Scottish Building Regulations: Fire Safety review and Compliance: Call for Evidence

Recommendation 8 of the Grenfell Tower Inquiry Phase 2 Report:

• That the guidance draw attention to the need to make an essential part of any fire safety strategy the calculation of the likely rate of fire spread and the time required for evacuation, including the evacuation of those with physical or mental impairments.

Linked to Recommendations 5,6,7 and 10, this seeks to encourage a more informed position on the level of risk occupants of a building will be exposed to in the event of a fire. Through a formal assessment of the likely rate of spread of fire (based upon typical hazard scenarios) and an assessment of the time needed to alert and evacuate occupants. This includes consideration of the time needed to support occupants, including ‘any with physical or mental impairments’.

At present, there are no provisions specific to domestic buildings which mandate the production of a fire safety strategy. However, a (simple) fire safety design summary is sought for new non-domestic buildings, regardless of whether fire engineering principles are applied or not.

In Scotland, Recommendation 57 asks that consideration be given to personal emergency evacuation plans. Scottish Government has asked the Scottish Law Commission to undertake a project on Compulsory Owners Associations. They are exploring legal options for the establishment, formation and operation of compulsory owners’ associations and the rights and responsibilities to be imposed on them. The recommendations from the Scottish Law Commission are anticipated in Spring 2026 for consideration by Ministers. Following the Law Commission's recommendations, Scottish Government will consider whether Compulsory Owners Associations may be a route to ensure that those who are unable to self-evacuate have a person-centred risk assessment in place.

As part of the review of Section 2 (Fire), Scottish Government will explore the introduction of a Fire Safety Design Summary process for certain domestic buildings at both the design and completion stage and will review assumptions in guidance relating to means of escape, in particular for vulnerable and disabled people, and explore where these assumptions and current provisions may be improved, for example relating to evacuation lifts. This will include public and targeted further consultation with appropriate stakeholders such as Scottish Fire and Rescue Service, local authority verifiers, designers and fire engineers.

Examples of potential areas for development may be: 

• develop a Fire Safety Design Summary process for flats and maisonettes in  multi-storey domestic buildings - this may be limited to the completion stage only due to the occupant’s vulnerabilities being unknown at the design stage
   
• review assumptions made in guidance for means of escape of vulnerable and disabled people and explore potential areas for improvement of provisions, for example evacuation lifts
   
• consider possible delivery through a potential threefold compliance pathway as highlighted in the previous question on the legal status of guidance
   
• explore a standardised approach to these (perhaps variable) calculations with guidance and clear methodology