7. Housing Landlord Compliance - Report
Renfrewshire Council · 11 March 2025
Back to Communities and Housing Policy Board — 11 March 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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___________________________________________________________________ To: Communities and Housing Policy Board On: 11 March 2025 ___________________________________________________________________ Report by: Director of Environment, Housing, and Infrastructure ___________________________________________________________________ Heading: Housing Landlord Compliance ___________________________________________________________________ 1. Summary 1.1 All social landlords must ensure they meet all duties in relation to tenant and resident safety and have an effective system in place to ensure compliance with statutory, legislative and regulatory responsibilities. 1.2 This report presents the Housing Landlord Compliance Strategy 2025-2028, which sets out the strategic approach to compliance across the six key areas of compliance relating to Council Housing assets (gas safety, electrical safety, fire safety, lift safety, asbestos management and water safety). 1.3 The report also presents the first two of six policies associated with the Strategy – the Gas and Carbon Monoxide Safety Policy and the Electrical Safety Policy – which describe how Renfrewshire Council will meet the statutory, contractual, and regulatory requirements in relation to gas safety and electrical safety relating to our housing assets. 1.4 Details of an independent external review of the strategy and policies by the Social Housing Safety Network Scotland are included within the report. ___________________________________________________________________ 2. Recommendations It is recommended that the Communities and Housing Policy Board: 2.1 Approves the Housing Landlord Compliance Strategy 2025-2028, set out at Appendix 1 of this report; 2.2 Approves the Gas and Carbon Monoxide Safety Policy, set out at Appendix 2 of this report.
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2.3 Approves the Electrical Safety Policy, set out at Appendix 3 of this report. 3. Background 3.1 In October 2019, the Scottish Housing Regulator wrote to all registered social landlords to stress that “Social landlords must ensure that they meet all duties on tenant and resident safety and that they obtain appropriate assurance about their compliance with all relevant safety requirements”. 3.2 In 2020, the Director of Communities, Housing and Planning commissioned an external consultancy, Savills, to undertake a high-level review of the management and delivery of landlord compliance obligations within Housing Services. The review identified recommendations for improvement in relation to evidence, validation, and assurance across the six main areas of compliance; gas safety, electrical safety, fire safety, lift safety, asbestos management and water safety. 3.3 A key recommendation from this review was for a Landlord Compliance Strategy and a suite of landlord specific compliance policies for the six areas to be developed. 3.4 The strategy and associated policies were completed in 2021 and are subject to three yearly review. An internal review of both the electrical and gas safety policies was completed which was followed up with an independent external review, the feedback from which has been Incorporated into the strategy and policies. The remaining four policies will be reviewed in 2025 and brought to future meetings of the Communities and Housing Policy Board for approval as each of the reviews are completed. 3.5 The independent external review has been undertaken by Ryan Hodgson of the Social Housing Safety Network Scotland, who provided feedback in January 2025. Mr Hodgson is suitably qualified to conduct such a review and is the appointed policy and procedure specialist for The Network providing policy reviews, feedback and up-dates, re-writes, development and support for a number of other social housing providers across Scotland. The following strategy and policies were submitted to the network to be reviewed: Housing Landlord Compliance Strategy Electrical Safety Policy Gas and Carbon Monoxide Safety Policy To summarise the feedback received, the Social Housing Safety Network has stated: From the documents received, which relate to two of the “big 6” compliance areas (electrical safety and gas safety) we can provide the following observations and opinions:
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The four-tiered structure of the documents reviewed (strategy/policy/management plan/guidance) is geared for the size and complexity of the organisation in terms of stock structure workstreams and assets. Each layer of documentation contains further levels of cascaded detail in relation to each workstream and to satisfy the level of detail required from Governance and management levels down to detailed day to day operational management. The documents reviewed were generally well written and contained good useful levels of operational detail. The feedback given to Renfrewshire Council included areas for consideration whereby additional detail could be added to further strengthen the existing documents. Some areas of the policy, management plan and guidance were replicated throughout the documents and suggestions were made to potentially remove some of the repetition to make the documents more streamlined and succinct. Due to the internal delivery of work at Renfrewshire Council it is advised to consider stating this within the scope to enable the reader to differentiate responsibilities between oversight and delivery of the “Big 6” compliance work. 4. Housing Landlord Compliance Strategy and Policies 4.1 The overarching Housing Landlord Compliance Strategy is set out in Appendix 1 of this report. The purpose of the strategy is to have an effective system in place to ensure compliance with statutory, legislative and regulatory responsibilities. The strategy outlines the framework in place including suitable resources, policies, procedures and processes, data management and control protocols, performance management and quality assurance. 4.2 The Gas and Carbon Monoxide Safety Policy is set out in Appendix 2 of this report, outlining how the commitment to gas and carbon monoxide safety will be met and how assurance of compliance will be provided to the duty holder. The policy sets out the scope, processes, data management and performance monitoring. Performance on gas compliance is already reported to the Scottish Housing Regulator and to the Policy Board in our twice yearly ARC performance reports. In addition to this, it is proposed that a more detailed report will be brought to the Communities and Housing Policy Board bi- annually in May and October. 4.3 The Electrical Safety Policy is set out in Appendix 3 of this report, outlining how the commitment to electrical safety will be met and how assurance of compliance will be provided to the duty holder. The policy outlines the scope, processes, data management and performance monitoring. Performance on electrical compliance is already reported to the Scottish Housing Regulator and to the Policy Board in our twice yearly ARC performance reports.
