Consultation on proposals to Update the School Premises (General Requirements and Standards) (Scotland) Regulations 1967: Analysis of Responses

5. Regulations to be removed

This chapter presents the analysis of responses to Q16 to Q23, which cover regulations that the Scottish Government proposes can be removed.

It should be noted that while the open-ended element of questions in this section asked those who disagreed with the removal to explain their reasons, comments were also frequently made by those who supported the removal, outlining why they held this view.

Q16 - General requirements (Regulation 4): Do you agree that this Regulation can be removed? If not, why not?

Respondent type	Sample size (n=)	% Yes	% No	% No answer
All respondents	264	53	8	39
All answering	161	86	14	-
Individuals	115	84	16	-
Organisations:	46	91	9	-
- Local Authority	23	100	0	-
- Equalities	3	100	0	-
- Disability	2	50	50	-
- Design/Engineering	6	67	33	-
- Schools, parents and carers	6	83	17	-
- Environment/Nature	2	100	0	-
- Education union/rep body	3	100	0	-
- Children's Rights	0	-	-	-
- Other	1	100	0	-

Among those answering Q16, there was widespread agreement that this regulation (General requirements (Regulation 4)) can be removed. Overall, 86% of those answering felt it could be removed, as did 84% of individuals, 91% of organisations, and a majority of most types of organisations, including all local authorities.

One in ten of all respondents left an open comment in response to Q16.

Reasons to remove

Some respondents explained their reasons for agreeing with the removal of this regulation. Most of these respondents indicated that the regulation was outdated and obsolete within modern processes.

“On the basis set out in the consultation, this appears to be an outdated provision and we have no objection to its removal.” – Landscape Institute

The importance of ongoing accountability to the principles of this regulation and adherence to minimum standards was noted by some respondents. They commented that while they agreed the regulation is no longer required, they would hope removal did not result in gaps or a weakening in expectations around new school development.

Reasons not to remove

Similar to the point above, some respondents who disagreed with the removal expressed the view that the regulation is required to maintain consistent standards. They felt that the regulation set essential baseline expectations and that its removal could risk fragmenting the process and creating inconsistencies across schools in Scotland.

“It supports consistency across the learning estate. The consultation acknowledges that the current regulations set broad minimum standards for school premises. Removing the general requirement risks widening inequalities between local authorities.” - Individual

A few respondents commented that a general requirements regulation is required to ensure school premises are suitable and adequate for their purpose.

“General requirements provide the essential framework for all other regulations, ensuring that schools meet minimum standards for safety, accessibility, hygiene, and pupil wellbeing. Removing it could create gaps in safeguarding and consistency, particularly for spaces that require clear single-sex provision, privacy, and dignity. Modernisation should update specifics where necessary, but the overarching general requirements must remain to guarantee that all schools continue to operate safely and effectively.” – Individual

A small number of other respondents expressed support for Ministerial oversight of general requirements. One respondent suggested the regulation allowed the Scottish Government to understand where substantial variance in costs of delivering school infrastructure existed. Another respondent felt that maintaining Ministerial approval could ensure changes to school buildings are accounted for and lawful.

Q17 - Sites for primary and secondary schools (Regulation 7): Do you agree that this Regulation can be removed? If not, why not?

Respondent type	Sample size (n=)	% Yes	% No	% No answer
All respondents	264	47	14	38
All answering	163	77	23	-
Individuals	114	77	23	-
Organisations:	49	76	24	-
- Local Authority	22	91	9	-
- Equalities	3	67	33	-
- Disability	2	50	50	-
- Design/Engineering	8	38	63	-
- Schools, parents and carers	7	100	0	-
- Environment/Nature	3	33	67	-
- Education union/rep body	3	67	33	-
- Children's Rights	0	-	-	-
- Other	1	100	0	-

Among those answering Q17, just over three quarters (77%) agreed that this regulation (Sites for primary and secondary schools (Regulation 7)) can be removed. While similar levels of agreement were recorded among individuals (77%) and organisations (76%) that answered, opinions varied considerably by type of organisation. The highest support for removing this regulation was recorded among schools, parents and carer organisations (100%) and local authorities (91%), with the lowest among design/engineering organisations (38%) and environment/nature organisations (33%).

Two in ten of all respondents left an open comment in response to Q17.

