Grenfell Inquiry phase 1 recommendations: Scottish Government response

Chapter 2: Responses to recommendations for "building owners and managers" 

Introduction

60. This Chapter deals with the 15 recommendations directed at "building owners and managers" and Government. The Scottish Government accepts the intended outcomes these recommendations seek to achieve in principle.  This report proposes the Actions where this was identified as necessary, in the context of the fire safety regime and practice in Scotland, to achieve required outcomes.  The Actions are set out in response to each recommendation.

61. The Scottish Government GIFSWG recognised the different legal and practical arrangements in Scotland compared to England and Wales. In the Scottish context, the term "those responsible for fire safety" is used rather than "building owners and managers" as stated in the Inquiry recommendations.  Also, it was agreed at the outset that the response would focus on fire safety outcomes rather than on the format of the recommendations that are proposed. Therefore, the Actions are proportionate and both reflect and build on the fire safety regime and existing practice in Scotland.  

62. This section sets out each recommendation; the established fire safety regime and practices; the relevant Scottish Government actions following the Grenfell Tower fire; and further actions by Scottish Government, and others as identified, as deemed necessary.  

63. Practical Fire Safety Guidance for Existing High Rise Domestic Buildings (Scottish Government: 2019) is referred to in many of the responses and primarily sets out good practice in relation to fire safety.  There is no legal requirement to follow the Guidance. 

Reponses to Recommendations for those Responsible for Fire Safety     

Recommendation 1  – That the building owner and manager of every high rise residential building be required by law to provide their local fire and rescue service with information about the design of its external walls, together with details of the materials of which they are constructed and to inform the fire and rescue service of any material changes to them.

Rationale for the recommendation 

64. The Inquiry report states: "A sound understanding of the materials used in the construction of any high-rise building is essential if the fire and rescue service is to be properly prepared to carry out its function in relation to that building. The risk of fire of the kind that occurred at Grenfell Tower may be low, but knowledge is the key to proper planning and effective training".

Response & Action

65. There are established practices in place so that SFRS obtain information on the design and construction of external walls, including external wall cladding.  

66. For new builds and new or replacement external wall systems, SFRS is a statutory consultee for Building Warrant applications for domestic buildings over 18m in height (under Regulation 11 of the Building (Procedure) (Scotland) Regulations 2004).  SFRS should be consulted and provided with the relevant information when material changes are made to the building that require a building warrant.  SFRS can review building warrant submissions for compliance with the Technical Handbooks' functional standards and guidance regarding fire.  SFRS also review and respond to proposed alternative or "Fire Engineered" solutions. 

67. Since the Grenfell Tower fire, the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings and the High Rise Inventory have been introduced and relevant SFRS Operational Procedures have been reviewed and strengthened.  

68. As the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings sets out, a Fire Safety Risk Assessment for high rise should include consideration of external facades, including cladding.  Where potential fire risks, including unsafe cladding are identified, SFRS should be consulted.  Those responsible for fire safety should consider what interim mitigation measures are to be put in place, prior to full remediation of the cladding. Part of the mitigation measures may include SFRS adjusting their response to incidents.  

69. This method that is "reporting by exception" is a proportionate way of complementing the other existing data gathering processes.  While there is a very low risk that a building with unsafe cladding is not identified, the data from the Inventory indicates that there are few buildings with, what is considered, unsafe cladding in Scotland.    

70. In addition, the High Rise Inventory gives SFRS access to data on external wall systems including cladding and provides a source of assurance to SFRS that they are aware of relevant buildings.  

71. In dealing with a fire in a high rise domestic building, SFRS Operational policies and procedures, recently updated, include the consideration of external wall systems including cladding.  The Incident Commander's dynamic risk assessment requires that external wall systems including cladding is considered.  SFRS pro-active and continuous monitoring of operational measures for all high-rise domestic buildings during an incident include:

• Personnel to maintain a constant 360 degree assessment of the building's external façade for early identification of any external fire spread.
• If external fire-spread is identified then Operations Control are to be alerted immediately so they may alter ongoing advice to people in the building. 
• Any change in tactics will be informed by a Dynamic Risk Assessment by the Incident Commander and update to Operations Control.