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In addition to this, it is proposed that a more detailed report will be brought to the Communities and Housing Policy Board bi-annually in May and October. 4.4 The Annual Assurance Statement for 2024 noted that policy board members would be supported with training on landlord compliance matters. A briefing session took place on 11th February for policy board members, which provided an overview of the six main areas of compliance in relation to tenant and resident safety in social housing (gas, electrical, water, fire, lifts and asbestos). The session was led by Vicki Cutler, CFIOSH, MIIRSM, MIFSM, CMgr FCMI, CIHM who is a sector leader in health and safety, particularly tenant and resident safety, Vicki has over 20 years experience in social housing and has worked with many social landlords across the UK, and co-founded the Social Housing Safety Network Scotland of which Renfrewshire Council are members. 4.5 The following policies will be reviewed in 2025 and brought to future Communities and Housing Policy Board meetings. Fire Safety Policy Asbestos Safety Policy Lift Safety Policy Water Safety Policy ___________________________________________________________________ Implications of the Report 1. Financial – Employee costs associated with the Housing Landlord Compliance team and maintenance costs associated with carrying out statutory and regulatory compliance works are included within the Housing Revenue Account (HRA) approved budget each year. 2. HR & Organisational Development – None. 3. Community/Council Planning – Our Renfrewshire is safe – ensuring tenants have a safe place to live. To manage risk to for staff, contractors or members of the public within council housing properties. 4. Legal – None. 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.
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No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and 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 - None. 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. COSLA Policy Position – None. 13. Climate Risk – None. 14. Children’s Rights – No negative impacts on children’s rights have been identified arising from the recommendations contained in the report. ___________________________________________________________________ List of Background Papers Appendix 1 – Housing Landlord Compliance Strategy 2025- 2028 Appendix 2 – Housing Gas & Carbon Monoxide Safety Policy Appendix 3 – Housing Electrical Safety Policy ___________________________________________________________________ Author: Karen Sillars, Housing Asset & Investment Manager Email: karen.sillars@renfrewshire.gov.uk
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1 Housing Landlord Compliance Strategy 2025 - 2028
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Housing Landlord Compliance Strategy 2025 - 2028 2 Table of Contents 1. Purpose and Scope ............................................................................ 3 2. Framework ......................................................................................... 3 3. Resources ........................................................................................... 4 4. Housing Landlord Compliance Policies ............................................ 4 5. Procedures and Processes ................................................................. 5 6. Data Management and Control Protocols ......................................... 5 7. Performance Management ................................................................ 6 8. Quality Assurance .............................................................................. 7
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Housing Landlord Compliance Strategy 2025 - 2028 3 1. Purpose and Scope 1.1 The purpose and scope of this Housing Landlord Compliance Strategy is to: Establish and maintain an effective system to plan and deliver housing landlord compliance activities, to manage risk to our customers, staff, contractors and third parties in residential premises owned or managed by Renfrewshire Council. Ensure compliance with the statutory, legislative and regulatory responsibilities of Renfrewshire Council as a landlord and employer and for which the Director of Environment, Housing and Infrastructure is the ‘Duty Holder’ and to provide reasonable assurance to officers, elected members and all relevant stakeholders that this is the case. 1.2 This strategy, its supporting housing landlord compliance policies and subsequent management plans are applicable to: All domestic properties within the Housing Revenue Account All non-domestic properties within the Housing Revenue Account (Offices, Shops, Lockups, Laundrettes) 1.3 Where properties are leased from, and managed on behalf of, third party property owners, statutory responsibility will be detailed within the terms of the lease / management agreement. Where the statutory responsibility lies with the property owner, Housing Services must check that the appropriate certifications and any other relevant Housing Landlord Compliance documentation is in place and be given assurance that they are safe in advance of occupation and use. 2. Framework 2.1 This strategy is based upon an interdependent framework, comprising of: Resources A suite of Housing Landlord Compliance Policies Procedures and Processes (within the Management Plans and Operational Guidance) to deliver each Housing Landlord Compliance Policy Data and Management Control Protocols Performance Management (Monitoring and Reporting) Quality Assurance
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Housing Landlord Compliance Strategy 2025 - 2028 4 Fig 1 3. Resources 3.1 The Director of Environment, Housing and Infrastructure and the Head of Housing Services will ensure that the organisation’s internal staffing structure and any external resources engaged on Housing Services behalf, includes the appropriate people, skills and levels of competence to meet the Housing Landlord Compliance obligations and requirements. 4. Housing Landlord Compliance Policies 4.1 A suite of Housing Landlord Compliance Policies will be maintained and regularly reviewed to ensure that statutory, legislative and regulatory requirements are met. 4.2 The ‘Big Six’ Compliance Policies will be developed and appended to the Housing Landlord Compliance Strategy, as follows: Appendix 1 – Gas Safety Policy Appendix 2 – Electrical Safety Policy Appendix 3 – Asbestos Management Policy Appendix 4 – Fire Safety Policy Strategy and Resourcing Policies Procedures and Processes Data Management / Control Performance Management Quality Assurance
