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.
In this blog 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 as short as possible so this blog is not set out to be completely 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 points within the table of contents on the annual return form. 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 exact contents of the arc return is set to change after a recent consultation which ends on the 14th of December 2018. The proposal is to reduce the list of overall indicators by a third whilst adding and amending some indicators. There looks like there will be fairly substantial changes to the SHQS and gas safety indicators.
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. After closely reviewing the SHQS standard, I am of the opinion that it 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.
Method of improvement
So with this in view, I think there is a simple way for the regulator give tenants of social housing properties peace of mind that the electrical safety of their properties is being taken seriously. This would be by adding a new indicator on electrical safety to the annual return to bring it in line with gas safety.
The question I would like to see the Scottish Housing Regulator add to the annual return would be as follows:
“Percentage of eligible stock that has a valid and satisfactory electrical installation condition report”.
This question would be along a similar vein to the gas safety question already held within the annual return.
Wording is key
The wording of this indicator is quite important and most of the sentence holds importance. The reason it is worded ‘eligible stock’ is because a new build property will have an EIC and not an EICR so these would be excluded. Eligible stock would also include communal landlord supplies which also need to be periodically checked.
The word ‘valid’ refers to certificates which are legible to read if they are handwritten certificates (yes they do still exist). It also refers to ensuring all the relevant parts of the certificate are completed. The standard for this could be similar to what is set out in the Housing (Scotland) Act 2006 for the repairing standard.
The word ‘satisfactory’ would refer to whether the certificate has been tested and found to be satisfactory, meaning that there are no immediate or potential dangers. The EICR certificate will be deemed unsatisfactory if there are C1 or C2 observations, or if further investigation is required to determine whether danger or potential danger exists.
The potential benefits
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.
Some associations might have an abundance of unsatisfactory certificates where they have rectified the C1 and C2 faults but have not re-issued a new satisfactory certificate. Reporting on this question would also encourage associations to firm up on this.
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 encourage 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 and the improvements that could be made to increase electrical safety within the social housing sector in Scotland. I have submitted an email to the regulator in regards to the consultation on electrical safety and I will update this blog with any response given.