72. Together these measures ensure a consistent approach to fire safety with due understanding and consideration to the potential for fire spread on external wall systems during a fire incident. 

73. These existing arrangements to keep SFRS informed, based on risk, of the external walls will be continued.  This approach will be kept under review, including consideration for a requirement for legislation and statutory enforcement.

Action: 
The existing arrangements are continued to inform SFRS about external wall construction, including cladding.  

Recommendation 5  – That the owner and manager of every high-rise residential building be required by law to provide their local fire and rescue services with up-to-date plans in both paper and electronic form of every floor of the building identifying the location of key fire safety systems.

Recommendation 6  – That the owner and manager of every high rise residential building be required by law to ensure that the building contains a premises information box, the contents of which must include a copy of the up-to-date floor plans and information about the nature of any lift intended for use by the fire and rescue services.

Rationale for the recommendation as noted in the Grenfell Inquiry Phase 1 Report

74. The Inquiry report states: "No plans of the internal layout of the building were available to the London Fire Brigade (LFB) until the later stages of the fire. However, because each floor of the building above floor 3 was laid out in the same way, the LFB was not unduly hampered in its attempt to fight the fire and rescue occupants by the absence of those plans. In another case, however, the lack of floor plans might easily have far more serious consequences."

Response & Action

75. Firefighters familiarise themselves with building layouts and test the operation of firefighters lifts as part of their quarterly Operational Assurance Visits.  As statutory consultees, SFRS should also be provided with floor plans for high rise domestic buildings as part of the Building Warrant consultation process.  This information informs the Operational Intelligence of buildings. Sufficient information on the layout of buildings is known to, and accessible by, crews. Providing and holding further data in Premises Information Boxes is not considered to be required to improve fire safety outcomes.

76. Many high rise buildings also display standard external information plates with core information on the building services and firefighting facilities.  This approach is recommended by the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings.  To strengthen information on building layout, the Scottish Government, working with relevant parties, will act to ensure these are on high rise domestic buildings where they are not currently.  There are likely to be cost implications for those responsible for fire safety. 

77. The assessment is that these existing provisions, strengthened as proposed meet the intention of the recommendations.  

Action: 

SFRS continue with established processes to gather information on the layout of high rise domestic buildings. 

Scottish Government will work with relevant parties to have external information plates on all high rise domestic buildings in line with the Guidance.

Recommendation 8  – That the owner and manager of every high rise residential building be required by law to carry out regular inspections of any lifts that are designed to be used by firefighters in an emergency and to report the results of such inspections to their local fire and rescue service at monthly intervals.

Recommendation 9  – That the owner and manager of every high rise residential building be required by law to carry out regular tests of the mechanism which allows firefighters to take control of the lifts and inform their local fire and rescue service at monthly intervals that they have done so.

Rationale for the recommendation as noted in the Grenfell Inquiry Phase 1 Report

78. The Inquiry report states: "When the firefighters attended the fire at Grenfell Tower they were unable to operate the mechanism that should have allowed them to take control of the lifts. Why that was so is not yet known, but it meant that they were unable to make use of the lifts in carrying out firefighting and search and rescue operations. It also meant that the occupants of the tower were able to make use of the lifts in trying to escape, in some cases with fatal consequences. The ability of fire and rescue services to take control of firefighting or fire lifts in a high-rise building is often key to successful operations."

Response & Action 

79. Under the 2006 Regulations, SFRS have enforcement powers to require those responsible for fire safety to maintain firefighting facilities in efficient working order and good repair, including firefighting lifts. Lift inspections are part of SFRS's Operational Assurance Visits activities and deficiencies are reported to those responsible for fire safety.  Local fire stations are also notified of deficiencies and details added to turnout information by Operations Control to ensure crews are aware on approach of any issues. 

