The impact that Government-induced change is now exerting across the social housing sector

We all know how vital it is for residents (on an individual level) and communities (as groups of people) to feel safe and secure in their homes, and of course, about the overriding need to ensure the highest levels of fire safety and awareness. These areas are of paramount importance.

In the wake of the Grenfell Tower tragedy that occurred in June 2017, and in which 72 people lost their lives due to the devastating fire at the location, fire safety for social housing has been at the very forefront of central Government debate. As a direct result, enhanced standards of provision are now enshrined in law thanks to the Building Safety Act 2022, which was granted Royal Assent on 18 April last year, and responds directly to Dame Judith Hackitt’s comprehensive Independent Review of Building Regulations and Fire Safety.

It’s now absolutely imperative that all homes are brought up to a standard that guarantees a better quality of life, and a higher level of fire safety for all residents. This is particularly true of the social housing sector, where individual residents rely on landlords and housing associations prioritising fire safety standards within their homes.

Social housing providers have wide-ranging responsibilities. They’ve featured heavily in the news of late with high-profile cases involving the spread of damp and mould inside properties. Robust strategies and increased awareness in terms of fire safety are crucial for social housing operators and residents.

This is a major step forward designed to confirm that social housing landlords and providers are aware of their responsibilities. They will be held accountable for any incident and, potentially, prosecuted for any demonstrable and proven negligence.

They are also responsible for informing and engaging with tenants about fire safety-related issues such that the latter feel safe in their properties at all times.

Landlords and duty holders must review their fire risk assessment policies so that, in the event of a fire outbreak, its correct containment and control will allow residents the necessary time to evacuate the premises and firefighters can prevent the episode from causing excessive damage and/or loss of life.

During the course of our own projects involving multiple social housing clients, we’ve seen the amount of detail that’s needed when it comes to in-depth survey , compartmentation work and fire door installation and maintenance. These are just one of the areas that must be addressed to ensure each building is as compliant and low-risk in nature as possible, while also being brought up to the standards now expected.

Addressing complications

Fire safety ranks as a foremost concern for social housing landlords, but there can be a lack of available data regarding the building when those landlord are looking to improve fire safety standards and the overarching fire strategy.

Concerns regularly focus on fire safety­-centric remedial work that’s required on the communal areas of properties and the best way in which to manage such projects from the perspectives of the owners/co-owners and tenants who use them. Often, landlords need to source a structural engineer in order to gather the relevant information underpinning the structural integrity of the building, and make certain that it complies with current legislation. The extent of work that still needs to be transacted within social housing in England is nothing if not vast in scope and challenging.

Another difficult task entails inspecting the external wall make-up of older buildings. Creating the building safety case report can prove tricky for social housing providers as there hasn’t been a template to use as a foundation.

The Government, of course, is in the process of introducing the new Building Safety Regulator, an enforcing body based within the Health and Safety Executive, and designed to oversee the effective management of building safety and standards. Further, the Building Safety Regulator is going to assist and encourage the built environment industry and building control professionals to improve competence within, as well as lead, on the implementation of the new regulatory framework for high-rise buildings.

Social housing landlords and providers must register their high-rise block of Hats (i.e. those with 7 or more storeys, or where the uppermost storey is at least 18 metres above ground level or higher), such that the Building Safety Regulator can readily identify any fire and structural risks and, thereafter, allow for the management and control of them.

While these moves are to be welcomed, there are complications that could prove problematic for social housing providers. For instance, the ‘Responsible Person’ is required to ensure all of the necessary actions are fulfilled, which could be costly and impact both maintenance and construction budgets.

List of requirements

The Fire Safety (England) Regulation·2022 commenced on 23 January this year and move matters on a stage further. In real terms, they implement the majority of the recommendations outlined by the Grenfell Tower Inquiry in its Phase I report (which required a change in the law) and, ultimately, seek to improve the fire safety regimes for blocks of flats in ways which are practical, cost-effective for individual leaseholders, and also proportionate to the risk of fire.

