In this blog I will be discussing the new fire safety standards which apply to Scotland. I will be going over the changes as well as the potential impact it will have on social landlords.
Following the tragic fire at Grenfell Tower in London there has been a stern focus on fire safety. A consultation on fire and smoke alarms took place in 2017 and out of that spurred the change to legislation which we are now seeing.
On the 1st of February the Scottish government published the news of the new fire safety standards for Scottish homes as well as fact sheets and guidance.
The big news is that there will be changes to the repairing standard in the Housing (Scotland) Act 2006 but the most impactful change comes through the tolerable standard under section 86 of the Housing (Scotland) Act 1987.
From the 1st of February 2021 an amendment to the tolerable standard which will require that all houses, regardless of tenure, must have satisfactory provision for detecting fires and for giving warning in the event of fire or suspected fire. After this addition, the definition what meets the tolerable standard will look something like the following:
A house meets the tolerable standard for the purposes of this Act if the house—
- Is structurally stable;
- Is substantially free from rising or penetrating damp;
- Has satisfactory provision for natural and artificial lighting, for ventilation and for heating;
- Has an adequate piped supply of wholesome water available within the house;
- Has a sink provided with a satisfactory supply of both hot and cold water within the house;
- Has a water closet available for the exclusive use of the occupants of the house and suitably located within the house;
- Has a fixed bath or shower and a wash-hand basin, each provided with a satisfactory supply of both hot and cold water and suitably located within the house;
- Has an effective system for the drainage and disposal of foul and surface water;
- Has satisfactory facilities for the cooking of food within the house;
- Has satisfactory access to all external doors and outbuildings;
- Has satisfactory equipment installed for detecting, and for giving warning of, fire or suspected fire;
- Has satisfactory equipment installed for detecting, and for giving warning of, carbon monoxide present in a concentration that is hazardous to health.
Smoke and Heat Detectors
So, what does the term satisfactory equipment mean exactly? The government guidance defines the term satisfactory for fire detection equipment to mean the following:
- One smoke alarm installed in the room most frequently used for general daytime living purposes (normally the living room/lounge);
- One smoke alarm in every circulation space on each storey, such as hallways and landings;
- One heat alarm installed in every kitchen;
- All smoke and heat alarms to be ceiling mounted; and
- All smoke and heat alarms to be interlinked.
This brings the requirements for existing properties up to the likes of the Scottish Building Regulations, BS 5839-6:2013 and the requirements already in place for private landlords in Scotland.
The alarms can be mains-operated alarms with battery backup or tamper proof long-life lithium battery alarms, PP3 type or user-replaceable battery alarms are not permitted.
There are various ways to achieve the interconnection between the alarms which will go from hard-wired interconnection, RF interconnection and a hybrid interconnection which is a mixture of the two.
Carbon Monoxide Detectors
The guidance on what constitutes satisfactory equipment for CO alarms is as follows:
- CO detectors will need to be fitted in all rooms where there is a fixed combustion appliance (excluding an appliance used solely for cooking) or a flue.
So for example where boilers have a horizontal flue passing through another room in the house, multiple CO detectors will be needed.
Combined heat and CO alarms are now available as well so landlords can hit two birds with one stone to reduce the amount of alarms fitted. From what I can tell, the guidance does not stipulate that the CO alarms need to be interlinked however this is easily achievable with RF interconnection.
CO detectors can be battery powered or hard-wired in compliance with BS EN 50291. The detector should incorporate a warning device to alert the users when its working life is due to expire. The sealed in lithium cell battery powered units usually come with just over a 10 year life expectancy.
These new standards are quite a big change for social landlords for a couple of reasons. Some associations have spent allot of money fitting alarms over the years that do not have the ability to be interconnected, so this money has been wasted as these will need to be replaced.
Most landlords will fit CO alarms during the annual gas safety check but for those who haven’t they will need to find the budget to supply CO detectors to all of the stock.
Ultimately this is an expense that social landlords will need to prioritise. For Scottish housing associations, failure to meet this standard will mean the property falls below the tolerable standard. This will be reportable to the Scottish housing regulator through the annual return on the charter.
There is a consultation out just now in regards to the questions set by the regulator for the yearly submission by housing associations. We might see some new questions added to specifically cover this new change in legislation or it may be covered by SHQS compliance. Either way I don’t foresee all associations managing 100% compliance straight away and it might actually make SHQS compliance go down before making its way back up as associations plan for the fire detection replacement.
Social landlords will also be looking to firm up on their asset management to keep track of the life expectancy of the individual units as well as storing other relevant details.
For homeowners compliance will form part of any Home Report when you come to sell your home. Local authorities will be able to use their statutory powers to require owners to carry out work on substandard housing but I doubt we will see many examples of this.
Update: SFHA has confirmed that the Scottish Government will be running an interest-free loan scheme to help registered social landlords achieve the new fire safety standards. The loan will cover the cost of the detectors and installation but not any decorative work required. The deadline for applications is 30 November 2019.
Training and more
Aico are very active with rolling out free training both for landlords and electrical contractors so if you are looking to learn more on this subject that would be a good place to start. I managed to get a hold of one of their training powerpoint presentations which has around 400 slides so as you can imagine this blog really only scratched the surface.
If you would like to read more on a range of topics that have an impact on the social housing sector, check out some of the previous blog posts on electrical safety, gas safety and more.