80. The Practical Fire Safety Guidance for Existing High Rise Domestic Buildings recommends that firefighters lifts should be subject to monthly inspections, annual testing and regular maintenance. It is recommended that those responsible should refer to BS EN 81-72 for guidance on testing and servicing of firefighters lifts. An assessment of the impact and effectiveness of the Guidance will be carried out in 2020/21. This will include whether further details on testing fire fighter lifts and whether maintenance of passenger lifts should be included in the Guidance. The Guidance could advise those responsible for fire safety to report any defects to SFRS.

Action: 

Continue with current approach under Operational Assurance Visits. 

Amend the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings to advise those responsible for fire safety to report any defects to SFRS. 

Consideration will be given as to whether further details on testing fire fighter lifts and whether maintenance of passenger lifts should also be included in the Guidance.

Encourage those responsible to make results of safety checks available to residents where requested. 

Recommendation 30  – That the owner and manager of every high rise residential building be required by law to draw up and keep under regular review evacuation plans, copies of which are to be provided in electronic and paper form to their local fire and rescue service and placed in an information box on the premises.

Rationale for the recommendation as noted in the Grenfell Inquiry Phase 1 Report

81. The Inquiry report states: "There were no plans in place for evacuating Grenfell Tower should the need arise."

Response & Action  

82. The Practical Fire Safety Guidance for Existing High Rise Domestic Buildings Guidance, advises that residents are made familiar with "Stay put" or the evacuation strategy (where one is required to be in place).  This Guidance also advises those responsible for fire safety to consult SFRS where potential fire risks have been identified, and together consider interim mitigation measures to be put in place. 

 "Stay Put" and general principles for evacuation 

83. High rise domestic buildings are built with the principles of 'Stay Put' in mind.  Other than in exceptional circumstances, 'Stay Put' will be the default strategy in place for these buildings in Scotland. The fire separating construction is designed to contain a fire in the flat of fire origin. Accordingly, people in flats who are not affected by fire or smoke are normally safe to stay where they are. In some circumstances, residents might be at greater risk if they do leave their flat. This is the basis of the 'Stay Put' policy in response to fires in high rise properties. It has been in guidance since the 1960s and is the basis for high rise domestic building design. It is an appropriate strategy in the majority of such buildings.

84. Consequently the vast majority of buildings will not need to have evacuation plans in place beyond the "stay put" strategy.  It is only those that have identified specific fire safety risks or are fitted with evacuation alert systems (post October 2019) that would require such plans.

85. Where there is a fire, SFRS will give initial advice over the phone to residents that call.  Upon arrival, firefighters will take control of the incident and may advise further. There may be fires where, for operational reasons, SFRS decides that a partial or total evacuation of a high rise is necessary. These uncommon situations include where a fire spreads beyond the flat of origin.  Any deviation from 'Stay Put' at an incident will be initiated and led by SFRS.  For buildings without evacuation alert systems, SFRS would advise residents directly of the need to evacuate.

86. The speed and extent at which an incident is escalating will dictate the urgency of the evacuation plan. The Incident Commander will need to consider the safest and most effective way to warn and inform the residents that they need to escape from the building. This could include, for example:

• Use of intercoms or door entry systems.
• Use of public address systems.
• Use of fire alarms.
• Use of building evacuation systems.
• Use of the media and social media.
• Internal telephones.
• Systematic door knocking.
• Forcing of doors to flats.

87. This approach is supported in the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings.

88. The alternative to a 'Stay Put' is an evacuation where all, or a number of residents, evacuate the building together. Ideally, this requires a system to alert all the residents to the need to evacuate, particularly if a full evacuation is required. As noted earlier, the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings advises that where serious fire risks are identified, which require a change to the 'Stay Put' strategy residents should be informed and, SFRS should be consulted.  Those responsible for fire safety should consider what interim mitigation measures are to be put in place, in liaison with SFRS, until the deficiency has been resolved.  There are, rightly, a very few examples of this needing to happen in practice at an incident. 

89. To support 'Stay Put', effective action with residents to reinforce and raise awareness is important.  This can build on the recent work by SFRS, those responsible for fire safety in high rise domestic buildings, and the Scottish Government. This was, most notably, the fire safety information leaflets^[7] delivered to all 46,000+ flats in domestic high rise buildings in 2019/20. 

