalities Impact Assessment we will look at evidence gathered under the following headings: Age, Disability, Sex, Pregnancy and Maternity, Gender Reassignment, Sexual Orientation, Race and Religion or Belief. Where there are gaps in evidence we will use the consultation to look for evidence to fill these gaps.

Extent/Level of EQIA required

The evidence captured in Stage 2: Data and evidence gathering, involvement and consultation is drawn from the Scottish House Condition Survey ( SHCS) module of the Scottish Household Survey ( SHS) collected in the period 2014-2015 and, where insufficient information is available from this source, from the 2011 census. The statistics may relate to the characteristics of the highest income householder - e.g. evidence relating to age and gender or to the characteristics of any of the members within the household such as provided under the disability heading.

We do not consider that any groups with protected characteristics will be disproportionately affected by the policy proposals to require all housing to meet the highest current standards for smoke and fire alarms. These are already applicable in new build housing and the private rented sector

During the consultation period, equality group representatives will be invited to comment and submit evidence in relation to those protected characteristic groups they represent. This will be taken into account together with any additional evidence gathered during discussions at consultation events and from formal responses received.