Read the text of this document (25 pages)
Housing Management
Strategy for occupied
Higher Risk Buildings
Draft - February 2025 v0.01
1
Contents
Page
1.Introduction:
1.1 Aims of the Strategy
1.2 Scope of the Strategy
1.3 Principles of the Strategy
1.4 Housing Management Safety Management System
1.5 Key objectives of the Strategy
1.6 Links to Corporate Strategies
1.7 Resourcing the Strategy
3
3-4
4
4
4-5
5
5
2. Regulatory framework
2.1 The Building Safety Act 2022
2.2 The Social Housing (Regulation) Act 2023
2.3 Fire Safety Act (2021) and Fire Safety Regulations (2022
5-6
6
6
3. Meeting the Regulatory Requirements
3.1 Managing safety
3.2 Housing Management Offer
3.3 Fire Safety Regulations
3.4 Building Safety Case
6-7
7-8
8
8-9
4. Vulnerable Residents
4.1 The Golden Thread
4.2 Customer Insight Data
4.3 Personal Emergency Evaluation Plans [PEEPs]
9-10
10
10-11
2
4.4 Premises Information Boxes [PIBs]
11
5. Delivering our objectives
5.1 Roles & Responsibilities under the Strategy
5.2 Governance & Performance Management
5.3 Staff Resources
5.4 Competencies, Training and Development
5.5 Resident Engagement & Communication
5.6 Data Management & Information systems
5.7 Quality Assurance
5.8 Review of the Strategy [and Delivery Plan]
11-12
12
12
12-13
13-14
14
14
15
6. Communication
6.1 Engagement strategies
6.2 Tailored Fire Safety Information
6.3 Complaints
6.4 Resident Obligations
6.5 Contravention Notice
6.6 Digital Notice Boards
15
15-16
16
16-18
18
18-19
Appendix 1: Schedule of higher risk buildings
Appendix 2: Glossary of terms
Appendix 3: Delivery Plan
20
21-23
24 -
3
1.Introduction
1.1 Aims of the Strategy
This document sets out the approach by the Housing Management Service in
making an effective and compliant contribution to the Council’s Building Safety
Policy in the context of occupied higher risk buildings within its ownership and
management. These buildings are set out in Appendix 1 – Schedule of Higher
Risk Buildings. This Strategy, and the accompanying Delivery Plan, has been
developed to ensure that the Council is fully compliant with the Building Safety
Act 2022, the Social Housing Regulation Act 2023 and other legislative and
regulatory obligations which at their heart are designed to ensure that our
residents are ‘fire safe’ and ‘fire aware’.
The Strategy details how the Service dovetails through a whole organisation
approach to ensuring that people and property across our in-scope buildings are
effectively managed so that our residents are kept safe. The Strategy picks up on
and takes forward the twin tracking of operational practices which have a clear
focus on ‘people’ and ‘property’ in the context of fire safety. This strategy
supports our work in delivering compliant buildings but has a clear focus on
ensuring our residents are safe. This necessitates proactive management activity
aligned to what people bring into our buildings and how they behave. In this
Strategy, compliant buildings are viewed as the ‘safety net’ when
behavioral risks are not effectively mitigated.
1.2 Scope of the Strategy
This Strategy applies to staff groups across the Housing Management Service
and is applicable to all Council owned high-rise residential blocks as defined in
the Building Safety Act 2022. This currently defines high-rise buildings [also
referred to as ‘higher risk’ or ‘in-scope’ buildings] of 18m+ in height or 7+ storeys.
This includes both tenanted and leasehold stock.
Built Environment
What people bring
into buildingsHuman Behaviour
4
It is anticipated that in future years the buildings that are within the scope of the
Act may change (for example to include buildings over 11m+ in height) and this
strategy will be reviewed and updated accordingly to ensure it remains fit for
purpose.
Based upon the current requirements of the Act, this Strategy applies to 11
council owned and managed occupied ‘higher-risk residential blocks as of
January 2025.
1.3 Principles of the Strategy
Key drivers for the delivery of the Strategy are:
To ensure the safety of all residents, irrespective of tenure or occupation
arrangement, living in the Council’s high-rise residential buildings
To make an effective contribution to the Council’s Building Safety Policy in
the context of legislative compliance applicable to occupied high-rise
residential buildings
To ensure that residents are involved in decisions regarding ‘safety related
matters’ associated with their homes and the buildings in which they live and
To ensure a positive communication culture based upon transparency and
treating residents with respect and which values their feedback
1.4 Housing Management Safety Management System
As part of fulfilling its role as outlined in this Strategy, the Housing Management
Service will adopt a simple management system for managing the safety risks it
has direct responsibility for. This system will be based on the ‘Plan, Do, Check,
Act’ approach. This model covers:
Plan – determine your policy and plan for implementation
Do – assess risks and implement your plan
Check – measure performance
Act – review performance and act on lessons learned
1.5 Key objectives of the Strategy
To achieve the principles of the Strategy, the Housing Management Service is
committed to:
Improving the effectiveness of existing compliance management, including
the need for an effective quality assurance framework which supports staff in
doing the right thing at the right time to the agreed quality threshold
Ensure clear and transparent monitoring and reporting to demonstrate
compliance, including the development of appropriate performance measures
Improving the measuring and reporting of resident satisfaction with the safety
of their home
Ensuring that an effective and sustained contribution is made to support the
delivery of the principles of the ‘golden thread’ of information
Ensuring there is clarity around respective roles, responsibilities and
accountabilities
5
Ensuring the training and development needs of relevant staff are met and
that appropriate refresher training is delivered
Support the ongoing need to embed a safety culture across Housing
Management, residents and other stakeholders
1.6 Links to Corporate Strategies
This Strategy seeks to support the delivery of the Council’s Building Safety
Strategy which sets out sets out Hillingdon Council's approach to preparing for
and implementing the building safety regime as set out in the Building Safety Act
2022. Keeping residents safe in their homes is the key priority underpinning the
Council’s Corporate Building Safety Strategy. Within this Strategy is clear
reference to the Council as owner and manager of ‘higher risk buildings’ within its
social housing portfolio. The Housing Management Strategy for occupied higher
risk buildings therefore complements and supports the aims and objectives within
the overarching Corporate Strategy.
