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

Closes 7 Mar 2025

Call for evidence on current standards

The questions in this section seek your views to inform developing policy areas. 

23. It is proposed to undertake further research and gather evidence to inform the policy. Please confirm any evidence, contribution or initial comments that would help towards this:

BS 476

Since the introduction of the Harmonised European Standards for Reaction and Resistance to fire into the technical handbooks it has always been the intention to remove the associated national classes (BS 476). Scotland removed the Reaction to fire classifications in 2019.

England have recently announced they will be removing the same Reaction to fire classifications but they will also include those relating to Vulnerability of roof coverings in 2025 and Resistance to fire in 2029.

Scotland are considering to align with England and remove the current dual system for testing and classification from guidance by removing the national classifications (BS 476) for Resistance to fire and Vulnerability of roof coverings.

24. It is proposed to undertake further research and gather evidence to inform the policy. Please confirm any evidence, contribution or initial comments that would help towards this:

Battery Energy Storage Systems

Battery Energy Storage Systems form a key part of renewable energy strategies. It is expected that there will be a rise in the number of battery energy storage systems being installed in dwellings given their effectiveness of storing energy from renewable energy technologies such as solar photovoltaic systems. 

PAS 63100:2024 Electrical installations – Protection against fire of battery energy storage systems for use in dwellings was published in March 2024. PAS 63100 aims to help installers reduce the risk of batteries in dwellings becoming a source of ignition and to limit the impact of a battery fire should one occur. The basic premise is that the best place for storage batteries is outside dwellings and away from habitable rooms.

Type 6 of schedule 1 of the Building (Scotland) Regulations 2004 covers “Detached fixed plant or machinery or a detached building housing only fixed plant or machinery, the only normal visits to which are intermittent visits to inspect or maintain the fixed plant or machinery”. It is considered that battery energy storage systems would fall into this category and would not require a building warrant provided the building / plant is 1m or more away from the boundary. The same principle applies for non-domestic buildings.  

Whilst battery fires, at the time of writing, are low frequency, they have a high impact due to their behaviour in fire. Since some batteries can exhibit focussed jet-like flaming, a higher degree of fire compartmentation should be considered. PAS 63100 recognises that fire compartmentation requirements might need to be assessed in future editions of this standard, as there are currently gaps in the knowledge of how fire compartmentation resists lithium battery fires.

For non-domestic applications, BS EN IEC 62619:2017 which specifies requirements and tests for the safe operation of secondary lithium cells and batteries used in industrial applications including stationary applications.  IEC 63056:2020 specifies requirements and tests for the product safety of secondary lithium cells and batteries used in electrical energy storage systems with a maximum DC voltage of 1,500 V (nominal). IEC 63056:2020 provides additional or specific requirements for electrical energy storage systems beyond the basic safety requirements covered by IEC 62619. It applies to cells and batteries for uninterruptible power supplies (UPS) but does not cover portable systems with a capacity of 500 Wh or below, which are addressed by IEC 61960-3 1.

It is proposed that further research for both domestic and non-domestic buildings is required to inform future policy decisions, for example related to compartmentation, early warning of fire, definition of place of special fire risk etc.

25. It is proposed to undertake a literature review to inform the policy on car parks and particularly in relation to electric vehicles. Please confirm any evidence, contribution or initial comments that would help towards this:

Car parks and electric vehicles

Scottish Government propose to commission a literature review of current research carried out globally on car park fire safety in relation to electric vehicles, hybrid vehicles and other forms of alternative energy vehicles. The outcomes of the research will inform decisions on current car park guidance in terms of compartmentation, fire resistance and automatic fire suppression systems.