Combustible external wall cladding systems: extending the ban to hotels, boarding houses and hostels

3 Phase 2- Review of SFRS reports and statement on CBA

The aim of the second phase of this project was specifically to:

• analyse fire investigation reports and post fire incident audit reports (see 3.1)
• provide a definitive statement on the likely outcomes of a cost benefit analysis (see 3.2)

3.1 Review of SFRS Fire Investigation and Post Fire Audit reports

The investigation of fire incidents following a fire fatality is led by Police Scotland, as they are responsible for the prevention and detection of crime, as well as for reporting any deaths resulting from fire to the Crown Office and Procurator Fiscal Service.

The SFRS supports the Police investigation as part of a multi-agency approach. This can involve SFRS specialist fire investigators working in partnership with Police Scotland, the British Transport Police and the Scottish Police Authority Forensic Services. A joint working protocol has been established between these organisations to support a collaborative approach. These investigations of fire incidents is a (non- statutory) key function of the SFRS and range from small-scale inquiries led by operational Incident Commanders to complex investigations undertaken by one or more of the agencies listed above.

As part of the information gathering process the investigating officer will look into the details of the building construction, which includes any cladding systems present. Following the official fire investigation, a report is produced by SFRS summarising the details of the incident.

Periodically, SFRS perform Post Fire Audits (PFA) that lack the detailed information and evidence in FI reports but do provide useful supplementary information to the data contained in the corresponding IRS report. Following a fire in any non-domestic premise, trained Protection (Fire Safety) personnel can carry out Post-Fire Audits. As part of this process, the Protection Officer collects detailed information to analyse causal factors. There is a section in the template (Q2 of the post fire audit form) in which any cladding issues would be highlighted. The collation of all this supplementary information supports premises profiling and informs future audit activity, building standards guidance, and other risk-based interventions aimed at improving safety.

As identified and presented in Figure 1, for the period from 1 April 2009 to 29 February 2024, there were six fatalities, six serious injuries and 49 slight injuries reported for the sub-type property categories in Table 1. By reviewing any additional data available about these incidents, further information might have shed new light on the original findings, thus providing a better overall picture of what happened during the fire and specifically if cladding played any part during those 61 incidents.

SFRS were contacted with a request for the FI reports covering six fire fatalities (in three FI reports) and any PFA reports for the six serious injuries or 49 slight injuries.

SFRS were able to provide two redacted FI reports (covering three fatalities) however the final FI report could not be released as it was in the process of supporting an ongoing prosecution. The two FI reports provided were redacted with no fatality details or information as to causes of death. Whilst SFRS were unable to provide the third FI report, they did supply details of the incident. The relevant information from all these FI reports is detailed in Section 3.1.1.

For the majority of incidents covering serious and slight injuries, there were no associated PFAs, however SFRS provided a PFA for one of the six serious injuries and four of the 49 slight injuries. The relevant information from all of these PFAs are detailed in Section 3.1.2.

3.1.1 Review of SFRS Fire Investigation reports

The first redacted FI report reviewed was for an incident that occurred in March 2016 resulting in one fatality. This incident occurred in a part three, part two-storey traditional Victorian-built, granite sandstone block walled detached hotel property. From the details in the redacted FI report it was evident that the victim had disposed of smoking materials in a wastepaper basket in room 1 and was found in room 2 (opposite and separated by a corridor). The smoke was confined to room 1 the door of which was opened by the victim which allowed hot fire gases and smoke/soot to spread to other compartments of the hotel. The fatality was presumably (as this information was missing from the FI report) overcome by toxic fumes but somehow managed to return to room 2 where firefighting personnel discovered the body. The fatality was therefore in a different room to the room of origin, but on the same floor of origin. The fire had not spread beyond the room of origin. There was no mention of cladding in the FI report, but it was stated that the external roughcast wall was visibly soot stained around an open vent aperture adjacent to the ground floor window.

The second redacted FI report reviewed was for an incident that occurred in December 2017 resulting in two fatalities. This incident occurred in an extensive Grade B listed hotel and leisure venue of mixed construction. The building was formed over several levels. From the details in the redacted FI report, it was clear that the fire started accidentally when a hotel member of staff decanted a large quantity of ash and embers into a large plastic bag, which was then placed directly inside the concierge’s cupboard. Two and half hours later smoke was seen issuing from the cupboard and shortly afterwards the door was opened. A well-developed fire was discovered within, and this enabled the fire to spread outward and via various wall and ceiling voids resulting in 75% of the contents, décor and fittings of the building being severely damaged by fire and heat. The FI report stated that the fire originated on the upper ground floor and the two fatalities were found on the second-floor landing. There was no mention of cladding in the FI report, but it was noted that the external walls were constructed from stone block.”

