The Cameron House Hotel is a luxury hotel on the shores of Loch Lomond consisting of the original B-graded structure of the original 19th century building and several modern extensions.
On 18 December 2017 a serious fire destroyed much of the older part of the house and killed two guests. Subsequently the damaged portions of the property were reconstructed and fitted with an automatic fire suppression system.
Hotel fire safety
It has long been recognised that hotels present a special risk in terms of fire and life safety.
Many of the greatest death tolls in fires internationally have resulted from fires in hotels. Fires in hotels and similar sleeping accommodation have been subject to special controls in the UK for many years – these being finally codified in the Regulatory Reform (Fire Safety) Order 2005 and the Scottish and NI equivalent.
In fact, the Fire Precautions Act 1971 was almost certainly introduced because of public concern following the fire at the Rose & Crown, Saffron Walden on 26 December 1969, which killed 11 people. There have been no further very large life loss UK hotel fires in the past 50 years compared with other countries (see Box 1 and Box 2).
Box 1 Major International Fatal Hotel Fires
1971 Daeyeonggak Hotel, 164 deaths
1977 Hotel Rossiya, 45 deaths
1979 Hotel Carona de Aragon, 72 deaths
1980 MGM Grand, 85 deaths
1986 Siddharth Continental, 38 deaths
1986 DuPont Plaza Hotel, 98 deaths
1993 Paxton Hotel, Chicago, 15 deaths
2003 Moscow Student Hotel, 36 deaths
2005 Paris Opera Hotel, 24 deaths
2006 Mizpah Hotel, Reno, 12 deaths
2009 Kamien Pomoroski Hotel, 21 deaths
2013 Southwest Inn, Houston, 4 firefighters killed
2022 Winters Hotel, Vancouver, 2 deaths
Box 2. UK Multiple Fatal Hotel Fires
Rose and Crown, Saffron Walden, 11 deaths
2004 Fairlawn Hotel, Edgbaston, 4 deaths
2007 Penhallow Hotel, 3 deaths
2017 Cameron House Hotel, 2 deaths
2023 New Country Hotel, Perth 3 deaths
Home Office 2022/23 data for hotel fires in England records a total of 587 primary fires in ‘Hotels, boarding houses, hostels etc.’ with two fatalities and 83 non-fatal casualties. By comparison, Scotland records 146 fires in similar categories but over a slightly different time scale.
While there have been several serious fires resulting in the virtual destruction of quite modern hotels – for example, the 2019 fires in the Holiday Inn, Willenhall and the Premier Inn, Bristol, there was no loss of life in either fire.
The fire on 18 December 2017
Unusually, the causes, spread and impact of the fire are well documented as a result of the SFRS investigation mandated by Sheriff Thomas McCartney under the Inquiries into Fatal Accidents and Sudden Deaths etc. (Scotland) Act 2016.
Quoting directly from the Sheriff’s findings, the two deaths resulted from:
‘…a fire which began in the concierge cupboard of the Hotel, as a result of hot embers within ash igniting combustibles within said cupboard. The fire spread from the cupboard through voids and cavities in the structure of the building and escaped into the reception area once the door to the cupboard had been opened, thus causing fire and smoke and fire gases to spread extensively throughout the old part of the Hotel.’
The proximate cause of the fire was therefore:
- Careless disposal of hot ash, i.e., the removal of hot ashes from open fires in the hotel as part of cleaning them; exacerbated by:
- The presence and impact of hidden voids allowing easy and rapid fire and smoke spread.
Fire risk assessments and FRS inspections prior to the fire
FRA: January 2016: This included a recommendation for a written policy to cover handling hot ash from ovens and fires:
‘…hot ashes must be transferred to a metal container and wetted down and that the metal container should be kept away from combustibles until the refuse was hauled away.’
The hotel responded by preparing a policy, but this was not promulgated to staff and no written procedure for handling ash was issued.
FRA: January 2017: The assessment noted that no action had been taken in respect of open fires. The hotel claimed that the statement was inaccurate, and the assessor modified the FRA without verifying the hotel’s actual response.
