Building Standards Compliance and Fire Safety – a consultation on making Scotland’s buildings safer for people

Compliance and Enforcement - Are the roles and responsibilities of verifiers, building owners and developers clearly defined and recorded and should there be greater emphasis on inspection and testing, particularly of safety critical elements, throughout construction and at completion?

Workforce - Do you agree that verifiers, building owners and developers have the expected level of resources and skills need to undertake verification activity? 

Fire Safety - About the structure of the Technical Handbooks and Annexes and other ways of complying with building regulations. Whether a national “hub” approach should be developed to assist the verifying of fire safety engineering designs. Whether external wall cladding systems meeting European Classification A1 and A2 should apply to more building situations and if full scale façade tests should continue to be cited as an alternative. Whether an additional escape stair and an evacuation alert system be introduced to new high rise domestic building.  Whether new build flats, houses in multiple occupation with care 24/7 and large HMOs with more than 10 residents should require automatic fire suppression systems (sprinklers).

We received a total of 222 responses to the consultation from individuals and organisations. 246 individuals attended world café events at Edinburgh, Glasgow, Stirling and Aberdeen to discuss proposals and help shape the policy.

Compliance and Enforcement - The vast majority of respondents said roles and responsibilities of all parties involved in the building standards system should be more clearly defined.  Most respondents said it is essential for a stronger focus on safety critical elements throughout the build.  Most believe there is already a strong focus on these aspects and that a holistic approach is taken to bring a focus on high risk and complex designs whilst the current approach to low risk buildings is retained.

Workforce - The majority of respondents agreed that more and consistent resourcing of verification and better skilled verifiers are required.  This can be achieved by Scottish Government setting a minimum requirement for skills and resource and that uneven levels of experience should be addressed with an up-skill in verifiers’ knowledge and competence to support independence in verification.  It was recognised that building owners and developers also require the necessary skills and resource to assure themselves and the verifier of compliance.

Fire Safety - The majority of respondents agreed that that European Classification A1 and A2 should be introduced at 11m and to assembly/entertainment buildings, hospitals and residential care buildings of any height. That the full scale façade test to BS 8414 (and BR 135) continue to be cited as an alternative. Over one-third of respondents who were unsure cited lack of knowledge. The majority of respondents agreed that two stairs, an evacuation alert system to assist the fire and rescue services and automatic fire suppression systems should be introduced in new build flats, houses in multiple occupation with care 24/7 and large HMOs with more than 10 residents. Of those who disagreed, many cited cost and lack of evidence base to support the proposals.

Compliance and Enforcement - We have worked with Local Authority Building Standards Scotland to strengthn existing guidance on roles and responsibilities of everyone involved in achieving compliance with building standards.  Guidance contained in the Building Standards Procedural Handbook has been updated to strengthen and clarify the roles and responsibilities of those involved from pre-application discussion, approval of a building warrant application, inspection and testing during construction and the types of information to show compliance throughout and at completion.  This includes improved guidance on the inspection of large complex buildings and the need for inspections of key safety critical elements. 

Guidance relating to the use of the Construction Compliance and Notification Plan has been updated to set out the key construction stages that will require inspection with specific advice on safety critical elements.  The guidance stresses the importance of the verifier being notified at the correct time to undertake effective inspection and testing.  The guidance encourages early engagement by all parties, regular communication and improved partnership working throughout the duration of the building project. 

Workforce - we are developing a national building standards verification workforce strategy aimed at improving resourcing and competence.  The outcome will be a verification service that is sustainable, responsive to change and focused on customers.  The strategy will embrace work to establish a Professional Development Framework for all building standards staff to gain an accurate picture of competence, identify specific skill gaps and inform the development of new educational routes for professional development.

A working group comprising representatives from local government, academia, the education and skills sector and industry bodies is supporting development of national and local level actions that will address the issues faced by verifiers.  The strategy is expected to launch in March 2020.

Fire Safety - We have published revised Technical Handbooks to include more stringent fire safety provisions for external wall cladding systems, an additional escape stair, evacuation alert system and storey identification signs to help fire and rescue services in the unlikely event of a partial or full-scale evacuation of a high rise domestic building.

 We have agreed to defer the introduction of automatic fire suppression systems (AFSS) in all new build flats, houses in multiple occupation with care 24/7 and large HMOs with more than 10 residents until 2021 to align with our commitment to introduce AFSS in new build social housing.