For high-rise residential buildings, the ‘Responsible Persons’ must:

• share electronically with their local Fire and Rescue Service information about the building’s external wall system, and provide firefighters with electronic copies of floor plan and building plan for the location
• maintain hard copies of the building’s floor plans – in addition to a single page orientation plan of the building, and the name and UK contact details of the ‘Responsible Person’ – in a Secure Information Box, which itself must be accessible by firefighters
• install wayfinding signage in all high-rise buildings which is visible in low­-light conditions
• establish a minimum of monthly checks on lifts in high-rise residential buildings, which are for the use of firefighters and also on essential pieces of firefighting equipment
• inform the Fire and Rescue Service if a lift used by firefighters or one of the pieces of firefighting equipment is out of use for longer than 24 hours

For multi-occupied residential buildings over 11 metres in height, the ‘Responsible Persons’ must:

• undertake quarterly checks on all communal fire doors and and annual checks on flat entrance doors

In all multi-occupied residential buildings, ‘Responsible Persons’ must:

• provide residents with relevant fire safety instructions and information about the importance of fire doors

Over time, there has been substantial concern among social housing providers in relation to building compliance. Previous apprehension has, in the main, been attributable to social housing providers being uncertain of their roles and responsibilities when it comes to the subject of fire safety.

What could prove problematic for social housing providers is the level of competence needed to conduct fire safety checks in-house. The new regulations mean that social housing providers have a huge responsibility to keep abreast of ever-changing legislation, and ensure their tenants are always safe inside a compliant building. That could be a significant burden for the ‘Responsible Person’.

Social landlords could well be forced to divert funds from maintenance and repair and providing new social housing in order to cover remediation costs. It could be argued that, given all of the responsibility involved, removing the legal requirement for the support of a building safety manager from the Building Safety Act 2022 was a mistake.

Golden Thread

Each residential high-rise building has an ‘Accountable Person’ who’s responsible for managing the building’s safety by preventing and reducing fire spread and structural failures. In parallel, the Building Safety Act 2022 now states the requirement for establishing and maintaining a ‘golden thread’ of information about the building.

Those responsible will retain a ‘golden thread’ of information to be stored and continually updated in order to understand, manage and mitigate risks throughout the life cycle of the building and its components, from design and manufacturing right through to installation and maintenance.

For example, the installation of fire doors can be problematic if there’s no data capture of the product’s life cycle. In order to be safe and compliant, information surrounding the installation must include evidence of compliance, the traceability of components, and independent verification.

One of the most crucial elements of the legislation is the introduction of the aforementioned ‘golden thread’ approach, which is purpose-designed to link the life cycle of a fire door at each stage.

Essentially, all components are to be tested, manufactured, surveyed, installed and maintained, and detailed records put in place. This process works to ensure compliance and traceability in a given building, and avoid any possibility of poor practice being part of the equation.

As a business, we’ve introduced modern technology to ensure compliance. To make certain that all relevant data regarding a given fire door’s life cycle is accurately documented, we’ve teamed up with PlanRadar to implement NFC tracking for these products. This form of technology actively enables all documents relevant to the life cycle of the fire door to be uploaded. If another individual requires access to relevant data at a particular point in time, this then becomes a simple process.

Importantly, the documents cannot be manually deleted. Key information cannot be lost. All relevant documentation is readily available. That makes life far easier for those involved.

Easy access to manufacturing and installation data helps to identify any major and minor alterations since the time of the previous fire door inspection.

This is crucial as it can be very easy to overlook small alterations that may render a fire door non-compliant.

‘Responsible Persons’ must be aware that, if any fire door has been installed by a non-approved installer, the warranty and quality of the product may well be negatively affected.

Engaging the residents

Many social housing providers employ a variety of strategies to ensure a smooth communication flow between themselves and their residents, one of which involves establishing committees to encompass all nationalities and backgrounds.

The Tenant Involvement and Empowerment Standard 2017 requires providers to listen to and engage with residents, affording the latter the opportunity to discuss any issues and collaborate on suggested improvements.

Legislation changes and meeting the strict standards needed will exert a huge impact on the social housing sector.

We’ve been working closely with social housing agencies to correct latent defects or update fire protection installations.

Fire safety is a critical issue in social housing where there are often large numbers of people living in close proximity to each other. With everyone involved working together to ensure that buildings are up to standard, and by including residents in the decision-making process, we can reduce the risk of fire, create safer living environments, and fashion a better quality of life for all.