1.7 Resourcing the Strategy
The Housing Management Service will strengthen front line resources across
teams who have a direct role in supporting the successful delivery of this
Strategy. This includes ensuring that there is Housing Officer to total number of
properties in management ratio which supports a more intensive level of
management across the Council’s in-scope buildings and a dedicated
management lead to ensure effective management oversight of the Delivery
Plan. Sufficient resources will also be available from the Resident Engagement &
Involvement Team to ensure that the voice of our residents is heard and acted
upon and that our tailored Resident Engagement Strategies for our in-scope
buildings are up to date, meet the needs of our residents and are compliant with
the Building Safety Regulator’s expectations.
2. Regulatory Framework
2.1 The Building Safety Act 2022
The Building Safety Act 2022 takes forward the government’s stated commitment
to fundamentally reform building safety. The Act establishes a building
safety regime in England with the introduction of a Building Safety Regulator
and sets out a legislative framework for those who procure, design, plan,
manage and undertake building work in relation to higher-risk buildings. The
focus of this Strategy is the management of occupied higher-risk buildings.
The Act establishes a duty holder regime which includes a statutory requirement
for a Principal Accountable Person [PAP], supported by an Accountable Person
[AP], to provide a ‘Safety Case Report’ which demonstrates how occupied
residential buildings’ safety risks are being identified, mitigated and managed on
an ongoing basis. The Act’s core theme is that there is a whole building
approach to safety and that the Accountable Person considers fire and structural
building safety risks and their mitigation.
The Act also introduces the requirement to maintain the ‘golden thread’ of
information throughout the life cycle of in-scope buildings. This must be provided
to the Building Safety Regulator at key gateways. Critically the Act requires the
6
creation of a Resident Engagement Strategy and places a legal obligation on the
PAP to ensure that residents are involved in the decisions that concern the
Safety of their building.
It can therefore be seen how Housing Management is best placed to deliver core
aspects of the Building Safety Act 2022 to occupied higher risk buildings. This
approach also supports the Council’s approach to fire safety which includes a
dual focus on ‘property’ and ‘people’.
2.2 The Social Housing (Regulation) Act 2023
This Act supports and complements the Building Safety Act in that it legislates to
ensure all social housing residents are safe in their homes, know how their
landlord is performing in relation to building safety, and that their voice is heard.
The Regulator of Social Housing has issued consumer standards against which
landlords will be inspected. The transparency, influence and accountability
standard requires landlords to be open with tenants and treat them with fairness
and respect. The Tenant Involvement and Empowerment Standard requires
local authority landlords to “treat all tenants with fairness and respect” and
“demonstrate that they understand the different needs of tenants, including in
relation to the equality strands and tenants with additional support needs”.
There is a specific expectation that landlords will “demonstrate how they respond
to those needs in the way they provide services and communicate with tenants”.
The Housing Ombudsman Complaints Handling Code 2024 states Landlords
“must consider their duties under the Equality Act 2010 and anticipate the needs
and reasonable adjustments of residents who may need to access the
complaints process” and also “Landlords must consider factors such as the
complexity of the complaint and whether the resident is vulnerable or at risk.”
2.3 Fire Safety Act (2021) and Fire Safety Regulations (2022)
The 2002 regulations came into force in January 2023 and supplemented the
duties contained in the Regulatory Reform (Fire Safety) Order 2005. The Act
clarifies that the responsible persons for multi-occupied residential buildings
must manage and reduce the risk of fire for the structure and external walls of
the building, including cladding, balconies, windows and entrance doors to
individual flats that open onto common parts.
These Regulations introduced additional requirements on Responsible Persons,
aimed at identifying and communicating fire risk information regarding
evacuation procedures to residents in a format they will understand. This
Strategy will build upon these fire risk and information requirements as part of
our approach to undertaking person centered fire risk assessments and
disseminating timely and tailored fire safety information.
3. Meeting the Regulatory Requirements
3.1 Managing safety
The Council, including the Landlord Service, has already put in place measures
7
to meet the requirements of the Building Safety Act and the Fire Safety Act.
Much of the ongoing development work is to improve our systems and
processes to better demonstrate levels of compliance. This Strategy builds
upon these workstreams by re-focussing the Housing Management Service on:
Information management – accurate data is required to enable the Service to
effectively manage the raft of occupation arrangements which exist across its
tower block portfolio, ensure vulnerable households are identified and tailored
interventions delivered / reasonable adjustments brought forward to mitigate
presenting risks, to drive robust inspection / re-inspection regimes and to enforce
standards swiftly and appropriately. A single source of data will support the
‘golden thread’ of information.
Compliance management – the provision of an appropriate and robust system
to maintain and report on all Housing Management compliance activities,
including enforcement activities applicable to tenant and leaseholder obligations,
is key to maintaining a safe environment for our residents, staff, contractors and
visitors, supported by up to date operational practices.
People and culture – establishing an effective compliance culture that sets the
basis of expected behaviour and accountability across the Housing Management
Service (staff, managers and residents) will facilitate reductions in fire safety risks
and foster the provision of safer homes for our residents. A key component will
be the training and development of staff, as well as residents who want to work
more closely with us, to incorporate the levels of understanding and competency
necessary for the professional and compliant management of fire safety in
residential buildings.
