Multi‑storey residential buildings - fire risk posed by external wall systems: consultation analysis

An independent analysis of consultation responses to the Draft Scottish Advice Note (SAN): Determining the fire risk posed by external wall systems in existing multi-storey residential buildings.

Executive Summary

1 This Executive Summary presents a brief overview of the independent analysis of consultation responses to the Draft Scottish Advice Note (SAN): Determining the fire risk posed by external wall systems in existing multi-storey residential buildings.

2 Both the UK Government and the Scottish Government have been developing updated advice for building owners of multi-storey, multi-occupied residential buildings following the Grenfell Tower fire in June 2017. In Scotland, Scottish Ministers agreed to set up a Technical Working Group to develop a SAN to bring clarity to the different legislative requirements and guidance in Scotland and take account of the key findings from large scale and intermediate scale fire testing of external wall cladding systems carried out by the UK Government.

3 The Draft SAN (Version 3) provides advice for those responsible for fire safety in residential buildings including building owners/managers, and residents groups where they exist, who are responsible for determining the fire risk posed by external wall systems on existing multi-storey residential buildings. The advice will also be of interest to fire risk assessors and specialist wall appraisal experts.

4 For the purposes of the Draft SAN, external wall systems include: cladding systems (i.e. outer cladding panel, support rails, cavity barriers and any insulation material exposed in the cavity behind the cladding), spandrel panels, window infill panels, balconies, solar shading and any other architectural feature or attachment to the building structure.

5 The scope of the Draft SAN applies to existing multi-storey residential buildings, including: blocks of domestic flats, including sheltered housing, extra care housing and supported flats; student accommodation, including boarding schools and halls of residence; hospitals or other premises with overnight patient accommodation; care homes; hotels and boarding houses; hostels; and prisons.

6 A targeted approach to the consultation was adopted given the Draft SAN's technical nature, and involved three main strands:

  • Webinars – 276 attended.
  • Consultation document and questions – 27 responses.
  • Meetings with Scottish Fire and Rescue Service (SFRS), Institution of Fire Engineers (IFE) (Scotland), and representatives from the Ministerial Working Group for Mortgage Lending.

7 The findings of the consultation will be used by the Technical Working Group to revise and finalise the SAN prior to its publication

