Implementing Electrical Regulatory Change

I have given allot of thought recently to the subject of electrical safety in social housing in Scotland and what could be done to place an emphasis on electrical compliance. To my mind there are a few possibilities, each with their own advantages and disadvantages.

I speak as both a current tenant within a socially rented property and as a maintenance professional working within a housing association. I think this gives me a unique perspective of both what I would like to see as a tenant and what I think is feasible as a professional.

In this article I would like to focus on the Scottish Housing Regulator and how a small change made to the requirements of the annual returns could have a huge impact on how we view electrical safety in social housing. I have tried my best to distill my viewpoint down to a short coherent article so this will be by no means exhaustive.

The Scottish Government’s Social Housing Charter came into force in April 2012. The Charter sets out the standards and outcomes that tenants can expect from social landlords.Within Section 31 of The Housing (Scotland) Act 2010, it states that ministers must set out standards and outcomes which social landlords should aim to achieve when performing housing activities.

The document in which those standards and outcomes are set out is to be known as the ‘Scottish Social Housing Charter’. The Scottish Housing Regulator monitors and assesses landlords’ performance against the Charter by way of an annual return (ARC Return). There are 83 sections where information needs to be submitted. Around 21 of these sections are dedicated to housing quality and maintenance.

Some of the key indicators on the report that relate to housing quality and maintenance include:

  • Percentage of stock meeting the Scottish Housing Quality Standard
  • Average length of time taken to complete repairs
  • Percentage of reactive repairs carried out in the last year completed right first time
  • Percentage of repairs appointments kept
  • Percentage of tenants satisfied with the repairs service
  • Percentage of properties that have had a gas safety check completed by the anniversary date

The main question which most closely deals with electrical safety within the annual return is the percentage of stock meeting the Scottish Housing Quality Standard. The line of questioning on SHQS standard  is a sub optimal way to assess an associations overall strategy on tackling electrical safety. The reason for this is both in the interpretation of what is considered safe and the way in which a housing association can demonstrate compliance with this standard.

Housing associations generally undertake stock condition surveys of a percentage of their properties to assess compliance with SHQS and evaluate the life expectancy of their assets. The percentage of properties inspected may only account for half of the overall stock. So many associations can’t be sure of full compliance to SHQS and many of the properties not directly surveyed will utilise data from neighbouring propeties which is termed as ‘cloned’ data. This is generally reasonable for assessing the life expectancy of building components but the same can’t be said for assessing electrical safety.

So with this in view, how could the regulator give tenants of social housing properties peace of mind that the electrical safety of their properties is being taken seriously. This would certainly be an interesting topic for discussion although I know where I would start. The question I think that would cause the least amount of disruption to the industry and in my view would create the largest shift in focus would be simple.

The question I would like to see the Scottish Housing Regulator add to the annual return would be as follows: “Percentage of properties that have had an EICR within the past 10 years”. This question would be along a similar vein to the gas safety question already held within the annual return. It would need to be made clear that this is not to be seen as an endorsement of 10 year frequencies. This would however show a proven benchmark for social housing in Scotland which does not currently exist.

By reporting on this question, housing associations would need to gather information on the EICR’s that they hold and this could highlight blind spots which may have not been considered. Arguably the industry is moving towards a 5 yearly standard  as can be seen in the private rented sector through the implementation of the repairing standard but a more flexible approach to inspection and testing still can be utilised when factoring in a risk based frequency approach.

Adding this simple question could prompt housing associations to consider investing in compliance management software to manage electrical certificates. This could trigger an information gathering exercise which could highlight issues in the storage of certificates. In my estimation it would at the very least force associations to reflect on the current level of electrical safety in their stock.

Hopefully this article has provided some insight into the functions of the Scottish Housing Regulator, the current flaws in the process and the improvements that could be made to increase electrical safety within the social housing sector in Scotland.


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