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

4. Extending the ban on combustible external wall cladding systems

The Scottish Government introduced a ban on combustible external wall cladding systems in 2022 for ‘relevant buildings’, as defined in the regulations but excludes hotels, boarding houses and hostels. In line with a change in scope in England to include hotels, boarding houses and hostels, the Scottish Government are seeking to reassess the Scottish ban to include these building types.

The Building Research Establishment (BRE) is conducting research on the topic, with Phase 1 identifying cases for exploration in Phase 2 work, among other things. The Building and Fire Safety Expert Working Group is awaiting results of Phase 2 to inform a consensus view on the evidence base to mandate a requirement to extend the ban on combustible external wall cladding systems to hotels, board houses and hostels.

Q11. Please confirm any evidence, contribution or initial comment that would help towards this policy direction.

Over six in ten respondents gave their views on this topic. The most prevalent themes were agreement with the proposal, to wait for research findings to inform developments, and wider comments about factors that can create or reduce fire risks. It should be noted that as well as comments on the policy direction, other respondents commented more generally on issues with combustible external wall cladding systems.

The ban should be extended

Many respondents felt the ban on combustible external wall cladding should be extended to hotels, boarding houses and hostels. Reasons for support included that: it was in the interest of public safety; that it would be in line with England; combustible cladding can cause fire to spread rapidly and defeat any fire safety design; there is no practical difference between hotels, boarding houses and hostels and domestic properties; occupants would be at risk otherwise; and the costly impact of fires to communities.

Suggestions included extending the ban to all sleeping accommodations or high-risk buildings, locating all guidance and necessary information in one place, and adopting a risk-based approach following a full fire risk appraisal of the external walls or holistic solutions that acknowledge the wider aspects of fire engineering.

Risks associated with combustible cladding materials on hotels, boarding houses and hostels were highlighted, such as:

• Delayed evacuation.
• Staff uncertainty.
• Occupant behaviours and characteristics, such as being unfamiliar with their surroundings, being asleep or intoxicated, and language barriers.
• Quality of workmanship.
• Protection systems being overwhelmed by fire.
• Cladding materials, insulation type, cavities, cavity barriers and sheathing boards.

“Extending the ban of combustible external wall cladding systems to hotels of a certain size/height/occupancy would make sense (especially in hotels without AFSS).” - LABSS

Wait for research findings

Some respondents referred to the current research cited in the consultation paper and either agreed with the need for research in this area or suggested using its findings to inform next steps in this area. One construction organisation highlighted that a cladding system deemed non-combustible in small-scale laboratory testing may have poor fire resistance or perform differently when assembled at scale as part of a cladding system.

“SFRS would welcome and support the move to review research and look toward including hotels, boarding houses and hostels in the ban on combustible external wall cladding systems which would align with England.” - SFRS

More clarity needed

More clarity was sought by some respondents. Areas highlighted included further defining which buildings would be impacted, such as whether low rise buildings are considered the same risk as higher ones or to clarify that the ban would not apply where no work on external walls is required, given that Standard 2.7 and Regulation 8 is not included in Schedule 6 of the 2004 Regulations. Other calls for clarity included consideration of how a ban would impact the cultural significance of traditional buildings and to outline how decision makers can minimise the impacts of proposed changes. One organisation expressed concern about the evidence underpinning the policy and indicated other aspects of fire safety should be highlighted:

“Whilst the ambition of improving fire safety is recognised in the ban on combustible external wall cladding, it is based upon BS 8414 testing which is an often criticised test and the ban perhaps inadvertently ignores other important aspects of fire safety.” - Building Systems UK

Ways to reduce risks

Some highlighted mitigating factors they felt could reduce risks associated with banning the use of combustible cladding in hotels, boarding houses and hostels. These included:

• Using a common approach to removing or mitigating fire risk from external roofs, walls or their attachments.
• The need for robust management practices to support fire strategies in buildings.
• Adopting a broader approach to fire safety e.g. fire resistance (how well the cladding system holds up under fire conditions) and fire strategy (how well the cladding prevents the spread of fire), which was considered lost with a blanket approach.