Consultation on new fire safety guidance for small bed and breakfast and self-catering accommodation

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CONSULTATION ON NEW GUIDANCE

Proposals for inclusion in the Consultation on new guidance

Executive Summary

The Government has responded to the concerns of the Scottish Tourist Industry by working in partnership with them and the Fire Service to produce new fire safety guidance for small bed and breakfast and self-catering premises. One of the main concerns of the Industry was the cost to businesses of complying with the existing guidance. The Government has addressed this by producing draft guidance which reduces costs for a property to put in place fire safety measures from an average of £14,000 to an average of just over £1,000. Government has also, at the Industry's request, aimed to provide clear guidance so that operators of businesses know what they have to do to comply with the Fire (Scotland) Act 2005.

Background

Prior to October 2006, fire certificates were required for hotels and boarding houses providing sleeping accommodation for more than 6 persons (staff or guests), or any sleeping accommodation above the 1st floor or below the ground floor. If the business had employees, then the employer was obliged to comply with the Fire Precautions (Workplace) Regulations (regardless of whether or not they had a fire certificate). Under the previous legislation owners of many self-catering accommodation available for rent and smaller B&Bs were not required to comply with specific fire safety legislation. Fire safety obligations were imposed through general health and safety law.

In October 2006, Part three of the Fire (Scotland) Act 2005 and the Fire Safety (Scotland) Regulations 2006 were brought into effect, creating new responsibilities for the owners of small B&Bs and self-catering properties.

Fire (Scotland) Act 2005 and 'small guide'

From the introduction in October 2006 of Part 3 of the Fire (Scotland) Act 2005, businesses which provide sleeping accommodation have been required to comply with a risk based fire safety regime. Under the legislation, anyone with control to any extent of the premises (such as the owner or manager of a B&B or self-catering accommodation) must undertake a fire safety risk assessment of the premises, and take reasonable steps to prevent fire and put in place fire safety measures. The fundamental principle of the risk-based assessment regime is that any action taken should be proportionate to the assessed fire risk.

To help owners understand their new responsibilities and to provide a basis for enforcement action by Fire and Rescue Services ( FRSs), the 'Practical Fire Safety Guidance for Small Premises Providing Sleeping Accommodation' (small guide) was issued in October 2007. FRSs then, depending on the priorities for inspection based on risk in their particular area, began a process of inspection visits.

During late 2008 concerns were raised with Ministers about the enforcement of the new legal duties. The concerns suggested that the small guide was resulting in expensive and unnecessary fire safety measures being put in place which were not proportionate to the risks. There was a suggestion that some of the smaller proprietors might cease operating as a result. There were also related concerns that the small guide was overly complicated and confusing.

Whilst Ministers were keen to be assured that risks facing paying guests in such accommodation were well controlled, they also recognised the valuable contribution that the proprietors make to local economies and to the wider economic aims of Scottish Government, particularly in the year of Homecoming. Ministers therefore agreed that the guidance for small B&B and self-catering properties would be withdrawn. Guidance for larger properties remains in place.

In December 2008, the Minister for Community Safety announced that a working group, including tourism industry representatives, would convene to produce new guidance, which would then be subject to full consultation. The working group first met in April 2009 and held its last meeting in October 2009.

The tourism industry, Fire Services and Scottish Government were all represented on the group. A full list of members is at annex A.

Current position

Collectively the working group has moved a long way since April. All members accept that well run, small B&B and self-catering accommodation is at the lower end of risks in relation to fire in properties with sleeping accommodation. Members recognise the good practice that exists across much of the sector 1 and respect the fact that B&Bs provide homes for proprietors as well as accommodation for paying guests. However, people who pay to stay in the accommodation are owed a duty of care and are entitled to expect all involved to find ways to continue to discharge this in a proportionate and effective manner.

Risks

The group considered whether fire risks in B&Bs and self-catering accommodation might be different from the risks in purely domestic homes. The group did not reach a full consensus on this issue but the general view is that risks are different for a number of reasons.

The main difference between B&B, self-catering accommodation and a purely domestic home is the presence of paying guests. These guests are, in the main, unknown to the owner of the property and unfamiliar with the accommodation. This is different from having friends and family to stay.

In a B&B guests are less likely to feel responsibility for ensuring the safety of other guests and the owners, compared to the way in which members of a family or a group of friends in a dwelling or self-catering property are likely to behave. 2

The frequency of guests (friends and family) in a domestic home is much lower than in a B&B. For example one Highland and Islands B&B reported 160 paying guests in one month in the summer.

As guests are usually unfamiliar with the lay out of the property and its escape routes, it is likely that it will take longer for them to escape than it would in a property with which they are familiar. 3 The behaviour and health of guests can also be an unknown quantity in a B&B or self-catering property, even in a well managed business. In addition the risk of fire can be increased by guests bringing their own electrical equipment such as hairdryers, chargers, plug-in air fresheners and laptops to B&B and self-catering properties. 4 This is a risk which is very difficult for the operator to control and which can reduce the personal safety of (in the case of a B&B) a resident operator.

The reputational risk to the Scottish Tourist Industry, should injuries or deaths occur in premises with inadequate fire safety measures in place, was also of concern to some members of the group.

Some Industry members of the group, however, felt that the intimate nature of the operation of a B&B, combined with the innate duty of care to guests and constant presence of the owner, could actually provide higher levels of safety than those associated with a normal dwelling.

The following information is from the UK and Scotland Fire Stats 2007 (latest published). 5 All data relates to and 2007UKall unless stated otherwise. Although all members of the group agreed that the statistics presented were correct, there were differences in opinion on the interpretation of these statistics.

