Building and Fire Safety Expert Working Group minutes: June 2025

Attendees and apologies

Chair

• Peter Wilkinson, Pyrology Ltd

Members

• Peter Drummond, Royal Incorporation of Architects in Scotland (RIAS)
• Colin Todd, CS Todd and Associates
• Edith McDowall – Optimal Economics
• Greg McKearney, Scottish Fire and Rescue Service (SFRS) – online
• Angus Law, Edinburgh University- online
• Lila Angelaka, Historic Environment Scotland (HES) - online
• Neil McDougall, NLM Consultancy - online
• Simon Montgomery, HES - online.
• Eileen McCutcheon, Local Authority Building Standards Scotland (LABSS)- online
• Fionnuala McKinney, Building Regulations, Northern Ireland Government - online
• Stewart Kidd, British Automatic Fire Sprinkler Association (BAFSA) - online

Scottish Government officials

• Stephen Garvin, Deputy Director, Building Standards Division
• Scott Young, Building Standards Division
• Benny Rooney, Building Standards Division
• Colin Hird, Building Standards Division
• Gavin Hammond, Safer Communities Division - online

Apologies

• Andrew Nicholson, The Fire Surgery
• Paul Keepins, Building regulations, Welsh Government
• Sean Cairns, Thistle Trade Group
• Damien Fairley, Northern Ireland Government
• Lisel Porch, Safer Communities Division
• Chris Booth, Safer Communities Division
• Charles-Elie Romeyer, Building Safety Regulator, HSE
• Jim McGonigal, Scotland Branch of the Institution of Fire Engineers (SIFE)
• Sharon McClure, Association for Specialist Fire Protection (ASFP)
• Samantha MacCuish, Federation of Master Builders
• Steven Scott, BSD

Items and actions

Welcome

The chair welcomed everyone to the fourth meeting of the Building and Fire Safety Expert Working Group (EWG) and covered the agenda for the meeting.

Meeting business

Apologies were noted.

Minutes of meeting 3 and action points were discussed.

AP1 – The minutes of Meeting 2 to be amended by SG officials and published - Completed

AP2 – SFRS and FRU to work on producing an updated signage template to show lift identification and two stairs, for inclusion in technical handbooks – to be carried forward.

AP3 – Group members to explore Quantity Surveyor option and further sprinkler contractors through different network, supported by required template from Optimal – Completed

AP4 – SG Officials to undertake Islands Communities Impact Assessment – to be continued as part of workstream.

AP5 – SG Officials to provide more guidance on the balance and expectation of what reasonably practicable is, including level of competency required – to be discussed as part of today’s meeting.

AP6 – Officials to look at background of 30m cavity barrier spacing related to point above - to be discussed as part of today’s Paper 5.

AP7 – SG officials to follow up on social housing question – to be discussed as part of today’s Paper 7.

AP8 – SG Officials to follow up on protected circuit and fire resistance questions – to be discussed as part of today’s Paper 8.

AP9 – SG officials to follow up for group comment on proposals – to be discussed as part of today’s Paper 8.

The minutes of the last meeting were then agreed.

Consultation analysis

(Paper 3)   

Members were provided with a summary of responses to the public consultation on the Proposed Review of Fire Safety Topics, including:

• Mandating fire suppression systems
• Fire suppression in conversions of historic buildings to hotels
• Definition of a hotel
• Amending the scope of application of mandatory standard 2.15 ‘Automatic Fire Suppression Systems’   
• Hidden cavities, voids, workmanship age and variations from standards
• Clarifying ‘reasonably practicable’
• The Scottish Government publication ‘Fire safety guidance for existing premises with sleeping accommodation’ (2022) currently being reviewed.
• Historic Environment Scotland guidance ‘Fire and Historic Buildings’ (2023) currently being reviewed.
• Extending the ban on combustible external wall cladding systems

Responses to the various miscellaneous fire safety issues were also indicated to panel members, including:

• Lath and plaster and materials
• Low level emergency lighting
• External premises information plates
• Clause 2.7.1 of the Domestic and Non-domestic Technical Handbook
• Regulation 8(4) and exemptions to European Classification A1 and A2
• Exit width from rooms in non-domestic buildings
• Proposal to remove the guidance in Annex 2.B of the NDTH and cite SHTM 81 Part 1 for new build Hospitals
• Electrically controlled exit systems

It was further indicated to panel members that the consultation proposed undertaking further research and evidence gathering to inform policy on three areas – the BS 476 national classification, Battery Energy Storage Systems (BESS), and car parks and electric vehicles.

Recommendation 4 of the Cameron House Hotel FAI

Consideration of Mandating Suppression to Traditional Buildings Converted to Hotel Use (Paper 4)      

Officials outlined the options presented within Paper 4 and responses to the consultation.