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Housing Landlord Compliance Strategy 2025 - 2028 5 Appendix 5 – Water Safety Policy Appendix 6 – Lift Safety Policy 4.3 Additional Housing Landlord Compliance Policies will be developed in line with new legislative requirements and recommended practice. 4.4 All of the Housing Landlord Compliance Policies will include: (i) A Statement of Intent (commitments) (ii) An outline of the relevant statutory, legislative and regulatory standards and obligations involved (iii) Objectives (iv) Details of the specific high-level key performance indicators (KPIs) to be used to monitor and report upon the status of service delivery. 5. Procedures and Processes 5.1 A Management Plan will be in place for each area of Housing Landlord Compliance, incorporating procedures and processes to ensure consistency of approach in the delivery of Housing Landlord Compliance responsibilities. 5.2 These procedures will provide clear guidance on Housing Services’ approach to: (i) Delivery (ii) Roles and Responsibilities (iii) Performance Standards (iv) Controls (v) Performance Reporting (vi) Assurance. 5.3 Process maps will detail the key end-to-end processes mapped-out in a simple, logical, and easy to interpret format. 5.4 Housing will monitor the implementation of the Management Plans through a series of performance reports. 6. Data Management and Control Protocols 6.1 Housing’s core database (OHMS or any future replacement database) will contain all asset information and the appropriate asset hierarchy to enable effective management of all housing landlord compliance areas. 6.2 The core database and associated databases (e.g EDM) will contain all key asset and property data including the key attributes that require management to ensure
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Housing Landlord Compliance Strategy 2025 - 2028 6 that Renfrewshire is compliant for every asset e.g. gas supply, lifts, fire risk assessments etc. 6.3 A consistent hierarchy will be established between the core database and all other databases (including, if operated, spreadsheets) to ensure that all records are aligned to the master and updates are managed accordingly via agreed, written protocols. 6.4 All amendments to the core database (addition of new assets, demolition, sale and disposal of assets, changes to the type of tenure etc.) will be effectively managed and documented in line with the approved data protocols. This is to ensure that all changes are fully reflected within the specific datasets, which establish the total landlord requirement for each of the housing landlord compliance activity/risk areas. 7. Performance Management 7.1 Housing Landlord Compliance Policies and Management Plans will ensure visibility of performance reporting and the status of delivery of Renfrewshire Council’s housing landlord compliance obligations and requirements – with such performance reporting allowing the monitoring and scrutiny of (and, if necessary and required, challenge to) service delivery at the appropriate levels. 7.2 Reports on the status of housing landlord compliance activities will be at appropriate frequencies and to the following key audiences within Renfrewshire Council in accordance with our internal governance framework as detailed below: Fig 2 Head of Housing Services Director of Environment, Housing and Infrastructure Housing Services Senior Management Team (SMT) Corporate Management Team (CMT) Audit and Risk Scrutiny Committee Communities and Housing Policy Board KPI Report Quarterly Quarterly Bi-annually Bi-annually Bi-annually Bi-annually (May and October)
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Housing Landlord Compliance Strategy 2025 - 2028 7 8. Quality Assurance 8.1 Appropriate Independent External Audit (IEA) arrangements will be established to test the quality of Renfrewshire Council’s housing landlord compliance service delivery outputs across all areas of activity. The scope of external audit will include reviewing the policies to ensure compliance with existing legislation and testing of the management plan to ensure the organisation is operating as it has set out within the documentation. This is to provide the Director of Environment, Housing and Infrastructure as duty holder, with reasonable assurance that activities and risks are being managed effectively and, in a manner, consistent with this strategy and its associated policies and procedures/processes (Management Plans). 8.2 An Internal Audit Programme (IAP) will also test areas of housing landlord compliance following approval of the Management Plans – and a ‘rolling’ IAP will be established based on the level of risk. The frequencies will be decided by Internal Audit and will be subject to review based upon an ongoing assessment and reconsideration of risk (being varied, for example, in response to a particular incident or series of incidents should they occur). 8.3 This quality assurance process will have a clear and explicit linkage to Renfrewshire Council’s Corporate Risk Register. 8.4 An overall compliance report will be prepared annually for Communities and Housing Policy Board and Audit, Risk and Scrutiny Board confirming the outcomes of both internal and external quality assurance checks as they relate to Housing Landlord Compliance. This reporting will include any changes and improvements made to Housing Services’ approach based on these outcomes, including any proposed revisions to/updating of this Housing Landlord Compliance Strategy and its associated supporting policies.
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8 Environment, Housing and Infrastructure Renfrewshire Council Renfrewshire House Cotton Street Paisley PA1 1BR
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1 Housing Landlord Compliance Gas and Carbon Monoxide Safety Policy
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Gas and Carbon Monoxide Safety Policy 2 Table of Contents 1. Introduction ....................................................................................... 4 2. Statement of Intent ............................................................................ 4 3. Policy .................................................................................................. 6 3.2 Process: ................................................................................................. 6 3.3 Delivery: ................................................................................................. 6 3.4 Additional Safety Measures: Smoke, Heat and CO Detection ............... 8 3.5 Contractors Competency: ..................................................................... 8 3.6 Internal Competency: ............................................................................ 9 3.7 Data: ...................................................................................................... 9 3.8 Assurance: ........................................................................................... 10 3.9 Communication: ................................................................................ 11 4. Implementation ............................................................................... 11 5. Consultation .................................................................................... 11 6. Equality Impact Analysis (EIA) .......................................................... 11 7. Monitoring Performance .................................................................. 12 8. Policy Review ................................................................................... 13 9. Amendment Log/Version Control .................................................... 13
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Gas and Carbon Monoxide Safety Policy 3 10. APPENDIX A ...................................................................................... 14
