G15 response to electrical safety in the social housing sector consultation

The safety and wellbeing of all the people we provide homes to is the number one priority of all G15 members. As organisations that are responsible for more than 650,000 homes, our members are continuously working to ensure the safety of well over 1 million people in their homes.

We welcome the opportunity to comment on the government’s consultation and call for evidence on electrical safety in the social rented sector. Generally, we support all moves to improve electrical safety through a tenure neutral approach to inspection and testing.

In our response to the consultation questions set out below, we focus on the following key issues, which we would like the government to consider in developing its proposals:

• Electrical installation condition reports (EICRs) can be difficult to understand, and it would help to create a summary that could give key information about safety rather than rely on the report
• We would recommend sharing EICRs and/or summaries via online portals, when giving this information to tenants. Together with other building safety information, paper copies of reports and/or summaries could be available on request
• The frequency of portable appliance testing (PAT) should be determined via a risk assessment
• Rather than testing tenants’ portable appliances, which would be very difficult, it might be better to improve the safety of devices through regulation or voluntary schemes. New electrical wiring guidance will also help to reduce the risks from faulty devices
• Making electrical safety a legal requirement may help housing associations gain easier access for electrical safety checks. However, this should be supported through increased legal rights for landlords to carry out electrical and other compliance checks together with enhanced access to legal remedies to achieve access. We feel a government-led communications campaign focussing on the need to provide access for safety related works, particularly in high-risk residential buildings, would give tenants the reassurance they need to encourage them to allow access
• The proposed regulations should be phased in over five years to allow the new requirements to be introduced as part of existing planned programmes
• Although we try to mitigate safety issues uncovered during checks it is not practical to require remedial work to be completed within a period of time as some works a complicated, such as rewiring homes
• Requiring mandatory electrical installation checks in leaseholders’ homes in housing association owned block is unlikely to be successful because it would be difficult and expensive to regulate and likely to be seen as an infringement on leaseholders’ freedom. We suggest instead a risk assessed requirement for leaseholders to undertake checks in all buildings where a risk is identified, either from the nature of the building or its residents. Leaseholders would then need to provide proof of compliance to the building owner or other responsible person.