The latest revisions to the Scottish Building Standards and Technical Handbooks, which came into force in October 2013, brought a number of technical changes and new requirements, but not the radical review of energy performance standards envisioned by the 2007 Sullivan Report1 route map. NBS Technical Author Donald Duncan MCIAT outlines what has changed, as well as what hasn't; and discusses what the change of pace means for the industry in Scotland, and the future strategy of the Scottish Government in response to the recommendations of the 2013 Sullivan Report.
The latest revisions to the Scottish Technical Handbooks, first published in June 2013, came into force on October 1st 2013. There have been amendments to the following sections:
- Section 0 – General
- Section 2 – Fire
- Section 3 – Environment
- Section 4 – Safety
- Section 7 – Sustainability
Notably, Section 6 (Energy) has remained unchanged, with the expected move to 'very low carbon buildings', as set out in the 2007 Sullivan Report route-map, now being deferred until 2015. A new programme has been indicated in response to the findings of a two year consultation on the 2010 Energy revisions, and the recommendations of the reconvened Sullivan panel, recently published in the 2013 Sullivan report.
2013 Technical Handbook Changes
Section 0 – General
Standard 0.17 - Continuing requirements (Domestic only) – Regulation 17(1)(b) now requires inspection reports for air conditioning systems to be provided to the building owner (and occupier where not the owner). The guidance in new clause 0.17.4 states the report should also recommend cost-effective energy performance improvements for the inspected system.
Section 2 – Fire
Suppression Systems for schools: Essentially current practice has been incorporated into the Technical Handbooks. Standard 2.15 (Non Domestic), which was added in 2010, was never intended to apply to small projects, which has resulted in a large number of relaxations being granted. The decision tree used by Building Standards officers to determine the outcome of relaxation applications is now available on the Scottish Government website 2, and the changes to Standard 2.15 are intended to clarify the scope of the requirement – i.e. to limit rather than extend its application. The intention is for the decision to be made based on economic considerations i.e. property protection as opposed to life safety.
Section 3 – Environment
- Standard 3.10 – Guidance has been expanded in recognition of evidence of increases in rainfall, allowing assessment of wind driven rain according to BS EN ISO 15927-3:2009. This allows for an alternative calculation methodology based on the present weather code, whereas BS 8104 is based on data from the 33 year period from 1959 to 1991.
- Standard 3.12 (Non-domestic only) – Introduction of more generous Changing Places Toilet (CPT) accessible facilities. This is an optional enhanced standard, and should not be included instead of the required accessible sanitary accommodation.
- Standard 3.20 – New clause 3.20.20 added - Guidance for domestic and non-domestic projects regarding detection of carbon monoxide. A detection system is required wherever a new or replacement fixed appliance is installed. This should consist of a detector in the space containing the appliance, and one in each habitable room that the flue passes through. Guidance for suitable location of detectors is based on BS EN 50292:2013, and lists locations where a detector would not be appropriate. Guidance for the detector itself refers to BS EN 50291-1:2010, including features to ensure continuous long term operation. For appliances in areas not frequently visited in non-domestic projects, such as boiler rooms, the detector should be linked to an audible or visual warning in a staffed area.
- Standard 3.25 – Refuse disposal (Domestic only) – Updated guidance on the policy framework in Scotland – there has been a general move toward de-regulation, with management at Local Authority level. The requirements no longer apply to dwelling houses in general, now referring to 'flats and maisonettes'.
- Standard 3.27 – New clause regarding water efficiency (Domestic only), aimed at achieving energy savings (not water-savings). Water usage limitations have been introduced for WHBs (6 L/m), WCs (average 4.5 L/m) and other self-limiting appliances. Guidance suggests care is taken when introducing these measures, such as supply rates to boilers with automatic low pressure cut-off, and increased gradients for WC waste to avoid solid separation.
Section 4 – Safety
- Standard 4.4 – Pedestrian protective barriers – amendments to reduce 'climbabilty' by children by reducing hand and footholds. As this amendment targets children specifically, it only applies where children have access.
- Standard 4.8 – Guarding of windows – The application of the requirement for protective barriers two stories or more above ground level has been qualified by adding 'young' before 'children', leaving room for discretion in low risk locations.
