Part Five: Costs, Timescale and Compliance
Estimate of the Cost of Alarms
46. Market figures indicate that a mid-range mains powered, inter-linked smoke alarm costs around £65 and that a mid-range, inter-linked sealed battery alarm with a 10-year battery life costs around £80. Installation of a mains powered alarm is likely to cost around £50, while sealed battery alarms do not require professional installation. The overall cost per dwelling will depend on the final form of the requirements and the built form of the individual dwelling – as this will determine the number and type of alarms which need to be fitted. This consultation is accompanied by a partial Business and Regulatory Impact Assessment, and we invite views on this under Question 17.
47. The Scottish Government’s view is that owner occupiers should pay for fire and smoke alarms in their own homes, and that social landlords should fund additional alarms from their own resources (ultimately from tenants’ rents). This is in line with what is expected for compliance with other minimum standards in housing.
Question 10 (a): Do you think that it is reasonable for home owners to pay for the work needed to comply with a new minimum standard for fire and smoke alarms? If not, who do you think should meet these costs?
10 (b) Do you think that it is reasonable for social landlords to pay for the work needed for their properties to comply with a new minimum standard for fire and smoke alarms? If not, who do you think should meet these costs?
48. A reasonable compliance period will be needed to allow landlords and owners to meet a new standard. We think that the same timescale should apply to social landlords and owner occupiers. In the case of battery-powered carbon monoxide detectors, regulations were laid on 26 June 2015, and private landlords were expected to comply by 1 December 2015.  More invasive works – including hardwiring – would require a longer period, and would have to take account of the availability of contractors to carry out work. The need to plan a schedule of works for a portfolio of properties in the social rented sector should also be taken into account.
49. We propose that the timescale for compliance should be one year (if battery alarms are permitted) and two years (if the standard is for mains wired alarms).
Question 11: Do you think that the timescale we have proposed for installing additional alarms is reasonable:
a) One year for battery alarms? Yes/no/don’t know -
Please explain your answer.
b) Two years for mains wired alarms? Yes/no/don’t know - Please explain your answer.
Question 12: Do you think that the timetable should be the same for both owner occupiers and social landlords? Yes/no/don’t know - Please explain your answer.
Compliance in Social Housing
50. The Scottish Social Housing Charter seeks assurance from social landlords that their homes comply with the Scottish Housing Quality Standard ( SHQS). The Scottish Housing Regulator has a statutory role to monitor landlords’ performance against this target. The Regulator sets out in its regulatory framework how it will make decisions about engaging with landlords.
51. The Scottish Government’s view is that the Regulator provides sufficient oversight for any change to the standard required in respect of fire and smoke alarms in social housing.
Question 13: Do you think existing enforcement routes are sufficient for the social housing sector? Yes/no/don’t know - Please explain your answer.
13 (a): If not, what else do you think is needed to enforce a new standard in social housing? Please also tell us what additional support is needed, for example training, advice or guidance.
Compliance in Owner Occupied Housing
52. Measures for encouraging compliance with a new standard in the owner occupied sector include:
- Local authorities have a wide range of enforcement powers to require owners to carry out work and, if necessary, local authorities can carry out work themselves and recover their costs from owners.  However, the scale of existing disrepair means that in most cases the duty to ensure that homes meet the tolerable standard is triggered reactively, through concerns raised by owners or neighbours, rather than by local authorities. Even if enforcement powers are used, and the cost of work is recovered, local authorities need to fund the cost of works up-front.
- Evidence of compliance at point of sale. This could be done, for example, by including a declaration on compliance with a fire and smoke alarm standard as part of the Home Report. This could be self-certification in the property questionnaire completed by the seller which would alert the buyer to a defect. This approach assumes that defects will be identified and addressed during house purchase, but does not formally require work to be done. It would also take time for this enforcement mechanism to apply across the stock: the average length of tenure in owner occupied properties is around 16 years, and 30% of owner occupiers have been in their house for more than 20 years. 
- A new right for any owner in a block of flats or tenement to ask for evidence of compliance from other owners. This could be similar to the existing duty to provide evidence of insurance against common risks, but it may be difficult to determine what evidence would be appropriate. 
- Gas and electrical engineers carry out regular safety inspections in rented homes and many owner occupied homes. Engineers may be able to flag non-compliance with owners and offer a suitable product, as is currently done with carbon monoxide alarms and smart meters. This might help to promote take up but commercial engineers would not be able to take on an enforcement role.
- Some stakeholders, including the Chartered Institute of Housing and the Royal Institution of Chartered Surveyors, have proposed intervention in tenements to encourage owners to participate in common works and essential maintenance. This could be in the form of reserve funds to support work and/or regular building surveys.  The Scottish Government intends to seek views on these ideas in the proposed public consultation on condition standards in owner occupied housing. 
53. We recognise that no single measure is sufficient on its own to ensure that all owner occupiers comply with a new standard. We think that a combination of such measures, over a period of time, could be effective in encouraging compliance.
Question 14: Do you have any views on the most effective approaches to encouraging compliance with a minimum standard for fire and smoke alarms in the owner occupied sector?
Email: Simon Roberts, firstname.lastname@example.org
Phone: 0300 244 4000 – Central Enquiry Unit
The Scottish Government
St Andrew's House