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

The fire risks posed by lath and plaster wall and ceiling coverings are covered in the guidance to support building and fire safety regulations, including clause 2.0.7 and most recent updates. Similarly, the fire risks associated with lath and plaster wall and ceiling linings is known and recognised in Historic Environment Scotland publications.

Paragraph 2.10 of schedule 5 of the Building (Scotland) Regulations 2004 states “Every building must be designed and constructed in such a way that in the event of an outbreak of fire within the building, illumination is provided to assist in escape.” This mandatory building standard is considered fit for purpose.

The supporting guidance allows for lighting of escape routes to be provided via artificial lighting supplied by a fire protected circuit or emergency lighting. When an existing building is being converted, the guidance recognises that it may be easier to install self-contained emergency luminaires than to install a protected circuit to the existing lighting system.

The guidance cites BS 5266-1 Emergency lighting – Part 1: Code of practice for the emergency lighting of premises. Emergency lighting is usually located at the ceiling level and helps occupants evacuate a building safely in the event of a fire by providing defined levels of lighting to escape routes and exits.

However, low level emergency lighting works in a similar manner but is positioned close to the floor to help building occupants wayfind along escape routes in low visibility conditions during a fire event. The expert panel has proposed that the current requirement for a fire protected circuit be removed, with no need for a separate or fire resisting circuit.

Paragraph 2.10 of schedule 5 of the Building (Scotland) Regulations 2004 states “Every building must be designed and constructed in such a way that in the event of an outbreak of fire within the building, illumination is provided to assist in escape.” 

This mandatory building standard is considered fit for purpose.

The supporting guidance allows for lighting of escape routes to be provided via artificial lighting supplied by a fire protected circuit or emergency lighting. When an existing building is being converted, the guidance recognises that it may be easier to install self-contained emergency luminaires than to install a protected circuit to the existing lighting system.

The guidance cites BS 5266-1 Emergency lighting – Part 1: Code of practice for the emergency lighting of premises. Emergency lighting is usually located at the ceiling level and helps occupants evacuate a building safely in the event of a fire by providing defined levels of lighting to escape routes and exits.

However, low level emergency lighting works in a similar manner but is positioned close to the floor to help building occupants wayfind along escape routes in low visibility conditions during a fire event. The expert panel has proposed that the current requirement for a fire protected circuit be removed, with no need for a separate or fire resisting circuit.

Mandatory Standard 2.14 Fire and Rescue Service Facilities states “Every building must be designed and constructed in such a way that facilities are provided to assist fire-fighting or rescue operations.” 

One of the actions committed to in the Scottish response to the Grenfell Inquiry Phase 1 report was for the Scottish Government to work with stakeholders to ensure external Premises Information Plates were fitted to all high rise domestic buildings in Scotland.

It is proposed to insert a new guidance clause 2.14.10 ‘External Premises Information Plates’ as below to ensure that such a provision is made where a high rise domestic building is constructed or formed by conversion.

New clause: 2.14.10 External Premises Information Plates

All new and converted or refurbished high rise domestic buildings with any storey at a height of more than 18 m above the ground, should have an external premises information plate fitted. It is also recommended that premises information plates are fitted to all existing premises of this type, in accordance with the Practical Fire Safety Guidance For Existing High Rise Domestic Buildings.

These plates display relevant, easy to see information to firefighters attending an incident or carrying out an inspection of a high rise domestic building including confirmation of the address of the building, the number of storeys, position of hydrants and dry risers and relevant information on lifts and escape stairs.

The information plates should be fitted above the main entrance to the building, the colour should be yellow as shown in the example image below and be at least 600 mm by 600 mm in size. They should be made of Di-Bond aluminium composite material.

The lettering font should be Helvetica, the text size will vary depending on characters per box but should be clear and readable from ground level. The signs should be affixed to buildings using either screws and wall plugs or a strong weatherproof bonding solution, at a height of no less than 3.5 m above the adjoining ground.

The External Premises Information Plates should contain the following information:

• confirmation of the building address;
• information on whether the premises contains maisonettes (with arrows denoting in and up or in and down);
• the number of hose lengths to the furthest flat;
• number of stairs and their location(s);
• the closest hydrant location and the number of hose lengths to an ideal appliance/pump location;
• location of dry/wet riser(s) and the number of hose lengths from appliance/pump to inlet;
• number of dry/wet risers, number of lifts noting odd, even or all floors served;
• building height in meters (m) and;
• number of floors.