Resident engagement and communication – improving the landlord tenant
relationship, building trust, treating residents with respect and improving levels of
resident empowerment and engagement will help to facilitate improved levels of
adherence with practices and processes to facilitate reductions in fire safety risks.
A successful communication strategy, supported by an effective digital platform,
will ensure core messages are shared in a timely and consistent way to ensure
residents are ‘fire safe’ and ‘fire aware’.
Safety Case Reports – will demonstrate the interrelationships of managing
property and people related risks in the context of fire safety. The Housing
Management Service will make an effective contribution to the development,
review and amendment of Safety Case Reports to ensure that all material
behavioural risks are appropriately considered and mitigated and that reliance is
not centred on building structure to prevent or minimise the risk of harm.
The Golden Thread of Information – will provide Regulatory bodies, our
governance structure and residents with the confidence that a ‘single source of
truth’ exists for each building in scope and that key information on property and
people is up to date and secure. This will support staff to improve decision
making and bring forward better and safer outcomes for tenants in the context of
fire safety.
3.2 Housing Management Offer
Taking a ‘whole building’ approach to fire safety requires a transparency,
the development of new relationships and the improvement of existing ones
with each and every household. As part of this Offer to residents living in our
tower blocks, the Council is committing to more personal contact with residents,
8
more inspections, more information sharing and improved channels of
communication. The Council knows that the people living in our high-rise blocks
are our greatest source of information about our buildings and must be listened
to. Through our housing management offer the Council is seeking to ‘get the
balance right’ between safety, the level of intrusion and cost. The delivery of the
Housing Management Offer is key in ensuring that our residents are fire safe and
Fire aware and sets out:
A more intensive approach to housing management with dedicated Housing
Officers as a key point of contact
An inspection regime covering shared areas of the building, flat entrance door
checks and property inspections.
The need to gather relevant information about residents who live in our higher
risk buildings to ensure that any presenting risks, including vulnerabilities, can
be managed and to improve the effectiveness of our communication.
Clear guidance for ‘staying put’ and carrying out partial or total evacuation of
buildings following direction by the fire and rescue service.
How residents can participate in matters relating to building safety as part of a
documented approach to engagement.
A commitment to provide safety related information to residents.
A dedicated Complaints system for residents living in tower blocks.
The rights and duties of all households who reside in tower blocks including
tenants, resident leaseholders and those who rent their home from a
leaseholder.
How new lettings are restricted to tenants and household members who can
self-evacuate in the event of being ordered to do so by the emergency
services.
3.3 Fire Safety Regulations
The effective delivery of the Housing Management Offer is a key component in
ensuring that our buildings are safe and includes a matrix of inspection activities,
the provision of tailored information and planned contact with residents. These
include:
New resident visits
Provision of tailored fire safety information packs
Person centred fire risk assessments
Planned reviews of Personal Emergency Evacuation Plans [PEEPs]
Flat entrance door inspection regime
Whole flat and balcony inspection regime
Shared area inspection regime
Updating vulnerability information within the Premises Information Box
[PIB]
3.4 Building Safety Case
This report summarises the measures in place to manage building safety risks
and demonstrates that the accountable person has taken ‘all reasonable steps’
to prevent and mitigate those risks. The reports for each in-scope building are
required to be submitted to the Building Safety Regulator.
9
The Housing management Service recognises that building safety risks are not
confined to the spread of fire or smoke in the building, or structural failure of the
building. The Housing Management Service will work with the Principal
Accountable Person to go above and beyond the requirements of the Building
Safety Regulator and ensure that behavioural and other management risks are
properly reflected in Building Safety Case Reports alongside robust approaches
to mitigating those risks. This includes the production and planned review of
Building Safety Case reports and triggering the need for unplanned reviews
linked to a material change in presenting circumstances associated with the
management of the building.
Where the Housing Management Service identify new or increased risks
associated with the management of the building, they will retain responsibility for
identifying, implementing and reviewing the effectiveness of further mitigation
measures to manage those risks.
4. Vulnerable Residents
As reflected in our Vulnerable Residents & Reasonable Adjustments Policy the
Landlord Service is committed to ensuring that vulnerable residents experience
fair and equitable outcomes when delivering landlord related services. This
commitment extends to the provision of Housing Management services to
residents living across our tower block portfolio where particular safety related
risks present.
This Strategy not only explains how the council will achieve good outcomes for
our vulnerable tower block residents but also commits to listening to their views
and opinions. We will develop approaches and mechanisms to ensure that
vulnerable residents take part in opportunities to get engaged, influence decision-
making and can easily complain about the quality of services delivered across our
tower block portfolio.
4.1 The Golden Thread
The scope of the ‘golden thread’ of information reflected in the Building Safety
Act 2022 is considerable and should be sufficient to serve as the basis for the
Building Safety Case Report. This includes but is not limited to; plans,
maintenance documents, materials documentation, certifications and risk
assessments. The expectation is that these records are maintained digitally, be
current, relevant and accessible, allowing proper retention, security and version
control to be maintained.
The Housing Management Service has a key role to play in this context. With
responsibility for the management of ‘people related risks’ and ensuring that
vulnerable residents receive fair and equitable outcomes in relation to fire safety,
it is essential that the Service follows the core principles of the ‘golden thread’
duties across all its records and processes associated with keeping residents
fire safe and fire aware. Central to this is our customer insight data. Individuals
have the right to be informed about the collection and use of their personal data.
