(iii) Fire Safety Content
7. Are the "person-centred" and "premises-based" approaches helpful in assessing fire safety requirements?
A large majority (35/38) answered "yes". This includes all advice agencies, 7/8 local authorities and 5/6 housing associations. The respondents answering "no" said the person-centred approach is too complicated for a lay person. Funding issues related to carrying out these assessments, such as the premises-based assessment, were also raised. The Scottish Fire and Rescue Service and two consultant/ contractors endorsed the checklists and found the approach useful.
8. Do you think the range of fire safety measures and benchmarks identified in Parts 1 and 2 of the Guidance are helpful?
Most respondents (34/38) answered "yes". This included all local authorities, 4/5 housing associations, the care provider, the Independent/private sector housing provider, and 11/12 advice agencies. Several respondents suggested that if an assessment is not carried out by someone that is not the landlord, the results should be shared with them. In addition, one housing association approved that the Guidance recognises premises may not be staffed at all times. A "no" answer came from a housing association, who commented on the section covering suitability of accommodation (i.e. specialised housing), which highlights that residents in specialised housing may become so vulnerable over time that they have to be transferred to a care home. The housing association queried how this would be assessed in relation to the provisions of the Guidance and if this approach could be used by multi-disciplinary agencies, where health, social, fire and housing experts would jointly assess risk.
9. Is it clear in the Guidance which premises are legally required to undertake a fire safety risk assessment under existing fire safety legislation?
Many respondents (25/38) answered "yes". Among these were nine advice agencies, five housing associations (the sixth did not answer the question), the care provider and managing agent, and 4/8 local authorities. Two advice agencies and one local authority asked for further clarification on the premises listed in paragraph 478 of the Guidance, which provides more detail on relevant premises, i.e. premises in scope to which relevant fire safety law applies. One local authority pointed to a potential for confusion over duties and obligations, due to the strong recommendation to carry-out person-centred assessments even though they are not mandatory.
A joint response by three contractors suggested adding a quick reference table in Figure 16 (Application of Fire Safety Law) to show whether a fire risk assessment is mandatory or best practice.
10. Do you think the Guidance clearly points the reader towards other existing guidance where appropriate?
Most respondents (31/38) answered "yes". This included ten advice agencies (two did not respond to this question), all housing associations and all local authorities as well as the Independent/private sector housing provider.
One consultant/contractor, two advice agencies, one care provider and one managing agent or facilities manager requested weblinks to relevant legislation in the fire safety law section (Chapter 7). The advice agency also voiced concerns about the compatibility of the Guidance with the Scottish Technical Handbooks 2019.
11. Do you think the Appendices are useful?
Nearly all respondents found the Appendices useful. One advice agency sought clarification on disability in the context of the "stay put" advice in Appendix 1 and evacuation strategy in Appendix 2. The agency also sought clarity on actions to take where high risk is confirmed in Appendix 3 (Person-Centred Fire Safety Risk Assessment Template). One local authority requested further information on leadership regarding Appendix 6: Matrix of Responsibilities, which lists landlords, housing providers, managing agents and facility managers, care providers and commissioners of services.
12. Is there anything missing from the Guidance or further information that should be included?
Overall, (16/38) respondents felt that nothing is missing from the Guidance. This included all housing associations, but for other respondent groups, responses were mixed. Two local authorities sought a clarification on fire alarm provisions in supported housing, specifically the connection between dwellings and common areas. In addition, one local authority housing provider commented that guidance on firefighting facilities should cover availability of access routes for emergency vehicles and that these areas should be clearly marked.
Another local authority housing provider felt that paragraph 266 on inner rooms may not be in accordance with Technical Handbook guidance or BS 9991 2015, and suggested this could be considered as part of the person-centred risk assessment. In addition, one advice agency suggested an additional Appendix on electricity and gas issues.
The Scottish Fire and Rescue Service suggested that the definition of "small domestic care home" be added to the guidance and queried the use of the word "domestic". A joint response of three consultants/contractors called for the promotion of multi-sensor detection devices in new fire alarm systems to reduce false alarms. The Guidance highlights that the use of such technology, rather than smoke detectors, may reduce false alarm incidents.
A risk assessment consultant/contractor suggested that hiring a specialist assessor should be encouraged in cases where the competence of staff is in question. Additionally, it was suggested that as many doors as practical should be sampled as part of the risk assessment process to ensure adequate fire resistance/self-closing ability
13. Is there anything further you think should be done to improve fire safety risk assessments in Specialised Housing or their impact?
Half the respondents (19/38) answered "no".
A housing association reiterated the need to consider mental health issues in a person-centred approach, particularly for people living in general needs housing.
An advice agency raised the issue of the ratio of carers to residents as part of the premises-based approach to evacuation.
An individual and a Managing agent /facilities manager called for expanding the scope of the Guidance to include all types of supported accommodation.
One local authority housing provider commented that good housekeeping should be promoted to reduce fire risk (acknowledged as a key prevention measure in the Guidance).
A joint response by three consultants/contractors advocated the deletion of references to similar professional registration schemes in paragraph 131 in the section Competence of Fire Risk Assessors.