Housing Health & Safety - Part 2 - How to carry out a Housing Health & Safety Rating System (HHSRS) Assessment

The inspector is required to undertake what is fundamentally a risk assessment of  29 different hazards and quantify this by calculating a score for each hazard.  Therefore a house could actually have 29 different scores.  A common misconception with HHSRS is that a single score is calculated for each dwelling

Source: http://blogs.aldermoorfarm.coventry.sch.uk

In last week’s article I discussed health & safety in the home and in particular the way in which habitation and health & safety issues were assessed under the former fitness standard.  The article identified why the fitness standard was limited in its scope and how this has now been addressed since the introduction of the Housing Health & Safety Rating System (HHSRS) in 2006.  

When an inspection is made under HHSRS, usually by an Environmental Health Officer or a Building Surveyor, the inspection will consider a wide range of potential hazards under 29 different categories, which are divided into four main groups:

Physiological requirements	Psychological requirements	Protection against infection	Protection against accidents
·         Damp and mould growth ·         Excess cold ·         Excess heat ·         Asbestos and manufactured mineral fibre ·         Biocides ·         Carbon monoxide and fuel combustion products ·         Lead ·         Radiation ·         Uncombusted fuel gas ·         Volatile organic compounds	·         Crowding and space ·         Entry by intruders ·         Lighting ·         Noise	·         Domestic hygiene, pests and refuse ·         Food safety ·         Personal hygiene, sanitation and drainage ·         Water supply for domestic purpose	·         Falls associated with baths ·         Falling on level surfaces ·         Falling associated with stairs and steps ·         Falling between levels ·         Electrical hazards ·         Fire ·         Flames and hot surfaces ·         Collision and entrapment ·         Explosions ·         Position and operability of amenities ·         Structural collapse and failing elements

The inspector is required to undertake what is fundamentally a risk assessment of each of the 29 different hazards and quantify this by calculating a score for each hazard.  Therefore a house could actually have 29 different scores (although this is unlikely as hazards would need to be identified for every category for this to happen).  A common misconception with HHSRS is that a single score is calculated for each dwelling, which is completely incorrect. By looking at the scope of the 29 categories it is clear to see how comprehensive the assessment is compared to the fitness standard (see last week's article) and although habitation issues are still included, a HHSRS assessment considers much wider health & safety issues that will impact on those occupying/visiting a dwelling.  

In order to arrive at a score for each hazard the inspector firstly needs to have a good knowledge of the rating system and how it works.  This requires an understanding of what to look for/at under each hazard, an appreciation of how serious an issue may be, which will include an assessment of the likeliness of the hazard occurring and also an understanding of the seriousness of the hazard should it occur.  This demonstrates that an inspection is much more than identifying hazards/issues, it is also about considering the likelihood and impact as well, which is not an exact science.  When HHSRS was first introduced and prior to undertaking the pilot surveys I discussed in my previous article I remember spending a great deal of time reading the guidance produced by the Department of the Deputy Prime Minister (now the Department of Communities and Local Government), which I have to say is very good and well worth a read if you are unfamiliar with HHSRS (Link).

Source:http://www.goodfieldconsulting.co.uk/risk-assessment/

The inspection itself is very different to anything that I had undertaken previously as a Building Surveyor.  To demonstrate how a hazard is assessed and how a score is calculated I will use the example of the potential for someone to fall out of a window.  This could be due to serious disrepair, inappropriate glazing, lack of sufficient guarding, damage or missing restrictors etc. It is important to note that this is something that would not have been considered under the fitness standard. Let us assume that the window in question is within the first floor bedroom of a typical two storey dwelling.  As with all risk assessment processes there needs to be an assessment of likelihood and severity. 

