Consultation outcome

Government response to the Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations consultation

Updated 20 December 2022

1. Introduction

1.1 On 9 June 2022 the Department for Levelling Up, Housing and Communities launched a consultation on the Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations. The consultation sought views on governments full proposals for the regulations.

1.2 The Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations complete the definition of higher-risk building. Higher-risk buildings are buildings which will be required to meet the legal requirements of the new more stringent regime for building safety.

1.3 The new regime is being brought forward to improve safety in high-rise buildings. It was a fundamental part of Dame Judith Hackitt’s recommendations, who outlined a new approach to managing fire and structural safety risks in high-rise multi-occupied residential buildings in her Building a Safer Future Report, commissioned by government after the Grenfell Tower tragedy.

1.4 The new regime will put in place stronger oversight, clearer accountability for, and stronger duties on, those responsible for the safety of higher-risk buildings throughout design, construction, and occupation, with stronger enforcement and sanctions to deter and rectify non-compliance. The new regime places legal responsibilities on those who participate in the design and construction of higher-risk buildings, commission higher-risk building work and those who are responsible for managing structural and fire safety in higher-risk buildings when they are occupied.

1.5 There are two parts of the new regime. The first establishes a new regime for the design and construction of new higher-risk buildings and building work to existing higher-risk buildings. The second establishes a new regime when higher-risk buildings are occupied.

1.6 The Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations, in conjunction with the Building Safety Act 2022 (the Act), will define which types of buildings will be required to meet the requirements of the new regime during design and construction and occupation. The regulations also set other technical definitions. Specifically, the regulations will:

• define which types of buildings are and are not considered higher-risk buildings for design and construction under section 120D of the Building Act 1984 (inserted by section 31 of the Act);
• define which types of buildings are not considered higher-risk buildings for occupation under section 65 of the Act;
• provide an overall definition for building for both parts of the regime under section 120D of the Building Act 1984 (inserted by section 31 of the Act) and under section 65 of the Act; and,
• establish how height and the number of storeys a building has is determined for higher-risk buildings.

1.7 The regulations, alongside the Act, will mean that residential buildings, care homes and hospitals which are at least 18 metres in height, or have at least 7 storeys, are subject to the new requirements during the design and construction of new buildings and during building work. During occupation, residential buildings which are at least 18 metres in height, or have at least 7 storeys, will be subject to the occupation requirements of the new regime.

1.8 The consultation sought views on all the provisions proposed to be included within the regulations. This government response summarises the responses received and sets out our response to them.

2. Consultation process and overview of responses

2.2 The consultation ran for 6 weeks from 9 June 2022 to 21 July 2022. It was published on the department’s online consultation platform Citizen Space, as well as on gov.uk. Responses were accepted via online survey and via email.

2.3 Overall, 101 responses were received. 77 responses were received via the online survey and 24 were received via email.

2.4 Of the 101 responses, 68 respondents responded on behalf of an organisation, 30 responses were submitted on behalf of individuals and 3 respondents preferred not to disclose this information.

2.5 Respondents came from a wide variety of backgrounds and organisations, including developers, building control professionals, fire engineers, local fire services, housing associations, local councils, tenants and industry trade bodies.

2.6 The consultation sought views on 26 questions. This response summarises respondents’ views by considering comments made in relation to each of the questions included in the consultation document. A break-down of the number of responses received to each question can be found in the table below.

