Housing Landlord Compliance – Damp and Mould Policy - Report
Renfrewshire Council · 18 August 2026
Back to Communities and Housing Policy Board — 18 August 2026 and its agenda
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PUBLIC __________________________________________________________________ To: Communities and Housing Policy Board On: 18th August 2026 ___________________________________________________________________ Report by: Director of Environment, Housing and Infrastructure ___________________________________________________________________ Heading: Housing Landlord Compliance – Damp and Mould Policy ___________________________________________________________________ 1. Summary 1.1 Social landlords are required to ensure that all duties in relation to tenant and resident safety are met and that effective systems are in place to ensure compliance with statutory, legislative, and regulatory obligations. 1.2 The Housing Landlord Compliance Strategy 2025-2028, which sets out the strategic approach to compliance across the key areas of compliance relating to Council Housing assets was approved at the Communities and Housing Policy Board on 11th March 2025 with six associated policies also subsequently presented and approved at Board. 1.3 The Housing Landlord Compliance Strategy 2025–2028 included a commitment to develop additional compliance policies in response to emerging legislative requirements and best practice. This report presents the proposed Damp and Mould Policy, which sets out how Renfrewshire Council will meet its statutory, contractual and regulatory obligations in relation to the management of damp and mould within Council housing stock. The policy has been developed to ensure compliance with the requirements of the Investigation and Commencement of Repair (Scotland) Regulations 2026, which come into force on 6 October 2026. 1.4 The report also outlines the additional resources that have been put in place within Housing Services to support compliance with the new regulatory requirements and the effective implementation of the policy. ___________________________________________________________________
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PUBLIC 2. Recommendations It is recommended that the Communities and Housing Policy Board: 2.1 Approves the Damp and Mould Policy, set out at Appendix A of this report. 2.2 Notes the additional resources established within Housing Services to support delivery of the policy and compliance with the new regulatory requirements. 3. Background 3.1 The Housing Landlord Compliance Strategy set out how Renfrewshire Council as a landlord and employer, complies with the statutory, legislative and regulatory responsibilities of Renfrewshire Council and to provide reasonable assurance to officers, elected members and all relevant stakeholders that this is the case. 3.2 The Damp and Mould Policy has been developed in response to new Scottish Government regulations implementing Awaab's Law. The legislation is named after Awaab Ishak, a two-year-old child who tragically died in 2020 from a respiratory condition linked to prolonged exposure to mould within his family's social housing property in England. The Investigation and Commencement of Repair (Scotland) Regulations 2026 will come into force on 6 October 2026 and place new duties on both social and private landlords in relation to the assessment and remediation of damp and mould. 3.3 A review of the current Housing Repairs and Maintenance Service, which is responsible for responding to damp and mould cases, has been undertaken to assess its capacity to meet the enhanced requirements arising from the new regulations. The review identified a need for additional dedicated resources to support compliance and service delivery to meet the requirements of the new regulations. 4. Housing Landlord Compliance Policies – Damp and Mould 4.1 The proposed Damp and Mould Policy is attached as Appendix A to this report. The policy sets out Renfrewshire Council's commitment to preventing, identifying and addressing damp and mould within its housing stock and describes how compliance will be achieved and monitored. The policy establishes the framework for managing damp and mould risks and includes the policy scope, guiding principles, roles and responsibilities, operational processes, data management arrangements and performance monitoring requirements.
