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

5. Miscellaneous fire safety issues

The FAI report stated that: “Other points, such as in respect of lath and plaster wall coverings, the presence of any fire-resistant material, and low-level emergency lighting were not matters explored in evidence to such an extent that this Determination can make any specific finding on these points. Nonetheless, these points can be expected to be part of the broader consideration by the expert working group exploring the risks posed by all such buildings used as hotel premises, which has been recommended in this Determination.”

Q12 to Q22 of the consultation paper explore these wider fire safety issues, along with other wider fire safety topics. More details are provided in the consultation paper.

Lath and plaster and materials

Q12. The expert panel proposes the existing guidance is fit for purpose and requires not further action in this context. Do you agree or disagree? If you disagree or strongly disagree, please provide any suggestions on how the current guidance could be improved.

Audience	Sample size (n=)	% Strongly agree	% Agree	% Neither	% Disagree	% Strongly disagree	% No answer
All respondents	40	8	48	23	8	0	15
All answering	34	9	56	26	9	0	-
Individuals	5	40	20	20	20	0	-
Organisations:	29	3	62	28	7	0	-
- Local Authorities	12	0	67	25	8	0	-
- Fire Engineering	11	9	55	36	0	0	-
- Other construction	5	0	60	20	20	0	-
- Other	1	0	100	0	0	0	-

56% of respondents answering Q12 agreed that existing guidance is sufficient, while 9% strongly agreed (65% in total). One quarter (26%) were neutral and 9% disagreed.

Four in ten respondents commented to explain their answer. The main themes were agreement that existing guidance was sufficient and the need for robust risk management.

Agree, guidance is fit for purpose

Some respondents reiterated their views that the guidance is fit for purpose and did not require revisions. Reasons included that the issue is addressed by the existing guidance on lath and plaster published by HES, the Guide for Practitioners 6 document currently being revised, and other external publications.

“The existing guidance is sufficient in highlighting the fire risks associated with this form of traditional construction.” - Comhairle Nan Eilean Siar

Strengthening risk management

A few respondents, who recorded various views at the closed question, suggested clearer guidance is needed on managing risks associated with lath and plaster materials. It was noted that such risks were well recognised, but respondents called for more practical guidance on managing such risks, or guidance on when risks should be addressed to avoid confusion and mistakes by the workforce. One fire engineering organisation highlighted that they had seen lath and plaster ceilings fail within 20 minutes in a fire resistance test, and that remedial upgrade systems are available.

Practical guidance needed

Aligned to the theme above, a few suggested that the guidance should be more practical. Singular suggestions were that it could contain links to all supporting documentation and that it should be streamlined.

Low level emergency lighting

Q13. The guidance provided in BS 5266-1 is considered to provide sufficient illumination to assist in escape at low level and satisfy the mandatory standard. 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. It is proposed that this key message is strengthened in existing fire safety guidance. Do you agree or disagree? If you disagree or strongly disagree, please provide any suggestions on how the current guidance could be improved.

Audience	Sample size (n=)	% Strongly agree	% Agree	% Neither	% Disagree	% Strongly disagree	% No answer
All respondents	40	15	58	13	5	0	10
All answering	36	17	64	14	6	0	-
Individuals	5	40	40	20	0	0	-
Organisations:	31	13	68	13	6	0	-
- Local Authorities	12	8	83	0	8	0	-
- Fire Engineering	12	17	50	25	8	0	-
- Other construction	6	17	67	17	0	0	-
- Other	1	0	100	0	0	0	-

Of respondents answering Q13, 64% agreed and 17% strongly agreed with the proposal to retain the guidance (81% in total), with 6% opposed and 14% neutral.

Over half of all respondents left an open comment at Q13, with the main themes being agreement with the proposal, agreement that it should be used on a case-by-case basis, or other considerations.

Agree, guidance is sufficient

Several respondents agreed that the guidance did not need to be changed. Reasons included the benefits of low-level lighting, such as its usefulness in complex situations, enhancement of wayfinding and evacuation safety, additional benefits for those with visual impairments, assistance for firefighters when tackling fires, and the fact that smoke rises and may obscure ceiling-level lighting.