This is a key transparency requirement under the General Data Protection
Regulations. Morre information on the type of data we collect is set out within the
10
Housing Management Privacy Notice https://www.hillingdon.gov.uk/privacy
4.2 Customer Insight Data
In order to influence what we do and how we do it, it is essential that we
develop a better understanding of who lives in our tower blocks. Accurate
and relevant information about our tower block residents will support us to
personalise our service offer, respond to the changing needs of residents and
above all, ensure or residents are fire safe and fire aware. The Housing
Management Service therefore recognises that accurate and relevant customer
insight data is a core element of the ‘Golden Thread’ and is key to the effective
management of risk.
We will ensure systems and processes support and enable vulnerable residents
to disclose their needs and help staff spot signs of vulnerability, ensuring that
systems can effectively note and retrieve information about a residents’ needs. In
addition, staff will be empowered to escalate where standard processes and
procedures do not provide the right outcome for vulnerable residents in the
context of fire safety.
4.3 Personal Emergency Evaluation Plans [PEEPs]
On 2nd December 2024 the government issued a response to the Emergency
Evacuation Information Sharing Plus (EEIS+) consultation which was held in
2022 to seek views on new proposals to support the fire safety of residents
who would need support to evacuate in an emergency situation. Government,
in its response at that time, confirmed that legislation would be introduced to
deliver Personal Emergency Evacuation Plans (PEEP) for residential settings
which would be known as a ‘Residential PEEP’. The scope of Residential PEEPs
would go beyond that of the consultation. It was stated that Regulations would
mandate Residential PEEPs for all high-rise residential buildings and for
residential buildings between 11 and 18 metres with simultaneous evacuation
strategies in place. All ‘higher risk’ buildings are the subject of a ‘stay put’
strategy.
Notwithstanding the government’s future intentions for mandating PEEPs
in higher risk buildings, the Housing Management Service will:
Make reasonable endeavours to identify vulnerable residents who require
‘Person Centred Fire Risk Assessments’ [PCFRAs] and potential mitigations
which are practical and proportionate.
At the end of the Person-Centred Fire Risk Assessment process, the resident
and the Housing Management Service need to be clear on what the resident
would do in the event of a fire affecting them. The Housing Management Service
will be responsible for recording and summarising this output in a Residential
PEEP statement.
PEEPs will be reviewed annually unless otherwise stated or as a result of a
material change in circumstances
Ensure information on vulnerable residents in high-rise buildings is maintained
and can be made readily available to the Fire & Rescue Service in a digital
format on request
11
Meet the cost of reasonable adjustments arising from PCRFAs within tenant’s
homes where practical and proportionate to do so
Where a leaseholder is the only beneficiary of a reasonable adjustment within
the home, the cost to implement measures will be charged to therm.
Where the Council determines that it is appropriate for all leaseholders to fund a
measure (for example, a common-area measure of benefit to many residents),
those leaseholders will have the opportunity to challenge costs they deem
unreasonable via existing leaseholder law mechanisms.
The practice of identifying vulnerable households and developing and reviewing
person centred ‘personal emergency evacuation plans [PEEPs] and undertaking
reasonable adjustments will be documented in the ‘Housing Management Offer’.
In summary terms the Housing Management Service will follow the following five
Step approach:
Step 1: Define the building evacuation strategy
Step 2: Identification of those needing support to evacuate
Step 3: Undertake Person-Centred Fire Risk Assessment and develop PEEP
Step 4: Share information with the local Fire & Rescue Service on request
Step 5: The Fire & Rescue Service access and use this information via the
Premises Information Box [PIB] in the event of a fire
4.4 Premises Information Boxes [PIBs]
Premises Information Boxes [PIBs] are secure metal boxes located to the front of
all higher risk buildings which are accessible to the Fire & Rescue Service. They
contain a range of building and resident related information. The Housing
Management Service is responsible for maintaining all resident related
information in line with the Code of Practice for the Provision of Premises
Information Boxes in Residential Buildings.
All residents who are the subject of a PEEP will be recorded as ‘category 1’
households within the ‘premises information box’. The Housing Management
Service will also annotate within the PIB any resident who is receiving oxygen
therapy and has oxygen cylinders stored within their flat. Use and storage of
oxygen cylinders will also be clearly marked adjacent to the flat entrance door.
This resident focussed information located within the PIB provides the Fire &
Rescue Service with key information ‘at a glance’ regarding residents who are
unable to self-evacuate unaided, in addition to resident-related issues which
could present as ‘high risk’ in the event of a real fire situation.
5. Delivering our objectives
5.1 Roles & Responsibilities under the Strategy
The Director of Operational Assets holds the statutory role of Principal
Accountable Person [PAP] for the Council’s portfolio of higher risk buildings
under the Building Safety Act 2022. The PAP is also the named Heath & Safety
lead under the social housing regulatory framework. In the context of managing
building safety and behavioural risks, the PAP is supported by an Accountable
Person [AP] who has a clear focus on the effective management of behavioural
12
risks and ensuring engagement and communication with residents is aligned with
the expectations of the Building Safety Regulator. The statutory AP role will
provide management oversight, advice and support to the Housing Management
Service to ensure that the commitments set out in this Strategy are met.
The Head of Housing Management will ensure the necessary allocation and
deployment of resources from across the Housing Management Service to
make an effective and sustained contribution to the Housing Management
Delivery Plan for Occupied Higher Risk Buildings with the overarching objective
of ensuring residents within the scope of The Building Safety Act 2022 remain
fire safe and fire aware. This will include; the appointment of a Neighbourhood
Housing Manager to take a lead role in relation to the Occupied Higher Risk
Buildings, ensuring that there are sufficient staff resources to deliver a more
intensive level of Housing Management and ensuring that staff receive
appropriate levels of training and development to deliver their roles effectively
and confidently under this Strategy.
