BAFE have responded to the Practical fire safety guidance for existing specialised housing and other supported domestic accommodation document published by Scottish Government 31/07/2019.

The draft guidance document (which this response refers to) can be found here: https://www.gov.scot/publications/draft-practical-fire-safety-guidance-existing-specialised-housing-supported-domestic-accommodation/

BAFE’s Response can be seen below:

General Comments

BAFE welcomes the publication of the practical guidance and believes that it is a comprehensive document of high quality. It is clearly thorough and will be the crucial reference document for those in charge of specialised housing and other supported domestic accommodation. The Glossary is especially helpful to those unfamiliar with fire safety terms, but should contain a reference to Third Party Certification which is mentioned in various parts of the document.

BAFE would comment that the Guidance should perhaps include a more comprehensive listing of subsections for easier reference.  The use of colour backgrounds per topic might also be helpful. The online version might have searchable links.

A valid question might be who is going to read this document and in what circumstances? Furthermore is specific advice on particular topics readily accessible? 

The production of a digest, a shorter version, an advisory leaflet or other form of guide to the Guidance would seem appropriate.

BAFE welcomes the introduction of the concept "the person – centred fire safety risk assessment" which appears to be a wholly new concept and one for which there is currently no standard.

Detailed Comments by Paragraph Number

Person-Centred Safety Risk Assessment

In Paragraph 13 in line 1 would it be sensible to add after domestic premises “including single dwellings” in case the plural of premises suggests that single dwellings are not included?

Paragraph 21 could include a more clear signpost on how to judge the competence of a fire risk assessor. The reference to Part two is helpful but could usefully be much more specific i.e. “see paragraph 131”.

Paragraph 30 might be more clear as to whether the text is referring to all sheltered and extra care housing. Is this a retrospective provision and if so should there be a reference to how the requirements might be met?

Paragraph 40 might usefully make reference to the fact that any visible compromise of separation should be identified by a proper fire risk assessment. The fire risk assessment should trigger rectification work.

Paragraph 49 and related paragraphs 101 and 343 should also refer to the need for fire alarm systems in specialised housing to be installed and maintained by a contractor, competent in fire protection standards.

Paragraph 52 should thought be given to requiring a different sound for alarms in communal detection systems to that in individual flats or rooms?

Paragraph 66 BAFE thoroughly endorses the comprehensive checklist in this section.

Paragraph 101 There are some significant problems of activation and failings in pipework in domestic and residential premises being fitted with sprinklers or water mist systems. There should be a reference to competence and third party certification to relevant standards.

Premises Based Fire Safety Risk Assessment

BAFE's scheme SP205 [Life Safety Fire Risk Assessment] is relevant to this section.

Paragraph 124 should highlight the importance of hiring a specialist assessor if there is any doubt as to the ability of those responsible for the management of the building being able to carry out a comprehensive fire risk assessment. To omit this is to risk someone exceeding or try to exceed their level of skill or experience or expertise.

Paragraph 126 does not give any suggestion as to what "a sample of entrance doors" actually means. BAFE would comment that as many doors as practical should be inspected including fire doors in passages. Fire safety doors have been found to be absent, ill fitted or damaged in many tower blocks and such faults caused the evacuation of a number of buildings in the London Borough adjacent to Kensington immediately after the Grenfell Tower disaster.

Paragraph 149 might the Guidance not include a sample template for reporting the findings fire safety risk assessments?

BAFE welcomes paragraphs 226 and 227.

Paragraphs 340 and 341 ought to include a reference to a regular testing and maintenance regime for lighting on escape routes. It is BAFE's experience that this is often neglected and can cause varying degrees of difficulty in emergency situations.

Attention is drawn on page 124 under Other Guidance to the second reference. Please note that the IEE wiring regulations are now in their 18th edition.