“Low level escape route lighting could be useful in complex buildings with complex routes of escape to help those escaping.” - Scottish Borders Council

Agree, use on a case-by-case basis

Some respondents agreed low level lighting solutions should be considered on a case-by-case basis. Reasons for using it included that it could be useful as part of a fire protection system, that it could enable fire risk assessors to consider the best course of action, that it could prevent more costly or additional systems being needed and that it could be useful for supplementary protection.

Other considerations

Others commented on low level lighting solutions more generally. Views ranging from LED (light emitting diode) technology making it an affordable solution to a view that it was not cost effective, agreeing it should not be mandated for all buildings, as it was very rarely the case that people would need to crawl along escape routes below a smoke layer. However, on this latter point, one fire engineering organisation highlighted it would still be valuable as a backup on the occasions when it was required:

“Emergency lighting is sufficient to assist in escape and is not intended to be designed for double failure (i.e power failure and smoke present within the corridor). In the event that an escape route does become smoke logged, low level way finding may assist in the evacuation of occupants.” - Arup Fire

A few respondents left varied views. These were that:

• A fire assessor may not be capable or qualified to judge whether to recommend low level lighting without consultation with an emergency lighting expert.
• The guidance citing BS 5266-1 should be strengthened for existing buildings.
• It was unclear when and where low-level lighting would be used; therefore, expectations should be set from the beginning.
• An emergency escape kit could be provided for occupants, containing a torch, smoke hoods and a whistle.

Q14. The expert panel proposes revision of guidance in standard 2.10 to remove the need for a separate and fire resisting escape route lighting circuit. Do you agree or disagree? If you disagree or strongly disagree, please provide any suggestions on how the current guidance could be improved.

Audience	Sample size (n=)	% Strongly agree	% Agree	% Neither	% Disagree	% Strongly disagree	% No answer
All respondents	40	8	30	38	13	0	13
All answering	35	9	34	43	14	0	-
Individuals	5	60	0	20	20	0	-
Organisations:	30	0	40	47	13	0	-
- Local Authorities	12	0	50	42	8	0	-
- Fire Engineering	12	0	33	42	25	0	-
- Other construction	5	0	40	60	0	0	-
- Other	1	0	0	100	0	0	-

Mixed support was evident among respondents answering at Q14, with 34% agreeing and 9% strongly agreeing (43% in total), while 14% disagreed and 43% were neutral.

Over four in ten respondents left comments explaining their answers. The themes highlighted were agreement with the proposal, that more information was needed, comments on circuits, and the need to adopt a case-by-case approach.

Agree, remove this need

A few respondents endorsed this proposal. Comments included that clear or strengthened guidance would be required to ensure standards are met and are in the interest of public safety. One individual felt occupants should use torches instead.

More information needed

A few respondents called for more information about the proposal. Areas highlighted were for the rationale behind the proposal to be made clear, and calls for clarity on specific changes being proposed, such as whether new builds were to be included. This respondent felt that Technical Standards section 2.10.2 already allowed for the installation of self-contained emergency lighting rather than a protected circuit.

“Proposal is unclear. Low-level lighting may be ok to supplement lighting provided by a protected circuit or as an alternative solution to be considered on a case-by-case basis.” - Orkney Islands Council

Comments on circuits

Comments on self-contained emergency lighting circuits were made by a few respondents at Q14, and a few who welcomed the proposal to remove the fire-protected circuit at Q15 which have been included here to remove repetition.

These included that:

• Self-contained emergency lighting is the industry standard, so the proposal made sense. Separate protected circuits were considered no longer used.
• It was possible to remove protected circuits, given that longer-life battery backups could be used.
• Circuits are only self-contained when operated with sealed batteries.
• Electrical circuits in certain historic or traditional buildings are not designed to current standards and may pose a greater fire risk or be readily affected in the event of a fire.

Adopt a case-by-case approach

A few respondents recommended adopting a case-by-case approach. These advocated replacing the requirement with a fire risk assessment of the need for a separate, fire-resistant escape route lighting circuit. Two respondents felt fire-protected circuits should remain. They felt high-level lighting may fail in a fire or should remain until research and testing have shown a robust system of self-contained lighting providing the same level of protection.

“Ensuring all buildings review the need for separate and fire-resisting escape route lighting circuits on a case-by-case basis ensures that appropriate fire safety measures can be applied based on the unique layout and structure of each building.” – Propertymark

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.

Q15. It is proposed to insert new guidance clause 2.14.10 External Premises Information as detailed. Do you agree or disagree? If you disagree or strongly disagree, please provide any suggestions on how the current guidance could be improved.

