Updating of the School Premises (General Requirements and Standards)(Scotland) Regulations 1967: consultation response analysis

Executive Summary

This summary sets out key messages from analysis of responses to a consultation on the Updating of the School Premises (General Requirements and Standards) (Scotland) Regulations 1967. The consultation proposals were provided under four categories, and suggest a number of areas for change. The four categories were:

• Regulations proposed to remain unchanged
• Regulations proposed to be updated
• Regulations proposed to be removed
• Regulations applicable to independent school

Common Themes

The response to the consultation was overwhelmingly positive with agreement to all but one proposal; that regarding sites for playing fields.

Responses were received from a wide range of organisations and individuals with an interest in school premises or education more broadly. Most contributors offered comment on their specific areas of interest or professional expertise, and details are provided within the body of the report.

The proposals which attracted most comments were those in relation to sites for playing fields, outdoor education and recreational areas, acoustic conditions and sanitary accommodation for pupils.

It is important to note that comments were requested at each question from those not in agreement with the proposal. These should be differentiated from those provided by respondents in agreement and this is stipulated within the report.

Common themes identified throughout include:

Sites for Playing Fields

Great importance was placed on ensuring children had access to nature and natural grassed areas; this was considered essential to promote health and wellbeing, play, socialisation and for children to learn to take risks. There was a strong view that a minimum space requirement should be set to ensure this was the case. It was also considered essential that the principles of the ‘Grounds for Learning’, ‘Play Scotland’ and ‘Learning for Sustainability’ strategies should be embedded into the Curriculum for Excellence through increased access to natural outdoor space.

The balance between Regulation and Local Flexibility

A need was recognised to ensure an appropriate balance between formal Regulation and flexible and informed decision making at local authority level. Local knowledge was seen to be essential in making the right decisions for individual communities.

It was further requested that detailed guidance be provided on key issues in relation to school premises. It was felt that such guidance would avoid any potential misinterpretation of requirement, and where appropriate would support local decision making to take place.

Safeguarding Standards

Although in agreement with all proposals for Regulations being removed, concerns were expressed that this may lead to a fall in standards or a lack of uniformity across schools. It was therefore requested that the Scottish Government made it clear that the requirement still existed within other legislation and that this was clearly signposted to.

Promoting Inclusion

Some challenges may be faced in implementing the Regulations in campus style schools with shared facilities, or mainstream schools where inclusion was a principle driver. Teaching and playing space was shared by early years, older children and young people with additional support needs. This was particularly raised in terms of acoustic requirements, storage and differing requirements for play.

Promoting Equality

The additional consideration given to children and young people not identifying with their biological gender was broadly welcomed as was the potential provision of gender neutral toilet and washing facilities. The need for gender specific facilities was an area of continuing debate.

All respondents agreed that the proposals would have no detrimental effect on those with protected characteristics, and indeed went some way in supporting greater equality and inclusion.

A Whole School Approach

A need was identified to consider the entire school site and the requirements placed on it. Increasing demands for parking and access requirements were seen to impact on a school’s ability to meet some individual Regulations; for example, sufficient pitch and play space and a desire to promote access to the natural environment.

Children First

Priority should always be placed on making changes that support better educational outcomes for children and young people, even if at times this requires additional investment in a time of austerity.

The Consultation Process

The opportunity to take part in the consultation was both welcomed and valued. A significant majority (80%) of respondents were either very satisfied, satisfied or expressed no concerns on the consultation process itself. A further 84% held the same opinion when asked about their experience using Citizen Space.

Future learning points were identified as:

The need to ensure that consultations are presented in clear English and can be easily understood; and,

That consideration should be given to greater use of free text for additional comments in the future.