11. Any Final Comments
11.1 Respondents were given the opportunity to provide any final comments regarding the Draft SAN and consultation process.
Overview of Responses
11.2 Firstly, most respondents repeated their views to Question 9 about specific areas where they thought advice was missing or very specific points relating to the different sections of the Draft SAN, such as suggested changes to wording and phrasing. As stated in Section 10, 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.
11.3 Secondly, most respondents also used the space for further comments to highlight the potential wider impact and implications of the Draft SAN as set out below e.g. implications for Fire Risk Assessors and impact on housing market.
11.4 Some respondents noted their appreciation at being given the opportunity to participate in the consultation process whilst it was also stated that "it is welcome to understand that Scottish Government are working to clarify legislation/advice on EWS and Fire Safety, as it is very important and having a severe impact nationally".
11.5 A few respondents reiterated points around the potential implications for Fire Risk Assessors, which included the following:
- A couple of respondents highlighted that the Draft SAN contains a suggestion that Fire Risk Assessors can make a judgement on external wall systems and noted how this could increase Professional Indemnity Insurance (PII) to an "unsustainable level". One of the respondents reported that this could "possibly endanger the fire safety regime of Scotland" with capacity issues given that there would be "few if any Fire Risk Assessors available with PII to carry out Fire Risk Assessments"; and
- One respondent raised concern that that the requirement for Fire Risk Assessors to be accredited, as implied within Draft SAN, would display a lack of recognition and consideration for non-accredited Fire Officers e.g. those operating within the NHS, Higher and Further Education "who undertake frequent fire safety risk assessments with confidence and competence".
11.6 Feedback from three organisations (Rockwool Ltd, The Property Managers Association Scotland, and Mineral Wool Insulation Manufacturers Association) was that the Draft SAN "doesn't go far enough". All raised concerns that the Draft SAN does not fulfil its fundamental purpose of ensuring "safe and fit-for-purpose buildings… as it allows the use of combustible materials on buildings". As such, the three organisations called for greater enforcement with a ban on combustible materials as well as an updated audit of existing buildings to "identify all combustible insulation and cladding materials used on the façades of all high-rise and other high-risk buildings".
11.7 Some respondents raised the issue of potential impact on the housing market with concern about the inclusion of EWS1 forms within the Draft SAN despite its "catastrophic impact on sales of flats in the UK":
"It should be noted that use of the EWS1 form should be treated with caution, as the system does not appear to be working for UK government, RICS, lenders or houseowners, and is largely used as financial instrument for underwriting mortgages. Furthermore, various instances of fraudulent use of EWS1 forms have been reported across mainstream media. We encourage these points of caution to be communicated within the SAN guidance should references to EWS1 be retained".
11.8 Finally, a couple of respondents reinforced the importance of ensuring the Draft SAN was accessible to, and able to be used by, both professional and non-technical audience/general public. This could be aided by the inclusion of diagrams/illustrations, and further clarifying the roles and responsibilities for any actions required to be undertaken in the implementation of the guidance.