Question	Number of responses
Question 1: We have proposed to align with the Building Act 1984 and define building as including any structure or erection, and any part of a building, as so defined, but does not include plant or machinery comprised in a building. Do you have any concerns about this definition?	92
Question 1A: Please provide an explanation for your answer to question 1.	72
Question 2: Would you like to provide any comments on this proposal? (Question related to including buildings which contain at least two residential units in the design and construction part of the regime)	82
Question 3: Would you like to provide any comments on this proposal? (Question related to including care homes and hospitals in the design and construction part of the regime)	88
Question 4: Would you like to provide any comments on this proposal? (Question related to excluding secure residential institutions and temporary leisure establishments from the design and construction part of the regime)	85
Question 5: Would you like to provide any comments on this proposal? (Question related to excluding military premises from the design and construction part of the regime)	76
Question 6: Would you like to provide any comments on this proposal? (Question related to excluding care homes and hospitals from the occupation part of the regime)	86
Question 7: Would you like to provide any comments on this proposal? (Question related to excluding temporary leisure establishments and secure residential institutions from the occupation part of the regime)	82
Question 8: Would you like to provide any comments on this proposal? (Question related to excluding military premises from the occupation part of the regime)	74
Question 9: Would you like to provide any comments on this proposal? (Question related to the definition of hospital)	66
Question 10: Would you like to provide any comments on this proposal? (Question related to the definition of care home)	65
Question 11: Would you like to provide any comments on this proposal? (Question related to the definition of secure residential institution)	63
Question 12: Would you like to provide any comments on this proposal? (Question related to the definition of temporary leisure establishment)	68
Question 13: Would you like to provide any comments on this proposal? (Question related to the definition of military premises)	63
Question 14: Do you agree our proposed method for determining the height of a building is the right one?	90
Question 14A: If no or partly what changes do you suggest or what alternative method would you suggest?	33
Question 14B: Do you think there are any potential issues with our suggested method for determining height?	88
Question 14C: If yes or partly please provide an explanation for your answer.	49
Question 15: Do you agree with following the approach we have set out for determining storeys?	91
Question 15A: If no or partly please provide an explanation for your answer.	48
Question 15B: What alternative approach to determine the number of storeys in a building would you suggest?	45
Question 15C: Please explain why you have suggested we make these changes?	44
Question 16: Do agree with the proposed definition of gallery?	89
Question 16A: If no or partly, what changes would you suggest or what alternative definition would you suggest?	36
Question 16B: Please explain why you have suggested we make these changes.	36
Question 17: What do you consider to be the equalities impact on individuals with protected characteristics of any of the proposed details to be included in the regulations? Please give reasons and any evidence that you consider relevant.	62

3. Part 1: definition of a building

3.1 Part one of the consultation sought views on the overall definition of ‘building’ for both the design and construction and in-occupation parts of the new regime.

Summary of responses and analysis

3.2 There were two questions in this section:

• Question 1: “We have proposed to align with the Building Act 1984 and define building as including any structure or erection, and any part of a building, as so defined, but does not include plant or machinery comprised in a building. Do you have any concerns about this definition?”
• Question 1A: “Please provide an explanation for your answer to question 1.”

3.3. The majority of respondents had no concerns about the proposed definition of building. A breakdown of responses to question 1 can be found in the table below.

Question 1: Do you have any concerns about this definition?

Option	Total	Percent
Yes	22	22%
No	70	69%
Not Answered	9	9%

3.4 Those who were supportive felt the proposed definition aligned with existing definitions within the construction sector and encouraged this. They also felt the proposed definition would likely be well understood in the construction industry. A small number of respondents disagreed with aligning with the existing definition in the Building Act 1984 and suggested that the regulations should be used as an opportunity to develop something clearer. A small number of respondents also raised that the proposed definition did not completely align with the Building Act 1984.

3.5 There were other concerns raised about the proposed definition. The most common concern was the exclusion of plant rooms and machinery from the definition, with many respondents recommending that plant rooms and machinery be included within the building definition. The reasoning most given for this was that plant machinery is integral to the overall safety of the building. It was also raised that plant rooms could contain firefighting or suppression equipment, as well as other key infrastructure important to the overall safety of the building. Some respondents also raised that plant rooms and machinery could be a source of potential fire or structural collapse.

3.6 A small number of respondents also raised concerns that the proposed definition was potentially confusing and vague. These respondents felt that the definition could define a building more clearly, and without using the word ‘building’ within the definition.

3.7 A smaller number of respondents raised comments about how several buildings classified under a single building name should be considered and how buildings attached by a wall (for example terraced buildings) should be defined.

Government response

3.8 The definition of building must clearly set out what is considered a building for both parts of the new regime. We have amended the proposed definition in the regulations to more clearly set out what is and is not considered a building for the purposes of the design and construction and occupation parts of the new regime.

3.9 The updated definition is significantly more detailed than the definition proposed in this consultation. The definition now provides different definitions of building for the purposes of the design and construction and occupation parts of the new regime. The updated definition can be found in the regulations currently being laid in parliament and a further explanation of the updated definition can be found in the related explanatory memorandum (PDF 65kb). The regulations set out here, on 19 December, are still subject to parliamentary approval.

