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.

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10. Areas of Guidance Missing or Requiring Clarification

Question 9. Is there any guidance that is missing or needs to be improved to provide greater clarity?

Overview of Responses

Table 18: Is there any guidance that is missing or needs to be improved to provide greater clarity?
  Yes No
  Number % Number %
Individual 8 100% 0 0%
Organisation 15 94% 1 6%
Fire Safety / Engineering / Consultants 4 100% 0 0%
Misc Construction 3 100% 0 0%
Finance and Insurance 1 50% 1 50%
Housing and Property Management 2 100% 0 0%
Local Government 2 100% 0 0%
Residents and Tenants 2 100% 0 0%
Further and Higher Education 1 100% 0 0%
TOTAL 23 96% 1 4%


10.1 Almost all respondents felt that there was either something missing from the guidance and/or that it could be improved to provide greater clarity (23, 96%), Table 18.

10.2 The comments provided were wide-ranging, and have been clustered into the following themes.

10.3 Firstly, many respondents provided suggested changes to wording or phrasing within different sections of the Draft SAN and/or identified aspects that could be updated. Every consultation response will be reviewed by the Scottish Government Building Standards division and the Fire and Rescue Unit in order to amend the Draft SAN where appropriate.

10.4 Secondly, several respondents suggested that the Draft SAN could be improved if it:

  • Made greater use of visualisations (e.g. flow charts, charts, process maps, photographs, roles and responsibilities) to help communicate key points more clearly and to help the audience understand it; and
  • Used Plain English reporting (or had a separate non-technical version) to improve accessibility and readability, in particular for the non-technical audience (e.g. homeowners, residents and tenants groups, mortgage lenders).

10.5 It was noted by several respondents that greater clarity within the guidance on the correlation between the Draft SAN and the use of EWS1 forms. If appropriate, it was noted that further guidance might be required that acknowledges and mitigates the challenges and issues with EWS1 forms already faced in the rest of UK (e.g. these respondents pointed to cases of EWS1 forms that have been fraudulently signed) and, if necessary, advice on how to procure a form. This point is reflected in the respondent quotes below

"You say that a fire safety risk assessment is not a legal requirement in Scotland, but it is a requirement by the mortgage lenders as a means to obtaining an EWS1 certificate if you want to sell your property. And EWS1 certificates are like hens teeth!"


"To very quickly list some of the real problems of the rUK advice notes, with this advice note containing all the same flaws - EWS1 forms fraudulently signed, mortgage providers questioning skills of assessors, buildings of almost exact same construction being given different ratings, building occupants being kept in the dark about findings, no way for anybody to check the validity of an artefact and no way to confirm or otherwise if a given building has been assessed. The real kicker is it doesn't even begin to address the issues with EWS1 form, indeed the guidance merely nods to it and says it's something unrelated."


10.6 Some respondents (e.g. Rockwool Ltd, ARUP, MIMA and Fire Sector Federation) noted concerns that the guidance could be misinterpreted, and that despite the recent update:

"the BS 8414-BR 135 test and classification procedure falls well short of providing the necessary level of assurance that the cladding systems tested will perform to an adequate standard of safety in the event of a real fire, on a real building, with cladding components as actually installed".

Rockwool Ltd

10.7 As such, it was suggested that other testing, including "bench scale testing" (e.g. ATR-FTIR, EDXRF, TGA) could also be considered within the guidance.

10.8 Others felt that the scope of the guidance could be widened to give due consideration of, for example:

  • Other measures of fire risk (e.g. combustibility, risk based approach, Euroclass ratings system);
  • Common construction types (e.g. masonry cavity walls, structural timber behind a leaf of masonry or ETICS systems); and
  • a broader definition of buildings (e.g. inclusion of "hospitals, schools, entertainment venues and other buildings with vulnerable occupants, regardless of height, and non-residential two-storey buildings such as offices").

10.9 The respondent quote below is reflective of the points raised:

"Given the growing concern and issues surrounding the purchase and sale of homes across the UK relating to external wall systems and use of EWS1 forms, we believe the guidance could go further in providing a more definitive and agreed interpretation of "acceptable" and "unacceptable" levels of risk based upon deviations from the benchmark standard set by the advice note. This would have the benefit of supporting a consistent approach to appraisal and determination of appropriate and pragmatic courses of action and help alleviate issues currently being experienced by affected homeowners looking to buy, sell and re-mortgage their homes".

Homes for Scotland

10.10 According to a few respondents, the guidance could be clarified to set out its potential impact and implications for particular groups, such as homeowners. Also, if remedial action is required, these respondents reported that it would be useful if the guidance set out who was responsible at each stage of the process (e.g. who is responsible for cost - flow chart might help illustrate what happens when remediation work is required). An example of how the guidance could clarify the implications for homeowners is reflected in the respondent quote below.

"The whole document is predicated on there being a Fire Risk Assessment (FRA) in place. It is unlikely that these documents exist for most high rise buildings. There requires to be some form of description as to how groups of owners can go about preparing and owning FRAs for their homes".


10.11 Another suggestion was that the Draft SAN could consider alignment with and/or learning the lessons from guidance that applies in the rest of UK and Europe (e.g. rest of UK looking at exemptions for under 18m; issues with EWS1 forms):

"Overall the guidance is not clear enough far too much 'maybe', 'might' and 'could'. It needs to be prescriptive in almost all areas, we know this from the failures of the rUK advice notes… it repeats all the same flaws and we can expect all the same problems. It also has the same ability for fraud and lack of transparency of the rUK advice notes".


10.12 Finally, a couple of respondents suggested that the Draft SAN could include more signposting to additional information and advice as it was stated that this could be furthered in places:

"Section 1.10 of the advice note references that "domestic building owners are encouraged to make use of the government's free screening programme to confirm the category of the core/filler material." However, no further information is provided to readers as to where to find more information or access this programme. In that context, the advice note should provide links through to referenced information as well as provide greater detail of the support packages available to support affected homeowners".

Homes for Scotland



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