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Gas and Carbon Monoxide Safety Policy 4 1. Introduction 1.1 At the time of policy approval Renfrewshire Council owns and manages in the region of 12,200 residential properties for let. Approximately 89% of these properties have gas appliances installed. 1.2 Communal gas boiler systems, electric heating and hot water systems, renewable energy systems (air or ground source heat pumps) or communal biomass systems, serve the remainder. Renfrewshire has a responsibility to maintain all installations and appliances owned by it, to the required statutory, legislative and regulatory standards. 1.3 This policy explains how the safety and maintenance requirements for gas appliances and installations (and those of other fuel types covered by this policy) within the housing stock will be met. Individual gas safety and carbon monoxide procedures and processes are contained in the associated gas and carbon monoxide safety management plan. 1.4 It will also cover how Renfrewshire Council’s Director of Environment, Housing and Infrastructure as Duty Holder, will receive assurance of statutory, legislative and regulatory compliance. 2. Statement of Intent 2.1 This Policy covers domestic appliances and communal and district heating systems including Gas-Fired, Solid Fuel (including biomass), Oil-Fired, Air and Ground Source Heat Pumps, Solar Thermal hot water. It also covers properties with a gas supply or a readily available gas supply (but no gas appliances) and other activities that are undertaken at the same time as servicing / inspection of the above appliances. 2.2 Maintenance of other forms of Electric-only Heating will be covered within the Electrical Safety Management Plan. 2.3 Renfrewshire will comply with all current and relevant legislation and specifically as detailed in the following: Health and Safety at Work Act (HASAWA) 1974, The Housing (Scotland) Act 1987, 2001, 2010 & 2014 The Gas Safety (Installation and Use) Regulations 1998 (GSIUR) and Gas Safety (installation and use) (amendment) Regulation 2018 Gas Safety (Management) Regulations 1996,
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Gas and Carbon Monoxide Safety Policy 5 Approved Code of Practice L56 (Fifth Edition) ‘Safety in the Installation and Use of Gas Systems and Appliances’ 2018 British Standards, Building (Scotland) Regulations. HETAS guidance (solid fuel systems). HASAWA 1974 and Housing (Scotland) Act 2010 may be applied. L122 Approved Code of Practice (ACOP) – Pressure Systems Safety Regulations. The Gas Industry Unsafe Situations Procedures (GIUSP). Safety in the Installation and use of Gas Systems and Appliances. IGEM/ G/ 11 The current Gas Industry Unsafe Situations Procedures (GIUSP). L80: A Guide to the Gas Safety (Management) Regulations 1996. 2.4 Renfrewshire Council also acknowledges its further obligations under the Acts, regulations and guidance noted in Appendix A. 2.5 In addition, as a landlord and provider of social housing, Renfrewshire Council must meet the requirements of the Scottish Housing Regulator’s (SHR) regulatory standards. 2.6 It is our duty under HASAWA 1974, as an employer to ensure, so far as reasonably practicable, the health, safety and wellbeing at work of all employees. This duty also extends to others such as tenants, visitors to our buildings, members of the public and contractors who could be put at risk through any work activity within our premises. Failure to properly discharge our statutory, legal or regulatory responsibilities may also result in: Prosecution by the Health and Safety Executive under Health and Safety at Work Act 1974. Prosecution under Corporate Manslaughter and Corporate Homicide Act 2007. Possible fines and imprisonment. Civil claims.
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Gas and Carbon Monoxide Safety Policy 6 SHR’s scrutiny and potential determination of a breach of Regulatory Standards and serious detriment having been caused/potentially caused. Reputational damage. Loss of confidence by stakeholders in the organisation. 3. Policy 3.1 In order to comply with statutory, legislative and regulatory standards and obligations, and to ensure the safety of our customers, tenants, residents, employees, contractors and other visitors to our properties, Renfrewshire will: 3.2 Process: Provide clear lines of responsibility for all appliances and heating systems within the scope of this policy supported by written guidance in the Gas and Carbon Monoxide Safety Management Plan. Ensure that a clear and consistent process including front-line engagement and enforcement is in place to obtain access to properties to conduct the safety checks and works, which shall include legal action when required. Assess available data for relevant information about the customer to help gain access (disability, vulnerability, local connections, etc.). Maintain a process for dealing with gas safety and carbon monoxide unsafe situations in accordance with the Gas Safety Regulations (IGEM/G/11 Edition 2 – Gas industry unsafe situations procedure with amendments July 2022 and June 204) and associated fuel types. 3.3 Delivery: Target that all domestic properties with gas appliances, gas supplies, solid fuel or oil-fired appliances have a valid landlord gas safety record (LGSR/CP12) and/or solid fuel (HETAS) or oil safety (OFTEC) certificate. Inspect all properties with air source, ground source and solar thermal heating/hot water annually and obtain appropriate documentation.
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Gas and Carbon Monoxide Safety Policy 7 All other properties with potential to have a gas supply will be subject to an annual check to confirm that no gas supply has been installed. This will not include properties in blocks with no gas infrastructure (e.g. blocks which are confirmed as 100% electric or biomass heating). Landlords do not have a legal responsibility for carrying out a safety check or maintenance to gas appliances owned by the tenant/s. However, at the time of the annual safety check, Renfrewshire Council will also check all tenant owned gas appliances, chimneys or flues that a tenant’s own appliance uses for safety. This will be done by means of: o A visual risk assessment check in line with Gas Safety (Installation and Use) 2018 - Regulation 26(9) and in line with GIUSP and Technical Bulletin TB055. o Application of the relevant Environment, Housing and Infrastructure Gas Safety Procedures. This is in order to comply with other legislation such as HASAWA 1974 and Housing (Scotland) Act 2010, and to ensure any works completed by the tenant that may have been undertaken since the last safety check are identified. Any safety critical faults found on a tenant-owned appliance will result in the appliance being isolated and disconnected from the gas supply and the tenant informed. Renfrewshire will not be liable for repairs to tenant owned appliances. Ensure, where required, that communal/district systems have a Written Scheme of Examination. Target that all communal/district systems are inspected and serviced in accordance with manufacturer’s requirements and the Written Scheme, but in any event at intervals of not more than 6 months and have a valid Landlord Gas Safety Record (LGSR). Disconnect and cap-off the gas supply at the meter and make safe upon a property becoming void. When the property is then re-let, the gas supply is reconnected and a new gas safety inspection will take place, with the issue of a new gas safety certificate (LGSR). If a property is void for more than a 12-month period a service/inspection visit will be made on or before the anniversary date to ascertain that the gas supply is still capped and disconnected (unless the gas has been terminated at the highway outside the property by the transporter and we are in receipt of a disconnection certificate).