3.10 We made these changes to appropriately capture complex buildings, specifically, large, attached buildings, in the definition. The updated definition will allow the operational requirements in occupation to be met more easily.

3.11 The updated definition will include plant rooms and machinery within the definition of building, giving the Building Safety Regulator (BSR) the ability to regulate them as parts of higher-risk buildings. This amendment will make sure that parts of a building which contain important fire safety equipment are included within the boundaries of higher-risk buildings.

3.12 We will be publishing full guidance on the regulations once they are approved by parliament. This will be made available before the new regime comes into force and becomes law. The guidance will explain the definition of building to help users understand whether or not they are in scope.

4. Part 2: including and excluding buildings from the design and construction part of the new regime and Part 3: excluding buildings from the in-occupation part of the new regime.

4.1 Part 2 of the consultation sought views on the buildings being included and excluded from the design and construction part of the new regime under section 120D of the Building Act 1984 (inserted by section 31 of the Act). Part 3 of the consultation sought views on the buildings being excluded from the occupation part of the new regime under section 65 of the Act.

4.2 Part 2 focused on the design and construction stage of the new regime. It set out governments’ proposal to include buildings which contain at least two residential units^{[footnote 1]}, care homes and hospitals in the definition of higher-risk building under section 120D of the Building Act 1984. It also set out government’s proposal to exclude secure residential institutions (e.g. prisons), temporary leisure establishments (e.g. hotels) and military premises (e.g. military barracks) from the definition of higher-risk building under section 120D of the Building Act 1984.

4.3 Part 3 focused on the occupation stage of the new regime. It set out governments’ proposal to exclude care homes, hospitals, secure residential institutions, temporary leisure establishments and military premises from the definition of higher-risk building under section 65 of the Act.

4.4 Overall, there were seven questions in these sections which asked respondents if they had any comments on the proposals to include and exclude certain building types from the new regime.

Summary of responses and analysis of part 2: including and excluding buildings from the design and construction part of the new regime

4.5 Responses to this area varied.

4.6 Some respondents expressed their support for the inclusions and exclusions proposed in this section and agreed that the proposed scope was suitable. Others expressed their approval of a risk-based regime. Respondents were particularly supportive of the inclusion of care homes and hospitals within the scope of the design and construction requirements. Respondents were also supportive of the exclusion of military premises on the basis that these buildings have their own safety requirements and that building owners will liaise with the BSR as appropriate, although a small number of respondents did raise concerns about the safety standards of military accommodation.

4.7 Some respondents raised concerns with the proposed exclusions. There were concerns about buildings which may have people sleeping in them or house vulnerable people being excluded from the scope of this part of the regime, with some responses suggesting these buildings should be included within scope. This included those housed in secure mental health facilities or secure local authority accommodation. A small number of respondents also felt military premises should be included in the regime.

4.8 Hotels and aparthotels were a particular concern with some respondents feeling they should be included within the scope of the new regime as people sleep overnight within hotels and may be unfamiliar with their surroundings in the event of a fire. There were concerns about the boundary between hotels and aparthotels and how and where this would be defined. A small number of respondents felt that apartment style hotels specifically should be included within scope on the reasoning that they are similar to residential buildings.

4.9 Some respondents also provided comments outside the scope of this consultation with many respondents suggesting that the 18 metre or 7 storey height thresholds should be lowered. Some suggested this should be 11 metres or 4 storeys. Particularly, these respondents felt that care homes and hospitals should be included at a lower height threshold of 11 metres or no height threshold at all. A smaller number of respondents suggested there should not be any height threshold during the design and construction part of the regime for any building type.

Summary of responses and analysis of part 3: excluding buildings from the occupation part of the new regime

4.10 Responses to this area varied.

4.11 Some respondents were supportive of the proposals and agreed with the proposed exclusions in occupation on the basis they are a reasonable and common-sense approach. Respondents were particularly supportive of the exclusion of military premises from the occupation regime.

4.12 Other respondents raised concerns with the exclusions. Some respondents felt that more buildings should be included in the occupation phase of the new regime, most commonly suggested for inclusion were care homes, hospitals and hotels. A smaller number of respondents also felt secure residential institutions should be included within scope.