Likelihood - Firstly, the inspector must ask themselves how likely is it that the hazard will occur? This will depend on a number of factors such as the severity of disrepair, location, where in the room the window is located etc. Likelihood is expressed as a ratio and is the subjective opinion of the inspector, based upon the evidence he/she sees at the time of inspection.  So, there will be a greater likelihood of a hazard occurring if a window is in serious disrepair, with damaged glazing which is located in a position that someone could fall onto it, compared with a window with minor disrepair and at a height that it would be more difficult for someone to fall onto it.  This demonstrates two possibilities under the same HHSRS hazard, but each posing a different likelihood of occurring.  In the first instance the inspector may decide on a 1 in 10 likelihood of the hazard being realised and in the second the inspector may decide there is a much lower likelihood and allocate a ratio of 1 in 100.  There is no exact science to this however the assessment allows the hazard to be quantified.

Severity – Next the inspector must ask themselves, if the hazard is realised how serious will the consequences actually be?  HHSRS refers to this as the ‘Spread of Harms’.  A great deal of research was carried out during the development of HHSRS and part of this involved the production of data from accident statistics and input from organisations such as The Royal Society for the Prevention of Accidents (RoSPA). This enabled the significance of hazard outcomes to be defined (HHSRS allocated classes – see below) and subsequently allowed these to be quantified for score calculation purposes. For example, research data showed that for every 100 people who have turned up in hospital Accident and Emergency departments, from information collected, it can be show (for each hazard) that: 

W% will be dead	Class I
X%  will have broken several bones and will be in traction for some months	Class II
Y%  will be patched up and referred to outpatients	Class III
Z%  will be told to go home and take an aspirin	Class IV

To avoid confusion HHSRS also defines each of the classes above to provide consistency during the inspection and assessment process and for the score calculation process. Each of the four classes are weighted to reflect the significance of the potential harm:

HHSRS  - Spread of harms definitions:

Class I – Extreme  Death, permanent paralysis below the neck, malignant lung cancer, regular severe pneumonia, permanent loss of consciousness, and 80% burn injuries.	Weighting 10,000
Class II – Severe Chronic confusion, mild strokes, regular severe fever, loss of a hand or foot, serious fractures, very serious burns and loss of consciousness for days.	Weighting 1,000
Class III -  Serious Chronic severe stress, mild heart attack, regular and persistent dermatitis, malignant but treatable skin cancer, loss of a finger, fractured skull, severe concussion, serious puncture wounds to head or body, severe burns to hands, serious strain or sprain injuries and regular and severe migraine.	Weighting 300
Class IV – Moderate Occasional severe discomfort, chronic or regular skin irritation, benign tumours, occasional mild pneumonia, a broken finger, sprained hip, slight concussion, moderate cuts to face or body, severe bruising to body, 10% burns and regular serious coughs or colds.	Weighting 10

For some situations there may be one likely outcome, but for most there could be a number of possible outcomes, in terms of the level of harm, so the spread of harms could cross all four separate classes. For example, falling out of a window on the 80^th floor of a block of flats would provide only one outcome – death (So class 1 would be 100% and classes II, III & IV would each be 0%), however falling out of a second floor window might give a range of possible outcomes, giving a figure (percentage) across each of the four classes of harm.

Once the inspector has decided on the likelihood and established the spread of harms (available from HHSRS guidance, within each hazard) it is then finally possible to calculate a score.  This is done by dividing the weighting of each harm class by the likelihood and multiplying by the spread of harms.  I know this is confusing so it more easily demonstrated by using our example of someone falling out of a first floor bedroom window, in the first instance let’s assume that the likelihood is low:

Class	Class of harm weightings		Likelihood 1 in		Spread of Harms		Total
I	10,000	÷	500	x	0.2	=	4
II	1,000	÷	500	x	1.6	=	3.2
III	300	÷	500	x	7.9	=	4.74
IV	10	÷	500	x	90.3	=	1.81
Total        13.75 (14)

As you can see the score calculation of 14 is low, but see what happens to the hazard score below if the issue is more serious and the inspector thinks there is a much greater likelihood: 