SFRS can be contacted for advice on the layout and information required on an information plate for your premises. Contact details can be found on the SFRS website: Scottish Fire and Rescue Service.

Please refer to section 2.5.3. of the consultation paper to view examples of typical premises information plate. 

Clause 2.7.1 of the domestic and non-domestic technical handbooks - Following industry feedback which has suggested it is unclear if sheathing or backing boards form part of external wall cladding systems, it is proposed to clarify the guidance in clause 2.7.1 of the domestic technical handbook and non-domestic technical handbook are amended as shown below in bold text.

External wall cladding systems - means non load-bearing components attached to the buildings structure, for example, composite panels, clay or concrete tiles, slates, pre-cast concrete panels, stone panels, masonry, profiled metal sheeting including sandwich panels, rendered external thermally insulated cladding systems, glazing systems, timber panels, weather boarding and ventilated cladding systems. For the purposes of compliance with the building regulations and associated standards, external wall cladding systems also include spandrel panels and infill panels. Many systems incorporate non-loadbearing backing boards or panels, support rails, fixings, thermal insulation, fire barriers and cavity barriers located behind the outer cladding.

Sheathing or backing board - attached to and providing structural support to the forming part of the elements of structure of the building are frame is not considered to form part of the external wall cladding system. For example, a sheathing or backing board that provides racking resistance to the structural frame. However, where combustible sheathing or backing board is proposed in any building with a storey 11 m or more above the ground, a large scale facade fire test should be carried out (see annex 2.B). This is regardless of whether the sheathing or backing board contributes to the structural performance of the building. 

Regulation 8(4) and exemptions to European Classification A1 and A2 components that form part of an external wall cladding system

In June 2022 Regulation 8 was amended so that ‘relevant buildings’ having any storey at a height of more than 11 m above the ground, must be constructed of products which achieve European Classification A1 or A2, subject to some limited exceptions. Following a recent comparison by the Scottish Government of these limited exceptions between Scotland and England, England currently include the following as exemptions when considering the external wall components where Scotland has no equivalent such exemptions when considering the external wall cladding system

• components associated with a solar shading device (which includes brie soleil), excluding components whose primary function is to provide shade or deflect sunlight, such as the awning curtain or slats.
• materials which form the top horizontal floor layer of a balcony which are of European Classification A1 fl or A2 fl-sl (classified in accordance with the reaction to fire classification) provided that the entire layer has an imperforate substrate under it.

To improve UK parity where possible and clarity of Scotland’s exemptions it is proposed to introduce these exemptions into Regulation 8.

Exit width from rooms in non-domestic buildings

It is proposed to make the following key changes to clause 2.9.8 in the non-domestic technical handbook in bold text below:

1. Where all exits are at least 1.050 in width, the aggregate unobstructed width in mm of all escape routes from a room should be at least 5.3 x the occupancy capacity of the room or storey. This assumes a unit width of 530 mm per person and a rate of discharge of 40 persons per minute. The largest exit from the room should be discounted and the remaining exits should be wide enough to accommodate this discharge rate. For exits less than or equal to 1,050 mm, the exit capacity of each doorway should be as shown below.
    
2. Where the number of occupants who will use an exit doorway is not more than 225,  200, the clear opening width of the doorway should be at least 1,050 mm.
    
3. Where the number of occupants who will use an exit doorway is not more than 100, the clear opening width of the doorway should be at least 800 mm.

Please refer to section 2.5.6 of the consutlation paper for further detail. 

Building Standards officials have been working with the NHS National Fire safety Advisor on revisions to NHS Scotland Firecode Scottish Health Technical Memorandum 81 Part 1: Fire safety in the design of healthcare premises published in October 2022.

It is proposed to remove the current guidance on hospitals in Annex 2.B of the Non-domestic Technical Handbook and cite SHTM 81 Version 5.0. This will avoid duplication and remove the risk of the guidance diverging.