90. Research into the impact of the fire safety leaflets found that over three quarters of respondents agreed they feel well informed about what they need to do in the event of a fire.  Most knew what to do if there was a fire in their flat.  Fewer were clear on what to do if there was fire in the building, but not in their flat, with two thirds not knowing they should 'Stay Put'. Half of respondents agreed that most high rise blocks in Scotland are built to resist the spread of fire, but 35% were unsure and 16% disagreed. This shows there is further work required to raise awareness regarding 'Stay Put' and what to do in event of a fire, that should be clear and included in information provided to residents by those responsible for fire safety in the building and SFRS.

Action: 

Those responsible for fire safety of the building, supported by SFRS, continue to reinforce and raise residents' awareness of "Stay Put" and other actions which may be required in the event of fire in high rise domestic buildings. 

Recommendation 31 – That all high rise domestic buildings (both those already in existence and those built in the future) be equipped with facilities for use by the fire and rescue services enabling them to send an evacuation signal to the whole or a selected part of the building by means of sounders or similar devices.

Rationale for the recommendation as noted in the Grenfell Inquiry Phase 1 Report

91. The Inquiry report states: "There were no plans in place for evacuating Grenfell Tower should the need arise."

Response & Action 

92. From October 2019, the Domestic Technical Handbook, which supports the Building Regulations, requires the installation of an evacuation alert system in newly built high rise domestic buildings to allow SFRS to initiate a partial or full evacuation in the unlikely event that a 'Stay Put' strategy is no longer appropriate. The building manager should give contact details to SFRS so that assistance to reset the alarm/undertake maintenance can be summoned without delay.  An evacuation alert system is an additional measure to aid partial or full evacuation in buildings that are normally considered as safe. 

93. Only a small proportion of buildings will have evacuation alert systems. Such systems are a requirement only for those for which a building warrant is applied from 1 October 2019.  

94. Building Standards are not usually retrospective. Upgrading existing buildings to meet current benchmarks should be done where the level of fire risk justifies it, taking into account the time, cost and disruption to building occupants involved.

95. Due to the high level of fire separation and containment in a building containing flats, it would be unusual for there to be a need to evacuate the fire floor or the entire building in the event of a fire. The level of fire separation should be such that, other than in the flat of fire origin, residents are safe to remain within their own flat. Circumstances may arise in which fire-fighters consider it necessary to evacuate residents from a small number of other flats and, on very rare occasions, the entire building.

96. If this happens in existing buildings without evacuation systems, SFRS have confirmed they have procedures in place that could include knocking on doors, using loud hailers and Operations Control advising callers of the need to evacuate. This includes calling people back who had previously been told to 'Stay Put'. 

97. The National Fire Chiefs Council (NFCC) and the Ministry of Housing, Communities and Local Government (MHCLG), comprise the Stay Put Technical Steering Group.  This is overseeing research on means of escape from a design, management and operational perspective. The Scottish Government and SFRS awaits the research findings, as they are key to informing future approaches for evacuation.

Action 

Continue with the current approach for evacuation alert systems in new buildings only, but to review new research findings when they are available.  

Scottish Government, working with SFRS and others, will use the outcomes of the Stay Put Technical Steering Group research on means of escape, once available to review, and consider potential improvements to the current approach.

Recommendation – 32 That the owner and manager of every high-rise residential building be required by law to prepare personal emergency evacuation plans (PEEPs) for all residents whose ability to self-evacuate may be compromised (such as persons with reduced mobility or cognition).

Recommendation – 33 That the owner and manager of every high-rise residential building be required by law to include up-to-date information about persons with reduced mobility and their associated PEEPs in the premises information box.

Rationale for the recommendations as noted in the Grenfell Inquiry Phase 1 Report

98. The Inquiry report states: "There were no plans in place for evacuating Grenfell Tower should the need arise."

Response & Action 

99. A disproportionate number of fires and fire fatalities involve older people or others with recognisable "contributory factors", including physical, cognitive and mental health issues and who may have trouble self-evacuating in the event of a fire.  As noted above, to address this the Scottish Government produced the Practical Fire Safety Guidance for Existing Specialised Housing and Similar Premises, (Scottish Government: 2020).  Its main purpose is to strengthen fire safety for people who receive care or support in any specialised housing or similar premises (not limited to high rise). It has been designed to also be useful for those receiving "care at home" services or support in general needs housing.