Audience	Sample size (n=)	% Strongly agree	% Agree	% Neither	% Disagree	% Strongly disagree	% No answer
All respondents	40	28	53	10	0	0	10
All answering	36	31	58	11	0	0	-
Individuals	5	40	60	0	0	0	-
Organisations:	31	29	58	13	0	0	-
- Local Authorities	12	17	67	17	0	0	-
- Fire Engineering	12	42	58	0	0	0	-
- Other construction	6	33	33	33	0	0	-
- Other	1	0	100	0	0	0	-

High levels of support were evident among respondents answering for the proposal at Q15, with 58% agreeing and 31% strongly agreeing (89% in total), and none disagreeing. 11% neither agreed nor disagreed.

Half of all respondents left an open comment to explain their answer. The main themes evident were agreement with the proposal and suggestions for implementation.

Agreement with the proposal

Many respondents endorsed the proposal. The predominant view was that this would help firefighters manage fires. It was felt that the plates would provide fire and rescue services with concise and vital information, allowing critical features of a building to be quickly identified. In turn, this would improve efficiency and response times by enhancing operational decision-making and interventions. Other positive comments were that this approach would help fulfil the action in response to the Grenfell Inquiry Phase 1, and that it was believed to be good practice.

Suggestions for implementation

Suggestions for implementing this proposal were given by some respondents. The most prevalent view was that a digital register of information could contain the data referenced on information plates, or any information relevant to high-risk buildings. This could be used as needed by local fire services. The Scottish Government, Scottish Fire and Rescue Service or the Building Safety Regulator were suggested as organisations who could be responsible for any register. One respondent felt a digital register would help compliance:

“We would advocate that a digital register of building types should be developed by Scottish Fire & Rescue to ensure that all High Risk Buildings are on a database (similar to London Fire Brigade's Pre-Incident Plans) and that fire safety inspections are current, compliance with the Fire (Scotland) Act 2005 by the Responsible Person (Duty Holder) is current and this data is then available in advance of site attendance.” - Building Systems UK

Two respondents advocated extending the requirement to residential blocks irrespective of height, or to extend it to all such buildings of 11m or above in height/with four or more storeys, to assist fire services and standardise arrangements. On the latter option, the respondent suggested this would be align with other Scottish guidance and regulation:

“For example, this provides a comparable height threshold to both the definition of ‘relevant building’ under Regulation 8 of the Building (Scotland) Regulations 2004 as well as the preferred definition of ‘high-risk residential building’ given by 83% of respondents to a previous consultation issued by the Scottish Government.” - Rockwool Ltd.

Other comments

A few commented on where information should be located on a building. Two did not support the proposal to have plates in yellow above main entrance doors and made alternative suggestions. These were to locate them to the side of doors, just within main common entrance doors to blocks or on a box like a dry riser inlet. One respondent called for the plates to be in a standard location and format.

One respondent called for definition of ‘refurbishment’ to understand when verifiers should require information plates on existing buildings subject to a building warrant.

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 and sought views on these.

Q16. It is proposed to amend the wording in 2.7.1 as detailed. If you disagree or strongly disagree, please provide any suggestions on how the current guidance could be improved.

Audience	Sample size (n=)	% Strongly agree	% Agree	% Neither	% Disagree	% Strongly disagree	% No answer
All respondents	40	3	55	18	8	3	15
All answering	34	3	65	21	9	3	-
Individuals	4	25	50	25	0	0	-
Organisations:	30	0	67	20	10	3	-
- Local Authorities	12	0	92	8	0	0	-
- Fire Engineering	12	0	50	33	17	0	-
- Other construction	5	0	60	0	20	20	-
- Other	1	0	0	100	0	0	-

Of respondents answering Q16, 65% agreed and 3% strongly agreed with the proposal (68% in total), while 9% disagreed and 3% strongly disagreed. Over a fifth (21%) neither agreed nor disagreed. Local authorities were most likely to lend support compared to other organisation types.

Almost six in ten respondents left an open comment. The most prevalent themes were to welcome the clarity provided by the proposed amendments, disagreement, or factors to consider with the proposed amendments.

Agree, clarity welcomed

Several respondents felt the proposed amendments either provided more clarity and removed ambiguity, or agreed strengthened guidance was needed to provide clarity. Comments were generally brief though the proposals were described as welcome, helpful and that they ‘made sense’.