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Gas and Carbon Monoxide Safety Policy 8 Prioritise defects and remedial works arising from gas safety checks and apply a timescale for action, as detailed within the Gas and Carbon Monoxide Safety Management Plan. 3.4 Additional Safety Measures: Smoke, Heat and CO Detection Install carbon monoxide Detectors in all properties where required – as detailed within the Gas and Carbon Monoxide Management Plan – and test these on an annual basis in conjunction with the annual safety inspection visits and record this test on the Landlord Gas Safety Record (or other applicable record/certification). Test smoke and heat alarms, where fitted, in conjunction with the annual safety inspection visits and record this test on the Landlord Gas Safety Record (or other applicable record/certification). Ensure there is an ongoing programme for life cycle replacement of all carbon monoxide detectors and smoke and heat alarms to meet current Scottish Government standards. Neither install, nor give permission for tenants to install, gas fires, wood burning stoves or open fires. Any unauthorised installations will be required to be removed by Renfrewshire Council’s appointed contractor at the tenant’s own expense. Other tenant alterations should be subject to prior notification, agreement and appropriate landlord’s permission from Housing to proceed before they are undertaken – as is required by the tenancy Agreement. Permission will not be unreasonably withheld. 3.5 Contractors Competency: Only engage with suitably qualified contractors to undertake work on gas installations, in accordance with the obligations of the Construction (Design and Management) Regulations 2015 Regulation 4 (6) – Gas Safe registered companies and Gas Safe registered engineers, with the appropriate Nationally Accredited Certification Scheme (ACS) to undertake any gas-related works.
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Gas and Carbon Monoxide Safety Policy 9 Ensure that contractors working with solid fuel appliances are competent to do so and hold current HETAS qualification and registrations, and those engaged in respect to oil-fired appliances are similarly OFTEC registered. Ensure that contractors working with air/ground source heat pumps hold BPEC Level 3 Award in the Installation and Maintenance of Heat Pump Systems or equivalent. Ensure that contractors working with solar/thermal systems hold BPEC Level 3 Award in the Installation and Maintenance of Solar Thermal Hot Water Systems. Ensure that contractors working with solar PV systems hold BPEC Solar PV Installation and Maintenance or equivalent. Carry out an assessment of all contractor competencies annually or at change of contract /contractor, as detailed within the Gas and Carbon Monoxide Safety Management Plan. 3.6 Internal Competency: Maintain a Skills/Training Matrix, through the Individual Development Plan (IDP) process, to ensure that all staff undertaking key roles within the scope of this policy have appropriate training. 3.7 Data: Maintain an up-to-date master database of all properties that have a gas supply including those that may not have a live gas supply but can be readily connected to the gas grid. Maintain an up-to-date master database of all properties that are served by a communal solid fuel (including biomass) heating system. Maintain an up-to-date master database of all properties with air source heat pumps ground source heat pumps, solar/thermal heating/hot water. For each relevant property, record and maintain up to date data confirming which of the appliances within the scope of this policy exist and do not exist and the organisation’s associated responsibility.
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Gas and Carbon Monoxide Safety Policy 10 Where a requirement exists, hold data and certification relating to at a minimum the last two safety checks and the next due date. Note that Building Services as a Gas Safe registered company are required to keep the records for 6 years. Where a requirement does not exist hold appropriate evidence. Maintain current and up to date records of remedial works for the entire portfolio, which will detail all recommendations from the safety checks. These records will include (i) Address and risk profile of property, (ii) Detail of the work item required, (iii) Priority and target completion dates/s, (iv) Person responsible, (v) Date of when the work was completed and (vi) Who it was signed-off by, (vii) Evidence of completion. 3.8 Assurance: Ensure that all persons involved with the installation, inspection, servicing and maintenance of Gas, Solid Fuel, Oil and Renewable Technology systems are competent to do so. This would include evidence and confirmation of persons being properly trained and accredited in accordance with this policy. Where necessary, operate a Permit to Work system when safety- critical work is being carried out near to appliances and flues by engineers that are not Gas Safe registered/HETAS or OFTEC approved. Carry out works-based assurance activity – including checks on certification and post-inspection of on-site works – to the level stated within the Gas and Carbon Monoxide Safety Management Plan. A proportion of such checks will be carried out by an Independent 3rd Party. Set a timetable for the review of the Gas and Carbon Monoxide Safety Policy and the associated management plan.
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Gas and Carbon Monoxide Safety Policy 11 3.9 Communication: Encourage customers, through the provision of publicity information on the importance of gas and other heating safety, to allow access to carry out safety checks and maintenance works. 4. Implementation 4.1 This policy will be effective from the date of approval by the Communities and Housing Policy Board. 4.2 Staff will be made aware of the policy through appropriate training and a copy will be available on the intranet. The policy will also be uploaded to the Renfrewshire Council website. 4.3 This policy should also be read in conjunction with the Housing Landlord Compliance Strategy and the associated Gas and Carbon Monoxide Safety Management Plan. 4.4 Appropriate training will be provided for all those staff involved with the operational delivery and implementation of the Housing Landlord Compliance requirements and obligations in respect to Gas and Carbon Monoxide Safety detailed within this Policy. 5. Consultation 5.1 This Policy is based on statutory, legislative and regulatory requirements and, as such, consultation with customers has not taken place. There has been consultation with internal teams within Renfrewshire Council. 6. Equality Impact Analysis (EIA) 6.1 We believe all people should be treated with dignity and respect regardless of their Age, Disability, Gender Gender reassignment,
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Gas and Carbon Monoxide Safety Policy 12 Race, Religion and belief, Pregnancy and maternity Marriage and civil partnership Sexual orientation or by association with someone with any of these characteristics or perception of having any of these characteristics. 6.2 An Equalities Impact Assessment was undertaken to identify the likely or actual effects of this policy. This includes identifying where there will be a positive impact and further opportunities to further promote equality. Where there are any potential negative impacts identified, we have identified actions required to eliminate or mitigate these negative impacts. (see the full EIA document for full details) 7. Monitoring Performance 7.1 The following KPIs will be subject to reporting: Number of times in current reporting year Renfrewshire failed to meet statutory obligation to complete a gas safety check within 12 months of a gas appliance being fitted or last checked (Charter Indicator 11) % of properties (against the stated total landlord requirement) with a valid LGSR within the past 12 months. % of properties (against the stated total landlord requirement) with other heating types covered by this Policy with a valid certificate within the relevant period. % of Communal/District Boilers (against the stated total landlord requirement) with valid certification within the relevant period. 7.2 Commentary will be provided for any properties out of date, to include the date they became overdue, days overdue and their position within the access legal process to bring them back into a compliant position. Additional context commentary will also include information on the proportion of activities within the reporting period that were undertaken before and after their due date. 7.3 A detailed Performance Indicator suite will be defined within the associated Gas and Carbon Monoxide Safety Management Plan. 7.4 The following Quality Assurance (QA) activity will be undertaken and reported in line with the Gas and Carbon Monoxide Safety Management Plan: Internal audit. Strategic review. 3rd Party assurance.