It is also under consideration to cite

• NHSScotland ‘Firecode’ Scottish Health Technical Memorandum 81 Part 2 – Guidance on the fire engineering of healthcare premises ; and
• NHSScotland ‘Firecode’ Scottish Health Technical Memorandum 81 Part 3: Atria in healthcare premises.

Building Standards officials have been working with the NHS National Fire safety Advisor on revisions to NHS Scotland Firecode Scottish Health Technical Memorandum 81 Part 1: Fire safety in the design of healthcare premises published in October 2022.

It is proposed to remove the current guidance on hospitals in Annex 2.B of the Non-domestic Technical Handbook and cite SHTM 81 Version 5.0. This will avoid duplication and remove the risk of the guidance diverging.

It is also under consideration to cite

• NHSScotland ‘Firecode’ Scottish Health Technical Memorandum 81 Part 2 – Guidance on the fire engineering of healthcare premises ; and
• NHSScotland ‘Firecode’ Scottish Health Technical Memorandum 81 Part 3: Atria in healthcare premises.

Electric locking and access control is becoming more prevalent and buildings are containing more security features for doors on escape routes and those having to be operated in an emergency.

Panic exit devices to BS EN 1125 are intended primarily for buildings where the public are likely to be present and a panic situation could arise if the building must be evacuated quickly. For this reason, the devices are designed to operate by body pressure alone and require no knowledge of their operation to enable safe and effective evacuation of a building.

Emergency exit devices to BS EN 179 are intended for escape from buildings where the public are unlikely to be present, and where the staff in the building have been trained both in emergency procedures and in the use of the specific emergency exit devices fitted. For this reason, panic situations are considered unlikely, and these devices are therefore permitted to have higher operating forces and do not have to release by body pressure alone.

All panic and emergency exit devices will provide a basic level of security against intrusion, but there is increasingly a need for higher security in buildings such as supermarkets and stores with high insured content, and even in schools and hospitals to protect the occupants against the attentions of intruders or to prevent the occupants from wandering out of the building.

BS EN 13637 ‘Electrically controlled exit systems for use on escape routes’ provides guidance on safe ways of combining physical security with effective means of escape. This increase in security provision, helps to avoid unsafe locking practices, for example, using additional padlocks and chains. These electronic devices should always be discussed with local building standards and fire authorities and will generally be determined on a building occupancy and risk assessment basis.

BS EN 13637 specifies the requirements for the performance and testing of electrically controlled exit systems, specifically designed for use in an emergency or panic situation in escape routes. These electrically controlled exit systems consist of at least the following elements, separate or combined:

• Initiating element for requesting the release of electrical locking element in order to exit;
• Electrical locking element for securing an exit door;
• Electrical controlling element for supplying, connecting and controlling;
• Electrical locking element and initiating element;
• Signalling elements

In addition these electrically controlled exit systems can include time delay and/or denied exit mode.

The EN 13637 standard applies to both emergency and panic risks and the correct system solution should be commensurate to the specific risk applicable. The performance requirements of this standard are intended to assure safe and effective escape through a doorway with a maximum of two operations to release the electrically controlled exit system. A risk assessment that takes account of the type and number of users must be undertaken to determine the correct system solution and be recorded as part of the fire safety design summary (FSDS) for the building. The FSDS is submitted to the LA verifier at the same time as the Completion Certificate for the Building Warrant in submitted.

In all cases it is essential that the escape function of the door is not compromised at any time while the building is occupied. In particular, any additional dead bolt locking used must still enable the exit device to comply with the release requirements of EN 13637.

If delayed egress devices are to be used, they must be designed such that after the agreed delay period, the door will automatically be released. In the case of genuine emergency, such as a fire alarm or power failure, the door must be released immediately.

Any electrically controlled locking systems should be installed in compliance with BS 7273-4, Code of practice for the operation of fire protection measures. Actuation of release mechanisms for doors. The standard applies to all aspects of the interface between these mechanisms and a fire detection and fire alarm system.

It is proposed to cite BS EN 13637 but noting no intention to replace references to BS EN 1125 or BS EN 179 in the Technical Handbooks. Any reference to electrically controlled exit systems to BS EN 13637 in the Technical Handbooks will be as a risk-based alternative approach and complement existing standards.   

The Scottish Government will continue work to draft amended guidance on locking mechanisms in the handbooks.