5.2 Governance & Performance Management
Fire Safety Board is an integral part of the Council’s Landlord Service
governance structure. Its overriding purpose is to ensure that, as a
a responsible social landlord, our residents are ‘fire safe’ and ‘fire aware’. Fire
Safety Board will have strategic oversight of all workstreams which have a direct
or indirect link to fire safety across the managed housing portfolio. It provides
assurance to Landlord Board, Corporate Management Team Leads and Cabinet
Member leads that, in the context of fire safety, the Council is self-aware,
Compliant and is striving to put the safety of residents first.
The ‘ownership’ of the Fire Safety Policy [including related Standards] and the
Building Safety Strategy [which included occupied higher risk buildings] is vested
in Fire Safety Board to ensure the effectiveness of strategic guidance and
oversight of operational delivery.
The terms of reference of Fire Safety Board include the ‘exercise of strategic
oversight of the management of ‘higher risk’ buildings, including the discharge
of all statutory functions’. Fire Safety Board will therefore exercise oversight and
monitoring of the content and delivery of the workplan linked to the Housing
Management Strategy for occupied higher risk buildings and will provide regular
updates to Landlord Board, Corporate Management Team Leads, Cabinet
Member leads and residents
5.3 Staff Resources
The Landlord Service has made significant and ongoing investment in its people
and property. These are stated strategic objectives within our [draft] Landlord
Strategy. We want to manage homes that are safe and which residents can
be proud of. In order to achieve this, and meet the commitments set out within
this Strategy, we will continue to ensure that levels of staff resources are
sufficient and receive appropriate and ongoing training and development.
5.4 Competencies, Training and Development
A key area of the Building Safety Act 2022 is to ensure that anyone undertaking
13
works is competent to work in buildings that are in-scope. Mirroring this
approach the Housing Management Service are committed to investing in the
professionalisation of managers and staff groups and this extends to those who
have specific operational, managerial and strategic responsibilities for the
management of in-scope buildings. We will ensure that staff receive appropriate
training and development to ensure that they are competent and confident in
fulfilling their roles and responsibilities and are aware of changes in Regulations
and emerging good practice in the context of managing higher risk buildings.
5.5 Resident Engagement & Communication
The resident voice and resident engagement are key areas of the Building Safety
Act 2022 and the Social Housing Regulatory regime. Transparency, influence
and accountability is a ‘golden thread’ running through the Regulator’s
Consumer Standards. The Landlord Service recognises that successful resident
engagement is therefore critical to achieving the outcomes which this strategy is
designed to achieve.
The Building Safety Act 2022 requires the creation of a tailored Resident
Engagement strategy and places a legal obligation on the PAP to ensure that
residents are involved in safety related decisions and receive information
regarding safety related matters which affect their building.
This statutory engagement strategy must include a complaints system to ensure
residents’ safety concerns are heard and dealt with. Residents also have the
ability to escalate complaints to the Building Safety Regulator. To ensure that
prompt and efficient action is taken to resolve, all building safety complaints
raised by residents living in one of the Council’s in-scope buildings will be
recorded and acknowledged within 24 hours and assigned, as appropriate, to
the designated Housing Management or Building Safety lead as the principal
investigator. All building safety complaint types will be responded to in
accordance with the Council’s Complaints Policy. Safety related complaints from
residents living in higher risk buildings will be specifically referenced within the
Annual Complaints and Improvement Report produced by the Landlord Service.
In relation to work with residents across our in-scope buildings the Landlord
Service is working on two levels; the production of a Resident Empowerment &
Influence framework at strategic level in addition to the more local specific
engagement that will take place with residents in each of our in-scope blocks.
This will ensure a building specific Resident Engagement Strategy is produced for
each of our high-rise, high-risk buildings.
The building specific Resident Engagement Strategies will be aligned to and
adopt the overarching principles of the Resident Empowerment &
Influence framework and will be regularly reviewed and adopted for all buildings
that fall within the scope of Building Safety Act now or in the future.
Our building specific Resident Engagement Strategies will:
include how we will share information about building safety with residents
set out those building safety decisions residents will be asked about
14
when residents will be asked about planned works and how to minimise
disruption
how opinions will be collected and used
show how communication needs have been considered
set out how we will measure and review participation
provide a route to enable residents to raise safety concerns formally
include the ability to capture formal and informal feedback
detail the ways in which we will engage with residents and how we will ensure
their diverse needs are considered
acknowledge the role of residents and their responsibilities to support safety.
be reviewed every two years in conjunction with residents
include how consultations will be undertaken and over what period
be distributed to all residents aged 16 years and over living in the building and
be published on the Council’s website
5.6 Data Management & Information systems
It is recognised that the scope of the ‘golden thread’ of information must include
a raft of building related data. The expectation is that these records are
maintained digitally, be current, relevant and accessible, allowing proper
retention, security, and version control to be maintained.
As part of this Strategy the Housing Management Service consider resident
insight data as an integral part of that body of information which constitutes
the ‘golden thread’ and which is necessary to effectively manage the building,
mitigate presenting risks and deliver fairer and better outcomes for residents.
Key to this is documenting a single view of the resident and their household.
The Housing Management Service use NEC Housing to record resident,
household and vulnerability information. NEC Housing has a pop-up flagging
function that alerts Officers prior to reading the tenant details. Accurate
recording and management of vulnerability data is essential for providing
appropriate support to our residents. The NEC Housing system is configured with
specific data fields designed to capture relevant information, ensuring
consistency and preventing the entry of irrelevant data. Our staff use these
predefined fields when recording vulnerabilities to maintain data integrity and
protect resident privacy.