Numbers of Fires

There were a total of 83,700 fires in buildings (9,637 in Scotland). This included 1,800 (214 Scotland) fires in hotels, boarding houses, hostels etc. (2.2% of all building fires) and 52,700 fires in dwellings (6,684 Scotland) (63.0% of all building fires, 69% Scotland). Advice provided by the Chief Fire Officers Association for Scotland ( CFOA(S)) to the group shows that over the last five years there have been 30 fires identified as being in small premises providing sleeping accommodation in Scotland.

Fires caused by electrical fault or misuse

  • Faulty appliance or lead:
  • 7,300 dwelling fires (664 Scotland)(8.7% of all fires);
  • 6,000 in other buildings (641 Scotland) (7.2% of all fires).
  • Misuse of appliance or equipment:
  • 15,200 dwelling fires (2,539 Scotland)(18.0% of all fires);
  • 3,200 in other buildings (334 Scotland)(3.8% of all fires) .

Any of these causes could happen in a room in a B&B or self-catering property. Adding the fires together shows that 37.8% of all building fires are caused by faulty appliance or lead or misused appliances and equipment, (43.4% in Scotland) causing 6 deaths in buildings in Scotland and 569 casualties.

Where we are now

The working group has now concluded its task and Ministers would like to thank all members for their willingness to work together to find an agreed way forward.

The group has agreed the bulk of the new guidance. This includes some key principles around:

  • The generally low level of risk across the sector;
  • The need to discharge the duty of care towards paying guests;
  • The process to be followed by proprietors;
  • General description (including size/numbers of residents) of properties covered; and
  • Some fire safety measures for small B&B and self-catering properties.

Some differences of opinion within the group were unresolved. These relate in particular to:

  • fire safety measures for fire/smoke alarms and for B&Bs to doors; and
  • whether the level of risk justifies interlinked smoke alarms in bedrooms and self-closers on doors opening into corridors that would provide an exit route in event of fire.

The professional view of the FRS, supported by Scottish Government and some sections of the industry group, is that the combination of occupant actions, automatic fire alarms, doors designed to limit the spread of fire and smoke and firefighting equipment ensure that occupant safety is preserved to a satisfactory standard. In particular, the addition of detectors to every bedroom, kitchen and living area will help compensate for the fact that occupiers are unfamiliar with the premises and subsequent delays in escape compared to a dwelling. This is particularly important as the majority of fires have been in either the kitchen or the bedroom.

The approach for self-catering suggests the use of case studies to assist with deciding on appropriate fire safety measures, in particular the use of self-closers to doors. This is different from the guidance for B&Bs for the following reasons:

  • Self-closers are often considered impractical and are unpopular in dwellings, particularly where there are young children who could trap fingers or spill drinks and where parents \ carers often prefer to leave bedrooms doors open particularly while children settle to sleep. This is less the case in B&B's where guests usually prefer doors closed to maintain privacy, and any guests who are young children normally sleep in the same bedrooms as parents/carers.
  • Where a family group or group of friends are sharing accommodation in a self-catering property, it is more likely that one guest will warn the others of a fire ( e.g.: parents rescuing their children) than where strangers share accommodation in a B&B. Although there is still the risk that such guests may forget to close the door behind them limiting the spread of smoke and fire, the warning is likely to be better than in a B&B. This earlier warning reduces to an extent the need for a self-closing door.

The opposing view regarding the way forward, put forward by some of the industry representative bodies and illustrated through a fire engineering expert, is that risks for self-catering and B&B are on the same level or less than those for dwellings and that, therefore, proprietors should not have to provide any higher degree of fire protection than currently recommended in a domestic home in respect of the installation of additional smoke alarms and door closers.

Industry representatives also drew the attention of the working group to a report produced by Building Research establishment which relates to smoke detection in dwellings. 6 The conclusion of this report was that the installation of additional alarms to rooms other than the hall /landing did not "lead to any discernable reduction in risk". However this report relates to dwellings only and it should be noted that in spite of this report, Scottish Government's Building Standards Division is intending to introduce new guidance to recommend detectors in living areas and kitchens of new dwellings in addition to those in halls and landings. Also Communities and Local Government have produced guidance for small B&Bs and self-catering premises in England and Wales (called "Do you have paying guests" 7) which recommends detectors in bedrooms as well as hall/landing and kitchen.

All members of the group agree that we should now seek a wider range of views on the draft guidance and the outstanding issues around risk.

Arrangements for transition period with regard to any enforcement action by Fire Services

We recognise that the Fire (Scotland) Act and its regulations have placed new responsibilities on owners. We also acknowledge that the current economic climate poses challenges for small business: we do not want to add to that. It is, therefore, proposed that transitional arrangements be put in place for a minimum of 18 months after the publication of the new guidance. During this transition period, FRSs may carry out visits and provide advice but, provided an action plan is agreed between the owner and the FRS, the FRS would not take any enforcement action. During this period all owners, whether or not they receive a visit from their FRS, will be expected to carry out a risk assessment of their properties and, where necessary, come up with an action plan which will help them to carry out gradual improvements in fire safety provisions to protect their guests.

Arrangements for training for FRS enforcement officers and dissemination to FRS and the general public

The group is committed to ensuring that the final version of the guidance is applied consistently across the eight fire and rescue services. Scottish Government will work with CFOA(S) to ensure that a training programme is provided for all officers who will be involved in enforcement action.