SFRS were unable to supply the third FI report as it was in the process of supporting an ongoing prosecution. However, SFRS supplied details from this incident that occurred in January 2023 and resulted in three fatalities. The incident took place in a hotel building which was of traditional sandstone construction, with two extensions (the extensions were not involved in the fire). The fire originated within a guest bedroom on the second

floor and spread from the room of origin into the connecting corridor. The three fatalities were located within this corridor on the second floor. No cladding was involved in the fire.

3.1.2 Review of SFRS Post Fire Audit reports

The only PFA report covering a serious injury was reviewed for an incident that occurred in November 2019. This incident occurred in a three-storey hostel of single occupancy in which the injured person set themselves on fire in a suicide attempt. The report confirmed that the smoke and fire was confined to the room of origin. The report also states, “The fire door withstood the spread of fire and smoke from bottom of door got into hallway. No other breaks in compartmentation noted at time of audit.” Later the report clarifies this, stating, “The fire door withheld back the fire some smoke escaped into hallway.” There was no mention of cladding in the report.

The first PFA report covering slight injuries was reviewed for an incident that occurred in March 2019. This incident occurred in a four-storey hostel of multiple occupancy providing supported living accommodation. The injured person, accidentally set themselves on fire whilst smoking. In terms of the compartmentation, it was noted that, “No obvious issues with compartmentation. Following a fire smoke was contained to the room of origin.” It also clarified that, “smoke did not spread beyond the room of origin; prior to fire service arrival and entry.” There was no mention of cladding in the report.

The second PFA report covering slight injuries was reviewed for an incident that also occurred in March 2019. According to the IRS report for this incident, it was in a hostel and hence was included in the analysis (see Table 1). However, according to the PFA this incident occurred in a care home of single occupancy. Care homes were not requested to be included in this research project. In this incident the injured person accidentally set themselves on fire with smoking materials, whilst falling asleep. The report confirmed that the smoke was confined to the room of origin. There was no mention of cladding in the report.

The third PFA report covering slight injuries was reviewed for an incident that occurred in January 2020. This incident occurred in a hotel of single occupancy in which, “A socket with a trailing extension linked to domestic items and a tropical fish tank overloaded causing the fire. This then melted and fell to the floor spreading to items of clothing.” The report confirmed that the smoke was confined to the room of origin. There was no mention of cladding in the report.

The fourth PFA report covering slight injuries was reviewed for an incident that occurred in August 2022. This incident occurred in a hostel of single occupancy in which the injured person, “… set fire to the bedding within his room using a liquid accelerant.” Fire and smoke were both confirmed to the compartment of origin” but there were no details of how far beyond the room of fire origin this was. There was no mention of cladding in the report.

3.2 Statement on cost benefit analysis

A detailed review of the RIAs prepared for England and Wales was undertaken in Section 2.2 as part of Phase 1, and the possible implications of extending the cladding ban in Scotland were considered in Section 2.3. A key finding of the review was that whilst both RIAs identified possible benefits, the risk reductions were not quantified or monetised.

In Section 2.3 it was proposed that the reason for this was the paucity of data for England and Wales and the challenge of linking deaths or injuries to the use of combustible materials in or on external walls. As noted in Section 3.1.3, the Phase 2 analysis of the available data for Scotland shows a scarcity of data and, although detailed analysis was undertaken, it appears that cladding did not contribute to the fatalities reported.

Therefore, whilst extending the cladding ban to include hotels, boarding houses and hostels in Scotland should reduce the level of risks in these buildings and make them safer (as in England and Wales), it is not possible to monetise these benefits.

Methods to estimate costs of extending the cladding ban in Scotland were discussed in Section 2.3 as part of Phase 1. These involved adopting the methods used in England and Wales. However, using the assumptions that the mix of affected buildings and the unit costs of compliance are comparable across the Devolved Administrations in the UK, it is possible to estimate the number of affected buildings and total cost for Scotland using population multipliers.

Using this broad-brush approach suggests that two to three buildings will be impacted each year in Scotland and the annual compliance cost will be about £0.3 to £0.4m.

It is not possible to undertake a full cost benefit analysis (CBA) given the lack of a monetised benefit