The outcomes of cost benefit and sensitivity analysis for AFSS to be installed when traditional buildings are converted to hotels was also indicated to panel members.

Panel members discussed challenges around defining large and complex hotels as well as the definition of a hotel, guest house, boarding house, hostel, boutique and apart hotel, having more than 14 lettable rooms. The definition of Traditional building was also indicated to panel members.

It was indicated to members that BSD intend to recommend to Ministers, to mandate suppression to all conversions of traditional buildings to hotels with more than 14 lettable rooms. This includes the definitions of traditional building and hotel and strengthening the performance based approach to all situations for both small and large hotels as noted in Annex B of the paper.

Members discussed height of a building being used as well as 14 rooms as a trigger point.

Members discussed whether sprinklers should be indicated rather than suppression. One member indicated that water mist may not be the issue rather it could be poor fitting of suppression systems.

Members indicated that the removal of `without a licence to sell alcohol` from the definition of a Hotel may be preferable.

One member advised against the inclusion of ‘with permeable components’ within the definition of Traditional building.

Members were asked if they agreed with the proposal to mandate suppression to all conversions of traditional buildings to hotels with more than 14 lettable rooms.

Members agreed but felt the 14 rooms and inclusion of building height needed further consideration.

Action: Officials to review and report on appropriate trigger criteria for application of the proposed provision, including why a trigger is appropriate.

Recommendation 5 of The Cameron House Hotel FAI

Hidden Cavities and Voids, Workmanship Age and Variations from Current Standards. (Paper 5)

Officials provided commentary on the contents of Paper 5 to panel members.

Proposals were outlined to members not to amend standard 2.4. but to add additional text to NDTH 2.4.0 Introduction.

Proposed changes to guidance clause 2.4.5 were also highlighted by officials.

Panel members were invited to discuss proposed changes to guidance.

Members discussed term `reasonably practicable` and were invited to define term by officials.

There was broad agreement of members on the proposal to changes in guidance to clause 2.4.5.

The appropriateness of providing cavity barriers at 10 m centres was discussed by the panel particularly in traditional buildings with auto-suppression.

Fire (Scotland) Act 2005 Guides (Oral update)

Members were provided with a short oral update on progress in the review of Fire (Scotland) Act 2005 Guides by officials.

It was indicated that feedback on the guides from stakeholders had been limited and that officials were to reach back out to stakeholders to seek further feedback on guides.

Action: Officials to seek further feedback from stakeholders.

Historic Environment Scotland (HES) Guides – review progress (Oral update)

Members were provided with a short oral update on progress in the review of (HES) Guides by officials.

Definition of traditional building used within guides is to be discussed with BSD officials.

First draft of revised Fire guide was in March 2025 and work with authors is ongoing.

Research to extend ban of combustible cladding to hotels, boarding houses and hostels (Oral update)

Officials provided an update on the research to date and that currently awaiting the outcome of phase 2 work following the recent receipt of the required data from SFRS to complete this work.

The panel agreed that upon completion of phase 2 work Officials will share this with the group for comment to help inform recommendations in consideration of the research outcomes, for preparing a Ministerial submission for decision.

Action: Officials to share research paper with Group once available

Programme update (Paper 6)    

Update by officials was provided on work undertaken so far and the ongoing programme. Officials indicated that the programme is on course for the dates previously provided.

Standard 2.15 Review

STANDARD 2.15 AUTOMATIC FIRE SUPPRESSION SYSTEMS (PAPER 7)

Members were provided with details of Paper 7 by officials and comments from the Group on the proposal to amend the limitations of standard 2.15 to take account of the current Direction – Dispensation of Building Regulations (Automatic Fire Suppression Systems) (Scotland) Direction 2024: letter to local authorities were requested.

Members agreed with the recommendation that Scottish Government solicitors are instructed to amend the limitations of standard 2.15 to take account of the current Direction.

Miscellaneous Issues (Paper 8)                     

The purpose of this paper was to seek comments from the Building and Fire Safety Expert Group (BFSEG) on Miscellaneous Issues included in the public consultation undertaken between 13 December 2024 and 7 March 2025.

Lath and Plaster Materials

Members agreed with the BSD proposal to take no further action.

Low level emergency lighting

Members were asked if they agreed with the proposed additional wording to Clause 2.10.3

Low level way finding systems may be used to supplement [protected] or emergency lighting and can be considered on a case-by-case basis as part of the fire risk assessment.

Members agreed with the proposal but with removal of the word [protected].

Requirement for a fire protected circuit be removed, with no need for a separate or fire resisting circuit.

The expert panel agreed with the proposed revision of guidance to standard 2.10 to remove the need for a separate and fire resisting escape route lighting circuit.

External premises information plates

The Scottish Government has proposed requiring an external premises information plate to be fitted on all new, converted, or refurbished high-rise domestic buildings with any storey at a height of more than 18 m above the ground.