Information held regarding a person’s vulnerability within an in-scope building will
be reviewed annually unless there is a material change in circumstances to
ensure that it is up to date and accurate.
5.7 Quality Assurance
Integral to the actions and workstreams contained in the Delivery Plan supporting
the Housing Management Strategy for Occupied Higher Risk Buildings, the
Service will develop a Quality Assurance Framework. This QAF will be
developed in conjunction with residents and used as a management tool to
ensure that the right task is being undertaken by staff at the right time and to the
agreed quality standard. Outcomes from the QAF will be shared with residents.
15
5.8 Review of the Strategy [and Delivery Plan]
The Housing Management Service, in conjunction with residents, will carry out
a review of the Strategy and delivery plan every two years to make sure that it
remains properly aligned to regulatory requirements and the needs of residents.
In the event of any material secondary legislation being introduced, a review will
take place in advance of the review period.
The review process will also enable us to assess how well we have delivered
against the priorities and targets set and identify areas for improvement. It will
also enable us to use feedback received from residents and latest best
practice to ensure that our Strategy for occupied higher risk buildings and
associated Delivery Plan remains fit for purpose.
6. Communication
6.1 Engagement strategies
In conjunction with residents the Council will co-create, document and publish
details on how all residents aged 16 years and over can participate in the
management of the building at a pace and level which suits them.
These tailored engagement strategies will support our overall approach to
transparency, information and accountability and the ‘social contract’ between
the Council and all residents residing in our higher risk buildings.
6.2 Tailored Fire Safety Information
All residents will be given a ‘Fire Safety Information Pack’. The content of the
pack will be explained to residents by their Housing Officer. All packs will be
tailored to individual tower blocks and individual property types.
‘Fire safety Information Packs’ will be reviewed and updated in the light of any
material changes to the building, Statutory / Regulatory changes and feedback
from residents.
We will agree with residents what information they would like us to publish and
make available on the Council’s website. This can include:
Full and summary versions of the Housing Management Offer to residents
living in our in-scope buildings
Service contracts – including a summary of specification, frequency and
compliance
Fire Risk Assessments – including due dates, completed dates and summary
outcomes
Building Registration and Building Assessment certification
Safety Case Reports – which document building safety risks and the steps
taken / being taken to reduce and control those risks
Mandatory occurrence reporting - specific issues which must be reported to
the Building Safety Regulator
Details of Accountable Persons who are responsible for ensuring that fire and
structural safety is being managed for each and every tower block
16
Fire safety concerns and complaints – details of how to raise fire safety
concerns, make a complaint and details of the complaints procedure operated
by the Building Safety Regulator
Dates for shared area inspections and the outcomes from shared area
inspections
6.3 Complaints
A tailored complaints handling process has been introduced by the Council for
residents living in tower blocks. This is to make sure effective action is taken
where concerns are raised in relation to building safety and compliance risks.
The Council will continue to work with residents to ensure this process:
Clearly defines a ‘relevant complaint’ associated with building safety risks and
compliance matters.
Sets out who can make a complaint and how.
States the timeframe to consider and responded to a complaint.
Sets out the circumstances when a complaint must be referred to the
Regulator [Health & Safety Executive] and
Commits to sharing information including the outcomes of ‘relevant
complaints’ with residents.
In its offer to residents living in tower blocks the Council has provided an element
within the complaints procedure that focuses on ‘building safety concerns’.
Residents can report and identify a specific tower block when reporting their
concerns. This feature within the complaints handling procedure allows for
notifications to be sent directly and immediately to the appropriate service team
for investigation, resolution and response. We will work with residents to review
formal complaints in order to influence how we deliver services and improve
outcomes for residents living in our in-scope buildings.
6.4 Resident Obligations
The Building Safety Act 2022, in addition to tenancy and lease conditions, place
obligations on the Council, tenants, leaseholders and other occupiers of in-scope
buildings. As owner and manager of the building the Council’s approach to
housing management is for all parties with a vested interest in building safety to
rely upon the ‘enforcement’ of rights and obligations as a last resort rather than a
first response. In all cases the Council’s preferred option is to work with residents
through a ‘social contract’ which reflects the rights, duties and obligations of all
parties to maintain safe, clean and well managed buildings and estate
environments. As building owner and manager, the Council accepts its full range
of statutory and contractual obligations associated with the management and
maintenance of in-scope buildings. Our housing management offer reflects the
Council’s commitment to all residents regarding its approach to meeting these
obligations. To support engagement in a ‘social contract’ it is also important that
tenants, leaseholders and other residents meet their obligations too. In order for
the Council to meet its obligations, it is important that all residents:
Provide access to the Council following reasonable notice for the purpose of
inspection, survey or to undertake work. This includes but is not limited to gas
and electrical safety testing
17
Keep in repair and proper working order any safety related item which is the
responsibility of the resident. In the case of leaseholders and leaseholders
who have sublet their flat, this will include gas and electrical installations
Take care not to interfere with, damage or allow to be damaged any safety
related item in the building
Cooperate in relation to the provision of relevant information needed by the
Council to assess risks and take reasonable steps to prevent major incidents
in the building
Refrain from storing any items on the internal shared areas of the building and
on private balconies which would add to the fire load
Participate in the management of the building and building safety decisions as
part of the Council’s engagement strategy with all residents
Gas Safety is important to everyone. This includes the Council in its capacity as a
landlord and building manager, resident leaseholders who have gas appliances
and gas heating and leaseholders who have sublet their flat and are therefore
also landlords. The implications associated with failures in gas safety can be
serious and far reaching. In the context of keeping everyone safe it is therefore
important that all residents and parties play their part.
