Written evidence submitted by Electrical Safety First [RSH 020]

1. About Electrical Safety First

1.1.      Electrical Safety First is the UK charity dedicated to reducing deaths, injuries and fires caused by electricity. Electrical Safety First is a campaigning charity that aims to reduce deaths and injuries caused by electricity in UK homes. We raise awareness of electrical safety issues with the public and work closely with Government, the electrical industry, manufacturers, retailers and consumer safety organisations in order to improve safety regulation and standards.

2. Electrical Safety in the Social Rented Sector

2.1.      Electrical Safety First’s primary commitment is to ensure that everyone can live safe from electrical risk in their home. The charity has long had an interest in electrical safety in the Social Rented Sector (SRS), following on from successfully campaigning for the introduction of mandatory 5-yearly periodic electrical safety checks in the Private Rented Sector (PRS)[1].  We recently released a report on electrical safety in the SRS in early 2021[2] which found overwhelming support from housing providers for parity protective measures for social tenants in England

2.2.      Whilst homes are becoming safer, the risk posed by electricity remains constant, with around 53% of all electrical dwelling fires in England caused by an electrical source of ignition[3]. Home Office statistics analysed by Electrical Safety First show fires caused by domestic wiring faults remain consistently high[4] even though the overall number of domestic fires have decreased over the years, suggesting that installation wiring issues are not being adequately tackled.

2.3.      We also know that electricity causes more fires than gas, and yet is subject to less protective legislative measures. The number of residential fires caused by electricity are around six times higher than gas[5], but whilst gas installations in social housing require an annual safety check there is no similar specified frequency for carrying out electrical safety checks in social housing in England.

2.4.      This means a tenant in the SRS can expect to have their gas boiler checked each and every year but may never see a regular safety inspection of their electrical installation. This is despite there typically only being one or two gas installations or appliances in most properties, but electrical circuits are present in every part of every property. This discrepancy was a major contributing factor in the introduction of mandatory electrical safety checks in the PRS.

2.5.      Social tenants in Scotland are already protected with five-yearly electrical safety checks since 2020 and the Welsh Government has committed to introducing a similar requirement in Summer 2022.  Safety should not be determined by a postcode lottery. 

2.6.      Electrical Safety First believes that all properties in the SRS in England should be subject to mandatory 5 yearly electrical safety checks, performed by a  competent person, such as a registered electrician, with a copy of the resulting Electrical Installation Condition Report provided to the tenant.

2.7.      This view is shared by many social housing providers. Electrical Safety First’s 2021 report, “Improving Electrical Safety for Tenants in The Social Rented Sector in England”[6], was informed through consultation with some of England’s largest social housing providers, responsible for tens of thousands of tenants.

2.8.      97% of the social housing providers who responded to our consultation backed mandatory five-yearly safety electrical checks for the SRS. Respondents believed that mandating the checks will clarify the requirements, removing potential confusion for tenants and make landlord access to properties for the purpose of these checks and any repairs easier - saving time, money and, most importantly, lives.

2.9.      The issue of landlord access to properties is of significant concern to social housing providers, with research showing that many social housing landlords were frustrated at being unable to secure access for electrical inspections in a proportion of tenants’ homes[7].

2.10.  Electrical Safety First recommends that the Government commit to aligning the SRS with the electrical safety standards in the private rented sector (England) regulations 2020.

3. Response to Questions

3.1.       

3.2.       

3.1.              What is the impact on social housing providers' resources, and therefore their ability to maintain and improve their housing stock, of the need to remediate building safety risks?

3.2.              As part of Electrical Safety First’s 2021 investigation into electrical safety in the SRS[8], social housing providers were asked for their views on available funding for electrical safety in their properties, and whether such funding needs to be ring fenced to ensure that a satisfactory level of safety can be maintained.

3.3.              The response to this proposal was that housing providers overall felt that existing levels of funding were sufficient for the purpose, and that ring fencing was unnecessary.  However, concern was expressed that changing priorities, both from Government and internally, could place funding levels at risk in the future.

3.5.              Electrical Safety First considers that tenant safety must never be compromised and recommends that the Government considers how best to support social housing providers fulfil their safety obligations.

3.6              It should also be noted that the clear schedule of inspections provided by periodic checks would simplify budget planning and improve risk mitigation.

4.              Does the current regime allow tenants to effectively resolve issues?

4.1.              At present the complaints procedure in the SRS, whilst guided by the regulator and charter set out in the recent Social Housing White Paper, is primarily dependent upon the policies and resources available to each Social Housing provider, with referral to the Ombudsman available. Electrical Safety First considers that, given the high risk potentially posed by unsafe electrical installations, any complaints related to electrical safety issues should be responded to as rapidly as is practicable.

4.2.              This should entail a set time period, communicated to the tenant, during which any electrical safety complaint must be responded to and dealt with.  

4.3              Electrical Safety First is presently supporting electrical safety amendments to the Building Safety Bill, entering report stage as of December 2021[9]. These amendments are aimed primarily at SRS and Leasehold properties in High Rise Residential Buildings (HRRBs) but may serve as an effective guide for the SRS as a whole.

4.4              The amendment proposed for SRS properties in HRRBs states that, upon receiving an electrical safety related complaint the social landlord must:

•    Investigate within 28 days of receiving that complaint.
• If the investigation shows that the electrical installations are unsafe, the landlord must rectify the situation using a qualified and competent person within 28 days.
• If the landlord believes that a complaint is not valid, they must write to the tenant within 28 days of receiving that complaint explaining why they do not think it is valid.

4.5               This also mirrors the requirements in the electrical safety standards in the PRS.  Electrical Safety First considers the above to be a clear and effective route to follow and should be incorporated into any future electrical safety legislation for the SRS.

5.              Will the reforms proposed in the social housing White Paper improve the regime and what progress has been made on implementing those reforms?

5.1.              Electrical Safety First welcomed the White Paper and the renewed focus on improving standards in the SRS, and in particular the commitment to “Consult on measures to ensure that social housing residents are protected from harm caused by poor electrical safety”.  As our report on the SRS demonstrates, the introduction of mandatory 5 yearly electrical safety checks in the sector already have widespread support[10]. 

6.              What changes, if any, should the Government make to the Decent Homes Standard?

6.1              Electrical Safety First considers that the Decent Homes Standard provides a solid baseline for good quality and safe housing in England.  However, we believe that a more explicit requirement for electrical installations to be inspected, tested and maintained would raise safety standards and improve clarity for providers and tenants alike.

December 2021