Sometimes it is worth going back to the very basics of electrical safety in social housing. Some do believe that completing an EICR is just a necessary stage in the process of letting void properties and nothing much more than that. When electrical safety is not carefully thought through it can lead to serious failures, one of which I will highlight in this blog.
On the 3rd of March a regulatory notice was published on the governments website. In this it stated that Shepherds Bush Housing Association Ltd made a self-referral to the regulator to notify a potential non-compliance with health and safety requirements. The two main issues that were highlighted revolved around electrical safety and asbestos safety.
I will focus on the electrical safety side of things as asbestos really requires its own blog as that is another large subject to breech. The regulatory notice sets out the following:
Regarding electrical safety, Shepherds Bush is required under the Landlord and Tenant Act 1985 to ensure that electrical installations are in working and safe condition both at the start of any tenancy and throughout that tenancy.
Shepherds Bush has identified around 200 communal areas in its properties without evidence of an electrical safety inspection having taken place. It is also unable to locate the electrical safety certificates for over 900 individual properties. Without this information for both communal areas and individual properties, Shepherds Bush are unable to determine if there were remedial actions that should have been addressed and therefore lacks assurance that its properties are maintained in a safe condition. Shepherds Bush have reported they have increased resources to remedy the failings in electrical safety.
If the electrical strategy focuses on dwellings only it seems to me that it would be possible that some communal areas were never fully considered. With the limited information on the notice it is impossible to say what actually went wrong here but it could have been a variety of things such as:
- lack of fire risk assessments for the common areas in general needs flats
- lack of electrical safety policy and procedure
- lack of a proper way to store and share certification
- lack of internal auditing process or quality assurance
- lack of external auditing process
- lack of training and electrical safety awareness
- lack of estate management (to include checking communal electric cupboards, taking meter reads, seeing whether there is a sticker with date of last check)
- failure of governance to provide adequate resources in regards to electrical safety
If you work for a housing association and you do not have an electrical safety policy you don’t need to reinvent the wheel. Carry out a google search or reach out to a neighbouring association to use theirs as a template. If you do have an electrical safety policy but you are not following it due to budget constraints, all it takes is a failure like the above example to land you in hot water.
If you lack the knowledge to write an electrical safety policy you may need to source external assistance or up skill by completing the likes of CORGI’s Level 4 VRQ Certificate in Electrical Safety Management in Social Housing which may place you in a better position for writing your own.
By joining the AESM and raising questions in the forum or attending technical meetings will sometimes give you more answers than specific training as you will be talking to people in similar positions with a similar mindset.
Certificates must be stored properly so that they can be used as proof to demonstrate compliance. If you can’t find the certificate it is as good as not completing the check in the first place in the eyes of the law. A good asset management system or the likes of the CORGI Compliance Document Management System (CDMS) can be used to gather, analyse and manage gas and electrical compliance documents.
If you have a completed certificate that shows unsatisfactory and then complete the repairs but do not get a new certificate showing that the installation is satisfactory this could also lead to problems.
Now, its worth keeping in mind this was an issue in England. The Scottish Housing Quality Standard does not specify electrical safety for common closes (this might change with potential revisions coming in after April). This does not remove the obligation under Regulation 4(2) of The Electricity at Work Regulations 1989 to maintain electrical systems but it does make things a bit more woolly.
This blog really just scratches the surface on the topic of electrical safety. If you would like to read more feel free to check out some of the electrical safety blogs highlighted below.
I am sure Shepherds Bush Housing Association will bounce back and rectify these issues without too much of a problem but hopefully they do not rush to complete a raft of EICR’s without considering the wider topic of electrical safety so that issues like this are less likely to occur again in the future.