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

4 Conclusion

There were 2,395 fire incidents reported in hotels, boarding houses and hostels by IRS for the nearly 15- year period from 1 April 2009 to 29 February 2024. As a result of these incidents, there were six fatalities, six serious injuries and 49 slight injuries reported. For the fatality incidents the fire investigation reports and for the serious and slight injuries post-fire audit reports, where available, were reviewed to establish the circumstances of the incident and if cladding was involved. There are sections in these reports for any details relating to the cladding to be reported.

From a review of three FI reports (covering six fatalities) and five PFA reports (covering five injuries) it was observed that the three fatalities occurred in hotels and for the injuries three of them were in hostels, one in a hotel and one was in a care home. In all of these incidents, there was no evidence of either injuries or fatalities being due to cladding.

Regulatory Impact Assessments (RIAs) are used by government departments to support proposed changes to regulations. Their purpose is to set out the costs and benefits associated with the proposed changes compared to a ‘do nothing’ benchmark, i.e. a ‘business as usual’ counterfactual. The RIA can consider a range of regulatory options and, potentially, a non-regulatory one.

A review of the RIAs for the amendment in England and the proposed amendment in Wales was performed, relating to the ban on the use of combustible materials in and on the external walls of buildings, to inform the evidence base for an equivalent mandate in Scotland. A review of the assumptions made, the data required, and the modelling undertaken in the two RIAs was performed in order to consider a CBA for Scotland, the principles of which could be adopted to produce an RIA.

A key finding of the review was that whilst both RIAs identified possible benefits, the risk reductions were not quantified or monetised. It is not possible to undertake a full CBA given the lack of a monetised benefit.