Class	Class of harm weightings		Likelihood 1 in		Spread of Harms		Total
I	10,000	÷	5	x	0.2	=	400
II	1,000	÷	5	x	1.6	=	320
III	300	÷	5	x	7.9	=	474
IV	10	÷	5	x	90.3	=	180.6
Total     1374.6 (1375)

Nowadays there are spreadsheets as well as various mobile technology applications, with built in spread of harms data for each hazard, which will do these calculations with only minimum input necessary from the inspector.  Having said that I would not let any of my Surveyors undertake these types of assessments without understanding the method explained above first.  This is important to help them understand the significance of each hazard as well as trying to achieve consistency between inspectors.  Remember, the assessment is the opinion of one individual and therefore subjective.

Once scores have been calculated for HHSRS categories’ each hazard into a category 1 or a category 2 hazard:

Band	Hazard Score
A	5000 or higher
B	2000 to 4999
C	1000 to 1999
D	500 to 999
E	200 to 499
F	100 to 199
G	50 to 99
H	20 to 49
I	10 to 19
J	9 or less

Any hazard identified with a score of 1000 or above will fall within band A, B or C (depending on the score), and is classified as a Category 1 hazard.  The existence of a Category 1 hazard will invoke compulsory Enforcement Action by the Local Authority if not dealt with urgently.  Also, category 2 hazards should not be ignored and steps should be taken to eliminate, reduce or manage these hazards as well.

In order to explain the system, discuss the assessment process and cover score calculation, this article is a little longer than my usual articles.  This was necessary in order to cover some of the key points in what at face value can seem to be a complicated system.  Hopefully, I have provided an appreciation of the different mindset that is required by an inspector and demonstrated that these assessments should only be carried out by those who have the right level of knowledge and understanding of the system and how it works.

Please feel free to share this article and other articles on this site with friends, family and colleagues who you think would be interested

Information/opinions posted on this site are the personal views of the author and should not be relied upon by any person or any third party without first seeking further professional advice. Also, please scroll down and read the copyright notice at the end of the blog.

Housing Health & Safety - HHSRS and why do we need it? – Part 1

In 2005 the World Health Organisation estimated that in the UK over 2.7 million people were injured at home, almost twice as many as those injured at work and over eight times those injured on the road.  This clearly demonstrates a need to consider, not just habitation issues but wider health & safety issues in the home

Source:http://tellallthecats.blog.com

I am regularly contacted by people who experience difficulty, sometimes silence when contacting their landlord to carry out repairs.  In nearly all cases this involves private sector Landlords who for some reason think that if they ignore their tenants for long enough then they will just go away.  The issue of course is that the Tenant has rights and the Landlord has responsibilities under a whole raft of legislation (and vice versa). In the event that a Landlord fails to carry out repairs for which he/she is responsible, a tenant can take action to remedy the situation. The problem becomes magnified if the repair that is necessary is something that may be dangerous or posing a health risk to the occupants

In my early career as a Building Surveyor I undertook a number inspections on behalf of Solicitors who had been appointed by Tenants where complaints had been made about living conditions and in particular habitation standards in their homes.  In those days (prior to HHSRS), a Surveyors report would be used as evidence that a landlord had breached their duty under legislation such as section 11 of the Landlord & Tenant Act 1985 or Public Health Acts such as the Environmental Protection Act 1990 or others.  In order to assess fitness for habitation at the time a Surveyor would consider the requirements of something known as the ‘fitness standard’ under section 604 of the Housing Act 1985.  From an inspection point of view the criteria for assessment was fairly straightforward where fundamentally a yes or no, pass or fail was considered under the following criteria: 

·         Be structurally stable;

·         Free from serious disrepair;

·         Free from dampness prejudicial to the health of the occupants (if any);

·         Have adequate provision for lighting, heating and ventilation;

·         Have an adequate piped supply of wholesome water;

·         Have satisfactory facilities in the house for the preparation and cooking of food, including a sink with a satisfactory supply of hot and cold water;

·         Have a suitably located water-closet for the exclusive use of the occupants (if any);

·         Have a suitably located fixed bath or shower and wash-hand basin each of which is provided with a satisfactory supply of hot and cold water, for the exclusive use of the occupants (if any); and

·         Have an effective system for the draining of foul, waste and surface water

A failure of an individual requirement or a combination of requirements would bring into question the habitability of a dwelling and provide occupants with potential grounds for action.