Reasons for disagreement

Perceived challenges with the proposed amended text were highlighted by some respondents, who mainly disagreed with the proposal. Singular comments were that:

• The sheathing/backing board in any external wall system may contribute to the fire itself, fire growth, and fire spread.
• If the stability and support of the cladding depends on the backing board being in place, then it is part of the cladding system and should therefore fall within the relevant requirements, particularly the fire classification A/B.
• Sheathing or backing board providing rack resistance should be excluded from the same non-combustible requirements in the event of a fire. If the structure deflects excessively due to failure of the sheathing used for racking, then the non-combustible cladding system may be compromised. Therefore, both are interlinked.
• The guidance was unclear in reference to the European Classification. For instance, stating that the external wall cladding system (excluding sheathing or backing board) should achieve European Classification X, where the corresponding European Classification X test must be carried out on a specimen with sheathing or backing board, air gaps, etc.
• The wording did not sufficiently differentiate between loadbearing and non-loadbearing sheathing and/or backing board/panels. This respondent provided alternative wording to replace the proposed amendments:

“External wall cladding systems - mean non-loadbearing components attached to the buildings structure, for example, composite panels, clay or concrete tiles, slates, pre- cast concrete panels, stone panels, masonry, profiled metal sheeting including sandwich panels, rendered external thermally insulated cladding systems, glazing systems, timber panels, weather boarding and ventilated cladding systems. For the purposes of compliance with the building regulations and associated standards, external wall cladding systems also include spandrel panels and infill panels. Many external wall cladding systems incorporate non-loadbearing backing boards or panels, support rails, fixings, thermal insulation, fire barriers and cavity barriers located behind the outer cladding. Load-bearing sheathing or backing board - attached to the frame to provide structural support is not considered to form part of the external wall cladding system. However, where combustible, load-bearing sheathing or backing board is proposed in any building with a storey 11m or more above the ground, a large-scale facade fire test should be carried out (see annex 2.E).”- Rockwool Ltd.

Factors to consider

A range of considerations were raised by some respondents who agreed with or were neutral about the proposal. Singular comments were that:

• Full scale façade tests will mitigate the risk associated with these materials.
• The intent of the guidance could be enhanced by emphasising the limits on the use of combustible sheathing over 11m.
• Findings from the Grenfell Tower Inquiry Phase 2 report should be noted, notably concerns of the use of BS 8414 and BS 9414 and that achieving the performance criteria in BR135 does not, in isolation, demonstrate adequacy.
• The Centre for Window and Cladding Technology guidance should be referenced.
• A competent person should assess the adequacy of a system following a large-scale façade fire test, with the basis for the assessment documented.
• The proposal appeared to contradict the guidance in clause 2.6.5.

Other views

A few respondents supported the proposed amendments. They agreed that full-scale fire tests are needed and that sheathing boards can contribute to fires.

A small number sought more details. Views were that set performance criteria would be useful, for instance, to determine when a large-scale façade test is needed, and a call to clarify the guidance as follows:

“An element arising from considering this point is to ensure that guidance is also clear that such a panel would be subject requirements for fire resistance, as part of the external wall of the building, from inside to out. Therefore, making it clear that it also requires fire testing for reaction to fire from an external fire source offers clarity that it would be subject to differing exposures.” - The Fire Sector Confederation

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

To improve UK parity and clarity of Scotland’s exemptions, 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-sf materials used in the top horizontal floor layer of a balcony, provided the entire layer has an imperforate substrate under it.

Q17. It is proposed to amend Regulation 8(4) to align with England (and Wales?) on these two exemptions. If you disagree or strongly disagree, please provide any suggestions on how the current regulation could be improved.

Audience	Sample size (n=)	% Strongly agree	% Agree	% Neither	% Disagree	% Strongly disagree	% No answer
All respondents	40	15	40	23	10	0	13
All answering	35	17	46	26	11	0	-
Individuals	5	40	40	0	20	0	-
Organisations:	30	13	47	30	10	0	-
- Local Authorities	12	17	50	25	8	0	-
- Fire Engineering	12	17	58	17	8	0	-
- Other construction	5	0	20	60	20	0	-
- Other	1	0	0	100	0	0	-

46% of those who answered Q17 agreed and 17% strongly agreed with the proposal at Q17 (63% in total). 11% disagreed and over a quarter (26%) neither agreed nor disagreed.