100. The central tenet is that risk will be reduced significantly if fire safety measures meet the needs of the individual, as well as the premises as a whole. The Guidance explains how a person-centred approach can best protect those who are most at risk from fire. It provides information on the formulation of personal emergency evacuation plans (PEEPs) in appropriate settings, such as in supported housing and small care homes where they can be kept up to date and where staff may be available to provide evacuation assistance, if required.  

101. The Guidance advises that fire safety risk assessments should be conducted by people with appropriate responsibility, suitable skills and involve other people as required. Where there are multiple relevant parties, one person should be responsible for instigating, managing and coordinating the assessment and action plans and ensuring they are shared. This will normally be whoever is responsible for the specialised housing or similar premises.  

102. It is recognised that housing providers may not know the status of all residents, especially in general needs housing.  In such cases, and in line with the Guidance, person-centred risk assessments for vulnerable people could be carried out by a family member or a care provider or personal assistant with appropriate skills and level of responsibility. 

103. The Practical Fire Safety Guidance for Existing High Rise Domestic Buildings will be updated to cross refer to the Specialised Housing Guidance for relevant cases. 

104. In the event of a fire, SFRS would undertake a rescue of any person who is unable to self-evacuate and who is affected by fire or smoke, immaterial of whether there is a PEEP. They may also provide assistance in the event of a partial or full evacuation.    

105. This approach is consistent with, and supported by, existing Guidance and will be straightforward to implement.  It gives those responsible the tools to help prevent a fire in a vulnerable person's home as well as keeping them, and others, safe in the event of fire.  

Action

Continue to disseminate and support the use of the Practical Fire Safety Guidance for Existing Specialised Housing and Similar Premises to improve fire safety for vulnerable people, including PEEPs in relevant settings.  

Carry out research to monitor and learn the impact this Guidance is having and to inform possible further improvements to fire safety for vulnerable people at home. 

Update the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings Guidance to cross-refer to the Specialised Housing Guidance.

Recommendation – 39 That all those who have responsibility in whatever capacity for the condition of the entrance doors to individual flats in high-rise residential buildings, whose external walls incorporate unsafe cladding, be required by law to ensure that such doors comply with current standards.

Rationale for the recommendation as noted in the Grenfell Inquiry Phase 1 Report

106. The Inquiry report states: "Among the experts, views differ about the desirability of requiring existing fire doors to be brought up to modern standards and if necessary be replaced with doors that comply with the requirements currently in force in relation to new buildings. However, the importance of fire doors in maintaining compartmentation and protecting parts of the building other than that in which a fire has occurred is plain and in my [Sir Martin Moore-Bicks] view justifies the expense that would inevitably be incurred."

Response & Action

107. In 2018 the Scottish Government wrote to Local Authorities and Housing Associations highlighting the emerging issue around fire doors. 

108. New guidance on fire doors was produced as a result of UK Government fire tests on Glass Reinforced Plastic (GRP) composite fire doors.  The Practical Fire Safety Guidance for Existing High Rise Domestic Buildings Guidance makes reference to this issue.

109. Guidance entitled "Advice for building owners on assurance and replacing of flat entrance doors" was issued to Local Authorities and can be found online https://www.gov.scot/publications/sample-testing-of-fire-doors-letters-to-local-authority-verifiers/ (updated 2 August 2018).  

110. For buildings that have an identified fire safety issue, such as unsafe cladding, there should be adequate interim safety measures in place to prevent fire, provide early warning and provide adequate protection from fire. All flat entrance doors should be in good condition and working order, regardless of any external cladding issues.

111. This approach continues the established practice for fire resisting doors in high rise domestic buildings.

Action

Continue with current approach, as set out in the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings updating advice to local authorities as required.

