The Scottish Government (SG) has been consulting on fire safety measures as a result of the Grenfell Tower tragedy in 2017. At present, as the consultation makes clear, there are different standards for different types of property, with the sector least amenable to influence - owner-occupier housing - having no minimum requirements (unless it is new build, where some do exist).
The consultation closed on 1 December, and this morning the SG issued a press release with its official response to that consultation. The main feature of the story is the requirement that all housing, including owner-occupied, should have an interlinked set of smoke alarms in at least two areas and a heat alarm in the kitchen, as well as a carbon monoxide detector.
It is hard (but not impossible) to argue against the requirement. Once implemented, it should result in fewer deaths from fires in the home. There is especial relevance for some of the larger cities in Scotland that feature a high percentage of tenement housing, where there is a kind of collective responsibility to ensure that residents do nothing that would harm their neighbours. So from a policy perspective, it would seem to make sense.
But it is more complex when it comes to implementation, and the press release has nothing to say in this regard. This makes the timing of the press release slightly odd: presumably the SG is not over-run with press officers on a Sunday to handle enquiries, but that is the day the SG picks to issue a press release with significant consequences for owner-occupiers, but no details on implementation.
Fortunately, the SG need not have worried: the news outlets I have seen have simply carried the press release with no comment. However, it struck me that there are some important issues here that deserve to be raised in reporting this story. First is the question of how much this will cost; second is when it will be required by; and third is how it will be enforced.
The press release does not refer to costs or timescales, although both are referred to in the original consultation. On costs, the consultation estimates around £80 for a battery operated system, and £120 for purchase and installation of a mains-wired system. On timescales, the SG is suggesting 1 year if the final decision is in favour or battery operated systems, or 2 years if the recommendation is for mains-wired systems.
Although the press release is mystifyingly silent on the issue, the original consultation document also contains a range of options for ensuring compliance. These include reporting neighbours to the local authority in cases of apparent non-compliance, and giving purchasers of tenement flats the right to see proof that other properties have complied with the legislation. Other measures mooted include using the annual gas safety check, or the Home Safety Report, as mechanisms to encourage compliance.
The consultation document concludes that more than one measure is likely to be required, which is probably policy-speak for saying that none of the measures on their own has the right characteristics of being palatable and effective.
The SG is now committed to the policy objective, but since the press release contains nothing on implementation, we can only assume that the SG will go with its original plans in the consultation. On that basis, at least 600,000 private homes in Scotland will require a new smoke alarm installation within the next 12-24 months. The press release specifically sets out that each home needs a heat alarm in the kitchen, a smoke alarm in each circulation space on each floor, at least one in the room most used in the house, all interlinked, and affixed to the ceiling. In addition, each home must have a carbon monoxide detector.
The costs of this - picking Amazon.co.uk as a basis for a reasonable amount - are seemingly more expensive now than when the consultation was written, at around £120 for a complete interlinked battery operated system (2 smoke alarms, a heat alarm, and a carbon monoxide detector). It would seem reasonable to assume that those costs will only increase over the next few years as demand increases to reflect the implementation timetable.
The consultation assumes that homeowners should simply pay for this. It is not in itself a huge cost, but for many households it will be an unwelcome additional expense. Although there is an impact assessment accompanying the consultation, this is in respect of equalities groups, of which those with little spare cash is not one, so there is no consideration of the impact on poorer households. This approach of 'owner pays' is in contrast to previous measures such as the phasing out of old light bulbs, which was accompanied by a mass giveaway of replacement long-life lightbulbs rather than a requirement that everyone simply pay more to replace their bulbs. And arguably this measure is more important.
But from a policy making perspective, it is the enforcement of the measures that seems so unusual in all this. The consultation acknowledges that asking gas and electrical engineers to enforce implementation in their visits to properties is not an option. It also notes that using the Home Report to highlight the need for works at the point of property sale would be sub-optimal given that 30% of properties have been in the same owner-occupation for over 20 years.
The consultation suggests that, for tenements, a new owner-occupier could ask to see evidence that other properties had suitable measures for fire safety. But the consultation notes that it would be hard to be sure what might constitute suitable evidence. Equally complex would be how this mechanism would work: would new tenement owners have to ask to see evidence; or would solicitors working on the sale incorporate it into their work (and increase their fees to cover this, presumably)? If so, how would they do this? And what would happen if no evidence was produced? Would that be enough to withdraw from the agreement to purchase the property?
But nor does pushing all the implementation onto local authorities seem a sensible option. There are several areas where a local authority would experience cost pressures:
- The costs of handling the anonymous reports that are expected to come from concerned neighbours about the state of properties nearby.
- The costs of taking action short of enforcement, surely a likely first step by local authorities to encourage homeowners to address fire safety measures.
- The costs of carrying out work on properties by enforcement action. As the consultation notes, even if an authority could recover costs from households where it had carried out work on their behalf, it would still need the money upfront to pay for all this. And that is before you consider the costs from owner-occupiers challenging the quality or cost of enforcement work.
So, what can we conclude about this initiative? The policy itself has a good deal to commend it, especially for tenements and houses in multiple occupation. What is odd is the unpalatable nature of the options for implementation, coupled with the absence of any alternative to what you might call the 'big stick' approach to delivering a policy outcome. There is little in the press release, or indeed the consultation itself, that discusses how you might incentivise homeowners to improve fire safety measures. And surely that would be worth considering, given the apparent difficulty of forcing homeowners to act. When it comes to implementing the policy objective here, the devil is well and truly in the detail, which makes it all the more curious that the SG issues a press release with no acknowledgement of this, at one minute past midnight on a Sunday.
News story as carried on the BBC (other outlets had a near identical story)
http://www.bbc.co.uk/news/uk-scotland-43443725
Original press release released at 00:01 on Sunday 18 March
https://news.gov.scot/news/improving-home-safety
Original consultation on fire safety
http://www.gov.scot/Resource/0052/00524309.pdf
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