The Scottish Government's public consultation on a proposed review of fire safety topics closed on 7 March 2025. Having had the time to consider the consultation responses, the Scottish Government has now issued its analysis. This article explains that analysis and summarises what it all means for the hotels and hospitality sector.
The Scottish Government's consultation on a proposed review of fire safety topics took place between 13 December 2024 and 7 March 2025. It considered different views on fire safety regulations by asking 29 questions and addressed recommendations made by the Fatal Accident Inquiry to the Scottish Government, concerning the fire at Cameron House Hotel.
Our article published in January 2025 set out the main issues that the consultation sought to address in more detail. This article provides an overview of the Government's analysis of the consultation responses received.
In brief, through analysis of the responses received, there appears to be general support for the government's recommendations to address varying parts of Scotland's building and fire safety regulatory frameworks.
40 consultation responses were received in total. We have noted the key takeaways below.
Mandating active fire suppression
The majority of respondents preferred the option to mandate active fire suppression for conversion of traditional buildings to hotel accommodation (Option 1) versus the performance/risk-based approach with strengthened guidance option (Option 2). The justifications for Option 1 included that it was a clearer approach and would enable minimum standards to be set. 70% of respondents supported amending the scope of the application of mandatory standard 2.15 of The Building (Scotland) Regulations 2004, stating that low risk extensions and conversions to flats, maisonettes, or social housing dwellings should not be required to use active fire suppression systems.
Hidden cavities and voids, workmanship age and variations from current standards
83% of respondents supported retaining Building Standard 2.4 of The Building (Scotland) Regulations 2004, addressing fire safety in cavities within buildings. The majority agreed that the Historic Environment Scotland guidance remains suitable when considering special risks posed by hotels and other premises and that proposed. Most supported revisions being made to the Non-domestic Technical Handbook.
Extending the ban of combustible external wall cladding systems to hotels, boarding houses and hostels
Most supported this proposal, and suggestions were received to extend the ban further to all sleeping accommodations or buildings at a high-risk.
Miscellaneous fire safety issues
The majority of respondents also agreed on the following:
- existing guidance on lath and plastic materials suffices;
- existing guidance on low-level emergency lighting suffices;
- the proposal to require External Premises Information to be installed on new, converted or refurbished high-rise residential buildings above 18m tall; and
- the proposed wording for clause 2.7.1 to clarify the reasons for the ban on combustible materials for specific buildings.
Impact
Businesses operating in the hotels and hospitality sector should be alert to any future changes implemented by the Government in response to the consultation. Significant time and cost may be involved to adapt to legislative changes relating to fire safety.
No further consultation has been announced. Based on the above responses received, the Scottish Government will now determine the policy direction. It is anticipated that draft regulations will be laid before the Scottish Parliament at the end of 2025.
This article was co-authored by Trainee Carissa Najafian.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