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PUBLIC 4.2 During 2025/26, the Council resolved 361 damp and mould cases within its housing stock. These cases were managed through the existing resources within the Housing Repairs and Maintenance Service. In recognition of both the volume of cases and the additional demands arising from the new regulatory framework, a dedicated Damp and Mould Team is now being established to ensure sufficient resources are in place to manage all reports of damp and mould within our housing stock and ensure compliance with the new regulations. 4.3 The new team will provide a specialist service focused on the effective management of damp and mould cases and delivering outcomes for affected tenants. The team will also play a key role in the monitoring of Council housing through the use of environmental sensors, supporting the early identification of damp and mould risks and helping to determine underlying causes. This targeted approach will strengthen compliance arrangements while enabling the existing team of Repairs and Maintenance Officers to focus on wider general repairs activities. The dedicated team will comprise: • 1 Housing Condition Manager (Damp and Mould) • 3 Repairs and Maintenance Officers; and • 1 Damp and Mould Case Officer. The effectiveness and capacity of the new structure will be kept under review as the impact of the new regulatory requirements becomes clearer and service demand is assessed. 4.4 Performance against the three new Damp and Mould Key Performance Indicators (KPIs) introduced by the Scottish Housing Regulator will be reported through the Annual Return on the Scottish Social Housing Charter and included in the annual performance report presented to the Communities and Housing Policy Board each May. . The KPIs measure: • the average time taken to resolve damp and mould cases, • the percentage of resolved damp and mould cases that are subsequently reopened, and • the number of damp and mould cases that remain open at the year end. In addition, a range of damp and mould performance indicators will be developed and refined in line with the new Scottish Government guidance and legislative requirements due to come into effect from October 2026, ensuring that performance monitoring and reporting arrangements remain compliant with national standards and reflect emerging best practice. _________________________________________________________________
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PUBLIC Implications of the Report 1. Financial – Employee costs associated with the Damp and Mould team and maintenance costs associated with carrying out statutory and regulatory compliance works will be funded through the Housing Revenue Account (HRA) and incorporated within the long-term HRA Business Plan as a permanent budget commitment. The additional resource requirement is driven primarily by increased statutory and regulatory obligations relating to damp and mould management and the need to ensure the Council is appropriately resourced to comply with emerging legislative requirements 2. HR & Organisational Development – Recruitment of new posts to the Damp and Mould team. 3. Community/Council Planning – • Our Renfrewshire is safe – ensuring tenants have a safe place to live. 4. Legal –The policy has been developed to support compliance with the Investigation and Commencement of Repair (Scotland) Regulations 2026. While no direct legal implications arise from approval of the policy, the implementation of the new statutory requirements may increase demand for legal advice and support and could result in an increased volume of disrepair- related claims or defences as tenant awareness of their rights increases. 5. Property/Assets - Ensuring assets are protected from risk. 6. Information Technology - None. 7. Equality & Human Rights - (a) The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. There is a positive impact on particular vulnerability groups that will be prioritised in line with the policy. The results of the assessment will be published on the Council’s website. 8. Health & Safety - The strategy and policies align with the Council’s Corporate Health and Safety Policy. 9. Procurement – None. 10. Risk - The absence of policies could put the Council at risk of failing to comply with statutory duties for landlord compliance and could be reputationally damaging. . 11. Privacy Impact – None. 12. Climate Risk – A Climate Change Impact Assessment has been completed. No impact has been identified.
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PUBLIC 13. Children’s Rights – There is a positive impact on particular vulnerability groups such as children that will be prioritised in line with the policy. 14. Cosla Policy Position – None. ___________________________________________________________________ List of Background Papers Appendix A – Housing Damp and Mould Policy ___________________________________________________________________ Author: Karen Sillars, Housing Asset & Investment Manager Email: karen.sillars@renfrewshire.gov.uk
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1 PUBLIC DAMP AND MOULD POLICY Policy Owner: Housing Asset & Investment Team Version: 1.2 Approval Date: July 2026 Review Date: July 2029
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2 PUBLIC Contents 1. Introduction ............................................................................................................. 3 2. How to report Damp and Mould .............................................................................. 3 3. Purpose .................................................................................................................. 3 4. Scope ...................................................................................................................... 4 5. Definitions ............................................................................................................... 4 6. Key Principles ......................................................................................................... 5 7. Roles and Responsibilities ...................................................................................... 5 8. Responding to Reports of Damp and Mould ........................................................... 6 9. Timescales for responding to reports of Damp and Mould ...................................... 6 10. Tenant Rights and Compensation ........................................................................ 7 11. Investigation .......................................................................................................... 8 12. Remedial Actions .................................................................................................. 8 13. Tenant Support and Advice ................................................................................... 9 14. Tenants Requiring Enhanced Support .................................................................. 9 15. Preventing Damp and Mould .............................................................................. 10 16. Data Management .............................................................................................. 10 17. Monitoring and Performance Management ......................................................... 11 18. Complaints and Escalation ................................................................................. 11 19. Training, Competence and Contractor Management .......................................... 12 20. Equality, Diversity and Human Rights ................................................................. 12 21. Policy Review ..................................................................................................... 12 22. Alternative formats .............................................................................................. 12