SFRS Inspection: 22 August 2017: The Scottish Fire and Rescue Service undertook an inspection and submitted a report with several recommendations inter alia:
‘The practice of storing combustibles in the concierge cupboard was highlighted as a risk specifying the possibility of electrical ignition of the combustibles and rapid fire spread due to voids etc.’
The Resort Director was informed that the practice was unacceptable, and an assurance received by SFRS that this issue would be rectified.
An email from the Resort Director to managers referencing the SFRS visit did not mention the risk of fire spread or damagers of stored combustibles and only required the ‘Concierge cupboard to be tidied and holes filled’.
Automatic fire suppression systems
There can be no doubt that the installation of automatic fire suppression systems is an effective method of protecting life and property in hotels.
This was recognised in Sheriff McCartney’s Report which included the recommendation that:
‘The Scottish Government should consider introducing for future conversions of historic buildings to be used as hotel accommodation, a requirement to have active fire suppression systems installed.’
And that:
‘The Scottish Government should constitute an expert working group to more fully explore the special risks which existing hotels and similar premises may pose through the presence of hidden cavities or voids, varying standards of workmanship, age, and the variance from current standards and to consider revising the guidance provided by the Scottish Government and others.’
It’s worth noting that within his observations regarding fire suppression, Sheriff McCartney went so far as to suggest that: ‘Given the potential added fire protection provided by an active fire suppression system, if such installation was said to be impossible or impractical in specific premises, it may be that such premises are simply not suitable as hotel accommodation.’
Commentary
There was nothing exceptional about the cause of this fire or the reasons for its spread, which was predictable. Hotel fires are not rare, but fatalities are not frequent in the UK.
What is perhaps egregious is that the operators of the premises (the ‘duty holders’ under Scots Law) had been told twice of the risks of fires resulting from common practices in the building and had the structural defects clearly identified for them. Even if there still had been any doubt about the presence of hazards, a thorough report from the fire authority identified the deficiencies and defects and set out necessary remedial action.
Sheriff McCartney references the undoubted benefits of automatic fire suppression systems several times in his report and several of the witnesses examined during the enquiry suggested that such protection should have been incorporated into the building at the time of its conversion into a hotel.
The Sherriff was clearly impressed by these suggestions as he included in his report recommendations that where conversions of historic buildings are to be used as hotel accommodation, they should have an active fire suppression system installed.
At the same time, the Sheriff recommended the establishment of the expert working group mentioned above.
The Scottish Government’s response and the Expert Working Group
Scottish Ministers accepted in total the Sheriff’s recommendations and the Scottish Building Standards Division were tasked with undertaking a detailed analysis of the recommendations to determine how they could be implemented. A task group, The Building and Safety Expert Working Group, consisting of representatives from all interested parties (including hoteliers and tourism) was set up and first met in November 2023.
The work is likely to take until Q1 of 2025 by which time it will have produced a Ministerial submission containing details of deliberations and Final Recommendations.
It is anticipated that draft regulations, standards and guidance will be submitted to Ministers in Q2 2025 with a view to being presented to the Parliament in Q3 2025 with an implementation date in January 2026.
Commentary
While there appears to be broad-based support in the Expert Group for the anticipated scope of the work, it is inevitable that there will be differing views on the extent and detail of any new recommendations or requirements. Considerations to be examined include:
- The scope of the new regulations – for example, to what extent will they be likely to include bed and breakfast establishments?
- The efficacy of automatic fire suppression systems in saving life
- A cost-benefit analysis of the inclusion of automatic fire suppression systems in hotel conversions
- The likely costs to the hotel industry
- Possible negative impact of retrofitting fire suppression on historic fabric
- The need for authoritative, independent guidance on how systems can be retrofitted
It should also be remembered that the Sheriff’s recommendations included the need for new guidance and possibly regulations on the dangers of cavities and voids and the presence of combustible building materials.
About the Author
Stewart Kidd MA, MSc, FIFireE, FIFSM, FSyI, FSA (Scot), CPP is a Chartered Security Professional. He has worked in security and fire protection since 1974 and now combines consultancy with expert witness assignments. He has a particular interest in the protection of national patrimony and built heritage, and he lectures and writes extensively on this subject. He is the author of eight books on fire and security topics including the Historic Environment Scotland’s Guide for Practitioners No 7, the Scottish Building Standards ACOP.