Reasons to remove

Some respondents agreed with the removal of the regulation as they felt there is an overlap between the regulation and other regulatory and planning guidelines, such as wider employment and health and safety standards, and proposed changes to Regulation 20. A few caveated that their agreement was on the condition that removal does not negatively impact the practical needs of pupils and staff.

Removal was viewed as an enabler for better decision-making by some respondents. They suggested that the current focus on the size of the school site means the regulation may not consider the practicalities of selecting a school site and the wider context of the local area. For example, prioritising the size of the site without accounting for the total land available in the area, the suitability and usability of the land available, and what transport links connect to the site. One respondent commented that the removal of the regulation could help local authorities to provide greater community influence in decision-making.

Reasons not to remove

Several respondents expressed the view that this regulation is required to maintain consistency in standards across Scottish schools. They felt that the regulation provided a safeguard for the quality of school estates and set a minimum standard that helps ensure future school sites are suitable for their purpose, and unsuitable sites are not selected.

“Regulation 7 should not be removed outright, because doing so would eliminate the only statutory safeguard that ensures schools are built on sites that are actually suitable for education. The consultation explains that the Scottish Government intends to remove school‑specific requirements that duplicate other legislation, but site suitability is not duplicated anywhere else. It is a uniquely educational requirement, and removing it would create a regulatory gap.” - Individual

The suitability of local authorities to have final approval on school sites was questioned by some respondents. They expressed concern that pressures on local authorities to reduce costs due to budget constraints could result in land for schools being sold and smaller schools being built.

“Local authorities will sell off land and space for profit in schools that are already too small for modern learning.” - Individual

Some respondents, most of whom were environmental or nature-focused organisations, highlighted that removing the regulation and related oversight could risk school sites being compressed into smaller areas, resulting in insufficient outdoor space for play, green space, and nature activities. A few respondents noted that outdoor space may be especially important for pupils in urban areas where access to nature can be limited, and shared the concern that removing the regulation could encourage inequality.

“Where children and young people are accessing nature less and less, the one outside place that they access every school day should be protected. This is particularly important in urban areas and in areas of high deprivation where access to nature is already restricted. This protection is therefore more important than ever.” – Learning through Landscapes

A potential reduction in safety and wellbeing measures was raised as a reason for retaining the regulation by some other respondents. Issues around poor air quality, proximity to busy roads, and reduced or limited physical access to buildings were highlighted, with concern that removing the regulation could result in these issues no longer being considered in planning decisions.

Some respondents suggested how the regulation could be updated rather than removed. A few individuals proposed that changes should be made to allow for flexibility in local design needs, but not at the expense of existing protections. A few respondents also emphasised that allowing for local community opinion within regulatory guidance would benefit the process. Other respondents shared additional measures that could be covered in any future iteration, such as pedestrian access, site shape, and increased space to class size metrics.

Q18 - Educational accommodation in schools providing both primary and secondary education (Regulation 11): Do you agree that this Regulation should be removed? If not, why not?

Respondent type	Sample size (n=)	% Yes	% No	% No answer
All respondents	264	52	9	40
All answering	159	86	14	-
Individuals	113	84	16	-
Organisations:	46	89	11	-
- Local Authority	23	100	0	-
- Equalities	3	67	33	-
- Disability	2	50	50	-
- Design/Engineering	5	80	20	-
- Schools, parents and carers	6	100	0	-
- Environment/Nature	2	50	50	-
- Education union/rep body	4	75	25	-
- Children's Rights	0	-	-	-
- Other	1	100	0	-

There was broad agreement with removing this regulation (Educational accommodation in schools providing both primary and secondary education (Regulation 11)). Among those answering Q18, 86% felt it should be removed, as did 84% of individuals, 89% of organisations and 100% of local authorities. While views varied by types of organisation, at least half of each type of organisation supported removing the regulation.

One in ten of all respondents left an open comment in response to Q18.

Reasons to remove

Some respondents commented to explain their reasons for agreeing. These respondents, who were mostly local authorities, commented that the regulation was adequately covered by other regulations but did not provide details. A few respondents stated they agreed with removal as long as it did not create gaps in metrics and standards for combined schools.