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3 PUBLIC 1. Introduction Renfrewshire Council is committed to providing safe, warm, dry, and habitable homes that are free from unacceptable levels of damp and mould. The Council recognises the significant impact these conditions can have on tenants’ health, wellbeing, and quality of life. It will take a proactive, preventative and rigorous approach, to the prevention, identification and resolution of these conditions. The Investigation and Commencement of Repair (Scotland) Regulations 2026 comes into force on 6 October 2026. This policy establishes the Council's approach to meeting the requirements of those Regulations and complying with the wider statutory and regulatory framework, including: • Housing (Scotland) Act 2001 • Housing (Scotland) Act 2006 • Housing (Scotland) Act 2025 • Scottish Secure Tenants (Right to Repair) Regulations 2002 • Investigation and Commencement of Repair (Scotland) Regulations 2026 • Equality Act 2010 • Human Rights Act 1998 • Data Protection Act 2018 • UK GDPR ________________________________________________________________________ 2. How to Report Damp and Mould This document sets out Renfrewshire Council’s policy in relation to damp and mould in houses managed by Renfrewshire Council. Damp or mould in houses managed by Renfrewshire Council can be reported by: • Telephoning the repair line: 0300 300 0300 • Using the freephone Repairs Direct phones which are located within Johnstone Town Hall and Paisley Customer Service Centre • Email: repairs@renfrewshire.gov.uk • Online services: www.myaccount.renfrewshire.gov.uk or scan the QR code below: Note – A “MyAccount” log in is required to use our online services. ________________________________________________________________________
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4 PUBLIC 3. Purpose The purpose of this policy is to enable the Council to: • Prevent and manage damp and mould effectively. • Provide clear response times and service standards. • Ensure properties are maintained to a high standard through the delivery of efficient and effective repair and maintenance services. • Have a focussed approach to the prevention, treatment and resolution of damp and mould, with better data and improved reporting and identification. • Provide assurance that measures are in place to identify, manage and mitigate risks associated with damp and mould; and • Comply with legal duties, regulatory requirements and good practice standards. ________________________________________________________________________ 4. Scope This policy applies to: • All properties owned or managed by the Council; this includes any properties where the Council has repair responsibilities. • All tenants, members of their household and occupants of these properties. • All staff, contractors, and partner organisations involved in the management and maintenance of these properties. ________________________________________________________________________ 5. Definitions Condensation The process whereby warm, moist air forms water droplets on colder surfaces. Damp The presence of excessive moisture in a building structure, including: • Rising damp (moisture rising from the ground due to missing or failed damp protection) • Penetrating damp (water entering due to external defects through walls/roof/gutters or building defects) • Condensation-related damp
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5 PUBLIC Mould Fungal growth resulting from excess moisture, often appearing as black, green, or white patches and spread through airborne spores. ________________________________________________________________________ 6. Key Principles In implementing this policy, the Council will: • Operate a proactive and rigorous approach to damp and mould. • Respond in compliance with The Investigation and Commencement of Repair (Scotland) Regulations 2026. • Take a whole-property (fabric-first) approach. • Prioritise health and vulnerability. • Ensure early intervention and prevention. • Diagnose the root-cause rather than treating visible symptoms only. • Invest in prevention and long-term solutions • Ensure transparency and clear communication ________________________________________________________________________ 7. Roles and Responsibilities The Council, its contractors and tenants are responsible for the implementation of this policy as set out below: Renfrewshire Council Communities and Housing Policy Board • Approve policy and oversee performance. Renfrewshire Council Environment, Housing and Infrastructure Service • Conduct appropriate investigations to identify the root cause(s) of damp and mould, using specialist surveyors where required. • Maintain clear, timely communication with tenants throughout the investigation and remediation of the damp and mould case. • Use technology such as humidity or environmental sensors to monitor moisture levels where appropriate and ensure appropriate ventilation is installed. • Train staff to identify damp and mould and understand effective remedies. • Provide guidance to tenants on how to prevent, manage and report damp and mould. • Ensure compliance, resourcing and performance monitoring and reporting. Contractors • Deliver works in line with this policy and required standards.
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6 PUBLIC Tenants • Report damp/ mould promptly to the Council using the contact details provided within this policy. • Provide access for inspections and works. • Engage with advice and support offered. • Work with the Council by following advice and guidance where appropriate. • Use ventilation systems properly and report faults quickly. • Allow sensors to be installed to monitor property conditions as appropriate • Follow professional guidance provided on ventilation and heating where appropriate. ________________________________________________________________________ 8. Responding to Reports of Damp and Mould When the Council receives a report of damp and/or mould in one of the houses it manages, it will: • Keep tenants informed at all stages. • Explain findings and actions clearly. • Provide a named contact for ongoing cases. • Ensure communication is accessible and inclusive. ________________________________________________________________________ 9. Timescales for responding to reports of Damp and Mould Emergency Safety Concerns Where a report indicates an immediate risk to health or safety, the Council will act in accordance with the Housing Repairs Policy and relevant emergency repair timescales. Investigation The Council or its appointed contractors will visit properties and investigate within 10 working days of being notified, beginning the day after the date it was made aware of the issue. Investigations will be undertaken by a competent person, and all findings will be documented and risk assessed. Written Summary The Council will provide a written summary of findings to the tenant within 3 working days of completion of investigation, beginning the day after the investigation is completed. This will include whether the repair is a qualifying repair (e.g. substantial damp or mould), the expected cause of damp/mould, any relevant safety work or repair required, including anticipated timescales for completion and the name, address and telephone number of the primary contractor and at least one other listed contractor from the list of contractors maintained by the landlord.