Table 1: Summary Analysis Feedback
Consultation Question Main Feedback
Q1. Overall, do you find the advice helpful in understanding the guidance, legislation and processes as they apply to buildings in Scotland?
  • A majority reported "Yes" (72%).
  • The main theme that emerged was that the advice note was "welcomed", "helpful", "useful" and a "positive step". The advice was largely considered helpful as it provided useful background to, and a practical understanding of, key Building Standards legislation, and described the links between relevant pieces of legislation and the guidance. There was also feedback that it helped clarify the intent of the Scottish Government and set out high-level parameters within which the guidance was intended to be applied.
  • There were various comments around the inherent challenges for any non-technical person in fully understanding the detail of the guidance (e.g. mortgage lenders, homeowners, residents and tenants groups). Suggestions were made to help enhance the document's readability (e.g. greater use of visualisations, reducing volume of text and level of information).
Q2. Does the advice clearly explain the risk of external fire spread in both low rise and higher rise buildings?
  • A vast majority reported "Yes" (76%).
  • There were a variety of comments that simply confirmed that the advice in this area was clear, concise, and/or well evidenced. There was also acknowledgement of the advice that each risk assessment/appraisal would need to be building specific, and that third party advice would likely be required.
  • A variety of comments were provided around how the Draft SAN could be further clarified, strengthened and/or improved to aid understanding for its intended audience.
Q3. Does the advice clearly explain the risk of Metal Composite Material (MCM) cladding?
  • A vast majority reported "Yes" (79%).
  • Few qualitative responses were provided by those who reported "Yes". This included a mix of responses who confirmed that the advice was clear, while others noted aspects where the Draft SAN could benefit from greater clarity regarding the risk of MCM cladding.
  • The remainder of respondents felt that the advice note's reference to the risk of MCM cladding could be further simplified, clarified and/or improved to avoid confusion and to aid greater understanding for the intended audience (e.g. by reducing the use of "jargon" in sections relating to fire performance, by amending language used, ensuring clear and full definitions of terms used, by annexing the technical detail with clear and simplified messaging in the main body of the document).
Q4. Does the advice clearly explain the risk posed by Category 3 Aluminium Composite Material (ACM) with an unmodified polyethylene filler, and what actions building owners should take if their buildings have these systems?
  • A vast majority reported "Yes" (75%).
  • Similar to previous questions, there were a mix of qualitative responses that noted the advice was clear, while others questioned elements of the advice as it is currently presented in the Draft SAN, thought it was ambiguous or lacked clarity, or thought there were too many caveats provided.
Q5. Is the guidance on non-ACM cladding (including High Pressure Laminate) panels helpful?
  • A majority reported "Yes" (72%).
  • There was acknowledgement within the feedback that the guidance on non-ACM cladding, including High Pressure Laminate (HPL), was welcomed given that the fire classification of this type of cladding varies significantly, the potential risks associated with non-ACM cladding, and the increased prevalence of its use in buildings.
  • There were also various comments that suggested areas where the guidance in this area could be further clarified and/or improved. For example, concerns were raised about the "narrow focus on ACM PE in Scotland", and that other types of non-ACM cladding (e.g. timber, insulated core sandwich panels, rendered EPS, etc) were as prevalent as MCM and HPL. Others considered the UK Government test and analysis report "Fire performance of cladding materials research" to be "flawed" and "minimised the risks and potential dangers associated with using non-ACM combustible materials".
Q6. Is the guidance on partial cladding helpful?
  • A vast majority reported "Yes" (76%).
  • As above there were a mix of qualitative comments. There were some that noted the advice was helpful as direct consideration of partial cladding in terms of fire spread risk within existing conditions, while others noted aspects where there was considered to be the potential for confusion and/or where further detail or clarity would be required.
  • For example, it was felt that more detail would be required: given how in-depth risk assessment/external wall appraisal is; in order to aid understanding of, and communication with, building owners/managers; and to define and distinguish between terms used in the Draft SAN,
Q7. Does the guidance clearly explain the difference between a fire safety risk assessment which considers external wall systems and one that requires an intrusive external wall appraisal?
  • A majority reported "Yes" (70%), but mixed views in particular from organisations.
  • Few respondents that answered "Yes" provided further qualitative feedback. Where comments were provided, this tended to focus on the need for clearer definitions of terms used or concerns with language used in that section of the Draft SAN (e.g. acceptable level of risk).
  • The remainder of respondents similarly raised concerns with this section of the Draft SAN and felt it was either limited, unclear in parts and/or potential misleading. A couple of specific examples include: perceived confusion over which materials and combinations are safe to use and how to identify them; a call for further advice to support assessors to determine where buildings do or do not require an intrusive external wall appraisal; and greater clarity regarding the level of information and physical inspection necessary/expected to determine the safety of a building.
Q8. Is the guidance clear on when a fire safety risk assessment may need to be informed by an intrusive external wall appraisal?
  • A majority reported "Yes" (61%), but mixed views in particular from organisations.
  • A common theme was that the guidance could be clearer on when a fire safety risk assessment may need to be informed by an intrusive external wall appraisal.
  • For example, on the range of factors that might be sufficient to consider the building safe without the need for an intrusive external wall appraisal. Wider points were around the challenges: for risk assessors to reach a firm conclusion about the external wall build-up without an intrusive inspection issues; for competent fire risk assessors to obtaining the necessary Professional Indemnity cover; and for business owners/ managers in obtaining building plans and/or that building records might provide insufficient detail; and
Q9. Is there any guidance that is missing or needs to be improved to provide greater clarity?
  • A vast majority reported "Yes (96%).
  • The comments provided were wide-ranging. Many respondents provided suggested changes to wording or phrasing within different sections of the Draft SAN and/or identified aspects that could be updated.



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