Section 7 – Sustainability
Sustainability Labelling (Non-domestic): Introduced in the 2011 Technical Handbooks, Section 7 offered a standardized method of sustainability assessment and labelling using established Building Standards procedures. Section 7 Domestic had fully elaborated standards for achieving the various levels of attainment in 7 "aspects" (areas of sustainability assessment); however, Section 7 Non-domestic was limited to the aspect of carbon dioxide emissions. The latest revisions to the Non-Domestic Technical Handbook seek to extend the scope by defining the full range of aspects for school buildings containing classrooms. Although the scope remains limited, the intention is for this to be a 'pathfinder' for assessment of all non-domestic buildings. Additionally, the limitations no longer reference alterations and extensions to standalone buildings. Beyond Bronze Level (achieved by compliance with Sections 1-6), the defined standards are voluntary.
Fire Safety Design Summaries
A new requirement for Fire Safety Design Summaries (FSDS) has been introduced in response to the Rosepark nursing home fire in North Lanarkshire. It seeks to learn from the England/Wales approach to fire safety information set out in the Fire Safety Order3. Although the requirement does not appear in the Technical Handbooks, the 2013 revisions to the Building (Procedure) (Scotland) Regulations 2004 and the Building (Forms) (Scotland) Regulations 2005 mean this is now a requirement for obtaining a completion certificate, and is to be included in the handover documentation. It is essentially a document summarizing the fire safety strategy of a project, which can be difficult to ascertain after completion. As the level of detail required is not more than that required for building warrant approval, the suggestion is that it could be prepared at this stage, preventing extra work, and developed/updated with as-built information at final completion. Templates and examples are available on the Scottish Government website4 demonstrating the procedure and level of detail required.
In 2007, an expert panel chaired by Lynne Sullivan was appointed by the Scottish Government to advise on the development of a low carbon strategy for Scottish Building Standards. The findings were published in the 2007 Sullivan Report, 'A Low Carbon Building Standards Strategy for Scotland' which recommended a roadmap toward 'total life' zero carbon buildings by 2030, with key milestones recommended for 2010 and 2013. The 2010 Standards followed the recommendations, setting demanding energy targets for the industry. The recommendations for the 2013 energy standards were reviewed by a Departmental Working Group in November 2011, and based on the proposals a consultation in early 2013 sought to outline the next set of energy standards.
The 2013 Sullivan Report and roadmap
However, challenging economic conditions lead Scottish Ministers to call for a review of the recommendations of the original Sullivan report, and in December 2012 the panel was reconvened for this purpose. Taking both the panel's recommendations5 and the 2013 consultation into account, the decision was made to delay significant changes to the energy standards in order to encourage economic recovery. The 2013 energy standards remained unchanged, and an announcement by Minister for Planning, Derek Mackay, on September 25th 2013 confirmed the next major revisions would come into force in October 2015. They will be published in 2014, giving the industry in Scotland a year to prepare for the new energy standards, and to build and train the workforce necessary to effectively deliver on the new standards. The measures will introduce the following improvements:
- Domestic: 21% reduction on current carbon dioxide emissions.
- Non-domestic: 43% reduction on current carbon dioxide emissions.
Beyond this, the report recommends that the Scottish Government should investigate whether the original 2013 carbon dioxide emissions targets recommended in the 2007 Sullivan Report would meet the 2019/2021 target for 'nearly zero energy' new buildings imposed by the Article 9 of the Energy Performance of Buildings Directive. This was an ambitious recommendation aimed at carbon dioxide emissions reductions of 60% domestic and 75% non-domestic over the 2007 standards.
Looking further ahead, the report recommends investigation of 'Allowable Solutions' to achieve 'net zero carbon' targets. Referring to the work of the Zero Carbon Hub (ZCH)6, these solutions allow alternative means for achieving required emissions reductions beyond fabric energy efficiency and on-site low and zero carbon technologies. More specifically, ZCH have posited two Allowable Solutions: investing in projects related to the development in question, such as extensions to district heating schemes; or making payments into a carbon fund. This fund would accumulate payments from developers to enable off-site schemes, such as low carbon electricity generation assets, development of Energy-From-Waste projects, or retro-fitting of carbon reduction improvements to communal buildings.