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Gas and Carbon Monoxide Safety Policy 13 8. Policy Review 8.1 The Policy will be reviewed every 36 months or earlier if deemed necessary though the Performance Monitoring process. 9. Amendment Log/Version Control 9.1 Revision Detail/Record: Date of Revision: Record of Amendments: Reason for Revision: 25/11/24 Changes recorded in tracked document held on file Updated legislation and changes to council department names, updates to processes 4/02/25 Changes recorded and held on file Feedback from SHSN – minor changes.
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Gas and Carbon Monoxide Safety Policy 14 10. APPENDIX A List of further legislation and regulations Management of Health and Safety at Work Regulations 1999 Equality Act 2010 The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (2013) (RIDDOR) Scottish Social Housing Charter (SHQS) Pressure Systems Safety Regulations 200 The Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEARR) Construction, (Design and Managemen) Regulations 2015 The Workplace (Health, Safety and Welfare) Regulations 1992 Guidance leaflet INDG285 (rev 3): A Guide to Landlord's Duties Technical bulletins and industry safety alerts (Gas safe) The Corporate Manslaughter and Corporate Homicide Act 2007 The Association of Independent Chimney Sweeps’ Code of Practise Control of Substances Hazardous to Health Regulations 2002 Control of Asbestos Regulations (CAR) 2012 Provision and Use of Work Equipment Regulations 1998 The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (2013) (RIDDOR) HETAS guidance (solid fuel systems) L122 Approved Code of Practice (ACOP) – Pressure Systems Safety Regulations The Gas Industry Unsafe Situations Procedures (GIUSP) Scottish Social Housing Charter (SHQS) Pressure Systems Safety Regulations 2000 The Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEARR) Construction, (Design and Management) Regulations 2015 The Workplace (Health, Safety and Welfare) Regulations 1992 Technical bulletins and industry safety alerts (Gas safe) The Corporate Manslaughter and Corporate Homicide Act 2007 L80: A Guide to the Gas Safety (Management) Regulations 1996 The Association of Independent Chimney Sweeps’ Code of Practise Control of Substances Hazardous to Health Regulations 2002 Control of Asbestos Regulations (CAR) 2012 Provision and Use of Work Equipment Regulations 1998
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15 Environment, Housing and Infrastructure Renfrewshire Council Renfrewshire House Cotton Street Paisley PA1 1BR
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1 Housing Landlord Compliance Electrical Safety Policy
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Electrical Safety Policy 2 Contents 1. Introduction ....................................................................................... 4 2. Statement of Intent ............................................................................ 4 2.3.1 Testing of Fixed Wiring Systems ........................................................ 4 2.3.2 Portable Appliance Testing................................................................ 4 2.3.3 Powered Doors, Gates and Barriers ................................................... 5 2.3.4 Lightning Protection Systems ............................................................ 5 3. Policy .................................................................................................. 5 3.2 Process ............................................................................................... 5 3.3 Delivery .............................................................................................. 6 3.3.1 Fixed Wire Testing .............................................................................. 6 3.3.2 Portable Appliance Testing ............................................................... 7 3.3.3 Automated Doors, Gates and Barriers ............................................... 7 3.3.4 Lightning Protection Systems ............................................................ 7 3.3.5 Solar PV .............................................................................................. 8 3.4 Additional Safety Measures ............................................................... 8 3.5 Contractors Competency ................................................................... 8 3.6 Internal Competency ......................................................................... 8
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Electrical Safety Policy 3 3.7 Data .................................................................................................... 9 3.8 Assurance ........................................................................................... 9 3.9 Communication ................................................................................. 9 4. Implementation ................................................................................. 9 5. Consultation .................................................................................... 10 6. Equality Analysis (EA) ....................................................................... 10 7. Monitoring Performance .................................................................. 10 8. Policy Review ................................................................................... 12 9. Amendment Log .............................................................................. 12 10. APPENDIX A ...................................................................................... 13
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Electrical Safety Policy 4 1. Introduction 1.1 At the time of Policy approval Renfrewshire Council (Renfrewshire) owns and manages in the region of 12,200 residential properties for let. 1.2 Electrical installations and equipment within housing stock and communal areas managed by Renfrewshire need to be kept safe and regularly inspected and maintained. 1.3 This policy explains how Renfrewshire’s commitment to electrical safety will be met. It will be supported by an Electrical Safety Management Plan providing more detailed guidance and procedures. 1.4 It will also cover how Renfrewshire Council’s Director of Environment, Housing and Infrastructure as Duty Holder, will receive assurance of statutory legislative and regulatory compliance. 2. Statement of Intent 2.1 The key objective of this policy is to describe how Renfrewshire will meet the statutory, contractual and regulatory requirements in relation to electrical safety. 2.2 The scope of this policy includes:- fixed wire testing portable appliance testing automated doors, gates and barriers lightning protection systems. Solar PV 2.3 Renfrewshire will comply with all current and relevant legislation; specifically, as detailed in the following; 2.3.1 Testing of Fixed Wiring Systems The IET 18th Edition of the Wiring Regulations BS7671:2018+A2:2022 The Electricity at Work Regulations 1989 (EAWR) Building (Scotland) Regulations. 2.3.2 Portable Appliance Testing Section 2.2 of the Health & Safety at Work Act 1974 (HSWA) requires employers as far as is reasonably practicable to “provide and maintain plant and systems of work that are safe and without risk to health. Plant covers any machinery, equipment or appliances including portable appliances.”