Source: Author's own

Over time it became clear that assessment of a dwelling under the fitness standard was limited to habitation only and did not take into account wider health & safety issues.  In 2005 the World Health Organisation estimated that in the UK over 2.7 million people were injured at home, almost twice as many as those injured at work and over eight times those injured on the road.  This clearly demonstrated a need to consider, not just habitation issues but wider health & safety issues in the home, something that the fitness standard was incapable of achieving due to its restricted nature. Also, the fitness standard did not provide for degrees of unfitness, it was black or white pass or fail, so there was no way of assessing how significant or serious a particular problem may be. In addition the fitness standard only considered the dwelling and did not take account of the wider site, such as gardens, access to the dwelling, boundaries etc.  The statistics stated above highlight the fact that the home can be and is a dangerous place and in order for us to make it as safe as possible there was a need for a review of the way we assessed and inspected our homes.

On 6^th April 2006 this all changed with the introduction of the Housing, Health & Safety Rating System (HHSRS):

‘The Housing Health and Safety Rating System (HHSRS) is a risk-based evaluation tool to help local authorities identify and protect against potential risks and hazards to health and safety from any deficiencies identified in dwellings. It was introduced under the Housing Act 2004 and applies to residential properties in England and Wales.
The HHSRS assesses 29 categories of housing hazard. Each hazard has a weighting which will help determine whether the property is rated as having category 1 (serious) or category 2 (other)’  Source: https://www.gov.uk

This new system is set out in part 1 of the Housing Act 2004 and was introduced to address the short comings previously discussed within the fitness standard. Instead of the previous pass or fail criteria, HHSRS is structured around an evidence based risk assessment. Many people are surprised to learn that HHSRS covers ALL housing, not just rented accommodation.  A Local Authority therefore has enforcement powers under HHSRS to ensure that category 1 hazards (to be explained later), are dealt with urgently whether the property is privately owned or rented.

The purpose of HHSRS enables hazards to health and safety to be identified in dwellings. A hazard is then quantified with the allocation of a rating score for each hazard and then used to decide what, if any, action needs to be taken to make a property safe.

When HHSRS was first introduced in 2006 there was a lot of confusion at the time from many in the housing sector, particularly social housing, on the likely impact of HHSRS.  Concerns were raised about how quickly and how many assessments would be required, how much would the assessments cost? How would identified hazards be dealt with and what would be the cost implications of this in terms of identified works.  I carried out a range of pilot surveys under HHSRS for a number of RSL’s and was able to provide them with some general guidance to answer some of these questions.  From an inspection point of view the process was very different from other types of surveys I had previously carried out and requires a good knowledge of HHSRS and especially a good understanding of the 29 hazard categories. 

In next week’s article I will discuss the inspection process in more detail and provide some examples which will demonstrate how the scope of HHSRS is much wider than the previous fitness standard.  I will also explain what a category 1 and a category 2 hazard is and how an inspector will arrive at an appropriate score for identified hazards.

Please feel free to share this article and other articles on this site with friends, family and colleagues who you think would be interested

Information/opinions posted on this site are the personal views of the author and should not be relied upon by any person or any third party without first seeking further professional advice. Also, please scroll down and read the copyright notice at the end of the blog.

Energy Efficiency - Why measuring ‘performance in use’ is the key to energy efficiency in buildings

Guest Article from Professor George Martin, Low Impact Building Centre, Coventry University

With approximately 80% of the properties that exist today still being in existence in 2050, the key issue for landlords in the run-up to the 2018 change is that they understand the scale, nature and cost of the various interventions that will be needed to update properties now

Source: www.sustainablecommercialsolutions.co.u

For the past 10 years or more I have been driven by the mantra - If you can’t measure it you can’t manage it. This applies to each and every key performance indicator linked to the built environment sector with energy arguably being the most important. It is for this reason that I consider it essential that the Government mandates the use of Display Energy Certificates (DECs) for all buildings as a vital first step to cutting carbon emissions.