Scottish Government ( SG) will work with the Federation of Small Business ( FSB), VisitScotland and the tourism sector to ensure that the guide is made available to those providing accommodation which falls within the scope of the guide. We will look at the possibility of promoting the guide in trade publications and local media to ensure that it has as wide a dissemination as possible.

Costs

The working group was keen to ensure that its proposals did not result in unreasonable or disproportionate financial costs for owners. SG has commissioned cost estimates for a number of case study properties to provide real life examples of what costs might be incurred by a B&B or self-catering property that does not currently meet all of the benchmarks in either the withdrawn guidance or this proposed new guidance.

The results of this cost study are summarised below. Full details are set out in annex B.

Case study

Using draft new guide

Using small guide

Difference

B&B Lower Cost / Best Case

£1,151

£16,359

£15,208

B&B Higher Cost / Worst Case

£1,612

£23,021

£21,409

Self-Catering Lower Cost / Best Case

£662

£8,820

£8,158

Self-Catering Higher Cost / Worst Case

£937

£13,303

£12,366

The cost study is a study of 4 specific cases, 3 of which are real properties. It does not claim to cover every eventuality and there will therefore be many cases where the cost to an operator of a particular property will be more or less than the costs detailed in the report. The costs are, however, considered reasonable and affordable considering that fire safety measures can be installed over a number of years. Examples of such cases are given below:

Examples of situations where costs may be less than those quoted in the report:

1. Costs are based on individual item costs. It may be possible for a group who own a number of properties or groups of operators to negotiate a bulk purchase price with a commercial supplier. SG has carried out some investigation to see if the FRS or the FSB could assist with bulk purchase, however this is precluded by conflicts of interests.

2. There will be many properties smaller in size than the lower cost examples in the report; in particular there are many self-catering properties which consist of only 1 or 2 bedrooms with one living /dining kitchen area, plus bathroom. Costs in the report include self-closers to doors for all properties which are not suggested for the smallest type of property in the case study examples.

3. There will be many properties which already have some of the required fire safety measures in place e.g. a fire blanket.

Examples of situations where costs may be more than those quoted in the report:

1. Costs for properties using the new guide assume that the operator will, in the interests of keeping costs to a minimum, choose to fix (screw-in) battery smoke detectors themselves and to test that the interlinking is working. However if they are unable or do not wish to do this, additional fitting and testing costs will be incurred;

2. There will be properties larger in size than the higher cost examples in the report, though examples given are large with 7 bedrooms and 4 bedrooms in the B&B and self-catering example properties respectively;

3. There may be properties where the cost of self-closers will be higher if a higher specification closer is required.

SG has also inquired about the effect of fire safety measures on insurance costs to businesses. The advice received suggested that the features advised in the draft new guidance would be seen as part of a necessary standard for fire safety with which insurers would expect their customers to comply. Where a client displays a particularly good overall standard of risk protection and management, this can be reflected through a relatively better level of premium, terms and conditions. A poor standard could affect an insurance company's willingness to provide a quote and could also affect a claim.

Impact on different user groups

Equality Impact Assessment

An Equality Impact Assessment has been completed for the new guide and the Scottish Government considers that nothing within the fire safety guide should impact disproportionately on equality groups within society. Tourist accommodation as a whole is open to all, subject to reasonable adjustments, regardless of specific need. Further the consultation guidance document reminds accommodation operators that they should consider, when compiling their risk assessments, the specific needs of vulnerable guests.

Strategic Environmental Assessment

The Scottish Government has also considered the potential for impact on the environment by the contents of this guide. The Scottish Government considers that nothing within the fire safety guide is likely to have an adverse impact on the environment. There is a possibility that the new guide may introduce limited environmental benefits. For example, this new guide, depending on individual risk assessments, may not require fire safety measures such as installation of new fire doors. This would represent a saving on the environmental impact of scrapping existing doors and the manufacture and installation of new doors.

Consultation

Ministers are committed to ensuring that all those likely to be affected by or interested in a subject should be given the opportunity to comment. We are, therefore, now consulting on the terms of the guidance as agreed by the group. Responders are invited to comment on part or the entirety of the guide. Specific questions are:

  • Do you agree with the description of the types of property that should fall under the scope of the guidance;
  • Does the section on benchmarks for fire safety fit with the principle that action should be proportionate with the general low risk but should also discharge the duty of care to paying guests;
  • What are your views on the proposal for 10 year battery interlinked smoke alarms in all guest bedrooms in B&B's and self-catering premises in addition to hall/landing, kitchen and living area;
  • What are your views on the proposal that doors opening onto any corridor in a B& B providing a route out in case of a fire should be fitted with self-closers (concealed type);
  • What are your views on the proposal that for self-catering properties the risk assessment should determine whether self-closers are required to doors, with case study examples (annex B of this document) being made available to assist with this;
  • Is the section on what to do if you disagree with FRS advice clear and helpful? Could it be improved in any way;
  • The proposed guidance (refer to "What does the law require") explains that a FRS may take enforcement action in cases where they are not satisfied with the degree of fire safety of the property. Do you agree that following the introduction of the new guidance, there should be a period of 18 months or 2 years during which FRS's would agree to delay any enforcement action (provided action plans are agreed);
  • Is annex A of the guidance (how to carry out a fire safety risk assessment) clear and helpful? It is suggested that this annex is set out as a tear off slip with tick-boxes/spaces for the operator to comment, so that this can be retained as a record of risk assessment being carried out. Do you agree? Could this annex be improved in any way?