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Electrical Safety Policy 5 2.3.3 Powered Doors, Gates and Barriers The Health and Safety at Work Act (1974) sections 3 and 4 place a duty to ensure the health and safety of users, so far as is reasonably practicable; Supply of Machinery (Safety) Regulations 2008 and BSEN 12453:2001 2.3.4 Lightning Protection Systems Detailed in BS EN 62305:3:2011: ‘Protection against Lightning – Physical damage to structures and life hazard’ and its subsequent amendments. Section 7 and E7 of the British Standard (BS EN 62305:3:2011) sets out the requirements for maintenance and inspections of lightning protection systems. 2.4 Renfrewshire Council also acknowledges its further obligations under the Acts, regulations and guidance noted in Appendix A. 2.5 In addition, Landlords and providers of Social Housing must meet the requirements of the Scottish Housing Regulator’s (SHR) Regulatory Standards. 2.6 It is essential to ensure customers, tenants, residents, employees, contractors and visitors remain safe in Renfrewshire premises (both individual homes and offices). Failure to properly discharge our legal responsibilities may result in: Prosecution by the Health and Safety Executive under Health and Safety at Work Act 1974 Prosecution under the Corporate Manslaughter and Corporate Homicide Act 2007 SHR’s scrutiny and potential determination of a breach of Regulatory Standards and serious detriment having been caused/potentially caused. Reputational damage Loss of confidence by stakeholders in the organisation 3. Policy 3.1 In order to comply with regulations, standards and guidance, and to ensure the safety of its customers, tenants, residents, employees, contractors and other visitors to our properties, Renfrewshire will: 3.2 Process I. Provide clear lines of responsibility for the management of fixed wiring systems; portable appliance testing; powered doors, gates and barriers;
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Electrical Safety Policy 6 lightning protection systems; and photovoltaic systems supported by written guidance in the Electrical Safety Management Plan. II. Ensure that a clear and consistent process including front-line engagement and enforcement is in place to obtain access to properties to undertake electrical safety checks, which shall include legal action when required. III. Assess available data for relevant information about the customer to help gain access (disability, vulnerability, local connections, etc.) IV. Maintain a process for dealing with defects in line with standards and guidance. 3.3 Delivery 3.3.1 Fixed Wire Testing I. Ensure all communal areas hold a valid Electrical Installation Condition Report (EICR) within the cycle specified by the competent person undertaking the test but, in any event, at intervals not exceeding 5 years. II. Ensure inspections and testing of fixed wiring systems within domestic properties takes place on a 5 year cycle (or sooner if recommended by the competent person undertaking the test). Hold a satisfactory EICR for all properties. III. Ensure all domestic electrical installations are tested and certified prior to letting. IV. If a property remains unoccupied for a period exceeding 12 months following its last test, a further EICR will be completed prior to occupation. Further EICRs will also be considered for properties unoccupied for less than 12 months should a risk of deterioration or damage to the fixed wiring electrics be identified. V. In addition to checking all installations maintained by Renfrewshire, inspect any electrical work carried out by the tenant at the same time. Any works found to be unsafe, or not complying with regulations will be disconnected and made safe appropriately at the time of inspection. VI. Certain tenant-own works will be allowed to be left in situ, such as light fixings and switches which have been appropriately installed and deemed safe for continued use by the competent person completing the inspection.
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Electrical Safety Policy 7 VII. Prioritise remedial works arising from fixed wire testing and apply a timescale for action, as detailed within the Electrical Safety Management Plan. VIII. All C1 (immediately dangerous) works will be made safe at the time of the inspection and testing. IX. All C1, C2 and FI (further investigation) works identified at the time of inspection and testing, should be completed in line with the ‘Urgent’ response repairs timescale. (30 days). X. A property will only be considered compliant once evidence and certification is provided that all C1 and C2 works are resolved. 3.3.2 Portable Appliance Testing I. Risk assess all appliances provided by Renfrewshire Housing which are used by employees, residents, customers, and visitors. II. Undertake Portable Appliance Testing (PAT) at a frequency arising from the risk assessed schedule as per the Code of Practice for In-service Inspection and Testing of Electrical Equipment. III. Renfrewshire will retain appropriate documentation. IV. Establish a cycle of subsequent re-testing at the time of the first test. 3.3.3 Automated Doors, Gates and Barriers I. Detail the frequency of inspections and procedures within the Electrical Safety Management Plan, but as a minimum this will be on an annual basis. II. Renfrewshire will retain appropriate documentation. 3.3.4 Lightning Protection Systems I. Carry out inspection and testing on an 11-month rolling basis to ensure that inspection and testing under different climatic conditions. II. Renfrewshire will retain appropriate documentation.
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Electrical Safety Policy 8 3.3.5 Solar PV I. Check systems annually in accordance with the Electrical Safety Management Plan. II. Renfrewshire will retain appropriate documentation. 3.4 Additional Safety Measures I. Require that tenant installations should be subject to prior agreement before works are undertaken. II. Any unauthorised installations deemed to be unsafe will be disconnected and remedial works, where required, will be carried out at the tenant’s own expense and by Renfrewshire’s appointed contractor. 3.5 Contractors Competency I. Only engage with suitably qualified electrical contractors to undertake work on electrical installations. (The National Inspection Council Electrical Installation Contractors (NICEIC) or equivalent.) II. Expect that contractors shall demonstrate that all engineers engaged in work for Renfrewshire shall meet the required standard of training. III. Only engage with suitably qualified and competent lightning protection systems specialist contractors to undertake work on lightning protection systems and shall be a member of ATLAS (The Association of Technical Lightning & Access Specialists). IV. Require a Microgeneration Certification Scheme (MCS) accreditation for those engaged with solar photovoltaic systems. V. Carry out an assessment of all contractor competencies as detailed within the Electrical Safety Management Plan. Our in-house service provider, Building Services, who carry out the majority of our domestic EICRs are responsible for ensuring that staff have appropriate training. 3.6 Internal Competency I. Maintain a skills/training matrix, through the Individual Development Plan (IDP) process, to ensure that all staff undertaking key roles within the scope of this policy have appropriate training.
