Written evidence submitted by Action Disability Training and Consulting [RSH 043]


  1. Summary.

This submission from Action Disability Training & Consulting to the LHC Select Committee looks at  the gaps in the proposed Regulation of Social Housing with regard to disabled people.

Action Disability contends:

  1. that the proposed new Tenant Satisfaction Measures (TSMs) do not address the challenges facing disabled people who live in social housing.
  2. That the Equality Impact Assessment (Annex 7) of the consultation papers is superficial in its approach and fails to address the challenges facing disabled tenants. 
  3. That the TSMs proposed would be strengthened by the inclusion of five Disability specific TSMs.


  1. General Observations

The consultation has a number of problems:

  1. The proposed TSMs highlight a rather narrow range of performance or satisfaction measures. Some appear to show a lack of front line experience of social housing services and challenges. The paucity of reference to disabled people is a weakness. 
  2. The measures reflect a top down approach which would have benefited from being resident led and defined performance measures.
  3. The Tenant satisfaction Measures need to have specific ones related to disability. Five such TSMs are highlighted in this submission

Learning from Grenfell.


When Greenfell Tower caught fire the biggest group of people to lose their lives were disabled people. Thirty (42%) of the 72 people who lost their lives. The inquiry into the tragedy heard, according to Inside Housing (20.04.21) that “Disabled residents of Grenfell Tower were regularly trapped in the building due to broken lifts and offered no plan for their escape.”  


The managers of Grenfell Tower, the Kensington & Chelsea Tenant Management Organisation are accused of not preparing a plan for disabled people to escape in the event of a fire.


Making homes Accessible.


In November 2020 the Centre for ‘Ageing Better’ tells us in the publication ‘Homes for Life’ that “91% of homes do not provide even the lowest level of accessibility.” So less than 10% of homes are accessible at a time when the population is ageing and the number of disabled people is growing. See:




There is a need to make social housing accessible so that tenants as they age can remain in their homes and community if they want to. Councils and other housing providers should be required to report on progress making homes accessible.


What about the needs of Disabled people?

The consultation paper is accompanied by an Equality Impact Assessment (Annex 7)  The Equality Impact Assessment highlights that: “54% of households had at least one household member with a long-term illness or disability, compared to 25% in the private rented sector and 31% of owner-occupied

households.” See:



It also sets out


a) the need to eliminate discrimination, harassment, victimisation, and any other conduct that is prohibited by or under the Equality Act 2010

b) to advance equality of opportunity between people who share a relevant protected characteristic and those who do not. This involves having regard to the need to:

i. Remove or minimise disadvantages suffered by people due to their

protected characteristics

ii. Take steps to meet the needs of people with certain protected characteristics where these are different from the needs of others

iii. Encourage people who share a relevant protected characteristic to participate in public life or in other activities where their participation is disproportionately low

There is a need for a link between TSMs and the experience of or challenges faced by disabled residents.  There is a strong case for separate disability related TSMs. These could be:




Disability Challenge


Satisfaction with fire escape measures.



Satisfaction with built environment access.



Satisfaction with engagement and consultation. Recognising the wide range of disabilities and needs.



Actions take to make homes accessible as the residents age or become disabled.



Evacuation plans to be agreed with disabled residents of blocks of flats.


About Nigel Long.



ACTION DISABILITY Training & Consulting is a specialist training organisation providing courses including:


              Understanding Disability Equality

              Managing disabled staff

              Empowering service users with physical disabilities.

              An introduction to mental health

              Housing and disability

              Mental Health and Housing

              Physical disability and housing.

              Disability training for councillors and Board members.


Website : https://actiondisabilitytrainingconsulting.co.uk/


December 2021