Consultation paper and consultation list

The draft guidance paper and questions are attached, along with a list of consultees. We have tried to cover all relevant interests but if you feel another party would benefit from seeing this consultation, please forward a link to this consultation or pass on a copy.

This consultation and all other Scottish Government consultation exercises can be viewed online on the consultation web pages of the Scottish Government website at http://www.scotland.gov.uk/consultations.

Responding to this consultation paper

I invite written or email responses to this consultation paper by 18 February 2010

Please send your response to:

Graeme Fraser

Room 1R
St Andrew's House
Regent Road
Edinburgh
EH1 3DG

Email: B&Bself-cateringfiresafety@Scotland.gsi.gov.uk

Please include a completed Respondent Information Form (see "Handling your Response" below).

Handling your response

We need to know how you wish your response to be handled and, in particular, whether you are happy for your response to be made public. Please complete and return the attached Respondent Information Form at the end of this letter, doing so will ensure that we will treat your response appropriately. If you ask for your response not to be published we will regard it as confidential and we will handle it accordingly.

All respondents should be aware that the Scottish Government is subject to the provisions of the Freedom of Information (Scotland) Act 2002 and would therefore have to consider any request made under the Act for information relating to responses to this consultation exercise.

Where respondents have given permission for their response to be made public, copies will be made available to the public in the Scottish Government library and on the Scottish Government web pages. Where agreement to publish has been given, we will check all responses for any potentially defamatory material before logging them in the library or placing them on the website.

Next steps in the process

Where respondents have given permission for their response to be made public and after we have checked that they contain no potentially defamatory material, responses will be made available to the public in the Scottish Government Library (see the attached Respondent Information Form). These will be made available to the public in the Scottish Government Library by 18 March 2010 and on the Scottish Government consultation web pages as soon as possible thereafter. You can make arrangements to view responses by contacting the SG Library on 0131 244 4552. Responses can be copied and sent to you but a charge may be made for this service.

What happens next?

Following the closing date all responses will be analysed and considered along with any other evidence to help finalise the draft guidance. We aim to issue a report on this consultation process during April 2010 with a view to publishing the final principles for use by public service delivery organisations in Scotland by early spring 2010.

Comments and complaints

If you have any comments about how this consultation exercise has been conducted, please send them to me at the address above.

ANNEX A: MEMBERS OF WORKING GROUP

WORKING GROUP: NEW PRACTICAL FIRE SAFETY GUIDANCE FOR SMALL BED AND BREAKFAST and SELF-CATERING PREMISES

List of members

MEMBER

ORGANISATION

Ian Walford

Head of Scottish Resilience, Scottish Government

Joanne Boyle

Fire and Rescue Strategy Unit, Scottish Government

Graeme Fraser

Fire and Rescue Strategy Unit, Scottish Government

Brian McKenzie

Scottish Fire and Rescue Advisory Unit,

Scottish Government

Hugh Adie

Building Standards Division, Scottish Government

Danny Doherty/
Steve McKenzie

Chief Fire Officers Association Scotland ( CFOA(S))

Mairi Caldwell

Tourism Unit, Scottish Government

Iain Herbert

Scottish Tourism Forum

Bob Flavell

VisitScotland

Bill Carcas

Scotland's Best B&B's

Sam Lewis

Association of Scotland's Self-Caterers

Pauline Twemlow

Farmstay Scotland

Amanda Frazer

Federation of Small Businesses

Hamish Fraser

Federation of Small Businesses

David MacIntyre

Guest House and B &B Association

Alan Keith

Association of Dumfries and Galloway Accommodation Providers

ANNEX B: CASE STUDIES ON COSTS

New Fire Safety Guidance for Small B&B and Self-Catering Premises: Cost Model Report

Jane Eckersall
Associate Director

Turner & Townsend Cost Management Ltd
Osborne House,
1 Osborne Terrace,
Edinburgh
EH12 5HG
United Kingdom


t: +44 (0)131 347 3400
f: +44 (0)131 347 3401
e: jane.eckersall@turntown.co.uk
w: turnerandtownsend.com

Section 1 - Executive Summary

Case Study

A. Using Draft New Guide

B. Using 'Small Guide'

Difference

B&B Lower Cost / Best Case

£1,151

£16,359

£15,208

B&B Higher Cost / Worst Case

£1,612

£23,021

£21,409

Self-Catering Lower Cost / Best Case

£662

£8,820

£8,158

Self-Catering Higher Cost / Worst Case

£937

£13,303

£12,366

1.0 Executive Summary

1.1 Forecast Summary

The anticipated costs for bringing each of the four typical properties in line with current guidance and with proposed new guidance are as summarised in the table above.

1.2 Inflation Summary

All costs are based on prices current at 3rd Quarter 2009

1.3 Contingency Summary

A contingency has been included within the order of cost for each property. The percentage applied in each case varies to reflect the type of property, its age and current condition, and the type of works to be carried out.

2.0 Introduction

This Cost Model Report has been produced in response to the Project Brief - "Costing for Potential Work to Small B&B and Self- Catering Properties Using Government Proposed and Recently Withdrawn Guidance" provided by the Scottish Government.

The purpose of the Report is to provide an order of cost, for four typical properties, to compare the costs of complying with the current guidance as typically interpreted by the Fire Authorities with the likely costs of complying with the proposed new guidance.

