Hi Messy
There are differences in terminology e.g. the FSA does not refer to a "responsible person" but refers to a person with Chapter 1 duties and an "appropriate person" in respect of Alterations Notices.
The main difference is in relation to domestic premises. In Scotland, the common parts of domestic premises are not considered "relevant premises" (unlike in E&W). However, there is an explicit duty to maintain facilities and devices in such parts, for the safety and use of firefighters e.g. dry risers, firefighting lifts etc.
A licensable HMO is a relevant premises also (covering private and common parts within the HMO) - not sure if this is the same in E&W or not.
Also, Scottish sector specific guidance refers to benchmarks derived from Scottish Building Standards Technical Handbooks which use different terminology and contain different standards. However, the guidance is not statutory and so, strictly speaking, this is not a difference between the two legislative regimes, only a difference in guidance.