Housing Health & Safety Rating

Introduction

NEA believes that an energy efficiency standard should be set for all housing to ensure that occupants have access to affordable warmth. The standard could be based on specified minimum heating and insulation standards or on a SAP rating, reflecting space and water heating costs for the dwelling. The Government’s Decency Standard for social housing includes a standard for thermal comfort (in NEA’s view insufficiently rigorous) and a similar approach should be adopted across all tenures. The most obvious way of doing this is to extend an enhanced Thermal Comfort standard covering minimum heating and insulation standards across the whole housing stock.

The Government has adopted a different policy and has replaced the Housing Fitness Standard with a new Housing Health & Safety Rating System (HHSRS), which is thought to reflect a modern understanding of the health and safety hazards and risks within dwellings. The Housing Act 2004 provided the basis for the new scheme which became operational from April 2006.

NEA’s view

NEA welcomes the introduction of the HHSRS as a tool for identifying potential hazards and for making owners and landlords better aware of these. Recognition that excessive cold and dampness pose serious health hazards is welcome. However, the system which is suggested raises a number of issues which NEA believes need further consideration:

• The system sets no requirements for heating, insulation and ventilation standards, which are a prerequisite for affordable warmth and healthy homes
• An additional risk assessment based on excessive humidity (>50%) should be introduced since this will indicate the risk of house dust mites, pathogens and allergens
• The effects of hazards on the occupant’s psychological health should be assessed in all cases – this should be included within a broader concept of health to include well-being and comfort
• A new system for enforcement in local authority stock must be introduced
• The onus for initiating the inspection process should be removed from the tenant – it should be carried out automatically at the commencement of a tenancy
• A licensing system should be introduced for all landlords, with licences dependent on properties satisfying specific criteria as fit for human habitation
• The heating requirements for a property should incorporate whole-house heating, healthy temperature regimes and ensure the ability of the householder to operate the system  

Conclusion

NEA believes that the HHSRS should have been adopted alongside an improved housing fitness standard as a means of providing a rigorous health and safety analysis of a property. However now that the system has become operational it is important that it be properly policed. In its revised guidance[1] on the Decent Homes Standard the Department for Communities and Local Government suggests that a SAP rating of 35 or below can be taken as a proxy for a Category 1 Health Hazard; local authorities are obliged to take enforcement action on Category 1 hazards. Almost 3 million properties in England have an energy efficiency rating of SAP 35 or below and action to remedy these housing conditions will be a stern test of the Government’s good faith