Scottish Building Regulations: Proposed review of fire safety topics including Cameron House Hotel recommendations:

Overview

This consultation seeks to obtain the views and opinions of stakeholders on a review of building standards relating to the fire safety of historic buildings converted for hotel use. Some wider fire safety issues are also considered to help ensure the safety of people in and around Scotland's buildings.

The consultation covers six main areas, as follows:

• considers introducing a requirement to have active fire suppression systems installed for future conversions of historic buildings to be used as hotel accommodation
   
• considers the special risks which existing hotels and similar premises may pose through the presence of hidden cavities or voids, varying standards of workmanships, age, and the variance from current standards and if revising the guidance provided by the Scottish Government and others is needed
   
• the application of mandatory building standard 2.15 - automatic fire suppression systems - to alterations, extensions and conversions of buildings within scope of the standard
   
• mandating of non-combustible external wall cladding systems in new build hotels, boarding houses and hostels over 11m in height
   
• miscellaneous fire safety issues
   
• impact assessments
   

The proposed changes outlined in the consultation aim to:

• improve fire safety for the design and construction of all buildings, including historic buildings converted for hotel use, making them safer for those in and around buildings in the event of an outbreak of fire
   

Background

The publication of the fatal accident inquiry report looking into the deaths of Simon Midgley and Richard Dyson following a building fire at Cameron House hotel on 18 December 2017 was published on 11 January 2023. Six recommendations were provided, two directed at Scottish Government.

• Recommendation 4: 'The Scottish Government should consider introducing for future conversions of historic buildings to be used as hotel accommodation a requirement to have active fire suppression systems installed.'
   
• Recommendation 5: 'The Scottish Government should constitute an expert working group to more fully explore the special risks which existing hotels and similar premises may pose through the presence of hidden cavities or voids, varying standards of workmanships, age, and the variance from current standards and to consider revising the guidance provided by the Scottish Government and others'

The Scottish Government established the short life working group as a forum to consider the recommendations from the fatal accident inquiry. It brought together those parties directly referenced within the fatal accident inquiry report by Sheriff McCartney, namely, Scottish Government, Scottish Tourism Alliance, UK Hospitality Scotland and the Scottish Fire and Rescue Service among others.

Following meetings of the group throughout 2023, a final report was published on 2 October 2023 outlining actions to be taken against each recommendation in the fatal accident inquiry.

As short term measures the Scottish Government

• amended the guidance in the technical handbooks (clause 2.0.7) to strengthen key messages on the challenges faced when converting traditional buildings and to promote the use of automatic fire suppression systems for historic building conversions to hotels
   
• amended the Section 34 letter to Local Authority Chief Executives under the Building (Scotland) Act 2003 (Section 34 - reports and information - notification of application for building warrant - Section 2 – fire) to require that a verifier must notify the Scottish Government where future conversions of historic buildings are to be used as hotel accommodation
   
• have worked with partners including industry to promote key fire safety messages around the special risk associated with historic construction techniques, materials, and fire spread in hidden voids

The building and fire safety expert working group has been created to look at the long-term commitments outlined within the Cameron House hotel short life working group report and to review other aspects of Scottish building standards and fire safety guidance. 

This consultation reflects the outcomes and proposals of the expert working group.

Read the consultation paper.  The consultation paper contains full background information for this consultation. You may find it useful to read or refer to while responding.

Why your views matter

The Scottish Government is now seeking the views of any organisation or individual with an interest in ensuring building standards legislation and associated technical handbook guidance fully address the issues raised in relation to:

• consideration given to mandating of automatic fire suppression systems through the building regulations when traditional buildings are converted to hotels.
• the role of voids and cavities in fire spread in traditional buildings used as hotels
• review associated guidance including the use of lath and plaster wall coverings, the presence of any fire-resistant material and low-level emergency lighting in hotels
• the application of mandatory building standard 2.15 automatic fire suppression systems to alterations, extensions and conversions of buildings within scope of the standard
• consideration given to mandating of non-combustible external wall cladding systems in new build hotels, boarding houses and hostels over 11 m in height
• miscellaneous issues in section 2 fire of the technical handbooks.