Recommendation – 35 That in all high-rise buildings floor numbers be clearly marked on each landing within the stairways and in a prominent place in all lobbies in such a way as to be visible both in normal conditions and in low lighting or smoky conditions.

Rationale for the recommendation as noted in the Grenfell Inquiry Phase 1 Report

112. The Inquiry report states: "The landings in the staircase at Grenfell Tower were not clearly marked with the relevant floor number and where floor numbers were marked they did not reflect the additional floors created during the refurbishment. As a result, firefighters were unable to identify floors clearly when carrying out firefighting or search and rescue operations within the building."

Response & Action 

113. The Practical Fire Safety Guidance for Existing High Rise Domestic Buildings advises those responsible for fire safety that "floor levels and flats should be clearly numbered so that firefighters can identify them in a fire." From October 2019, a new requirement for floor and flat signage was added to the Domestic Technical Handbook which complements Building Regulations for new building work.

114. In the SFRS Operational Assurance Visits the absence of floor/flat signage are deficiencies reported to those responsible for fire safety for remediation.

Action

Continue with current approach, as set out in the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings and via the SFRS Operational Assurance Visits, and Guidance.

Recommendations for residential buildings containing separate dwellings whether or not it is a high-rise building

115. The following three recommendations apply beyond high rise domestic buildings to all residential buildings containing separate dwellings. As noted in the Scope section of the report (paragraph 17), the consensus of the GIFSWG was to consider the Phase 1 recommendations for application to high rise buildings only.  

Recommendation – 36 That the owner and manager of every residential building containing separate dwellings (whether or not it is a high-rise building) be required by law to provide fire safety instructions (including instructions for evacuation) in a form that the occupants of the building can reasonably be expected to understand, taking into account the nature of the building and their knowledge of the occupants.

Rationale for the recommendation as noted in the Grenfell Inquiry Phase 1 Report

116. The Inquiry report states: "The evidence… indicates that many occupants of Grenfell Tower were unable to read or understand the fire safety instructions placed in the lobbies throughout the building. Such information is important because it helps to save lives. In the case of Grenfell Tower, fire safety advice was prominently displayed in the lobbies, but it was written only in English, despite the fact that many of the occupants were unable to read English easily or at all. These considerations apply to residential buildings of all kinds containing separate dwellings."

Response & Action 

117. The Practical Fire Safety Guidance for Existing High Rise Domestic Buildings contains advice and information on communicating with residents on fire safety, such as using residents' handbooks and other media to engage and communicate fire safety information, and to have a channel for receiving concerns from residents.  To complement this, Scottish Government and SFRS jointly produced a fire safety information leaflet for residents of high rise domestic buildings which was delivered to every high rise home in Scotland. This was designed to be clear and accessible, using graphics and easy to read language.  Translations into the main five languages used in Scotland, in addition to English are available from the SFRS website for ongoing use by those responsible for fire safety.  

118. In addition, SFRS have accessible fire safety information for all domestic premises available to the public on the SFRS website. SFRS also provide home fire safety visits on a risk based priority to any home.  

119. These actions ensure that those responsible for fire safety in high rise domestic buildings have Guidance that includes advice on communicating fire safety information with residents with consideration on their ability to understand the information. 

Action

Continue with current approach, as per the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings and SFRS Community Fire Safety information. 

Recommendation – 37 That the owner and manager of every residential building containing separate dwellings (whether or not they are high-rise buildings) carry out an urgent inspection of all fire doors to ensure that they comply with applicable legislative standards.

Rationale for the recommendation as noted in the Grenfell Inquiry Phase 1 Report

120. The Inquiry report states: "One important reason why fire doors failed to perform their essential function [during the Grenfell Tower fire] was the absence of effective self-closing devices, some of which were broken or had been disabled or removed. Fire doors play an essential role in preventing or inhibiting the spread of smoke and toxic gases and in preserving effective compartmentation of buildings. In many cases they are critical to saving life."