3.1 Cost Report

3.1.1 Properties Reviewed

As part of the brief, the Scottish Government identified four different properties for review, the exact details of which are included at Appendix A to this report. These properties fall into the following broad classifications:

  • Property 1 B&B lower cost / best case: small 2-storey B&B with street lighting.
  • Property 2 B&B higher cost / worst case: larger 3-storey B&B with no street lighting.
  • Property 3 Self-Catering lower cost / best case: small lower storey self-catering property with street lighting.
  • Property 4 Self-Catering higher cost / worst case: larger 2-storey self-catering property with no street lighting.

In preparation of this Report, Turner & Townsend carried out site visits to three identified properties and used existing information on a 'typical' property for the fourth.

3.1.2 Capital Cost Estimates

For each of the four properties reviewed, Turner & Townsend have prepared two cost estimates as follows:

  • Costs to fulfil 'requirements' using draft new guide
  • Costs to fulfil 'requirements' using existing 'small guide'

A summary of these costs is included in Section 5, and the detailed cost estimates are included at Appendix B to this report.

3.2 Basis of costs

3.2.1 Information Used

This report has been prepared on the basis of the following information:

  • Scottish Government Project Brief: Costing for Potential Work to Small B&B and Self-Catering Properties Using Government Proposed and Recently Withdrawn Guidance, amended 23 September 2009;
  • Working Group: New Practical Fire Safety Guidance for Small B&B and Self-Catering Premises, Consultation Draft of New Guidance;
  • Information gathered during Turner & Townsend site visits to selected properties;
  • Turner & Townsend benchmark cost data for similar projects;
  • Market tested rates for specific elements of the works.

3.2.2 Scope of Works

The scope of works included within the costs, as identified within the Scottish Government's project brief is as follows:

B&B Properties - A. Requirements Using Draft New Guide

  • Supply only battery powered interlinked heat detector to kitchen, smoke detector to each room (excluding en-suites), plus landings in multi-storey properties. Detectors to be fitted with a long-life lithium battery. The RF range is 150m in free space and upto 30m buildings
  • Supply & install concealed self-closers to all room doors (excluding en-suites):
  • Supply only 'plug-in' nightlights with battery back-up for hall and landings in multi-storey properties only;
  • Supply only fire blanket and dry powder extinguisher to kitchen;
  • It is assumed there will be no need for redecoration.

Self-Catering Properties - A. Requirements Using Draft New Guide

  • Supply only battery powered interlinked heat detector to kitchen, smoke detector to each room (excluding en-suites), plus landings in multi-storey properties. All detectors to be fitted with long-life lithium battery. The RF range is 150m in free space and upto 30m buildings
  • Supply & install concealed self-closers to all room doors (excluding en-suites) in multi-storey properties only;
  • Supply only 'plug-in' nightlights with battery back-up for hall and landings in multi-storey properties only;
  • Supply only fire blanket to kitchen;
  • It is assumed there will be no need for redecoration.

B&B Properties - B. Requirements Using Small Guide

  • Supply & install full mains wired detection system including break glass units, heat detector to kitchen, smoke detectors to all other rooms (excluding en-suites) and hallway, plus landings in multi-storey properties;
  • Allow for redecoration following installation of flush wiring;
  • Supply & install FD 30S self-closing fire doors to all rooms leading onto escape routes (including stores). The size and weight of the door will determine the type of closer.
  • Supply & install self contained luminaires to hallway, and to landings in multi-storey properties
  • Supply only fire blanket to kitchen, dry powder extinguisher to hall or kitchen, and dry powder extinguisher to landings in multistorey properties.

Self-Catering Properties - B. Requirements Using Small Guide

  • Supply & install full mains wired detection system including break glass units, heat detector to kitchen, smoke detectors to all other rooms (excluding en-suites) and hallway, plus landings in multi-storey properties;
  • Allow for redecoration following installation of flush wiring;
  • Supply & install FD30S self-closing fire doors to all rooms leading onto escape routes (including stores). The size and weight of the door will determine the type of closer.
  • Supply & install self-contained luminaires to hallways, and to landings in multi-storey properties;
  • Supply only fire blanket to kitchen, dry powder extinguisher to hall or kitchen, and dry powder extinguisher to landings in multi-storey properties.

3.3 Assumptions and Exclusions

3.3.1 Location

All properties reviewed in preparation of this report are located in Edinburgh, Fife and East Lothian and the works have therefore been costed on the basis of Central Belt prices. The RICS' Building Cost Information Service provides typical location factors which can be applied to estimate the effect on costs of varying locations throughout Scotland, as indicated in the table below:

Location

Index

Scotland

104

Borders

104

Central

103

Dumfries & Galloway

97

Fife

101

Grampian

95

Highland

97

Lothian

108

Orkney

116

Shetland

133

Strathclyde

108

Tayside

103

(Source BCIS; updated 25/09/09; UK mean = 100)

It should be noted however that these indices are based on a sample of 1,035 projects nationally and no information is provided on the exact nature or location of the projects. We would advise therefore that in applying these indices due cognisance should be taken of the exact nature of the properties in question. For example, although the indices suggest that prices in Dumfries and Galloway are below the national average, this might be based on accessible properties in and around Dumfries, whereas a remote property in rural Galloway may attract a premium due to a shortage of skilled tradesmen in the immediate vicinity.