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7 PUBLIC Commencement and Completion of Works Following investigation, if substantial damp or mould is determined, any repair work required will commence within 5 working days, beginning the day after the investigation was completed. The Council is required to complete any qualifying repairs within a maximum of 20 working days from the date the repair is reported or identified during an inspection. Delays Where the Council is unable to meet these timescales for reasons beyond its control, the Council will advise the tenant in writing setting out the reasons for the delay and the expected timescale for compliance with the above timescales. Until it can comply with the above timescales, the Council will ensure that reasonable steps are taken where practicable to minimise the extent to which the house is affected by damp or mould. Suspension The statutory investigation and repair commencement timescales may be suspended where circumstances beyond the landlord's control prevent access, inspection, investigation or commencement of works. In such cases, tenants will be advised in writing of the reason for the suspension, the expected timescale for progressing the case, and any practicable interim measures to mitigate the effects of damp and mould. ________________________________________________________________________ 10. Tenant Rights and Compensation Tenants have rights under the Scottish Secure Tenants (Right to Repair) Regulations 2002 and associated legislation. Where the Council is required by legislation to investigate, commence or complete repairs within prescribed timescales, tenants may be entitled to compensation if these timescales are not met. The Council will: • Inform tenants of any statutory rights relating to repairs and compensation. • Comply with the Scottish Secure Tenants (Right to Repair) Regulations 2002 and any subsequent amendments. • Process any compensation payments due in accordance with legislative requirements and Council procedures. • Provide information on how tenants can request a review where they believe repair obligations have not been met. ________________________________________________________________________
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8 PUBLIC 11. Investigation The Council will undertake a property investigation when an issue relating to damp and mould is reported. The investigation will involve a comprehensive assessment which may include the following: • Building fabric condition (walls, roof, windows) • Insulation levels • Ventilation systems (extractors, passive vents) • Heating provision • Moisture levels and humidity readings The investigation will attempt to identify root causes of damp and mould, not just symptoms. ________________________________________________________________________ 12. Remedial Actions The Council will take appropriate remedial action to address damp and mould issues identified within its housing stock. The type and extent of works undertaken will be determined by the nature, severity and underlying cause of the problem. Actions may include, but are not limited to the following: Monitoring and Assessment • Installation of environmental monitoring sensors, where appropriate. • Follow-up property inspections to assess conditions and review the effectiveness of remedial measures. • Ongoing monitoring of identified cases to ensure issues have been resolved. Short-Term Measures • Mould washing and specialist mould treatment. • Provision or installation of temporary ventilation equipment or dehumidifiers. • Provision of temporary heating solutions where required. • Completion of minor repairs to address immediate concerns and prevent further deterioration. Long-Term Solutions • Structural repairs, including works to roofs, external walls, pointing, damp-proof courses and other building elements. • Installation or improvement of insulation measures to reduce condensation risk. • Installation, repair or enhancement of ventilation systems.
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9 PUBLIC • Replacement of windows or other building components where these contribute to damp and mould issues. • Consideration of wider investment and improvement programmes where recurring or systemic issues are identified. • The Council will seek to remedy the underlying cause of damp and mould and will not rely solely on cleaning, decoration or mould washing where structural or environmental defects remain unresolved. 13. Tenant Support and Advice The Council recognises that effectively addressing damp and mould requires both property improvements and appropriate tenant support. The Council will: • Provide clear, accessible information and guidance on preventing and managing moisture, condensation and ventilation within the home. • Offer practical advice and support tailored to the individual needs and circumstances of tenants and household members. • Signpost tenants to relevant services, including energy advice, fuel poverty support, financial inclusion services and health and wellbeing resources. • Work collaboratively with tenants to identify and implement measures that help reduce the risk of damp and mould occurring or recurring. • Ensure advice and information are provided in a clear, sensitive and accessible manner, taking account of any vulnerabilities or support needs. ________________________________________________________________________ 14.Tenants Requiring Enhanced Support The Council recognises that some households may be disproportionately affected by damp and mould due to health conditions, age, disability or other circumstances. Tenants should inform the council if they consider themselves to be disproportionately affected by damp and mould. The Council will take a person-centred approach and prioritise cases where occupants may be at greater risk from the impacts of damp and mould. Prioritisation measures may include: • Accelerated response and inspection times. • More frequent monitoring and follow-up visits. • Enhanced communication and support throughout the investigation and remediation process. • Consideration of temporary decant or rehousing arrangements where this is necessary to protect the health, safety or wellbeing of occupants. • Coordination with relevant support services and partner agencies, where appropriate.