Almost half of all respondents left a comment at Q17. Prevalent themes were agreement to align with England and Wales, risks of exemptions and agreement with exemptions.

Agree, align with the UK

Brief comments were left by several respondents endorsing the proposal to amend Regulation 8(4) to align with England and Wales. Reasons for support included that in matters of public safety there should be parity across jurisdictions, that it helped consistency and that it was sensible to align regulations that address the same fire risks. One noted the height of buildings affected by the regulation differs in England and Wales.

Risks of exemptions

Some respondents suggested how to mitigate risks potentially arising from the proposed exemptions, or felt that exemptions should be limited due to the risks presented.

A few commented on the exemption for components associated with a solar shading device. It was highlighted that devices covering larger areas could pose fire hazards, for instance, creating a route for fire to spread across the façade. These respondents either disagreed with the proposal or felt guidance should consider and address these risks.

Other singular comments included that:

• Verifiers should still have discretion to raise concerns where a solar shading solution is extensive, such that it would compromise a building’s ability to comply with standard 2.7.
• The Scottish Government should take expert concerns seriously regarding types of cladding or areas of a building and avoid exempting cladding that would pose a fire safety risks for occupants if left unreplaced.
• Exemptions were not necessary if a wide-ranging ban on combustible materials was deemed proportionate, so there should be no relaxation of regulations.
• While exempt, components should not be able to provide a fuel source for fire, especially fire that exits the building, e.g. window plume, and not form a continuum on the exterior of the building, to reduce the potential for external fire spread.

Agreement with exemptions

Two respondents agreed with the proposed exemptions as long as components with limited fire load were required. One felt components should conform to Euroclass A1 fl or A2 fl-sl to align with England and Wales and the alternative European classification system, used for the reaction to fire of flooring materials. They highlighted this classification standard indicates flooring materials should be non-combustible and produce very little smoke.

Exit width from rooms in non-domestic buildings

Q18. It is proposed to amend the wording in clause 2.9.8 as detailed. If you disagree or strongly disagree, please provide any suggestions on how the current guidance could be improved.

Audience	Sample size (n=)	% Strongly agree	% Agree	% Neither	% Disagree	% Strongly disagree	% No answer
All respondents	40	10	58	13	5	3	13
All answering	35	11	66	14	6	3	-
Individuals	5	40	40	0	20	0	-
Organisations:	30	7	70	17	3	3	-
- Local Authorities	12	8	83	8	0	0	-
- Fire Engineering	12	8	58	17	8	8	-
- Other construction	5	0	80	20	0	0	-
- Other	1	0	0	100	0	0	-

A majority of respondents answering Q18 supported the proposal, with 66% agreeing and 11% strongly agreeing (77% in total), while 6% disagreed and 14% neither agreed nor disagreed. Support was highest among local authorities (91%) across organisation types.

Over a third of all respondents left a comment to explain their answer. The most prevalent themes were that more clarity was needed, general agreement, that it enhanced accessibility or safety, and that figures must be precise.

More clarity needed

Some highlighted a range of areas where more information would be beneficial. The most prevalent request was for detail about the implications for exits and exit doorways, such as phased evacuation strategies and their impact on exit width calculations. One suggested that Approved Document B guidance could be adopted to provide more detail.

Two respondents called for clarity on the accuracy of the proposed paragraph 2. Other singular comments were that Figure 2.7 of the NDTH appeared at odds with its guidance at section 4.2.5, to provide the rationale for the proposal, and that a case-by-case approach may be needed for conversions of traditional buildings.

General agreement

Brief comments supporting the proposal were provided by some respondents. It was felt the amended wording made sense, that it would be ‘appropriate in most cases’ to achieve the specified dimensions, and it would improve fire safety at relatively little cost.

Enhances accessibility and safety

The amended wording was felt to be beneficial for easing the exit of people from fire, particularly vulnerable people or wheelchair users. Fire engineering organisations felt the amendments aligned with current fire safety standards and best practices and could promote safe evacuation, prevent bottlenecks, and improve exit route design efficiency.