Taking Case Study 1 as an example, the following table illustrates what the effect on costs might be were the property to be located in Shetland rather than Edinburgh:

A. Using Draft New Guide

B. Using 'Small Guide'

Difference

Current Cost Based on Edinburgh Location (index 108)

£1,151

£16,359

£15,294

Potential Cost Based on Shetland Location (index 133)

£1,417

£20,146

£18,834

Potential Cost Increase (23%)

£266

£3,787

£3,540

3.3.2 Programme

All costs included within this report are based on 3 rd Quarter 2009 rates. If the works are not programmed to be undertaken immediately, an inflation factor should be applied to the costs. The BCIS' 5 Year Forecast (updated September 2009) indicates likely variations to cost if the works are carried out during the next 5 years, as indicated in the table below:

Annual % Change

1Q09-1Q10

1Q10-1Q11

1Q11-1Q12

1Q12-1Q13

1Q13-1Q14

Tender Prices

-5.2

-1.8

+3.3

+4.5

+4.8

Retail Prices

-0.4

+3.1

+2.2

+2.6

+2.5

As with location factors, we would advise caution in the application of these indices and would advocate that all works be reviewed on a case by case basis.

3.3.3 Contingency

A contingency has been applied to each order of cost prepared. The percentages applied have been adjusted according to the type and age of the property in question, its condition, and the type of work to be carried out.

3.3.4 General Assumptions and Exclusions

  • It is assumed that battery operated smoke detectors, nightlights, fire blankets and extinguishers will be installed by the property owners, i.e. the order of cost allows for supply only of these items;
  • For the fully wired detection systems it is assumed that all wiring is flush rather than surface mounted in conduit;
  • Costs include for plaster repairs and decoration to ceilings following installation of the fully wired detection systems;
  • It is assumed that under A. Draft New Guidance there will be no need for redecoration;
  • VAT on construction works is excluded;
  • Professional and statutory fees are excluded, but would not normally be required.
  • All costs are based on rates obtainable in a competitive tendering situation;
  • All costs included within this report are for budget purposes only - costs could vary by +/- 10% depending on the actual specification of materials selected, the type of contractor appointed and the market conditions at the time the works are executed.
  • The costs were based on 4 typical properties, where it was assumed that all measures required were installed
  • The costs were based on the properties having no existing fire safety measures, prices would be lower if existing measures (in line with the requirements) had been installed

4.0 Conclusions

In response to the Scottish Government's Project Brief, Turner & Townsend have prepared orders of cost for four typical properties in order to compare the costs of complying with current guidance as typically interpreted by the Fire Authorities with the likely costs of complying with the proposed new guidance.

The costs within this report are based on 3 rd Quarter 2009 prices for works to properties within the Central Belt, however we have provided an indication of the likely effects on costs of location and programme.

Our report concludes that, on average, the costs for fulfilling the requirements of the draft new guide are more than 90% lower than the costs of fulfilling the requirements of the current 'small guide'. It is likely therefore that proprietors of small B&B and self-catering properties would find the proposed new guidance to be significantly less onerous in financial terms than the current guide.

Section 5 Cost Model Summary

Case Study 1 - B&B Lower Cost / Best Case

A. Using Draft New Guide

B. Using 'Small Guide'

Difference

Detection

£624

£8,560

£7,936

Doors & Self-Closers

£450

£6,050

£5,600

Lighting

£24

£940

£916

Fire Fighting Equipment

£30

£30

£0

Contingency

£23

£779

£756

TOTAL

£1,151

£16,359

£15,208

Case Study 2 - B&B Higher Cost / Worst Case

A. Using Draft New Guide

B. Using 'Small Guide'

Difference

Detection

£884

£12,205

£11,321

Doors & Self-Closers

£630

£8,250

£7,620

Lighting

£36

£1,410

£1,374

Fire Fighting Equipment

£30

£60

£30

Contingency

£32

£1,096

£1,064

TOTAL

£1,612

£23,021

£21,409

Case Study 3 - Self-Catering Lower Cost / Best Case

A. Using Draft New Guide

B. Using 'Small Guide'

Difference

Detection

£364

£4,915

£4,551

Doors & Self-Closers

£270

£3,000

£2,730

Lighting

£0

£470

£470

Fire Fighting Equipment

£15

£15

£0

Contingency

£13

£420

£407

TOTAL

£662

£8,820

£8,158

Case Study 4 - Self-Catering Higher Cost / Worst Case

A. Using Draft New Guide

B. Using 'Small Guide'

Difference

Detection

£520

£7,390

£6,870

Doors & Self-Closers

£360

£4,000

£3,640

Lighting

£24

£940

£916

Fire Fighting Equipment

£15

£45

£30

Contingency

£18

£928

£910

TOTAL

£937

£13,303

£12,366

Appendix A Schedule of Properties Reviewed

Case Study 1 - B&B Lower Cost / Best Case
Edinburgh
4 en-suite guest bedrooms
1 owner's bedroom
1 guest lounge
1 owner's lounge
1 kitchen
1 toilet
1 bathroom
1 store
2 halls / landings

Case Study 2 - B&B Higher Cost / Worst Case
North Berwick
1 en-suite guest bedroom
2 guest bedrooms
4 owner's bedrooms
1 guest dining room
1 owner's lounge
1 owner's study
1 kitchen
2 guest bathrooms
1 owner's bathroom
1 store
3 halls / landings

Case Study 3 - Self-Catering Lower Cost / Best Case
Anstruther
1 en-suite guest bedroom
2 guest bedrooms
1 guest lounge
1 guest kitchen / diner
1 guest bathroom
1 hall

Case Study 4 - Self-Catering Higher Cost / Worst Case
Typical 2-Storey Property
2 en-suite guest bedrooms
2 guest bedrooms
1 guest lounge
1 guest kitchen
1 guest dining
1 guest bathroom
2 halls / landings

