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

Recommendation 4 of the fatal accident inquiry into the deaths of two people following a fire at Cameron House hotel in 2017, was as follows:

“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.”

Automatic Fire Suppression Systems help to control the intensity and size of a fire, suppress it and in some cases may even extinguish it. It can provide occupants with the additional time necessary to escape following the outbreak of fire.

The fatal accident inquiry determined “that the installation of an active suppression system is a precaution which could reasonably have been taken and which, had it been taken might realistically have resulted in the deaths being avoided”. This led to recommendation 4 being made. It is understood that in making the recommendation, it was not anticipated:

“that sprinklers might be required for all future hotel (or guest house) conversions but rather that there might be a case for them where a similar range of complex, interlinked factors came into play and thus presented a high(er) risk to occupants”.  

It is understood that ‘complex, interlinked factors’, referred to in evidence, relates to attributes that increase the likelihood of non-compliance with the current building standards and the need to consider all risk factors holistically.

The general consensus of the expert panel being that small hotels, bed and breakfast establishments and boarding houses are outwith the scope of recommendation 4.

If legislation is required to mandate recommendation 4 of the fatal accident inquiry, a definition of ‘hotel’ may be required. Alternatively introduction of a prescriptive limitation under Standard 2.15 based upon size of premises, e.g. a hotel with more than XX letting bedrooms can be considered. 

Fire safety standards specify that occupants, once alerted to the outbreak of the fire, are provided with the opportunity to escape from the building, before being affected by fire or smoke. In the context of an existing traditional building converted for use as a hotel, this generally requires a need for detailed appraisal of the risk factors of the building under consideration.

Recommnedation 4 is currently being considered as intended to apply either: 

• to all instances of future traditional buildings converted to hotel use (which would be in Regulation, as a limitation within Mandatory Standard 2.15), or
   
• focused to those future conversions of traditional building to hotel use with complex and interlinked factors which present a high risk to occupants (and so incorporated as additional guidance within the non-domestic technical handbook under clause 2.0.7 alternative approach and sub heading for existing and traditional buildings and/or alternatively within the guidance for Mandatory Standard 2.15).

Two options have been identified:

• Option 1 -  mandating active fire suppression in traditional buildings converted to hotel use; or 
   
• Option 2 -  strengthen guidance to support the performance based approach to risk when converting traditional buildings to hotel use.

Noting, as part of the consideration of recommendation 4 (Option 1), the following research has been undertaken - Automatic Fire Suppression System installations - traditional building conversion to hotels: cost benefit analysis - gov.scot . The research shows that for traditional buildings, the benefits outweigh the costs if the AFSS is installed to BS 9251 direct off the mains supply. When the system is installed to BS 12845, the costs significantly outweigh the benefits where a tank and pump is required.

Please refer to sections 2.1.7, 2.1.8 and 2.1.9 of the consultation paper for the full supporting information and commentary to each option.