4.13 Some respondents mentioned that care homes and hospitals should be included on the basis that they house vulnerable people. Some respondents also raised concerns that the existing fire safety legislation, which regulates hospitals and care homes, does not go far enough to maintain peoples’ safety, and for this reason felt the occupation requirements of the new regime should apply to them.

4.14 Respondents who felt that hotels should be included raised the fact that residents may be unaware of their surroundings and evacuation routes.

Government response

4.15 We understand the concerns raised in both part two and part three of the consultation on the exclusion of buildings from both parts of the new regime and the height-threshold.

4.16 The new regime is focused on providing proportionate rigour where most necessary. We need to make sure that the scope of the new regime is proportionate to risk. Government has always been clear the focus of the regime is on high-rise residential buildings. Therefore, we are not proposing to amend the types of buildings excluded from the definition of higher-risk buildings through these regulations.

4.17 The height-threshold is already set within primary legislation in the Act. Height was identified by Dame Judith Hackitt as a suitable way to identify the level of risk and to set the scope of the new regime. This is, in part, due to height being objective and measurable. While we recognise that height is not the only indicator of risk, we chose height as evidence shows the risk to multiple households is greater when fire does spread in buildings which are at least 18 metres.

4.18 We are including hospitals and care homes which meet the 18 metre, or 7 storey height-threshold in the design and construction part of the new regime as this means high-rise buildings which may be occupied by those who are unable to evacuate quickly, or without assistance, are designed and constructed with more stringent oversight by BSR. Hospitals and care homes are regulated as workplaces through the Regulatory Reform (Fire Safety) Order 2005 so they are already subject to duties placed on those in control of these buildings to make sure these premises are safe. They are also subject to the local Fire and Rescue Authorities’ and the Care Quality Commission’s inspection regimes, who will take action if required.

4.19 The fire safety provisions in the Fire Safety Act 2021 have further strengthened the Fire Safety Order by placing new requirements on Responsible Persons for all regulated buildings. These new measures will sit alongside existing protections under the Fire Safety Order and existing standards under the Housing Act 2004, which is assessed using the Housing Health and Safety Rating System.

4.20 All building work must meet building regulations requirements. Some elements of the new design and construction regime will also apply to all buildings. There will be dutyholder requirements on all those involved in the procurement, design and construction of buildings intended to proportionately address risks for all building work in the design and construction phase.

4.21 The BSR will also have wider responsibilities for overseeing the safety of all buildings, including identifying patterns of regulatory failure and making recommendations for improving standards. This will drive continuous improvement in the performance of all buildings to protect the safety of occupants.

4.22 We have, therefore, excluded hotels and other temporary leisure establishments, as well as secure residential institutions like prisons. In occupation these buildings are also already regulated by the Fire Safety Order, and generally, these buildings are staffed 24/7, have multiple routes of escape, signage and emergency lighting to assist evacuation and have a higher level of detection and alarm systems than residential buildings.

4.23 Taken together, measures in the Act, the Fire Safety Act improvements to the Fire Safety Order, and wider changes we have and continue to make to the building regulations will help protect residents in buildings of all uses and heights.

4.24 We have designed the regime to be future proof, and the scope can be altered following evidence-based advice or recommendations by the BSR. The BSR will provide oversight of the building safety regulatory system and will analyse data from the operating regime. We have shared all responses from this consultation with the BSR, who will keep the scope of the regime under review^{[footnote 2]}.

5. Part 4: defining buildings which are excluded and included in the new regime

5.1 This section of the consultation sought views on the definitions of the building types being included in and excluded from both parts of the new regime.

5.2 It sets out government’s proposed definitions for care homes, hospitals, secure residential institutions, temporary leisure establishments and military premises.

Summary of responses and analysis

5.3 Most respondents in this section were supportive of the definitions, and particularly that they were aligned with existing definitions.

5.4 Some respondents did, however, raise comments on the definitions and suggested:

• Removing ‘leisure’ from the definition of temporary leisure establishment, as hotels aren’t always necessarily used for leisure and it could be ambiguous.
• Clarifying whether temporary leisure establishments used for long term stays are within scope of the regime, and on when a temporary leisure establishment becomes a residential building.
• Removing secure hospitals and secure local authority accommodation from the definition of secure residential institutions.

5.5 Some respondents also raised concerns about the height threshold and exclusion of certain building types through this part of the consultation. These comments aligned with the comments given in response to part 2 and part 3 of the consultation, these responses can be found above.

