Building and Fire Safety: Cameron House Hotel short life working group minutes - May 2023

Minutes from the meeting of the group on 23 May 2023.

Attendees and apologies

Scottish Government officials

  • Stephen Garvin, Deputy Director, Building Standards Division (SLWG Co-Chair) – chair for this meeting
  • Maureen Rooney, Deputy Director, Safer Communities Division (SLWG Co-Chair)
  • Lisel Porch, Safer Communities Division
  • Chris Booth, Safer Communities Division
  • James Clark, Safer Communities Division
  • Terri O’Donnell, Building Standards Division
  • Benny Rooney, Building Standards Division
  • Steven Scott, Building Standards Division
  • Callum Grigor, Sponsorship and Historic Environment Division
  • Tom Hardy, Safer Communities Division

External members

  • Clare Winskill, Scottish Tourism Alliance
  • Steven Bosworth, Scottish Fire and Rescue Service (SFRS)
  • Sam North, National Trust for Scotland
  • Alan McAulay, Local Authority Building Standards Scotland (LABSS)
  • Steven McCallum, National Trust for Scotland
  • Marc Crothall, Scottish Tourism Alliance
  • David Weston, The Scottish Bed and Breakfast Association
  • Margo Paterson, Hostelling Scotland
  • Fiona Campbell, The Association of Scotland’s Self-Caterers (attended part of the meeting)
  • Peter Drummond, Royal Incorporation of Architects in Scotland (RIAS)


  • Elizabeth McCrone, Historic Environment Scotland 
  • Colin Hird, Building Standards Division
  • Helen Stephenson, Sponsorship and Historic Environment Division
  • Leon Thompson, UK Hospitality, Scotland

Items and actions

Welcome and introductions

The chair invited any new members or officials to introduce themselves. 

Note of the last meeting and matters arising (paper 03-02)

No comments were made on the previous minutes. Actions from the previous meeting discussed. It was highlighted that any interest can be noted at any time. Website is now up and running for the CHH SLWG. Officials will issues the link to the website with the note of the meeting.


  • officials will issue the webpage for all to comment on by COP 2 May 2023: Completed
  • officials to issue register of interest paper. If anyone has anything else please send to officials: Completed
  • the BS Hub will issue their contact details for all to get in touch with any general issues with the building standards system, now or in the future: Completed
  • SFRS to provide a note of the number of audits in hospitality and hotel premises since implementation on 6 March 2023: See below, Completed
  • copies of documents on audits to be provided to all members: See below, Ongoing
  • feedback to be provided at the next meeting from officials on how the audits and letters are being perceived by external members: Completed

Actions in relation to recommendation 6 were reported by SFRS. They have completed 160 audits on premises. A copy of the handover sheet and auditing details can be shared with the SLWG. 


  • officials to include a link for the website
  • officials to update the website with the notes of the meetings
  • auditing details and handover sheet templates to be issued to members by SFRS

FAI report recommendations 4 and 5 paper (paper 04-03)

The purpose of the paper is to seek comments from the group. Recommendations 4 and 5 are for the Scottish Government and relates to conversion of historic buildings. 

Role of planning permission

The paper considered the potential role of planning permission and listed building consent. It was agreed that this is not the right trigger for automatic fire suppression systems in the conversion of buildings to hotels. There was agreement that this was therefore an issue to be further considered under the building regulatory framework.

Members highlighted that there was a need to work on communicating with the planning colleagues, which is not always done and not always clear. It varies across the country dependent on each authority. A member highlighted that it may be worth HES looking at their relevant guidance in this area. 

Cost/benefits analysis

A cost benefit analysis would be required as part of a review of the relevant building standards for automatic fire suppression. Members agreed that research should be undertaken on the cost benefit of installing automatic fire suppression systems when converting historic properties to hotels.

Members also noted that the research should also consider other relevant issues. The following points were noted:

  • understand where the risk lies in historic and converted relevant buildings
  • what experience and practice exists in other countries
  • what is the contribution to property protection, although members noted the primary objective of building standards and fire risk assessment is life safety

It was proposed that a meeting be set up between BAFSA and Scottish Government officials to discuss current practice with regards to use of automatic fire suppression systems in historic buildings.

Fire safety regime

Recommendation 5 was discussed and it was highlighted that the special risks posed in complex historic buildings were referred to in guidance. The FAI was more about how we ensure that people are made aware of them and the risks from cavities and voids. Recommendation 5 is not specific about when the conversion is taking place and so still needs to be captured within existing historic buildings being used as hotels. Members noted that equipping fire risk assessors to understand the risks in older converted buildings is imperative.

A member requested that the draft regulations are clear about what is required in the conversion of buildings to hotels. Wording has to be clear and concise in order to understand the output. 

It was recommended to the SLWG that the expert group should cover both existing historic buildings/assessment of cavities and voids (5) and future conversions (4). Members accepted this recommendation. 

Historic Environment Scotland (HES)

It was proposed that the suite of guidance from HES will be scrutinised by the expert group. This is in accordance with recommendation 5. It was noted that the HES Guide for practitioners 6 has to be in ‘sync’ with other relevant publications. Officials noted that they are already discussing this with HES. Officials also noted that HES are about to start a formal review of the document and this will be in liaison with the Scottish Government. The timing for this review will fit in well with the expert group. 

Short term action

As a short-term measure it was proposed that where a building warrant is applied for to convert a historic property to a hotel should be referred to Building Standards Division, as a risk management approach. This can be carried out via an amendment to the Section 34 letter. 

Members asked about the trigger for referral via the Section 34 letter, would it include all sizes and types of accommodation, or be limited in scope. Member noted that the number of bedrooms can be problematic due to differing hotel layouts and design of buildings. 

The proposal was accepted by the SLWG, subject to a sub-group meeting to discuss the change to the letter. The approach would be subject to Ministerial approval.

Long term action

Officials noted that an expert working group to consider recommendations 4 and 5 is being proposed. This would act as a review group for building standard 2.15 on automatic fire suppression systems. It could consider aspects around conversions of other properties into hotels. Experts would be from areas such as fire testing, fire engineering, construction, academia, architecture, HES and the hotel industry. It is important to have a rounded group with experience from the different backgrounds. There may be a need to split the interests of this group into sub groups looking at each recommendation. 


  • officials to set up a meeting with BAFSA
  • officials to issue the slides from the meeting
  • BSD and LABSS/ the Building Standards Hub to meet discuss the application of the Section 34 letter to relevant conversions

SLWG report

Officials will begin to draft the SLWG report, which will encompass the full work of the group. Draft versions of relevant sections and the full report, when ready, will be issued to members.

Officials will report progress to the Ministerial Working Group at its meeting on 21 June.


  • officials will issue the SLWG report a week before the next meeting
  • as noted above

Any other business

No other business discussed. 

Date of next meeting(s)

27 June 10.30–12.00

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