Appendix B Detailed Cost Models

CASE STUDY 1 - B&B LOWER COST / BEST CASE

EDINBURGH

A - REQUIREMENTS USING DRAFT NEW GUIDE

Comments

Description

Quantity

Unit

Rate (£)

Total (£)

Detection

Supply only new battery powered radio interlinked smoke and heat detectors

12

nr

52

624

1nr to each room plus 1nr to each hallway / landing

Doors & Self-Closers

Supply & install concealed perco self-closers to existing doors

10

nr

45

450

to each room

Lighting

Supply only plug-in nightlights with battery back-up

2

nr

12

24

to hall & landing

Fire Fighting Equipment

Supply only fire blanket

1

nr

15

15

to kitchen

Supply only portable dry powder fire extinguisher

1

nr

15

15

to kitchen

Contingency

2

%

23

only 'construction' works are fitting of closers

TOTAL FOR 1A

1,151

CASE STUDY 1 - B&B LOWER COST / BEST CASE

EDINBURGH

B - REQUIREMENTS USING 'SMALL GUIDE'

Comments

Description

Quantity

Unit

Rate (£)

Total (£)

Detection

Supply and install full mains wired flush fixed fire detection system

Item

8,560

including 11nr smoke detectors, 1nr heat detector to kitchen and 2nr break glass units

Allowance for redecoration following installation of the above

Item

included

spot repairs to plaster plus full redecoration to ceilings

Doors & Self-Closers

Supply and install FD30S self-closing fire doors plus ironmongery

11

nr

550

6,050

include removal of existing doors; assume re-use of existing frames; to all doors leading onto escape route

Lighting

Supply and install self-contained luminaire; mains powered with battery back-up

2

nr

470

940

to hall and landing; includes plaster repairs

Fire Fighting Equipment

Supply only fire blanket

1

nr

15

15

to kitchen

Supply only portable dry powder fire extinguisher

1

nr

15

15

to hall or kitchen

Contingency

5

%

779

reflects Georgian property, good condition; works as above

TOTAL FOR 1B

16,359

CASE STUDY 2 - B&B HIGHER COST / WORST CASE

NORTH BERWICK

A - REQUIREMENTS USING DRAFT NEW GUIDE

Comments

Description

Quantity

Unit

Rate (£)

Total (£)

Detection

Supply only new battery powered radio interlinked smoke and heat detectors

17

nr

52

884

1nr to each room plus 1nr each to hallway and landing

Doors & Self-Closers

Supply and install concealed perco self-closers to existing doors

14

nr

45

630

to each room

Lighting

Supply only plug-in nightlights with battery back-up

3

nr

12

36

to hall & landings

Fire Fighting Equipment

Supply only fire blanket

1

nr

15

15

to kitchen

Supply only portable dry powder fire extinguisher

1

nr

15

15

to kitchen

Contingency

2

%

32

only 'construction' works are fitting of closers

TOTAL FOR 2A

1,612

CASE STUDY 2 - B&B HIGHER COST / WORST CASE

NORTH BERWICK

B - REQUIREMENTS USING 'SMALL GUIDE'

Comments

Description

Quantity

Unit

Rate (£)

Total (£)

Detection

Supply and install full mains wired flush fixed fire detection system

Item

12,205

including 16nr smoke detectors, 1nr heat detector to kitchen and 3nr break glass units

Allowance for redecoration following installation of the above

Item

included

spot repairs to plaster plus full redecoration to ceilings

Doors & Self-Closers

Supply and install FD30S self-closing fire doors plus ironmongery

15

nr

550

8,250

include removal of existing doors; assume re-use of existing frames; to all doors leading onto escape route

Lighting

Supply and install self-contained luminaire; mains powered with battery back-up

3

nr

470

1,410

to hall and landings; includes plaster repairs

Fire Fighting Equipment

Supply only fire blanket

1

nr

15

15

to kitchen

Supply only portable dry powder fire extinguishers

3

nr

15

45

1nr to hall or kitchen plus 1nr to each landing

Contingency

5

%

1,096

reflects Victorian property, good condition; works as above

TOTAL FOR 2B

23,021

CASE STUDY 3 - SELF-CATERING LOWER COST / BEST CASE

ANSTRUTHER

A - REQUIREMENTS USING DRAFT NEW GUIDE

Comments

Description

Quantity

Unit

Rate (£)

Total (£)

Detection

Supply only new battery powered radio interlinked smoke and heat detectors

7

nr

52

364

1nr to each room plus 1nr to hallway

Doors & Self-Closers

Supply and install concealed perco self-closers to existing doors

6

nr

45

270

to each room

Lighting

Supply only nightlights

0

nr

12

0

not required where no stairs

Fire Fighting Equipment

Supply only fire blanket

1

nr

15

15

to kitchen

Supply only portable dry powder fire extinguisher

0

nr

15

0

not required

Contingency

2

%

13

only 'construction' works are fitting of closers

TOTAL FOR 3A

662

CASE STUDY 3 - SELF-CATERING LOWER COST / BEST CASE

ANSTRUTHER

B - REQUIREMENTS USING 'SMALL GUIDE'

Comments

Description

Quantity

Unit

Rate (£)

Total (£)

Detection

Supply and install full mains wired flush fixed fire detection system

Item

4,915

including 6nr smoke detectors, 1nr heat detector to kitchen and 1nr break glass unit

Allowance for redecoration following installation of the above

Item

included

spot repairs to plaster plus full redecoration to ceilings

Doors & Self-Closers

Supply and install FD30S self-closing fire doors

6

nr

500

3,000

include removal of existing doors; assume re-use of existing frames; to all doors leading onto escape route