Reasons not to remove

A few respondents commented that the regulation was needed to maintain standards in schools providing both primary and secondary education. They felt that removal could result in a loss of clarity on minimum expectations for these schools and result in inconsistent provision across Scotland.

“To ensure consistency of provision and offering across Scotland, we believe that educational accommodation in schools providing both primary and secondary education should be set out in regulation.” – Educational Institute of Scotland (EIS)

Some respondents felt the removal of the regulation could result in the needs of some children not being met. They expressed concern that removing the regulation could result in mixed-school designs not providing age-appropriate accommodation for both primary and secondary pupils. It was noted that each age group has different needs, and respondents felt that a lack of consideration for either group could impact learning quality and wellbeing.

“Schools that combine primary and secondary stages must manage: very different developmental, social, and safeguarding needs, different curriculum requirements, different space, furniture, and environmental expectations, different outdoor and recreational needs, different sanitary and wellbeing requirements. No other regulation currently ensures that these differences are properly accounted for in a shared campus.” - Individual

One respondent also highlighted that combined schools may present challenges for children with additional support needs, particularly neurodivergent children. They stated that the current regulation contains clear requirements for combined schools that may make it less likely children with additional support needs are exposed to environments that are overwhelming, unsafe or developmentally inappropriate.

Two respondents noted that the requirements of the regulation could be made clearer.

Q19 - Playroom accommodation in nursery schools and classes (Regulation 12): Do you agree that this Regulation is no longer required and can be removed, and that ELC settings, including those housed within school buildings should be specifically excluded in the updated Regulations? If not, why not?

Respondent type	Sample size (n=)	% Yes	% No	% No answer
All respondents	264	39	22	38
All answering	163	64	36	-
Individuals	115	60	40	-
Organisations:	48	73	27	-
- Local Authority	23	78	22	-
- Equalities	3	100	0	-
- Disability	3	33	67	-
- Design/Engineering	5	40	60	-
- Schools, parents and carers	7	86	14	-
- Environment/Nature	2	50	50	-
- Education union/rep body	4	75	25	-
- Children's Rights	0	-	-	-
- Other	1	100	0	-

Almost two thirds (64%) of those answering Q19 agreed that this regulation (Playroom accommodation in nursery schools and classes (Regulation 12)) can be removed and that ELC settings, including those housed within school buildings, should be specifically excluded in the updated Regulations, while 36% disagreed. Support was higher among organisations than individuals (73% compared to 60%, respectively). However, views varied by type of organisation, with 85% of schools, parents and carer organisations and 78% of local authorities in favour, compared to 67% of disability organisations and 60% of design/engineering organisations that were opposed.

Almost two in ten of all respondents left an open comment to Q19.

Reasons to remove

Some respondents who agreed that the regulation should be removed explained why they felt this was the right approach. Specifically, some noted that the regulation is no longer required as it is covered by standards and guidance set by other regulatory bodies, such as the Care Inspectorate, and felt that trying to meet different standards could cause confusion and duplication. Some other respondents caveated their agreement on the exclusion of ELC settings from updated regulations, on the condition that ELC settings will be clearly and robustly regulated. They suggested a cross-referencing exercise with other related guidance to ensure removal does not result in any gaps.

“As the Care Inspectorate carries out inspections and only registers businesses to operate if they meet the requirements in the current ELC design guidance ‘Space to Grow and Thrive’ and the Social Care and Social Work Improvement Scotland (Requirement for Care Services) Regulations 2011 then this provides assurances that the space provided in nursery schools and classes does not compromise the health and safety of young children. This Regulation is therefore no longer needed.” – Kindred Advocacy

Reasons not to remove

Conversely, some respondents expressed the view that the regulation is needed to maintain consistency in provision. They noted that removal could create ambiguity and inconsistent standards for early years spaces, if standards shift from a legal requirement to guidance only.

“I believe it is still important to retain these regulations to ensure consistent and equitable design across all nursery spaces. Aligning them with the ‘Space to Grow’ document would strengthen the guidance and help ensure responsibility does not rest solely on the Care Inspectorate to verify that appropriate provision is in place.” – Individual

A few respondents noted that the Care Inspectorate guidance may be weighted more towards the health and safety of settings rather than their suitability for education and learning. One respondent mentioned that, in their view, Care Inspectorate guidance is likely to change, and that retaining the regulation means a legal minimum requirement ‘backstop’ is maintained.

