Social Housing Management: Photovoltaic Fire Safety

In this blog, I will be discussing an aspect of fire safety in relation to smoke detection systems in loft spaces. I will be discussing a property refurbishment and how the fire safety regulations and guidance has changed recently. This blog is more particular to Scotland however I will be going into general good practice so it might be interesting to anyone within the UK.


If a homeowner was at risk of having their home repossessed in Scotland, the Home Owners’ Support Fund is an option to consider. This is run by the Scottish government and is made up of two schemes, one of which is the mortgage to rent scheme.

The mortgage to rent scheme seemed to very popular and allowed homeowners to become socially rented tenants. A housing association or local authority would then purchase the property and the homeowner would continue to reside within the property as a tenant.

This seemed to have led to associations purchasing properties that were unlike their stock profile and were in some cases far away from the rest of their stock, but this is beside the point.

The association I work for purchased a mortgage to rent property and I was heavily involved in this project. I carried out a survey detailing all of the repairs required which then guided the decision on whether to go ahead with the purchase. Part of the consideration was bringing the property up to a standard to meet the Scottish Housing Quality Standard (SHQS) and The Energy Efficiency Standard for Social Housing (EESSH).

To meet the EESSH standard it was decided to replace the heating system with a high-efficiency combination boiler and to install photovoltaic panels. The new boiler was fitted and the PV panels were installed as part of a re-roofing project that was completed.

Fire Safety

Now that you have a bit of a background of this project I can go into the main crux of this blog. Fire detection was not really considered as the property met the SHQS standard, this standard as I have mentioned in previous blogs is a low bar to meet.

The SHQS standard states that there must be at least one smoke detector present in the property. There was no requirement to determine if existing smoke detectors are in working order because the minimum SHQS requirement is the presence of a smoke detector not the presence of a working smoke detector.

This will no longer be the case from the 1st of February 2021 as an amendment to the tolerable standard will require that all houses, regardless of tenure, must have satisfactory provision for detecting fires and for giving warning in the event of a fire or suspected fire.

The new standard, amongst other things, will require:

  • One smoke alarm installed in the room most frequently used for general daytime living purposes (normally the living room/lounge);
  • One smoke alarm in every circulation space on each storey, such as hallways and landings;
  • One heat alarm installed in every kitchen;
  • All smoke and heat alarms to be ceiling mounted; and
  • All smoke and heat alarms to be interlinked.

So, when the mortgage to rent project was going ahead the above amendment had not been announced so although the fire detection system was not upgraded at the time we will be bringing it up to the new standard very soon. However, if we are following good practice, the extent to the upgrade does not stop there.

Photovoltaics and Fire Risk

As we fitted photovoltaics during this project, it never crossed my mind at the time that there could be a potential fire risk that we were introducing that was not previously there.

BS 5839:6 2019 describes the increased use of loft spaces to house electrical equipment such as inverters for photovoltaic systems could result in a fire within the loft space. The standard states:

In 2019 it is increasingly common for electrical equipment to be installed in loft spaces, particularly in premises fitted with photovoltaic power systems and other plant (e.g. boilers). In such cases, a Category LD2 system needs to incorporate a smoke detector within the loft space.

There are two things to keep in mind here, firstly the British standard is best practice guidance and not mandatory, and secondly, the inverter for a photovoltaic system might not necessarily be located within the loft space.

However, this guidance did take me off guard as it was not something I had considered during the project mentioned at the start of this blog.

Final Thoughts

The emphasis on fire safety is really coming into focus with a lot of housing associations and local authorities. Although there is a big financial burden to the implementation of the new fire safety standards in Scotland, I think it will ultimately be a good thing.

We are in an age now where a mass of electrical equipment within houses are the norm and renewable technologies such as photovoltaics are adding to this. I think on the scale of things the risk of photovoltaic inverters within loft spaces is low, however, this is still a risk to be considered.

In cases where there is electrical equipment installed within a loft space, it seems to me to be sensible to also include the installation of a detector. The cost of doing so will be pretty minimal when looking at it against bringing a property up to the new fire safety standard in Scotland or the installation of a new photovoltaic system.

The example of the mortgage to rent project really shows how the standard around fire safety has changed over time from it not being a prime consideration to now it having a much higher standard of fire safety.


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