The Display Energy Certificate (DEC) provides an up to date snapshot of how well a particular building is performing, based on actual energy consumption unlike its poor relation the Energy Performance Certificate (EPC) that only provides a theoretical rating based on assumed patterns of use and occupation and can be up to10 years old!  The DEC also reveals what the rating score was in previous years. Consequently it is possible to see at a glance the progress in making that building more energy efficient and less costly to run.  There is now considerable evidence (initially anecdotal, increasingly academic) that requiring energy usage to be professionally monitored and the results made visible, delivers enormous improvements in performance.

Landlords need to be aware that the Energy Act 2011 proposes to make it unlawful to lease residential or commercial buildings with an Energy Performance Certificate (EPC) rating of F or G from April 2018.  In addition, there is a requirement for all new build domestic to be 'zero carbon' from 2016 and for new build non-domestic to be ‘zero carbon’ from 2019.  However, the biggest challenge, especially for landlords, relates in particular to the UK's ageing property stock, not built for a world of high energy prices and carbon reduction targets, and lacking in investment in low carbon retrofit over time.

Source: http://valentemike.blogspot.co.uk

With approximately 80% of the properties that exist today still being in existence in 2050, the key issue for landlords in the run-up to the 2018 change is that they understand the scale, nature and cost of the various interventions that will be needed to update properties now. And that means learning in more detail about how properties actually perform in use.  A one-size-fits-all approach will not work and landlords will need to develop an evidence based approach, backed up with a robust whole life cost database for their properties.  Smart landlords will be using sensors to monitor energy use against temperature and other indicators such as relative humidity in order to identify more specific issues – so that they can identify whether the source of any inefficiencies is due to the building fabric, the equipment, the maintenance regime or indeed the behaviour of occupiers.

Property developers and landlords also need to ensure that their design, delivery and maintenance teams do not have a blinkered approach to energy efficiency and carbon reduction - as it is vitally important to ensure that the health of the fabric and the occupants are also considered. The existing stock of ‘leaky’ properties, whilst bad for energy efficiency, is good in terms of ventilation and here there is some distressing news from recent research that is showing that many - if not most - of the Mechanical Ventilation and Heat Recovery units installed in recent times are underperforming, which is seriously bad news for the occupants.

It is most certainly not right to assume that all 'modern' property will achieve a good performance in use just because it has a good EPC rating or indeed an ‘high’ BREEAM design rating.   Even the highest spec builds with energy efficiency in mind may not be performing as expected. The limited performance gap research available has demonstrated that design targets (and we must remember that EPC is a design tool) are missed by between 20% and an astronomical 500%. We must stop assuming that sustainability-minded design and construction methods are the whole story. Buildings need to be monitored and evaluated for performance once occupied.  Only then is it possible to gain a clear picture of the performance in use and capture the learning for future designs.

The property sector needs to move from making procurement decisions based on design tools (e.g. EPCs), capital cost and payback time to making primary decisions based on the performance in use (DECs)  and 'whole life costs', backed up by an assessment of the return on investment.  

In turn, as attitudes and understanding begins to evolve around performance  in use and whole life costs, the construction industry and here I include clients, designers and constructors, will become more focused on delivering buildings that perform sustainably i.e., environmentally, socially and economically.

Professor George Martin, Low Impact Building Centre, Coventry University

http://www.coventry.ac.uk/business/supporting-your-business/sustainable-building-futures/

Please feel free to share this article and other articles on this site with friends, family and colleagues who you think would be interested

Information/opinions posted on this site are the personal views of the author and should not be relied upon by any person or any third party without first seeking further professional advice. Also, please scroll down and read the copyright notice at the end of the blog.