“While I recognise that nursery provision has evolved significantly, particularly with the expansion of provision for 2 and 3 year olds, and that the Care Inspectorate plays an important role in regulating and inspecting these settings, I do not consider that this alone is sufficient to ensure consistently high-quality learning environments across Scotland.” – Hamilton School for the Deaf

Some respondents felt that removing this regulation could lead to some children losing out. They stated that ELC settings have distinct spatial and developmental requirements and reflected that poorly designed spaces can disadvantage many children, such as those with additional support needs. A few respondents highlighted the importance of appropriate and mandated acoustic requirements in ELC settings. They noted that this stage in the learning journey can be critical for deaf children, specifically their language development, learning, and social interaction. For this reason, respondents emphasised the importance of robust protections for ELC spaces.

“Regulation 12 should not be removed, and Early Learning and Childcare (ELC) settings should not be excluded from the updated Regulations. For young children with Additional Support Needs, particularly neurodivergent children, the physical environment of playrooms is critical to sensory regulation, emotional safety and early development. Many children in nursery and ELC settings are at an early stage of identification and support, making them especially vulnerable to sensory overload, noise, crowding and poorly designed spaces. Removing this regulation and excluding ELC settings risks weakening protections at a crucial developmental stage and allowing environments that are not sensory-appropriate or supportive of regulation. Clear, enforceable requirements for playroom accommodation remain essential to ensure inclusion, wellbeing and safeguarding for young children with ASN.” - Individual

Some respondents suggested updates to the regulation rather than removal, including:

• Aligning content with Care Inspectorate guidance to limit confusion.
• Explicitly asking people to refer to the Care Inspectorate standards within the guidance.
• Providing greater clarity on governance and expectations for within-school ELC spaces.
• Introducing maximum size requirements (and therefore maximum number of children in one room).
• Recognising indoor and outdoor space minimum requirements

Q20 - Educational accommodation in special schools (Regulation 13): Do you agree that this Regulation should be removed? If not, why not?

Respondent type	Sample size (n=)	% Yes	% No	% No answer
All respondents	264	31	31	38
All answering	163	50	50	-
Individuals	116	43	57	-
Organisations:	47	66	34	-
- Local Authority	23	70	30	-
- Equalities	3	100	0	-
- Disability	4	0	100	-
- Design/Engineering	4	75	25	-
- Schools, parents and carers	7	86	14	-
- Environment/Nature	1	100	0	-
- Education union/rep body	4	25	75	-
- Children's Rights	0	-	-	-
- Other	1	100	0	-

Very mixed views were recorded among those answering Q20. Overall, half (50%) supported and half (50%) opposed removing this regulation (Educational accommodation in special schools (Regulation 13). Individuals were more likely to oppose removal than support it (57% compared to 43%, respectively). While organisations that answered were more likely to support removal (66%), and most types of organisations also supported removal, a few organisations were opposed, including all (100%) disability organisations and 75% of education union/representative bodies that answered.

Three out of ten respondents left an open comment in response to Q20.

Reasons not to remove

Many respondents disagreed that the regulation should be removed, as they felt doing so could result in a loss of explicit recognition of the distinct requirements of special schools. Within this, many individuals left the same response:

“There should be a Regulation that acknowledges the different premises standards for Special Schools, linked to detailed statutory guidance.” - Individual

Several respondents reflected that the regulation is required to protect the accessibility of spaces and to ensure pupil wellbeing. They felt that children attending special schools have needs that are unlikely to be met in mainstream school environments and that deregulating requirements for special schools could result in school environments that do not address the full range of pupils’ additional needs. Respondents also commented that removing the regulation could mean there is less of an obligation to include tailored spaces and designs in special schools. For example, the potential loss of calm or sensory rooms, adequate acoustics for deaf learners, and extra space for safe transitions and mobility support.