Response & Action 

121. Following the Metropolitan Police investigation and fire testing of Manse Masterdor composite fire doors fitted on the Grenfell Tower, which were found to be deficient, the Scottish Government wrote to all Local Authorities and Housing Associations to bring to their attention the situation.  The Ministry for Housing, Communities and Local Government provided details from the order book for Manse Masterdor fire doors to specifically flag details to relevant bodies. All bodies were advised although this was not a comprehensive list. A Scottish version of the guidance note for existing fire doors was produced and issued to all local authorities in August 2018.

122. The Practical Fire Safety Guidance for Existing High Rise Domestic Buildings contains advice on the testing and maintenance of fire doors for those responsible for fire safety. The testing regimen is proportionate and aligns with existing standards.

123. For high rise domestic buildings, SFRS check fire doors on firefighting stairs and lobbies during their Operational Assurance Visits. Relevant deficiencies are reported to those responsible for fire safety for remediation and checked again during the next quarterly Operational Assurance Visit.

Action

Continue with current approach, as set out in the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings.

Recommendation – 38 That the owner and manager of every residential building containing separate dwellings (whether or not they are high-rise buildings) be required by law to carry out checks at not less than three-monthly intervals to ensure that all fire doors are fitted with effective self-closing devices in working order.

Rationale for the recommendation as noted in the Grenfell Inquiry Phase 1 Report

124. The Inquiry report states: "One important reason why fire doors failed to perform their essential function [during the Grenfell Tower fire] was the absence of effective self-closing devices, some of which were broken or had been disabled or removed. Fire doors play an essential role in preventing or inhibiting the spread of smoke and toxic gases and in preserving effective compartmentation of buildings. In many cases they are critical to saving life."

Response & Action 

125. In Scotland there are already standards and regulations in place regarding the maintenance regime of fire doors in buildings, which includes inspection of the self-closing device. Regulation 24 of the Fire Safety (Scotland) Regulations 2006 require those with control of the common parts of high rise domestic premises to ensure the common areas and facilities, equipment and devices for firefighter protection or use are maintained in good repair and efficient working order.  British Standard 9999 recommends 6 monthly inspections, which is reflected in the Guidance.

126. The Practical Fire Safety Guidance for Existing High Rise Domestic Buildings contains a section on testing and maintenance of fire doors, which includes consideration of self-closing devices. For high rise domestic buildings, SFRS check fire doors on firefighting stairs and lobbies during their quarterly Operational Assurance Visits. Any deficiencies with the fire doors, including issues with self-closing devices, are reported to those responsible for fire safety for remediation and checked again during the next quarterly assurance visit.

Action

Continue with current approach, as set out in the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings.

Responses to Recommendation for Government

The following recommendation was the only one directed at the UK Government, Recommendation 28 – That the Government develop national guidelines for carrying out partial or total evacuations of high-rise residential buildings, such guidelines to include the means of protecting fire exit routes and procedures for evacuating persons who are unable to use the stairs in an emergency, or who may require assistance (such as disabled people, older people and young children).

Rationale for the recommendation as noted in the Grenfell Inquiry Phase 1 Report

127. The Inquiry report states: "There were no plans in place for evacuating Grenfell Tower should the need arise."

Response & Action 

128. The National Fire Chiefs Council (NFCC) and the UK Government's Ministry of Housing, Communities and Local Government (MHCLG), comprise the Stay Put Technical Steering Group.  This is overseeing research on means of escape from a design, management and operational perspective. The research findings will be considered by the Scottish Government and SFRS with an assessment of the need for changes to the current arrangements.  New guidelines on evacuation procedures could be integrated into the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings. 

129. Some residents of Grenfell Tower said they did not receive information on what to do in the event of a fire. The Practical Fire Safety Guidance for Existing High Rise Domestic Buildings will continue to recommend that those responsible for fire safety ensure that consistent messaging on what to do in the event of a fire is provided to all residents on a regular basis. 

Action

Use the findings from the Stay Put Technical Steering Group research on means of escape from a design, management and operational perspective.

This research to inform potential changes to guidance on evacuations of buildings, including means of escape and evacuation assistance procedures and where necessary, integrating these into a revision of the Practical Fire Safety Guidance for Existing High Rise Domestic Buildings.