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10 PUBLIC This approach will be applied based on individual circumstances and assessed risk, ensuring that those most affected receive timely and appropriate support. ________________________________________________________________________ 15. Preventing Damp and Mould In addition to responding to reported damp and mould issues, the Council will take a proactive approach to identifying and preventing damp and mould within its housing stock. Stock Condition Surveys • The Council will undertake periodic stock condition surveys to identify signs of damp, mould, condensation, water ingress and any contributing factors. • Where issues are identified, findings will be recorded and appropriate follow-up action arranged. Follow-Up Visits • Follow-up visits may be carried out where damp and mould issues have been identified to monitor conditions and assess the effectiveness of remedial actions. • Staff undertaking these visits will be trained to recognise signs of damp, mould and potential underlying causes. Data Monitoring and Analysis • The Council will record and analyse damp and mould cases to identify trends, recurring issues and property types that may be more susceptible. • This information will be used to inform inspections, repairs, planned investment programmes and tenant guidance. Empty Homes and Re-Lets • Vacant properties will be inspected for damp, mould and any contributing defects before being re-let. • Any identified issues will be investigated and appropriate remedial works completed prior to the commencement of a new tenancy. Planned Investment • Damp and mould trends and risk information will be used to inform future capital investment programmes, including insulation, ventilation and energy efficiency improvements. ________________________________________________________________________ 16. Data Management The Council will maintain detailed records of all damp and mould cases and use this to monitor repeat reports and trends. Data will also be used to inform asset management and investment planning, and to identify properties at higher risk of damp and mould and act proactively to address damp and mould in these properties.
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11 PUBLIC Records will be maintained in accordance with data protection legislation and the Council's records management arrangements. ________________________________________________________________________ 17. Monitoring and Performance Management Performance against the three new Damp and Mould Key Performance Indicators (KPIs) introduced by the Scottish Housing Regulator will be reported through the Annual Return on the Scottish Social Housing Charter and included in the annual performance report presented to the Communities and Housing Policy Board each May. . The KPIs measure: • the average time taken to resolve damp and mould cases, • the percentage of resolved damp and mould cases that are subsequently reopened, and • the number of damp and mould cases that remain open at the year end. In addition, a range of damp and mould performance indicators will be developed and refined in line with the new Scottish Government guidance and legislative requirements due to come into effect from October 2026, ensuring that performance monitoring and reporting arrangements remain compliant with national standards and reflect emerging best practice. Performance is reported to the Communities and Housing Policy Board twice a year. ________________________________________________________________________ 18. Complaints and Escalation Tenants can raise complaints by visiting www.renfrewshire.gov.uk/complaints . The Council will: • Investigate promptly and fairly in line with target timescales • Provide clear responses • Use outcomes to improve service delivery ________________________________________________________________________
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12 PUBLIC 19. Training, Competence and Contractor Management Staff Competence Relevant staff will receive training to ensure compliance with legislation and best practice on: • This policy and its implementation • Identification and diagnosis of damp and mould • Resident engagement and vulnerability awareness Contractor Competence Contractors will be assessed as part of the procurement, tender evaluation and contract renewal process, and whenever there is a change of contractor or contract arrangements. The Council will monitor contractor performance throughout the contract period to ensure required standards are maintained. ________________________________________________________________________ 20. Equality, Diversity and Human Rights We will deliver services that are: • Fair, inclusive, and accessible • Responsive to individual needs • Compliant with equality legislation An equalities impact assessment has been undertaken for this policy and is available on the Renfrewshire Council website: www.renfrewshire.gov.uk ________________________________________________________________________ 21. Policy Review This policy will be reviewed every 3 years, or sooner if: • Legislation or regulatory guidance changes • Learning from cases indicates changes are required • New best practice emerges ________________________________________________________________________ 22. Alternative formats This document can be made available in a range of languages and formats, including large print, Braille, audio and accessible format. Please contact us by phoning: 0300 300 0222 to discuss your needs.
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13 PUBLIC Environment, Housing and Infrastructure Renfrewshire Council Renfrewshire House Cotton Street Paisley PA1 1BR