Government response

5.6 We agree with respondents that the definitions in the regulations should align with existing legislation as much as practicable.

5.7 We understand concerns that the definition of ‘temporary leisure establishment’ may not be well understood. We have, therefore, amended this definition within the regulations to ‘hotel’, which we believe provides a clearer definition.

5.8 We also understand concerns around ‘secure hospitals’ being included within the definition of secure residential institutions. We have, therefore, removed these from the definition, as we understand their primary function is as a hospital and they are regulated in the same way as other healthcare institutions but with additional security measures.

5.9 We will be publishing full guidance on the regulations once they are approved by Parliament. This will be made available before the first parts of the new regime come into force and become legal requirements. The guidance will explain each of the building type definitions to help users understand whether they are in scope.

6. Part 5: measuring height

6.1 This section of the consultation sought views on the method for measuring the height of higher-risk buildings.

Summary of responses and analysis

6.2 The majority of respondents supported the method set out for measuring height.

Question 14: Do you agree our proposed method for determining the height of a building is the right one?

Option	Total	Percent
Yes	64	63%
No	3	3%
Partly	23	23%
Not Answered	11	11%

6.3 Some respondents felt there may be potential issues with the proposed method for measuring height, although the most common response was ‘no issues’.

Question 14B: Do you think there are any potential issues with our suggested method for determining height?^{[footnote 3]}

Option	Total	Percent
Yes	18	19%
No	42	42%
Partly	28	28%
Not Answered	13	13%

6.4 Of the respondents who did not agree or partly agreed with the method for measuring height, and respondents who felt there were potential issues with the definition, most suggested small technical changes to the method. The most common responses included:

• Concerns that the method was unclear and should be further explained either through regulations or guidance.
• Requests for further clarification on the meaning of ground level and where this should be measured from. Some responses suggested this needed to be clearer and felt that different users may interpret ground level in different ways.
• Requests for further clarification on whether roof level should be counted, particularly in the scenario it is used as a rooftop garden or similar. A small number of respondents suggested roof levels should always be included within the height measurement regardless of use.
• A small number of suggestions that levels with plant machinery and basements should be included within the height measurement. This was to prevent people gaming the system and building multiple plant levels or basements to house residents.
• Requests that the method for measuring height better aligned with Approved Document B and for further clarification on how this method will work alongside existing methods for measuring height.

Government response

6.5 We want to make sure the method for measuring height is clear to future dutyholders and accountable persons and supports our aim of creating a proportionate and effective building safety system.

6.6 We have made some small amendments to the method for measuring height. We have further clarified what ground level means in the regulations by setting out that buildings should be measured from the lowest part of the surface of the ground to which they are adjacent. This will make sure that owners of buildings built on uneven ground e.g. a hill, are not able to game the height threshold.

6.7 We have also amended the definition to make sure not all plant machinery levels are excluded and set out that only levels which consist exclusively of rooftop plant rooms or rooftop machinery are excluded from the height measurement.

6.8 These amendments can be found in the regulations currently being laid in Parliament. The regulations set out here, on 19 December, are still subject to parliamentary approval.

6.9 We have chosen this method for measuring height as it is a known standard for the sector and is effectively the vertical distance a person would need to travel to escape a building from the top floor.

6.10 We will be publishing full guidance on the regulations once they are approved by Parliament. This will be made available before the new regime for higher-risk buildings comes into force. The guidance will explain the method for measuring height and support users in understanding whether or not their building meets the height threshold.

7. Part 6: measuring storeys

7.1 This section of the consultation sought views on the method for measuring the number of storeys in higher-risk buildings. It also sought views on the definition of galleries for the purpose of measuring higher-risk buildings.