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Electrical Safety Policy 9 3.7 Data I. Maintain up to date records of all properties where they have a responsibility to provide electrical safety checks and maintenance, including testing of fixed wiring systems, portable appliances, powered doors, gates and barriers, lightning protection systems and photovoltaic systems. II. Where a requirement exists hold data and certification relating to the last two EICRs and record the next due date III. Maintain current and up to date records of remedial works for all properties which will detail all recommendations from the fixed wire testing. IV. The records will include; address and risk profile of the property, detail of the work item required, priority and target completion, person responsible, when the work was completed, who it was signed off by and evidence of completion 3.8 Assurance I. Ensure that all persons involved with the installation, inspection and servicing of electrical systems and appliances are properly trained and accredited. II. Carry out works-based assurance activities including checks on certification and post-inspection of onsite works to the level stated within the Electrical Safety Management Plan. A proportion of such checks will be carried out by an independent party. III. Set a timetable for the review of the Electrical Safety Policy and the associated Electrical Safety Management Plan. 3.9 Communication I. Encourage customers, through the provision of publicity information, to allow access to carry out EICRs, other safety checks and inspections and remedial works. 4. Implementation 4.1 The policy and any revisions will be effective from the date of approval by Communities and Housing Policy Board.
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Electrical Safety Policy 10 4.2 Staff will be made aware of the policy through appropriate training and a copy will be available on Renfrewshire’s intranet. The policy will be uploaded to the Renfrewshire Council web site. 4.3 This policy should also be read in conjunction with the Housing Landlord Compliance Strategy and Electrical Safety Management Plan. 4.4 Appropriate training will be provided for all those staff involved with the operational delivery and implementation of the Housing Landlord Compliance requirements and obligations in respect of Electrical Safety detailed within this Policy. 5. Consultation 5.1 This policy is based on statutory, legislative and regulatory requirements and, therefore, consultation with customers has not taken place. There has been consultation with Internal Teams within Renfrewshire. 6. Equality Analysis (EA) 6.1 We believe all people should be treated with dignity and respect regardless of their Age, Disability, Gender Gender reassignment, Race, Religion and belief, Pregnancy and maternity Marriage and civil partnership Sexual orientation by association with someone with any of these characteristics or perception of having any of these characteristics. 6.2 An Equalities Impact Assessment was undertaken to identify the likely or actual effects of this policy. This includes identifying where there will be a positive impact and further opportunities to further promote equality. Where there are any potential negative impacts identified, we have identified actions required to eliminate or mitigate these negative impacts. 7. Monitoring Performance 7.1 The following Key Performance Indicators (KPIs) will be reported:
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Electrical Safety Policy 11 % of Domestic Properties having a valid Electrical Installation Condition Report (EICR) within the cycle No of domestic properties with outstanding C1 or C2 works % of Portable Appliance Testing (PAT) completed within required date % of automated doors risk assessed /serviced within required date % of automated gates and barriers risk assessed /serviced within required date % of Lightning Conductors inspected and tested within required date. % of Communal Areas / Commercial Properties having a valid Electrical Installation Condition Report (EICR) within the cycle No of Communal Areas/Commercial Properties with outstanding C1 and C2 works 7.2 Satisfactory reports shall mean that all immediately and/or potentially dangerous faults have been resolved. 7.3 Commentary will be provided for any properties out of date to include the date they became overdue, days overdue, and their position within the access legal process to bring them back into a compliant position. 7.4 Commentary will also be provided if any properties have outstanding overdue actions. 7.5 Additional context commentary will also include information on the proportion of activities within the reporting period that were undertaken before and after their due date. 7.6 A detailed Performance Indicator (PI) suite will be defined within the Management Plan. 7.7 The following assurance activity will be undertaken and reported in line with the Management Plan: Internal audit Strategic review 3rd Party Assurance
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Electrical Safety Policy 12 8. Policy Review 8.1 The policy will be reviewed every 36 months or earlier if deemed necessary though the performance monitoring process. 9. Amendment Log Date of revision: Record of amendments: Reason for revision: 11.11.24 Changes recorded and held on file Updated legislation, changes in Council Department names, updates to processes. 4.02.25 Changes recorded and held on file Feedback from SHSN – minor changes
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Electrical Safety Policy 13 10. APPENDIX A List of further legislation and regulations The Health and Safety at Work etc. Act 1974, The Housing (Scotland) Act 2010 and The Housing (Scotland) Act 2014. The Management of Health and Safety at Work Regulations 1999 Guidance note 3 (inspection and testing) The Electrical Equipment (Safety) Regulations 2016 The Scottish Social Housing Charter The Tolerable Standard Building Standards (Scotland) Regulations 2014 Corporate Manslaughter and Corporate Homicide Act 2007. Scottish Government - Building Standards. Technical Handbook 2009 Domestic Environment Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR 2013) The Workplace (Health, Safety & Welfare) Regulations 1992 Health and Safety (Safety Signs and Signals) Regulations 1996 Provision and Use of Work Equipment Regulations 1998 Construction, (Design and Management) Regulations 2015 Personal Protective Equipment Regulations 1992 The Code of Practice for In-Service Inspection and Testing of Electrical Equipment (ISITEE) INDG236: ‘Maintaining portable electrical equipment in offices and other low risk environments’ ‘Landlords’ Guide to Electrical Safety Scotland 2017’. HSR25 The Electricity at Work Regulations 1989, Guidance on the regulations. IET Guidance Notes 1-8 Electricity at work – Safe working practices HSG85 Keeping electrical switchgear safe HSG230 Maintaining portable and transporting electrical equipment HSG107 Avoiding dangers from underground services HSG47 The IET Code of Practice for in service inspection and testing 2013
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15 Environment, Housing and Infrastructure Renfrewshire Council Renfrewshire House Cotton Street Paisley PA1 1BR