It is proposed to insert a new guidance clause 2.14.10 ‘External Premises Information Plates’ to ensure that such a provision is made where a high rise domestic building is constructed or formed by conversion.

Members agreed with the BSD proposal to implement the new clause but discussed the inclusion of FRS lift information to be provided on the information plate.

Clause 2.7.1 of the Domestic and Non-domestic Technical Handbook

The consultation document proposed changes to the wording in clause 2.7.1. of the Technical Handbooks.

Members discussed the point around combustible material being attached to non-combustible material in some instances.

Members agreed with the proposed change to the wording in Clause 2.7.1.

Regulation 8(4) and exemptions to European Classification A1 and A2

Officials indicated that the Scottish Government has proposed two exemptions to European Classification A1 and A2 components that form part of an external wall cladding system. These relate to components associated with a solar shading device and A1 fl or A2 fl flooring materials used in the top horizontal floor layer of a balcony, provided the entire layer has an imperforate substrate under it.

One member raised an issue with the presence of timber ‘brise soleil’ resulting in more combustible material being on buildings. Members indicated further clarity around wording and intent were necessary.

Exit width from rooms in non-domestic buildings

The consultation document proposed to make changes in the NDTH in relation to exit width from rooms in non-domestic buildings.

Members agreed with the BSD proposal to amend the exit widths as shown to them.

Hospitals

Members agreed with the BSD proposal to remove Annex 2.B of NDTH and cite SHTM 81 Part 1 for new build hospitals.

Members agreed with the BSD proposal not to proceed with citing SHTM81 Part 2 and 3 until these are properly reviewed, as part of the section 2 review work later in the year.

BS EN 13637:2015 Electrically controlled exit systems for use on escape routes

Members agreed with the BSD proposal to cite BS EN 13637 as a risk based alternative approach.

Call for evidence questions to be taken forward to section 2 review, commencing research

Members agreed with the proposal to align with England on the phased removal of reference to BS 476 fire tests within the technical handbooks. However it was indicated that the fire door industry should be consulted as part of this process.

Battery Energy Storage Systems

It was indicated by officials that a research bid has been accepted and will go ahead in 2025/26.

Car parks and electric vehicles (EVs)

It was indicated by officials that a research bid has been accepted and will go ahead in 2025/26.

Call for Evidence – Compliance Pathways (Paper 9)

It was indicated to group members by officials that the purpose of this paper is to seek views from the expert working group on proposals to issue a call for evidence – relating to compliance pathways and other issues identified in the Grenfell Tower Inquiry (Phase 2) Report.

The Scottish Governments response to the Grenfell Tower Inquiry was published on 25 March 2025. The report accepts all 58 recommendations in full or in principle. The key themes relevant to this call for evidence will include :

• Legal status of the Technical Handbooks
• A general call for evidence on any aspects of fire safety guidance that requires new guidance and / or clarification.
• Compartmentation / external fire spread and stay put strategy
• Means of escape for vulnerable and disabled people
• Fire Strategy / Fire Safety Design Summary
• Membership of the expert review group; and
• Regulating the profession of fire engineering.

The reliance on compliance with guidance documents in Scotland and England which may be relied on as tending to negative liability was discussed by the group. One member indicated that the problem stems from peoples understanding of the status of the guidance.

Officials indicated that it is proposed to consult in the autumn on potential changes to the Building (Scotland) Act 2003 or the Building (Scotland) Regulations 2004 to formally recognise three distinct pathways to compliance with the building regulations:

• prescriptive code (Route A) e.g. simple conservative guidance contained in the technical handbooks or allowable alternative solutions or
• prescribed - performance (Route B) e.g. target levels of safety / performance and verification methodology e.g. NFPA or CMV2 (New Zealand) or
• full performance (Route C). This would require the design to be carried out by a chartered engineer in accordance with IFEG or BS 7974 or SFPE guide and reviewed by an equivalent chartered fire engineer or performance verification committee established by the Scottish Building Standards Hub

Discussion on the functional based system in Scotland was undertaken by the group.

One member indicated that the guidance being provided within the Technical Handbooks was the preferred option and members indicated that we should be looking at ways to improve the current system rather than adopting another. The prescribed performance route adopted in other countries was criticised by the panel and was not a recommended route to compliance within the Scottish building regulatory system. 

Any other business

No date was indicated for any future meeting but members were asked to keep the group assembled to deal with issues as they present themselves. Members were agreeable to this request from officials.

One member suggested that the Scottish Government should convene its own panel to shadow the current MHCLG Fire Engineers Advisory Panel.

It was indicated that officials from the Scottish government were observers on the MHCLG panel and that there was a current proposal from BSD to hold a round table with stakeholders to allow feedback into the MHCLG group.

Closing remarks from the chair thanked group members for their involvement with the group with special thanks to one official from BSD who was retiring from the Scottish Government duly noted.