Publication - Consultation analysis

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.

60 page PDF

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60 page PDF

495.3 kB

Multi‑storey residential buildings - fire risk posed by external wall systems: consultation analysis
4. Risk of External Fire Spread

60 page PDF

495.3 kB

4. Risk of External Fire Spread

Question 2. Does the advice clearly explain the risk of external fire spread in both low rise and higher rise buildings?

Overview of Responses

Table 11: Does the advice clearly explain the risk of external fire spread in both low rise and higher rise buildings?
  Yes No
  Number % Number %
Individual 8 100% 0 0%
Organisation 11 65% 6 35%
Fire Safety / Engineering / Consultants 2 50% 2 50%
Misc Construction 1 33% 2 67%
Finance and Insurance 3 100% 0 0%
Housing and Property Management 1 50% 1 50%
Local Government 2 100% 0 0%
Residents and Tenants Groups 1 50% 1 50%
Further and Higher Education 1 100% 0 0%
Total 19 76% 6 24%


4.1 A vast majority of consultation respondents reported that the advice clearly explained the risk of external fire spread in both low rise and higher rise buildings (19, 76%), Table 11.

4.2 Individuals were more likely to note agreement with Question 2 than organisations. While a majority of organisations agreed that the advice clearly explained the risk, this varied by sub-group.

4.3 Where qualitative feedback was provided by this cohort of respondents (i.e. those that responded "yes"), this in the main confirmed that the Draft SAN's explanation of the risk of external fire spread in both low rise and higher rise buildings was indeed clear.

4.4 This is reflected in various respondent quotes such as "reasonably so", "clearly and concisely stated and is well evidenced for the various types of cladding systems" and "it seems very clear" (e.g. University Safety & Health Association (USHA) Fire (Scotland) Group, Individuals). Further, Kingspan voiced support of the guidance in that each risk assessment/appraisal must be building specific.

4.5 A number of these respondents, however, took the opportunity to highlight additional points of note. Firstly, a couple of respondents indicated that third party advice would be required to aid understanding of the guidance in relation to the risk of external fire spread in both low rise and higher rise buildings or that further clarity was required. These points are illustrated in the respondent quotes below.

"While providing technical clarity, from a lenders perspective the level of technical detail is such it will require third party professional/expert input to support understanding".

UK Finance

"….there should be further advice provided to lenders and RICS members as to the difference in Scottish and UK Government advice, and a clarified approach in recommending EWS1s are required in a home report and to satisfy lenders. RICS advice is similar to the draft advice note, in that buildings of 3 storey (generally 11m) or less, should not require an EWS1 form. However, in practice, surveyors and lenders are negating liability and requesting they are carried out in all multi-storey buildings. It should be made clearer that in the first instance a fire risk assessment should only be required, and a further intrusive inspection should be completed, should there be concern or doubt over the materials and other factors of the report".


4.6 Wider individual points raised include the following:

  • It was noted that future changes and uncontrolled fires would need to be considered given their consideration by SFRS in determining access; and
  • The National Fire Chiefs Council suggested that "specialised housing"[2] could be included in the examples provided in the advice note (Section 2.5 – "in buildings under 11m, remediation, if required, may only be necessary for buildings which are considered higher risk e.g. hospitals, care homes, and other premises with delayed evacuation") due to the vulnerability of occupants.

4.7 Almost one-quarter of respondents (all organisations) reported that the advice did not clearly explain the risk of external fire spread in both low rise and higher rise buildings (six, 24%), Table 11.

4.8 These respondents raised various concerns with the Draft SAN and went on to suggest areas where the guidance in relation to the risk of external fire spread in both low rise and higher rise buildings could be further clarified, strengthened and/or improved to aid understanding for its intended audience.

4.9 Firstly, Ravelston Terrace Cladding Working Group noted that the SAN "does not help owners understand how the risk of fire spread would impact on their ability to evacuate". The point made was that the focus of the Draft SAN was on the "remediation of all buildings to the latest gold standard which has no regard to the ability to evacuate. Most fires would spread throughout a building if no action is taken. The important question is, "how long will it take". It was noted that the Draft SAN could take greater cognisance of the ability of occupants to evacuate from buildings of varying heights.

4.10 This view was further supported by the Fire Sector Federation who noted that the guidance could be improved if the "context of vertical fire spread could be made clearer"[3].

"Our reasoning is that commencing with this explanation stresses the relevance of both internal and external fire sources. The mechanism for fire spread…and the key consideration of unprotected openings, EWS materials, number of exposed compartments and time in that process. This would also lend itself to the consideration of height and why rapid external fire spread is a concern below 11m. Given the wide readership this document is likely to attract this would ensure that any readers have the right context".

Fire Sector Federation

4.11 ARUP pointed to the need for a clear and simple explanation in the Draft SAN as to why the external wall of a building is an area of particular risk. It was noted that the guidance could be improved by "explaining why the fire performance external walls are so important to the safety of occupants and integrity of the building".

"The only distinction….between low and high rise buildings is in the technical definition of height, rather than the differing consequences of fire in an external wall. The guidance does not explain why occupants in a high-rise building may be at more risk from an unsafe cladding system than those in a low-rise. Therefore, building owners/managers…are unlikely to be able to understand without clarification the inherent differences in design of these building types".


4.12 ARUP went on to highlight where it felt further clarity was required within the advice note, as illustrated in the quote below.

"The guidance does not cover all possible component parts of an external wall, particularly with regards to fire safety (e.g. fire stopping). It is recommended that the guidance provides examples and clear definition on all possible aspects of external walls and fire safety features. The guidance….contradict the functional requirements of current and previous regulations, in that fire and smoke are permitted to spread from the apartment of fire origin (fire compartment) to multiple apartments (separate fire compartments). These explanations should be reconsidered and addressed …. (the inference being currently that it is safe, acceptable, and compliant to allow fire and smoke to spread in this way, when it is not)".


4.13 Rockwool Ltd and MIMA commented that the Draft SAN downplayed the risks posed by building fires and the importance of ensuring compliance with current regulations. The point made is reflected in the quote below.

"Fire Statistics: We were disappointed that a section appearing to downplay the risk posed by building fires has been included in an advice note intended to encourage the diligent assessment of potential fire risk. The narrative around the decline of fire related deaths and injuries is also similar to what the Ministry of Housing, Communities and Local Government (then the Department for Communities and Local Government) said before the tragic fire at Grenfell tower. Rockwool firmly believes that we should not wait for fire related deaths to increase before regulations are strengthened. Furthermore, the Association of British Insurers (ABI) has countered this type of data with its own research, showing that the severity of fires has actually increased".

Rockwool Ltd

4.14 Linked to this was wider feedback from MIMA that the Draft SAN places "unreasonable expectations on installers to ensure external wall systems made of combustible materials are installed as per BS 8414 tests". It was reported that test reports are confidentially held by their sponsors, and detailed/relevant information on all the components tested and their precise fixing and relative configuration is not made available.