“Removing this regulation risks weakening minimum standards and allowing environments that do not meet the specific sensory, emotional and wellbeing needs of pupils who rely most on appropriate accommodation. Special schools exist precisely because mainstream environments are not suitable for some children; therefore, clear, enforceable requirements for educational accommodation are essential to safeguard access, dignity and wellbeing for pupils with ASN.” - Individual

“We see no reason to exclude educational accommodation in special schools from the regulations. As previously described, good acoustic environments support the learning of all children, not just those who are deaf. This will be particularly important when children have more complex additional support needs.” – National Deaf Children’s Society

The importance of oversight of education accommodation across local authorities was noted by several respondents, who felt that the regulation is needed to limit any potential risks of leaving decision-making solely to local authorities. A small number of respondents stated that removing the regulation could lead to significant variation in standards across local authorities. Similarly, a few respondents shared their concern that cost could be a driver in determining local provision. These respondents emphasised the need to protect special schools from cost-cutting measures and reductions in requirements that could be taken to meet rising demands for accommodation in special schools.

“NASUWT is concerned that cost saving will be a driver in agreeing local provision. The Union would prefer a protection to be maintained within legislation to ensure that all children and young people whose educational needs are best supported in a special school are able to have those needs accommodated.” - NASUWT

A few respondents stated that the regulation should remain, but could be updated. These respondents suggested that any updated regulation should include explicit baseline expectations for accommodation in special schools and could also include wording which would give local authorities flexibility to determine requirements on a case-by-case basis. One respondent commented that the terminology ‘special school’ should be updated.

Reasons to remove

Some respondents agreed that this regulation should be removed, stating that educational accommodation in special schools is better governed by local authorities, rather than these existing regulations and Scottish Ministers. Specifically, respondents suggested that local authorities are best placed to understand local needs and therefore determine special school requirements.

Similarly, a few respondents highlighted that design needs can vary across special schools and that removing the regulation could support local flexibility to meet the variety of needs.

Although agreeing that the regulation should be removed, a small number of respondents emphasised that removal should not weaken standards or requirements for pupil welfare.

Q21 - Washing accommodation for pupils (Regulation 16): Do you agree that this Regulation is no longer required as it is met within the revised toilets and washing facilities Regulation? If not, why not

Respondent type	Sample size (n=)	% Yes	% No	% No answer
All respondents	264	50	13	38
All answering	164	80	20	-
Individuals	121	76	24	-
Organisations:	43	91	9	-
- Local Authority	23	91	9	-
- Equalities	4	75	25	-
- Disability	2	100	0	-
- Design/Engineering	4	100	0	-
- Schools, parents and carers	6	100	0	-
- Environment/Nature	1	100	0	-
- Education union/rep body	2	50	50	-
- Children's Rights	0	-	-	-
- Other	1	100	0	-

There was widespread agreement among those answering Q21 that this regulation (Washing accommodation for pupils (Regulation 16)) can be removed. Four fifths (80%) felt it should be removed, and 20% felt it should not. Three quarters (76%) of individuals and nine in ten (91%) organisations that answered felt this regulation should be removed, as did the vast majority of most types of organisation.

Fewer than two in ten of all respondents left an open comment in response to Q21.

Reasons to remove

Several respondents gave a range of reasons for supporting the removal of the regulation. Some respondents stated that the regulation was outdated and sufficiently covered by the revised toilet and washing facilities regulation. Some other respondents agreed with removal as long as it did not result in gaps in standards, specifically, ensuring accessibility, safety and inclusivity for pupils. Some respondents approved of the removal on the condition that the change only applies to new developments and schools, with no expected action to be taken in relation to existing schools.

“If the new regulations explicitly incorporate all functions of Regulation 16—such as adequate handwashing facilities, accessibility, privacy, sensory considerations, and hygiene standards—then it can be consolidated, rendering separate regulation unnecessary.” – REPAIR (Edinburgh) Network

Reasons not to remove

Some respondents felt that the regulation is required to maintain standards in washing facilities. They expressed a concern that combining washing facilities with toilet facilities in the regulations could risk diluting protections for washing facilities, and that substituting this regulation could result in expectations becoming more vague. Similarly, some respondents voiced concern that removing the regulation could result in insufficient washing facilities. A few respondents expressed the view that handwashing provision is not adequately addressed in the revised toilets and washing facilities regulation, which could lead to a lowering of hygiene standards and infection control in schools.

