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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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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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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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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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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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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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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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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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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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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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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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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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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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• 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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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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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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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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Environment, Housing and Infrastructure
Renfrewshire Council
Renfrewshire House
Cotton Street
Paisley
PA1 1BR