Attendees and apologies
- Dr Stephen Garvin, Head of Building Standards, SG (Chair)
- Luke Bisby, University of Edinburgh
- Craig Ross, RICS
- Jim McGonigal, IFE
- Steven Daws, CS Todd & Associates
- Alan McAulay, LABSS
- Chris Getty, SFRS
- Debbie Smith, BRE
- Simon Routh-Jones, HM Chief Inspector of the Scottish Fire and Rescue Service
- Colin Hird, Building Standards, SG
- Gavin Gray, Fire and Rescue Unit, SG
- Shona Harper, Building Standards, SG
- Benny Rooney, Building Standards, SG
- Karen Coyne, Better Homes, SG
- Colin Todd, CS Todd and Associates
- Bill Connelly, NHS
Items and actions
1. Welcome, introductions and meeting protocol
The chair welcomed members to the group and explained the meeting protocol. The group comprised representation from academia, professional institutions, local authority building standards, fire testing, research and consultancy, fire and rescue service, HM Fire Service Inspectorate, UK and Scottish Government officials.
2. Background and programm
The chair provided background to the development of a Scottish version of the UK Government Expert Panel’s Consolidated Advice Note and set out the short programme. It is intended to have the draft guidance completed by the end of May 2020.
3. Experience with MHCLG Consolidated Guidance
Members of the working group were invited to share their experience with the guidance. The key points made by members were as follows:
- The Consolidated Advice Note was broadly supported and seen as a good reference point but it could be improved;
- The target audience and roles and responsibilities should be clarified and the intent of the guidance made clear i.e. life safety or property protection;
- Challenges around technical writing for building owners;
- The Consolidated Advice Note emphasises the need to assess fire risk to ensure the health and safety of occupants and the intention would be for any Scottish guidance to also focus on life safety, and not property protection.
- The reasonableness of undertaking intrusive inspections (which are implied by the Consolidated Advice Note) was called into question, and the competency of professionals and contractors highlighted;
- It was clear from members that a risk based approach should be emphasised in the Scottish advice especially considering the Consolidated Advice Note applies to existing low rise residential buildings;
- More detail and a risk based approach for buildings partially clad with combustible material would be welcome;
- Competence was a key issue including the shortage of chartered fire engineers available to do the work. It was agreed to defer the competency question until the second meeting;
- The cost / extended waiting times for large scale BS 8414 tests and delays in remediation was emphasised;
- The application of building regulations to building work only and NOT retrospectively to existing buildings was emphasised.
4. Content, format and layout of guidance
- Officials provided an overview of the risk-based fire safety regulatory regime in Scotland and the potential content, format and layout of the guidance;
- It was highlighted that external wall cladding was not always given detailed consideration in fire safety risk assessments prior to Grenfell, as compliance with Building Regs was often treated by assessors as “deemed to satisfy”;
- Guidance for existing buildings contains brief information on external fire spread, referring to the need for specialist advice should verification be needed;
- Differences between the fire safety regimes in Scotland and England were discussed. It was noted that legislation doesn’t generally apply to the common parts of domestic premises in Scotland, unlike in England and Wales where risk assessment is a legal requirement;
- New legislation for E&W will go further and clarify that cladding and flat entrance doors are part of the common parts, so should be part of the fire risk assessment;
- In Scotland, it is best practice to risk assess common parts of domestic premises, supported by new guidance. The effectiveness of this approach is being monitored and evaluated.
- A stand-alone Scottish version of the MHCLG Advice Note was agreed, as opposed to integrating into existing guidance documents;
- Links signposting the document could be inserted into existing sector specific fire safety guidance;
- Views were expressed for and against mirroring the layout and content of the MHCLG Advice note;
- A risk was identified that mortgage lenders could set their own standards for lending regardless of clarifications in the Scottish version.
5. Behaviour of cladding materials in fire
- The Building Research Establishment (BRE) and officials provided an overview of the large scale fire tests carried on Aluminium Composite Material (ACM) and High Pressure Laminate (HPL) panels.
- BRE also provided members with a summary of the intermediate scale experimental fire tests carried out for MHCLG and published on 2 April 2020.
- It is clear from the experimental work that none of the common (Non-ACM) cladding products (including HPL) represented the same risk as ACM with an unmodified polyethylene core. This evidence should help inform risk assessments going forward;
- Some members voiced concerns with HPL. It was acknowledged that the Consolidated Advice Note highlights the dangers of Euro Class C and D HPL cladding and the use of any Class of HPL with combustible insulation.
- A question was asked as to whether EPS rendered cladding systems were included in BRE post Grenfell cladding research. It was confirmed they were not included as the main focus of the research was ventilated rainscreen cladding systems. However, the BRE list of cladding systems tested to BS 8414 and classified to BR 135 is available on the BRE web site and this does include some EPS rendered cladding systems.
6. Key Issues and fire doors
- The definition of residential building was agreed.
- Clarify that structural elements of buildings (including timber framed buildings) are out with the scope of the advice note;
- The need to consider vulnerable people, evacuation strategies and delayed evacuation times as part of a risk based approach was recognised;
- Views for and against the 18m or 11m trigger height (as introduced in revised building standards from October 2019) were expressed.
- It is clear that a Scottish version of the MHCLG Consolidated Advice Note should not exacerbate the mortgage lending crisis. Although there was some support for the 11m threshold, officials are minded to consider the potential unintended consequences if adopting the 11m trigger height and potential costs of large scale remediation.
- The Expert Panel had considered referring to 11m, but wasn’t supported by AD.B guidance at the time. (Note: the current MHCLG consultation is currently considering this issue);
- Guidance benchmarks for existing buildings draw heavily on current design guidance from British Standards or Technical Handbooks, which in Scotland refers to 11m. As the Consolidated Advice Note repeatedly refers to residential buildings regardless of height, it was agreed to consider this issue further.
- Building regulations in relation to fire doors (including their replacement) in Scotland were explained. Officials consider that advice on fire doors is sufficient in existing fire safety guidance documents but agreed to consider the flow charts for GRP composite doors at the next meeting.
- It is intended to provide a ‘crude first draft’ of the Scottish Advice Note for the next meeting.
8. Date of next meeting
Wednesday 13th May 14:00 – 16:00
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