Building regulations - proposed review of fire safety topics: analysis of responses

1. Introduction

Background

The Fatal Accident Inquiry (FAI) report into the Cameron House hotel fire directed two recommendations at the Scottish Government. These were:

• Recommendation 4: The Scottish Government should consider introducing for future conversions of historic buildings to be used as hotel accommodation a requirement to have active fire suppression systems (AFSS) installed.
• Recommendation 5: The Scottish Government should constitute an expert working group to more fully explore the special risks which existing hotels and similar premises may pose through the presence of hidden cavities or voids, varying standards of workmanship, age and the variance from current standards, and to consider revising relevant guidance.

To address these recommendations, the Scottish Government has been undertaking a review through a Ministerial working group on building and fire safety. Two stages were involved in the review. A short-life working group (SLWG) was set up to review the FAI recommendations (which were reported in October 2023). Secondly, an ongoing fire safety expert panel has been created to look at the SLWG’s report and to review other aspects of Scottish building standards and fire safety guidance.

Certain recommendations from the SLWG report have already been implemented, such as amending guidance to promote the use of automatic fire suppression systems (AFSS) for traditional building conversions to hotels, and to require local authorities to inform Scottish Government where future conversions of traditional buildings are to be used as hotels. As part of the ongoing review for longer-term recommendations, a panel of experts have considered mandating AFSS where traditional buildings are being converted into hotels, including the special risks these may pose.

The Scottish Government conducted a public consultation on the proposed review of fire safety topics between 13 December 2024 and 7 March 2025. The consultation consolidated the recommendations made by the expert panel and sought views on proposed changes to building regulations and supporting guidance contained in Section 2: Fire of the Technical Handbooks^[1].

Respondent profile

In total, 40 consultation responses were received, mostly via the online consultation platform Citizen Space, with four of these received in an alternative format^[2]. Six responses were provided by individuals; the remaining 34 were from organisations (see Appendix A for a list of organisations responding). To aid analysis, organisations were grouped by the nature of their work. Table 1 shows the number of each type of respondent.

Table 1: Respondent profile

Analysis approach

The Lines Between was commissioned to provide a robust, independent analysis of the responses to the public consultation. The main purpose of consultation analysis is to understand the full range of views expressed, and, where possible, using closed questions, to quantify how many respondents hold particular views. This report provides a thematic analysis of responses based on the analysis approach outlined below.

Reflecting the knowledge of respondents, it is impossible to detail every response in this report; some, especially organisations, shared lengthy submissions reflecting their specific expertise. Full responses to the consultation, where permission for publication was granted, can be found on the Scottish Government’s consultation website.

Similarly, the technical nature of some of the proposals outlined in the consultation means it is impractical to fully repeat or explain these within this report. Further information on the proposals can be found in the consultation paper. A glossary of terms is included in Appendix B.

Quantitative analysis

The consultation included 24 closed questions. Not all respondents answered every question. To compare across sub-groups, this report presents the results of the closed questions based on those who answered each question. For clarity, each table shows:

• The percentage of respondents from the total sample of 40 respondents who selected each response (grey row).
• The number and percentage response among those who answered each question, broken down by individual and organisation responses (rows including and under “All answering”).

A full breakdown for each question, including a breakdown by each type of organisation answering, can be found in Appendix C. Please note that the row percentages may not add to 100% due to rounding.

Qualitative analysis

Qualitative analysis identifies the key themes across responses to each question. The research team developed a draft coding framework based on a review of the consultation questions and a sample of responses. During the coding process, new codes were created if additional themes emerged.

Where appropriate, quotes from a range of the 40 consultation responses are included to illustrate key points and provide useful examples, insights and contextual information.

When reviewing the analysis in this report, we would ask the reader to consider that:

• Public consultations invite everyone to express their views; individuals and organisations interested in the topic are more likely to respond than those without a direct or known interest. This self-selection means the views of respondents do not necessarily represent the views of the entire population.
• Similarly, only a very small number of responses (six) were received from individuals. As such, quantitative results for this group and any comparisons between individuals and organisations should be treated with caution.
• In a few instances, qualitative comments from individuals may not align with their response to the quantitative questions. For example, a respondent may agree in principle but use their open comment to caveat their agreement or suggest an alternative approach.

Weight of opinion

This report presents the themes identified in responses from most to least commonly mentioned. All themes, including views shared by small numbers of respondents, are covered; a view expressed by a very small number of participants is not given less weight than more general comments shared by a majority.

Similarly, all responses have an equal weighting. We recognise this means a response from an individual has the same weight as the response from an organisation which may represent many members, but this approach ensures all views are presented.

Qualitative analysis of open-ended questions does not permit the quantification of results. However, to assist the reader in interpreting the findings, a framework is used to convey the most to least commonly identified themes in responses to each question:

• Many respondents, 15 or more respondents, a prevalent theme.
• Several respondents, between 10 and 14 respondents, a recurring theme.
• Some respondents, between 5 and 9 respondents, another theme.
• A few / a small number, fewer than 4 respondents, a less commonly mentioned theme.
• One respondent; a singular comment or a view identified in only one response.