Figures must be precise

A few respondents highlighted the need for accurate figures due to their implications for construction, such as being used for risk assessments to determine building risk ratings. Respondents emphasised the need for evidence-based figures, with one recommending that a case-by-case approach may be required due to the complexity of converting historic or traditional buildings. Calls were made to reconsider the exit width figures provided in the consultation paper, with issues raised such as:

• A change could cause confusion with the figures of 1100mm and 1000mm.
• Inconsistent units or no units provided on 1.050 (should be m), then mm are used.
• What evidence exists to suggest that an opening width of not more than 1050mm is not sufficient for 225 persons, and should this be reduced to 200 persons?
• To explain the background of the exit width unit in the technical guidance, and the assumed total evacuation time of 2.5 minutes used in the calculation.

Other views

One respondent disagreed with the proposal, believing it was inappropriate to change one provision in isolation and felt it should be considered further as part of the full review of the Section 2 Fire guidance following the publication of the Grenfell Inquiry Phase 2 report. Another respondent felt the Scottish Government should take note of industry experts on whether the measures would impact the safety of occupants and consider adopting any alternative widths of doorways that would provide greater safety.

Hospitals

Q19. To avoid conflicting information and recognise current practice, it is proposed to remove the guidance in Annex 2.B of the NDTH and cite SHTM 81 Part 1 for new build. If you disagree or strongly disagree, please provide any suggestions on how the current guidance could be improved.

Audience	Sample size (n=)	% Strongly agree	% Agree	% Neither	% Disagree	% Strongly disagree	% No answer
All respondents	40	10	48	18	5	0	20
All answering	32	13	59	22	6	0	-
Individuals	3	0	67	33	0	0	-
Organisations:	29	14	59	21	7	0	-
- Local Authorities	12	0	75	17	8	0	-
- Fire Engineering	12	25	50	25	0	0	-
- Other construction	5	20	40	20	20	0	-
- Other	0	0	0	0	0	0	-

Of respondents answering Q19, 59% agreed and 13% strongly agreed (72% in total), while 6% disagreed and over a fifth (22%) neither agreed nor disagreed.

Under half of all respondents left an open comment to explain their answer. Themes included factors to consider, agreement and links between the two documents.

Factors to consider

A range of suggestions were made by several respondents for the Scottish Government to consider. Comments in order of prevalence included:

• To update the Scottish Health Technical Memorandum (SHTM) 81/the ‘NHS Scotland Firecode’ and align this proposal to it.
• A call for suppression including sprinklers to be mandated in new build hospitals, or any undergoing significant renovations.
• Integrating Human and Organisational Factors (HOF) into the guidance, with details given of how this could be achieved. This individual raised this issue throughout the consultation.
• If removing the Annex from the Technical Standards affects how it is applied.
• To clarify the requirements for private hospitals, such as whether they are to meet the requirements of this guidance, or the NHS Scotland guidance.

Agree, remove Annex 2.B

Some respondents agreed that Annex 2.B could be removed, mainly to avoid duplication and the potential for confusion. For instance, it could provide clarity, reduce misinterpretation, and allow all parties to follow the same guidance. One respondent suggested tidying up the references to the Annex.

“This will provide clarity of requirement by building use. It eliminates any possibility of misinterpretation by having two locations for guidance.” - Hilti Great Britain Ltd

Links between the two documents

Comments on links between the SHTM 81 and the NDTH were noted by some. These respondents often gave detailed information, though were split as to whether they agreed with the proposal or not at the quantitative question.

Points in order of prevalence were:

• Comments on links between the SHTM 81 and the NDTH, such as to compare the differences in minimum standards or to align fire safety guidance.
• To clarify, where SHTM 81 is cited, if any parts are outwith the scope of the relevant standard or building regulation.
• Views on combining the two documents, notably incorporating the content of SHTM 81 into the Handbook and removing duplication.
• Comments on verifiers, such as whether they would be expected to review applications against the SHTM 81 guidance or if they might miss aspects when assessing hospital applications if Annex 2 were removed, as it was a useful tool.

Q20. It is also being considered to cite SHTM 81 Part 2 and 3. If you disagree or strongly disagree, please provide any suggestions on how the current guidance could be improved.

