Publication - Advice and guidance

Fire safety guidance consultation: analysis of responses

Published: 13 Jun 2018
Safer Communities Directorate
Part of:

Analysis of consultation responses on the practical fire safety guidance for existing premises with sleeping accommodation.

8 page PDF

185.1 kB

8 page PDF

185.1 kB

Fire safety guidance consultation: analysis of responses
4. The responses

8 page PDF

185.1 kB

4. The responses

4.1 Overview

There were 37 responses in total:

1. Aberdeen City Council
2. Aberdeenshire Council
3. Airbnb
4. Arup
5. BAFE (British Approvals for Fire Equipment)
6. British Holidays and Home Parks Association
7. British Hospitality Association
8. Care Inspectorate
9. Certsure LLP
10. Chartered Institute of Housing Scotland
11. Clan Gordon Limited
12. East Dunbartonshire Council
13. East Renfrewshire Council's Housing Service
14. Falkirk Council
15. Gowrie Care Ltd
16. Health and Safety Executive - Transport and Public Services Unit
17. Historic Environment Scotland
18. Hoare Lea
19. Knoydart Foundation Bunkhouse
20. NHS Grampian
21. Olsson Fire & Risk UK Ltd
22. Port of Leith Housing Association
23. ROCKWOOL Group
24. Rushbrook Consultants Ltd
25. Scottish Council on Deafness
26. Scottish Fire and Rescue Service
27. Scottish Water
28. Shetland Islands Council
29. South Lanarkshire Council
30. The Association of Scotland's Self Caterers
31. Unite Scotland
32. University of Edinburgh
33. Institution of Fire Engineers
4 individual respondents

4.2 Respondent Groups

Type of Organisation/Sector Number of Responses
Local Authority 7
Individuals 4
Academic 1
Fire Risk/Safety Consultant 11
Other e.g. charities/health/professional organisations/manufacturer 14


As the majority of the comments on content came from organisations with specific interest in fire safety, suggestions for inclusion or amendment covered a range of topics, many of which are of a fairly technical nature.

Question 1

Three fire safety guides are being combined to assist with reference and future updating. Do you have any suggestions for improving the structure of the combined guide?

23 respondents commented on this question.


There were many constructive responses on the combination of the guides including that the new format is concise, simplified, logical and user friendly.

In addition to these comments, it was suggested that more graphics/diagrams were included throughout the document, and that more emphasis should be placed on the fact that the guides are for existing buildings.

Question 2

Are there any changes that should be made to the content of the guide?

24 respondents commented on this question.


The respondents offered a range of mainly technical suggestions and additions to specific paragraphs as well as requesting that some of the guidance was clearer.

A common theme in the responses was uncertainty with the scope of the guidance. As a result we have made changes to clarify the scope of the guidance and included guidance on the application of fire safety law. This has included the insertion of a new annex.

Two respondents thought that the revision was introducing a higher level of benchmark for certain room doors. We agreed with this and therefore amended the guidance in this area.

In response to other comments on technical issues, where we thought it appropriate, we have accordingly amended the guide through additions, deletions and some re-ordering of paragraphs.

Question 3

Is there any information or guidance that is not covered in the revision which you think needs to be included?

12 respondents commented on this question.


These were a number of mainly technical suggestions. Where we thought it appropriate, we have accordingly made some amendment to the guide.

Question 4

Do you have any other comments on the guidance document?

23 respondents commented on this question.


From those who provided additional comments, it was clear that the respondents felt that the Annexes to the guidance were particularly helpful and easy to read. Overall they felt the guidance to be generally clear and informative and that this will contribute to greater future safety in Scotland especially in support of the dutyholder.

One respondent suggested that there should be wider promotion of this guidance to make the relevant dutyholders aware of its existence.

Question 5

An Equality Impact Assessment ( EQIA) and partial Business Regulatory Assessment ( BRIA) are also available, and we welcome any comments you may have on each of these documents.

Only one comment was received on the BRIA and that was to make an easy read version of these forms available.

We would like to thank all respondents for taking the time to respond to this consultation.

In light of the comments received, the Practical Fire Safety Guidance for Existing Premises with Sleeping Accommodation was amended in a number of areas.

Scottish Government
Fire and Rescue Unit: Safer Communities Division
31 May 2018