“While revised toilet and washing facility standards may cover basic requirements, removing Regulation 16 entirely risks losing clarity on expectations for hygiene provision beyond toilets, such as dedicated handwashing stations in practical areas (science labs, art rooms, dining spaces).” – West Dunbartonshire Council

Updates to the regulation were suggested by some respondents. A few respondents proposed introducing a higher ratio of washing basins to pupils, and expressed a desire for more washing basins in schools. One respondent offered an additional suggestion for any update to the regulation:

“The proposed changes to the regulations should consider reference to non-statutory guidance that includes areas not covered previously in the consultation paper. These would include spaces for feet washing for religious observance; nappy changing facilities that are in a school rather than Early Years; and Changing Places toilets which are covered by Building Standards regulations.” – City of Edinburgh Council (Officers)

Other views

Some respondents reiterated that the toilets and washing facilities regulation should include clear guidance on single sex facilities, and not default to mixed sex spaces. Conversely, a few respondents noted concerns for transgender pupils who could be forced into using facilities that may encourage discrimination or that do not align with their identity. These views are explored in more detail in the responses to Q8 and Q9, which cover the proposed revised toilets and washing facilities regulation.

Q22 - Accommodation for staff (Regulation 17): Do you agree that this Regulation can be removed? If not, why not?

Respondent type	Sample size (n=)	% Yes	% No	% No answer
All respondents	264	34	27	39
All answering	162	56	44	-
Individuals	119	46	54	-
Organisations:	43	84	16	-
- Local Authority	23	91	9	-
- Equalities	3	100	0	-
- Disability	2	50	50	-
- Design/Engineering	4	50	50	-
- Schools, parents and carers	6	100	0	-
- Environment/Nature	1	100	0	-
- Education union/rep body	3	33	67	-
- Children's Rights	0	-	-	-
- Other	1	100	0	0

Very mixed views were recorded in response to removing this regulation (Accommodation for staff (Regulation 17)). Among those answering, just over half (56%) agreed it could be removed, while 44% disagreed. Individuals were more likely to be opposed than in favour (54% compared to 46%, respectively). Support for removal was much higher among organisations, however, with 84% of those answering in favour and 16% opposed. While high levels of support were recorded in many types of organisations, views were more split among the small number of disability and design/engineering organisations that answered.

Three in ten of all respondents left an open comment in response to Q22.

Reasons not to remove

Many respondents expressed the view that this regulation should remain to ensure that school staff have the same inclusive access to accommodation that they feel should be available to pupils. Within this, several individuals left the same response:

“This Regulation should remain and must ensure that staff toilet facilities have the same inclusive approach as pupil toilet facilities.” - Individual

Conversely, a small number of respondents, also all individuals, expressed the opposite view, and felt that this regulation should remain to ensure that staff continue to have access to single spaces and facilities.

The importance of separate accommodation for staff was noted by several respondents. Their comments highlighted the value of staff having their own dedicated space to support their wellbeing and to undertake work tasks such as lesson preparation. These respondents expressed specific concern for staff rooms and indicated that removal of these spaces could result in a loss of privacy.

“While workplace regulations provide a baseline for staff welfare, removing this requirement risks the loss of dedicated staff spaces such as staffrooms, planning areas, and private meeting rooms. These spaces are essential for wellbeing, collaboration, and safeguarding conversations. Omitting this could lead to inconsistent provision across schools and pressure on teaching spaces being repurposed for staff use. Retaining clear guidance ensures that staff accommodation remains a priority in school design.” – West Dunbartonshire Council

A few respondents suggested that the existing regulation does not offer adequate consideration for staff space and should be amended to strengthen staff provision.

“The separate workplace regulations are too vague and don’t ensure that sufficient spaces to support staff wellbeing in schools are provided. The regulation should not be removed but reworded to include specific requirements for minimum levels of staff accommodation in schools.” – Aberdeen City Council

At Q8, and reiterated at this question, by a small number of organisations and individual respondents was concern around toilet and hygiene facilities for menstruating and perimenopausal staff who may require privacy and availability of facilities near their workspace or classroom. One individual respondent noted concern around shared washbasins in public areas. Another individual suggested that terms such as ‘readily accessible’ be clarified.

As with other questions, a few respondents stated that the regulation should remain to maintain consistency and standards across schools.

Reasons to remove

Some respondents agreed that this regulation can be removed, but they caveated their agreement by stating that no standards should be diminished as a result. A few respondents, particularly local authorities, advocated cross-referencing with existing standards to ensure there are clear expectations for staff facilities. A small number reflected that another option could be to update the regulation to reflect more recent standards, rather than removing it altogether.