Audience	Sample size (n=)	% Strongly agree	% Agree	% Neither	% Disagree	% Strongly disagree	% No answer
All respondents	40	5	50	18	5	0	23
All answering	31	6	65	23	6	0	-
Individuals	2	0	100	0	0	0	-
Organisations:	29	7	62	24	7	0	-
- Local Authorities	12	0	67	25	8	0	-
- Fire Engineering	12	17	58	25	0	0	-
- Other construction	5	0	60	20	20	0	-
- Other	0	0	0	0	0	0	-

Over seven in ten 71% of respondents answering lent their support to the proposal at Q20 including all individuals, with 65% agreeing and 6% strongly agreeing and 6% disagreeing. Almost a quarter (23%) neither agreed nor disagreed. Fire engineering organisations were most likely to support the proposal across organisation types.

Four in ten respondents left an open comment to explain their answer. The main themes were general agreement, comparisons between the documents and that more detail was needed. Comparisons between the documents have been combined with those made at Q19 and incorporated into the analysis above.

General agreement

Support for the proposal was expressed by some respondents. Singular reasons for support included that it recognised current practice, that the move towards sector-specific design guidance for hospitals was welcome, and that it provided for the fullest scope in healthcare premises design.

More clarity needed

A few respondents called for clarity, making suggestions such as referring to all relevant parts of SHTM 81, clarifying arrangements for private hospitals, and making clear the training and competencies required for fire engineers and verifiers.

Electrically controlled exit systems

Q21. It is proposed to cite BS 13637. If you disagree or strongly disagree, please provide any suggestions on how the current guidance could be improved.

Audience	Sample size (n=)	% Strongly agree	% Agree	% Neither	% Disagree	% Strongly disagree	% No answer
All respondents	40	10	55	20	3	0	13
All answering	35	11	63	23	3	0	-
Individuals	4	25	50	25	0	0	-
Organisations:	31	10	65	23	3	0	-
- Local Authorities	12	8	75	8	8	0	-
- Fire Engineering	12	17	50	33	0	0	-
- Other construction	6	0	67	33	0	0	-
- Other	1	0	100	0	0	0	-

Of respondents answering Q21, 63% agreed and 11% strongly agreed (74% in total), while 3% disagreed and 23% neither agreed nor disagreed with the proposal. Higher support was evident among organisations than individuals (with 65% compared to 50% respectively strongly agreeing or agreeing).

Around four in ten respondents commented at Q21. Two themes emerged: agreement with the proposal and factors to consider.

Agree, cite BS EN 13637 in the Handbooks

Some respondents agreed that BS EN 13637 should be cited in the Technical Handbooks, though a few provided caveats (included in the next theme). Reasons for support included that systems and design are improving due to technological advances, residual locking seems to be a thing of the past and a recognition of the importance of having effective access control systems in the interest of building security and occupant safety.

“Agree that such devices can be used on a risk-based principle and quoting the relevant standard is appropriate.” - The Fire Sector Confederation

Factors to consider

Equally prevalent were comments on aspects the Scottish Government could consider, provided by some respondents. These included that:

• A flow chart should be provided to illustrate the section on electric locking and access control within the Technical Handbooks, to help reduce complexity and challenges associated with interpreting the guidance.
• Additional guidance would be needed to set out the parameters where such a locking device may be appropriate, even if it just refers to the BS guidance.
• Systems should be fully tested and compliant.
• Checking and fail-safe devices should be mandated to ensure that locks are disarmed should there be a power interruption.
• This approach should complement existing standards and not reduce the standards required within BS EN 1125 and BS EN 179.

One local authority disagreed with the proposal. It preferred that electrically controlled systems be considered only as an alternative solution, so it felt it best to keep them out of the Technical Handbooks.

Other issues relevant to this review

Q22. Do you have experience of issues affecting development which you consider have arisen from application of current fire safety standards set under building regulations.

Audience	Sample size (n=)	% Yes	% No	% No answer
All respondents	40	25	55	20
All answering	32	31	69	-
Individuals	4	50	50	-
Organisations:	28	29	71	-
- Local Authorities	12	25	75	-
- Fire Engineering	11	18	82	-
- Other construction	4	50	50	-
- Other	1	100	0	-

Over two thirds (69%) of respondents answering had no experience of issues affecting development, though around three in ten had (31%). Fire engineering organisations and local authorities were most likely to have experienced issues affecting development, at 82% and 75% respectively.

The consultation paper included an open element to Q22 to allow respondents to provide additional comments or elaborate on their experience. However, this open question was not available on the Citizen Space platform. The Scottish Government will ensure that additional evidence is sought from stakeholders at the next stage of developing any new regulations or guidance.