Lighting

Supply and install self-contained luminaire; mains powered with battery back-up

1

nr

470

470

to hall; includes plaster repairs

Fire Fighting Equipment

Supply only fire blanket

1

nr

15

15

to kitchen

Supply only portable dry powder fire extinguisher

0

nr

15

0

not required

Contingency

5

%

420

reflect early 20th century property, good condition; works as above

TOTAL FOR 3B

8,820

CASE STUDY 4 - SELF-CATERING HIGHER COST / WORST CASE

TYPICAL 2-STOREY PROPERTY

A - REQUIREMENTS USING DRAFT NEW GUIDE

Comments

Description

Quantity

Unit

Rate (£)

Total (£)

Detection

Supply only new battery powered radio interlinked smoke and heat detectors

10

nr

52

520

1nr to each room plus 1nr to each hallway / landing

Doors & Self-Closers

Supply & install concealed perco self-closers to existing doors

8

nr

45

360

to each room

Lighting

Supply only plug-in nightlights with battery back-up

2

nr

12

24

to hall & landing

Fire Fighting Equipment

Supply only fire blanket

1

nr

15

15

to kitchen

Supply only portable dry powder fire extinguisher

0

nr

15

0

not required

Contingency

2

%

18

only 'construction' works are fitting of closers

TOTAL FOR 4A

937

CASE STUDY 4 - SELF-CATERING HIGHER COST / WORST CASE

TYPICAL 2-STOREY PROPERTY

B - REQUIREMENTS USING 'SMALL GUIDE'

Comments

Description

Quantity

Unit

Rate (£)

Total (£)

Detection

Supply and install full mains wired flush fixed fire detection system

Item

7,390

including 9nr smoke detectors, 1nr heat detector to kitchen and 2nr break glass units

Allowance for redecoration following installation of the above

Item

included

spot repairs to plaster plus full redecoration to ceilings

Doors & Self-Closers

Supply and install FD30S self-closing fire doors

8

nr

500

4,000

include removal of existing doors; assume re-use of existing frames; to all doors leading onto escape route

Lighting

Supply and install self-contained luminaire; mains powered with battery back-up

2

nr

470

940

to hall and landing; includes plaster repairs

Fire Fighting Equipment

Supply only fire blanket

1

nr

15

15

to kitchen

Supply only portable dry powder fire extinguishers

2

nr

15

30

1nr to hall or kitchen plus 1nr to landing

Contingency

7.5

%

928

assumes Victorian property, average condition; works as above

TOTAL FOR 4B

13,303

LIST OF KEY STAKEHOLDERS FOR CONSULTATION

Local Government

Convenors of Fire Boards
Chief Fire Officers
Chief Fire Officers Association Scotland ( CFOA(S))
Chief Executives of local authorities
Convention of Scottish Local Authorities ( COSLA)
Society of Local Authority Chief Executives and Senior Manager ( SOLACE)

Scottish Parliament

Justice Committee
Scottish Labour Party
Scottish Liberal Democrats
Scottish Conservative and Unionist Party
Scottish Nationalist Party
Scottish Green Party
Ms Margo MacDonald, MSP
Scottish Youth Parliament
Scottish Parliament's Information Centre

Other Government Departments/Organisations

Building Standards Division
Scottish Fire Services College
Health and Safety Executive
Scottish Environment Protection Agency ( SEPA)
Maritime and Coastguard Agency
Scotland Office
National Assembly for Wales
Northern Ireland Executive
Communities and Local Government ( CLG)
Audit Scotland
Cairngorms National Park Authority

Trade Unions/Staff Associations

Fire Brigades Union ( FBU)
Scottish Trades Union Congress ( STUC)
Retained Firefighters Union ( RFU)
Fire Officers' Association
Association of Principal Fire Officers
UNISON

Professional Bodies/Trade Associations

Institution of Fire Engineers
Association of British Insurers
World Fire Statistics Centre
Royal Institution of Chartered Surveyors ( RICS) in Scotland Building Control Forum
Scottish Association of Building Standards Managers

Equality and Diversity Groups

Positive Action in Housing
Commission for Racial Equality
Equal Opportunities Commission
Action of Churches Together in Scotland
Scottish Interfaith Council
Scottish Human Rights Centre
Scottish Gypsy/Traveller Association
Scottish Refugee Council
BEMIS
Inclusion Scotland
Scottish Disability Equality Forum
Disability Rights Commission
Enable
SENSE Scotland
Capability Scotland
Royal National Institute for the Blind ( RNIB)
Royal National Institute for Deaf People ( RNID)
Scottish Association for Mental Health
Scottish Council on Deafness
Glasgow Women's Library
Engender
Scottish Council of Jewish Communities
Equality Network
Lesbian, Gay, Bisexual and Transgender ( LGBT) Youth
Age Concern Scotland
Help the Aged
OUTRIGHT Scotland

Business Sector

Confederation of British Industry ( CBI)
Federation of Small Businesses
Forum of Private Businesses
Institute of Directors
Scottish Chambers of Commerce
Scottish Retail Consortium
Scottish Food and Drink Federation
Fire Industry Confederation
Mason Communications Ltd
Avecia
Firebreak Services Ltd
British Automatic Sprinkler Association Ltd
Chubb Fire Scotland
Gent Ltd
Kidde plc Fire Investigation and Risk Management

Others

Fire Protection Association
Fire Service Research and Training Trust
Building Research Establishment
Arson Prevention Bureau
Members of the Guidance Working Group