Similarly, some other respondents agreed with removing the regulation as they felt it is no longer required, as the key features are covered in other measures, in particular, the Technical Handbook and existing Workplace Regulations that cover staff welfare areas.

Q23 - Storage accommodation (Regulation 19): Do you agree that this Regulation can be removed? If not, why not?

Respondent type	Sample size (n=)	% Yes	% No	% No answer
All respondents	264	28	33	39
All answering	160	46	54	-
Individuals	112	49	51	-
Organisations:	48	38	63	-
- Local Authority	22	32	68	-
- Equalities	3	100	0	-
- Disability	2	0	100	-
- Design/Engineering	5	20	80	-
- Schools, parents and carers	6	83	17	-
- Environment/Nature	5	20	80	-
- Education union/rep body	4	0	100	-
- Children's Rights	0	-	-	-
- Other	1	100	0	-

Among those answering Q23, 46% agreed that this regulation (Storage accommodation (Regulation 19)) can be removed, while 54% disagreed. A similar pattern was recorded by individuals, with 49% agreeing and 51% disagreeing. Overall, organisations were less likely to agree, with 38% in favour of removal compared to 68% who were opposed. However, there was no clear consensus across the different types of organisation.

Two in ten of all respondents left an open comment in response to Q23.

Reasons not to remove

Several respondents highlighted the critical nature of this regulation, expressing the view that storage is an essential component of school design. These respondents also noted that the benefit of removing the regulation was unclear.

Some respondents stated that not everything covered by the existing regulation is covered elsewhere. Respondents felt that although workforce safety regulations may ensure a degree of storage accommodation, this can happen with a view to structural safety, not educational functionality, and the existing regulation takes a better approach. For example, respondents noted that other standards or regulations do not make explicit the requirement for storage space for outdoor clothing and other equipment needed for the proper running of the school.

“There is concern about the proposal to remove this provision. Storage is a critical component of effective school design and has a direct impact on how efficiently a school is able to operate.” – Aberdeenshire Council

Existing storage accommodation challenges were highlighted by some respondents, who expressed concern for a reduction in storage in new schools if the regulation were to be removed. These respondents highlighted the potential for cost-cutting measures to result in reduced storage, despite growing school rolls and the increasing number of pupils with additional support needs, meaning more resources and equipment need to be stored.

“Already in my school there is no storage, would be concerned if this was further diluted.” - Individual

Risks that could result from the removal of the regulation were raised by several respondents. They felt that ensuring adequate space goes beyond having enough space for free movement, and that more storage space is essential for preventing clutter or unsafely stored equipment. Respondents reflected that adequate storage, beyond healthy and safety requirements, was necessary for safe, tidy, and hazard-free spaces.

“Adequate storage is essential for safe and effective school operation. Without minimum standards, there is a risk that storage is deprioritised, leading to cluttered or unsafe learning environments.” - Individual

Some respondents felt that removing the regulation could negatively impact pupils’ learning experience. They highlighted potential negative impacts such as not being able to store equipment that is important for supporting children with complex physical needs, space for storing outdoor clothing that is important for encouraging and supporting outdoor education in all weather conditions, and the storage of materials, props and resources required for practical and creative subjects.

“Modern expectations for high-quality, child-friendly, age-appropriate learning environments depend on sufficient space to store resources that support flexible pedagogy. Schools increasingly rely on equipment for outdoor learning, play, and specialist curricular activities, all of which require secure, accessible storage to support safe delivery.” – North Lanarkshire Council - Forward Planning and Specification Team

The suggestion to update the regulation to better reflect current storage needs in schools was raised by several respondents. A few respondents mentioned expanding the regulation, given the increasing use of equipment for pupils with additional support needs. A small number of respondents suggested the removal of coat hanging from the regulation, as they felt it applied more to early years or primary only.

“If anything, I feel this regulation should be strengthened to ensure adequate storage is available to avoid disposal of resources or the need for them to be stored off-site.” – Individual

Reasons to remove

A small number of respondents, mainly local authorities, commented that this regulation could be removed as it was adequately covered by workplace safety regulations. A few other respondents agreed with the removal, but caveated their agreement on the condition of no resulting loss in standards.