The tragedy occurred when ashes from a fireplace were incorrectly disposed of, leading to a devastating fire at the luxury hotel on the banks of Loch Lomond. The FAI found that multiple safety measures had been overlooked, including inadequate fire risk assessments and insufficient staff training. As a result, the inquiry called for direct action by the Scottish Government.
Mandatory fire suppression systems
Propertymark backs the proposal to require active suppression systems in historic building conversions, with the caveat that where such systems are not feasible, effective alternatives are available.
Properly designed and installed systems can take account of the realities of individual historic buildings and compensate for weaknesses in terms of escape routes and smoke spreading within existing buildings.
We recognise that there will be installation and maintenance costs for building owners associated with this measure; however, failing to mandate action not only puts occupants at risk but may also cost more in the long-term. Since the Grenfell Tower fire, insurance premiums have increased considerably, impacting all buildings as their risk profiles have increased. Installing fire suppression systems reduces the risk profile of a building, lowering insurance costs.
Extending the cladding ban
The consultation asks for input on whether combustible external wall cladding systems should be prohibited for hotels, boarding houses and hostels.
Occupants are at risk if a fire breaks out in these buildings, which is more likely if combustible external wall cladding is present. Therefore, we believe the ban on combustible external wall cladding should apply to all buildings.
If not, occupants would be at risk of harm and owners of these buildings could face considerable additional costs as financial institutions and insurance providers reassess the risk of these buildings.
Defining a hotel
To avoid loopholes where unscrupulous owners could circumvent their regulatory requirements, we strongly agree that ‘hotel’ needs to be defined. This will stop business owners from being confused ,and support enforcement bodies to act against non-compliance.
Currently, the most widely used criteria is in the Hotel Proprietors Act 1956, which defines a hotel as an establishment held out by the proprietor as offering food, drink and, if so required, sleeping accommodation, without special contract, to any traveller presenting himself who appears able and willing to pay a reasonable sum for the services and facilities provided and who is in a fit state to be received.
Next steps
The Scottish Government will consider responses to the consultation before finalising any regulatory updates. Propertymark will continue to advocate for balanced policies that enhance fire safety while supporting property professionals and building owners in meeting new requirements.