Summary of responses and analysis

7.2 The most common response was in support for the method set out for measuring storeys.

Question 15: Do you agree with following the approach we have set out for determining storeys?^{[footnote 4]}

Option	Total	Percent
Yes	48	48%
No	5	5%
Partly	38	39%
Not Answered	10	10%

7.3 The majority of respondents also agreed with the proposed definition of galleries.

Question 16: Do agree with the proposed definition of gallery?^{[footnote 5]}

Option	Total	Percent
Yes	58	57%
No	8	8%
Partly	23	23%
Not Answered	12	12%

7.4 Some respondents suggested there may be potential issues with the proposed method for measuring storeys and recommended changes. Some respondents also suggested changes be made to the definition of gallery. The most common comments included:

• Concerns that the method for measuring stories was unclear and should be further explained either through regulations or guidance.
• Requests for further clarification on the meaning of ground level and where this should be measured from, particularly in reference to buildings built on sloping sites.
• Requests for further clarification on whether roof level should be counted, and what would be considered a finished roof level. Some respondents suggested roof levels should be counted as a storey.
• Respondents suggested that plant machinery and basements should be included within the height measurement. This was suggested to prevent people gaming the system and building multiple plant levels or basements to house residents. It was also suggested as some respondents felt people may use these levels and therefore may need to evacuate from them.
• Requests that the definition better align with Approved Document B and requests for further clarification on how this method will work alongside existing methods for measuring storeys.
• Concerns that gallery floors could be used to game the system if they are not counted. Respondents suggested that gallery floors be counted as storeys regardless of their floor area. Other respondents suggested that the definition of gallery should be amended so that smaller galleries are counted as storeys.

Government response

7.5 As with the method for measuring height, we want to make sure the method for measuring storeys is clear to future dutyholders and accountable persons and supports our aim of creating a proportionate and effective building safety system.

7.6 We have made some small amendments to the method for measuring storeys. These align with the changes we have made to the method for measuring height. We have further clarified the meaning of ground level and set out that the number of storeys in a building should be measured from the lowest part of the surface of the ground to which they are adjacent. This will make sure that owners of buildings built on uneven ground, e.g. a hill, are not able to game the height threshold.

7.7 We have also amended the definition to make sure not all plant machinery storeys are excluded and set out that only storeys which consist exclusively of rooftop plant rooms or rooftop machinery are excluded from the storey measurement.

7.8 We have also amended the definition of gallery to set out that galleries are floors whose internal floor area is less than 50% of the internal floor area of the largest storey vertically above or below. This is instead of defining galleries as storeys whose floor area is less than 50% of the largest storey in the building. This is to further prevent gaming.

7.9 These amendments can be found in the regulations currently being laid in Parliament. The regulations set out here, on 19 December, are still subject to parliamentary approval.

7.10 We will be publishing full guidance on the regulations once approved by Parliament. This will be made available before the first parts of the new regime come into force. The guidance will explain the method for measuring storeys and support users in understanding whether their building meets the height threshold.

8. Part 7: equalities impact of our proposals

8.1 This section of the consultation asked for respondents’ views on any potential equalities impacts of all the proposals within the regulations.

Summary of responses and analysis

8.2 Respondents most commonly raised the potential impact of the regulations on vulnerable people, particularly people who may have disabilities or older people who may be unable to self-evacuate. The majority of these respondents felt that the scope of the new regime should consider and support the safety of vulnerable people.

8.3 A small number of respondents raised the importance of Personal Emergency Evacuation Plans and the need for these to be in place.

8.4 A small number of respondents felt there would be no equalities impact of the proposed regulations.

Government response

8.5 All the potential equalities impacts of our proposals have been carefully considered as part of our public sector equality duty requirements and we are content there is no evidence of a negative impact on any one group which shares a protected characteristic. We have passed any relevant responses on to relevant departments including the Home Office^{[footnote 6]}.

9. Summary

9.1 We are grateful to all respondents for taking the time to submit responses to this consultation. All responses have been carefully considered and taken into account in the development of the regulations.

9.2 We have made some amendments to the regulations building on the feedback from this consultation, as well as further policy work and engagement with stakeholders.

9.3 At 19 December the regulations are currently subject to the affirmative parliamentary procedure, and will be debated by both Houses of Parliament in due course. If approved by Parliament the regulations will be made and come into force in early 2023.

1. The Building Safety Act defines residential unit as a dwelling or any other unit of living accommodation, for example a flat or rooms in a university hall of residence where amenities are shared. ↩

2. Responses have been shared in line with all data protection requirements and no personal data has been shared outside the department. ↩

3. Percentages may not always add up to 100 percent due to rounding ↩

4. Percentages may not always add up to 100 percent due to rounding ↩

5. Percentages may not always add up to 100 percent due to rounding ↩

6. Responses have been shared in line with all data protection requirements and no personal data has been shared outside the department. ↩