The Gas Safety (Installation & Use) Regulations 1998 as amended deals with the
installation, maintenance and use of gas appliances, fittings and flues in domestic
premises. They place duties on landlords to ensure that gas appliances, fittings
and flues provided for tenants’ use are safe.
In summary terms the Council will require landlords to:
Ensure gas fittings and flues are maintained in a safe condition
Gas appliances must be serviced annually
Ensure an annual gas safety check is carried out on each appliance / flue
Inform tenants of where to turn off the gas and what to do in an emergency
Keep records of the gas safety check
Issue a copy of the latest safety check record to the existing tenant
All servicing and checks must be undertaken by an appropriate Gas Safe
Registered engineer.
Annual servicing to ensure that gas appliances, fittings and flues are in safe and
proper working order is equally important to resident leaseholders.
In order for the Council to meet its obligations it will:
Require all tenants to provide access to ensure that the annual gas service
can take place
Require all leaseholders who have sub-let their flat to provide the Council with
evidence each year that it has completed an annual gas safety check by a
Gas Safe registered engineer in their capacity as a landlord
Check with all sub-tenants to ensure that they have received a copy of the
latest gas check safety report
18
Require all resident leaseholders to show that they have had their gas
installations serviced each year by a Gas Safe registered engineer
British Standards – BS7671 require all electrical installations to undergo
Inspection and testing at regular intervals. The industry agreed standard is 5
years for rented property or a change of tenant. This requirement applies to the
Council in its capacity as a landlord and to leaseholders who have sub-let their
flats.
British Standards also require landlords to have a mains wired smoke detector
installed on the escape routes for each floor, a detector in the lounge (or principal
habitable room), and a mains wired heat detector in the kitchen. All landlords are
also required to ensure a carbon monoxide alarm is installed in every room where
there is a fixed combustion appliance (including a gas boiler). Where a new fixed
combustion appliance is installed, a carbon monoxide alarm will be required to be
installed by law.
Landlords are legally required to repair or replace smoke and carbon monoxide
alarms once they have been informed that they are faulty. Testing of alarms
remains the tenant’s responsibility.
6.5 Contravention Notice
The Housing Management Service will develop, and share with residents,
operational practices associated with the use of Contravention Notices.
The Building Safety Act 2022 gives Accountable Persons (APs) the power to
issue contravention notices to residents and owners of residential units who
breach their building safety duties. APs can also request access to premises to
carry out their duties. If necessary, a County Court can grant an order for access.
APs can issue contravention notices if they believe a resident or owner is:
Causing a building safety risk
Interfering with a safety item
Failing to comply with a request for information
The notice requires the recipient to remedy the breach or pay a sum within a
specified period
If the recipient is not the owner, the AP must provide a copy of the notice to
the owner
6.6 Digital Notice Boards
The Housing Management Service will work with residents to pilot and
potentially roll-out ‘digital notice boards’ across its tower block portfolio, save for
those blocks scheduled for demolition under the Hayes regeneration programme.
Engaging with and keeping residents informed in relation to key messages and
ensuring they are properly sign-posted in relation to core services is key to the
Council’s approach in ensuring that residents remain ‘fire safe’ and ‘fire aware’.
Under the Building Safety Act 2022 the Council has a statutory duty to bring
forward tailored Resident Engagement Strategies for each of its ‘higher risk’
buildings. Digital notice bords, with the potential for real time updates’ has
potential to support a tailored approach to the ongoing development of these
19
strategies in line with expectations laid down by both the Regulator of Social
Housing and the Building Safety Regulator.
Our rationale for piloting the installation of digital notice boards include:
Fire Safety information: regular updates on fire safety protocols, emergency
procedures and reminders for residents to check smoke alarms and not to use
for storage or clutter fire escape routes. Signposting residents to tailored
resources on the London Fire Brigade website.
Anti-Social Behaviour issues: Timely notifications about ongoing ASB
issues within the building including unauthorised entry, reporting procedures
[including when and how to report to the Police] and support resources for
affected residents.
Tenancy Management updates: reminders regarding applicable tenancy
conditions including access for gas and electrical compliance checks,
reminders regarding planned visits in relation to the housing management
offer for residents in ‘higher risk’ buildings, notifying change of circumstances
associated with vulnerability / ability to self-evacuate, upcoming meetings /
how to be involved and resources available for tenants to report ‘safety
related concerns.’
Repair and maintenance work notifications: including FAQ information
about planned work such as timelines and anticipated disruption, routine
servicing to active fire precautions and other installations such as lifts and
pumps to ensure residents are aware and prepared.
Governance
Effective from: 00/00/2025 Review Date: 00/00/2028
Policy Owner: Head of Housing Management
Policy Author: Housing Landlord Programme Manager and Accountable
Person
Approved by: Cllr Tuckwell – Cabinet Member for Planning, Housing &
Growth
Version Number: V0.01
20
Appendix 1: Schedule of ‘in scope buildings
Building Address Flats No of storeys
Harding House, Addison
Way, Hayes, Middx, UB3
2DH
Harding House 2-96
(evens)
13
Sutcliffe House, Addison
Way, Hayes, Middx, UB3
2DJ
Sutcliffe House 134-228
(evens)
13
Melbourne House,
Yeading Lane, Hayes,
Middx, UB4 9LJ
Melbourne House 1-96
13
Skeffington Court, 51
Silverdale Road, Hayes,
Middx, UB3 3BY
Skeffington Court 1-75
14
Wellings House, 236
Avondale Drive, Hayes,
Middx, UB3 3PN
Wellings House - 1-48
13
Fitzgerald House, 237
Avondale Drive, Hayes,
Middx, UB3 3PW
Fitzgerald House 1-48
13
Glenister House, 238
Avondale Drive, Hayes,
Middx, UB3 3PP
Glenister House 1-48
13
Fairlie House, Pantile
Walk, Uxbridge, Middx,
UB8 1LT
Fairlie House - 1-72
11
The Gouldings, Pantile
Walk, Uxbridge, Middx,
UB8 1LR
The Gouldings - 1-72
11
Rabbs Mill House, 14
Chiltern View Road,
Uxbridge, Middx, UB8
2PB
Rabbs Mill House 1-79
14
Cavenham Court, 18
Millington Road, Hayes,
Middx, UB3 4FZ
Cavenham Court 1 - 113 7
21
Appendix 2: Glossary of terms
Term or reference in Strategy Definition
‘In-scope’ and ‘higher risk’
buildings.
