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BAFE Respond to Scottish Government Fire Safety Consultation on High Rise Domestic Buildings
Monday 15th July 2019
Scottish Government Fire Safety Consultation on High Rise Domestic Buildings
BAFE, the independent register of quality fire safety service providers, have officially responded to the Scottish Government’s Strengthening Fire Safety for High Rise Domestic Buildings consultation.
BAFE comments that the guidance created regarding fire safety in high rise domestic buildings appears “to have been sensibly composed.” BAFE also notes at this time there is “nothing wrong with the Fire (Scotland) Act 2005. It is rather the implementation of the legislation and accompanying Regulations wherein difficulty lies, especially the lack of clarity regarding the ongoing use and maintenance of buildings and the competence of providers.”
Common areas within residential properties were a major focus and BAFE noted that the Duty Holder and property management have a big role here to enforce action (such as removal of items) and therefore create a safer environment. A fire safety awareness campaign is seen to be a good thing stressing “that awareness campaigns with Duty Holders and building managers are essential”.
Part 3 looked at fire safety in existing high rise domestic buildings. BAFE stresses that “There should be a much stronger warning [in the guidance document] against proceeding if not competent or not ensuring that service providers are competent.” BAFE is also disappointed that there is a glaring omission of any emergency lighting provision and no mention of competent maintenance of systems, doors, lighting etc for these to remain effective.
BAFE comments that fire risk assessments for common areas should be made compulsory by regulation by the Scottish Government but welcomes “the emphasis placed upon third party certification of products as a way to obtain quality, reliability and safety”. This would be enhanced in Scottish Government guidance by “adding that obtaining third party certificated products is one means for the duty holder to demonstrate due diligence”.
The consultation ends stating that a Business and Regulatory Impact Assessment (BRIA) will be published by Scottish Government that will “set out any expected impact that implementation of the guidance might have on a business”. BAFE’s response on this states “this argument is often advanced that requiring qualifications adds to business’ burdens. BAFE is of the view that while such considerations need to be taken into account these should be secondary where defective, substandard or negligent work can lead to a threat of life. If is further of importance to say that setting basic competence standards for the quality of workmanship means that all should be able to commence at the same threshold and cost base which allows for fair competition. The reassurance of tenants is of primary importance and their clear understanding that work is being undertaken to appropriate standards by competent providers is a key to achieving this”.
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Legal obligations nationwide require the appointed responsible person for fire safety for non-domestic premises to have adequate fire protection.