A residential building of at least 18m in height
or over 6 storeys, whichever is reached first
Building Safety Regulator The ‘Regulator’ in respect of duties and
responsibilities for ‘higher risk’ buildings is
the Health & Safety Executive
Principal Accountable Person
[PAP]
A position defined in law with statutory
responsibilities for occupied higher risk
buildings including fire and structural safety
Accountable Person [AP] A position defined in law with statutory
responsibilities for occupied higher risk
buildings. The post holder is answerable to
the Principal Accountable Person
Building Safety Certificate Are issued by the Regulator when satisfied
that the Council is fully compliant and has not
breached any relevant duty in respect of its
management of a ‘higher risk’ building
Tenancy Management Officer
[High Rise Living]
The Tenancy Management Officer (High Rise
Living) is the ‘point of contact’ responsible for
the delivery of a more intensive form of
housing management service to all residents
living in the Council’s tower block portfolio
Building safety risks These are safety related risks associated
with the building which must be identified,
regularly reviewed and effectively managed
Building Safety Case Report This report summarises the measures in
place to manage building safety risks and
demonstrates that the AP has taken “all
reasonable steps” to prevent and mitigate
those risks
Building Assessment Certificate After a higher-risk residential building (at
least 7 storeys or 18 metres high with 2 or
more residential units) in England is
registered, the Building Safety Regulator will
ensure the building’s Principal Accountable
Persons (PAPs) and Accountable Persons
(APs) are managing relevant risks and are
working to keep all residents safe.
22
The Building Safety Regulator will regularly
carry out assessments and, if all standards
are met, they will provide a Building
Assessment Certificate to those PAPs that
have been asked to apply for one.
The certificate aims to highlight the building’s
performance and show that the Accountable
Persons are correctly managing the
residential building. The certificate must be
displayed in an area where it can be
immediately visible by residents and visitors.
Residents’ Engagement Strategy Is a statutory plan produced by the owner
and manager of the’ higher risk’ building
which sets how all residents can participate
in the management of the building.
Building safety charge Is a statutory element within the service
charge payable by leaseholders which
relates to all costs associated with building
safety work
Stay put strategy A strategy based on the design principle that
only the residents of the flat of fire origin
need to escape initially, while other residents
may remain in their own flats unless their flat
is affected by smoke or fire, they feel
threatened, or they are instructed to leave by
the Fire & Rescue Service. A stay put
strategy does not preclude residents, who
are aware of a fire within a building but not
directly affected by it, from deciding to
evacuate.
Personal emergency evacuation
plan
[PEEP]
An evacuation is the process whereby people
leave the building in the event of an incident.
A rescue is where a person receives physical
assistance to get clear of the area involved in
the incident. A PEEP will be developed
where a person is unable to self-evacuate
unaided. The plan is intended to be executed
without relying upon intervention by the Fire
& Rescue Service
Personal Emergency Plan
[PEP]
Contains an assessment of risk [in the
context of fire safety] and a corresponding
mitigation plan to control or eliminate the
presenting risks identified.
23
Privacy Notice A document that the Council publishes to
explain how personal data relating to
residents is processed. It has two aims: to
promote transparency and to give individuals
more control over the way their data is
collected and used
Relevant Complaint Are Complaints associated with associated
with building safety risks and compliance
matters rather than day to day service
provision
24
Translations
If you would like to receive this information in another language please contact us on 01895 277
038
اگر آپ یہ معلومات کسی دوسری زبان میں حاصل کرنا چاہتے ہیں تو برائے مہربانی ہم سے
ٹیلیفون 01895 277 308 پر رابطہ کریں .
Urdu translation.
ਜੇ ਤੁਸ ੀਂ ਇਹ ਜਾਣਕਾਰ ਕਕਸੇ ਹੋਰ ਭਾਸਾ ਕਿਚ ਪ੍ਰਾਪ੍ਤ ਕਰਨਾ ਚਾਹੁੁੰਦੇ ਹੋ ਤਾੀਂ ਕਕਰਪ੍ਾ ਕਰਕੇ ਸਾਡੇ ਨਾਲ ਟੈਲ ਫੋਨ 01895 277
038 'ਤੇ ਸੁੰਪ੍ਰਕ ਕਰੋ .
Punjabi Translation.
જો તમે આ માહિતી બીજી ભાષામાાં પ્રાપ્ત કરવા માાંગતા િો, તો ક ૃ પા કરીને અમારો સાંપક ક કરો ટેહિફોન 01895
277 038
Gujrati traditional.
यदि आप यह जानकारी दकसी अन्य भाषा में प्राप्त करना चाहते हैं तो क ृ पया हमसे टेलीफोन 01895 277 038 पर
संपक क कर ें
Hindi
Hadii aad rabto macluumaad dheerad ah, oo habkale loo dhigey fadlan nala soo xidhiidh nambarka
01895 277 038
Somalia
Version: v0.01 February 2025
Text extracted automatically from the PDF, so layout, tables and images are not shown. Open the original PDF on LB Hillingdon’s website.