8. Housing Landlord Compliance – Bi-annual Performance Report
Renfrewshire Council · 13 May 2025
Back to Communities and Housing Policy Board — 13 May 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Page 1
___________________________________________________________________ To: Communities and Housing Policy Board On: 13 May 2025 ___________________________________________________________________ Report by: Director of Environment, Housing, and Infrastructure ___________________________________________________________________ Heading: Housing Landlord Compliance – Bi-annual Performance Report ___________________________________________________________________ 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 The Housing Landlord Compliance Strategy 2025-2028 was approved by the Policy Board on 11th March 2025 and Section 7 of the strategy provided details of the internal governance arrangements for performance management, which includes a bi-annual report to be presented to the Communities and Housing Policy Board. 1.3 This report is the first bi-annual performance report for the twelve-month period from April 2024 to March 2025. ___________________________________________________________________ 2. Recommendations It is recommended that the Communities and Housing Policy Board: 2.1 Notes the content of the Landlord Compliance Performance Report and the suite of Key Performance Indicators (KPIs) at Appendix 1 of the report.
Page 2
_________________________________________________________ 3. Background 3.1 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) was approved by the Communities and Housing Policy Board on 11th March 2025. 3.2 There are six landlord compliance policies in place to support the Housing Landlord Compliance Strategy, each with a suite of key performance indicators and detailed performance reporting arrangements which include a bi-annual report to the Communities and Housing Policy Board. Each of the policies is reviewed on a regular basis and further policies will be created for any new areas of compliance regulation that are introduced. 3.3 Following a review of housing compliance which was undertaken by Savills consultancy in 2020/21, it was recommended that a dedicated compliance team be established within Housing Services. Prior to this team being created, responsibility for housing compliance was complex, with various services across the Council having different elements of responsibility. The housing compliance team structure was developed and the majority of posts filled during 2023/24. The Statutory Compliance Data Officer post is vacant and expected to be filled in 2025. The structure of the team is set out below: 3.4 Staying informed about changes in legislation or regulations in relation to housing compliance is essential and this is achieved through subscribing to industry newsletters, participating in training sessions and workshops, engaging with other local authorities and utilizing online resources that provide updates on legislation and best practice.
Page 3
Renfrewshire Council joined the Social Housing Safety Network (Scotland) in November 2023 which, as an organisation dedicated to tenant and resident safety in Scotland, provides a forum for keeping members updated and aware of changes to legislation, regulations or regulator requirements with the opportunity to share resources and knowledge. The housing compliance team also actively engage with the Council’s Health and Safety Team and participate in corporate compliance related working groups. 3.5 Data management is a key aspect of the statutory compliance team and due to the multiple systems in place for recording information and a reliance on manual record keeping for some data, it is essential that robust audit arrangements are in place. The Housing Innovations Project (HIP) to replace the housing management system is expected to significantly enhance and assist the data management for compliance with this phase of the system anticipated to go live in mid-2027. The compliance team carry out their own audits on data and are seeking to engage external agencies to carry out further audit checks. 4. Housing Landlord Compliance Performance Report 4.1 The first bi-annual housing Landlord Compliance Performance Report 2024/25 is set out in Appendix 1 of this report. There are 26 key performance indicators covering the six compliance areas. 23 indicators showing greater than 85% compliance. Of these 18 (69%) are indicating greater than 99% compliance. 5 we have designated as amber status showing compliance between 85-98% compliance and 3 (12%) designated as a red status indicating a compliance level lower than 85%. All compliance indicators rated amber or red have actions in place for improvement. The 3 indicators with red status are: Common area Electrical Installation Condition Report (EICR) Re-inspections of common areas with asbestos containing materials Actions outstanding from notices received from Scottish Fire and Rescue Services These areas are prioritised for improvement during 2025/26 with actions already underway to achieve full compliance which are set out in each of the relevant paragraphs below in section 4.2. All indicators will be continually reviewed and it is expected that additional indicators will be added in line with recommended practice. 4.2 The key points to note for each area of compliance are as follows: Gas Safety The Council are required to carry out annual gas safety inspections on all 10469 residential properties that have a gas supply.
Page 4
Within 2024/25 there were 5 properties where the gas service was not completed within the 12-month timescale. All five are now complete. Instances where services are not complete within the 12-month timescale are always investigated to determine the reason and assess whether any lessons can be learned to prevent similar cases re-occurring. All communal heating systems with gas boilers have had their annual safety checks completed within timescale. Electrical Safety The focus of attention in the past year has been to continue with the programme of domestic electrical checks (EICRs) that became overdue as a result of the change from a 10-year cycle to a 5-year cycle and to ensure that any checks due in 2024/25 were carried out prior to the anniversary date. 2911 EICRs were completed during 2024/25 and there were 252 tenanted properties with EICRs overdue at 31st March, all of which are scheduled to be carried out in April. Following this, there may be a small number of cases which will require forced access which will be arranged in May, in line with our usual procedures. There are currently 44 cases which cannot be completed due to environmental issues, for example in cases where significant hoarding has been identified. The compliance team are engaging with colleagues across housing services and other service areas to support tenants to ensure the EICR can be completed as quickly as possible. Any follow on work identified during the inspection which is classed as C1(danger present) is always addressed immediately to make safe. Where follow on work is identified and classed as C2 (potentially dangerous), in the majority of cases this is carried out at the same appointment as the electrical check with just a small number that require a new appointment to be arranged. There were two properties with outstanding C2 work at the end of March requiring additional appointments. The housing compliance team have developed robust record keeping systems to ensure that data and monitoring is accurate and this will be further improved with the introduction of the new housing management system in 2027. With the position for domestic electrical checks having improved significantly, it was possible to commit resources to commencing a programme of common area electrical checks. This programme started in November 2024 and at the end of March approximately 21% of the 953 common areas had been completed. The remainder are programmed for completion over the course of 2025/26 to ensure full compliance with this indicator by March 2026.
Page 5
Fire Safety Fire Risk Assessments (FRAs) are required for multi-storeys, sheltered complexes, HMOs and common areas of flatted blocks. All FRAs are in place, apart from 2 Homeless Person Units which have appointments arranged. Ongoing review will continue in line with the legislative requirements and any actions identified from fire risk assessments are followed up promptly with repairs instructed where required. Ongoing review will continue with some requiring 6 monthly review and others 12 monthly. Where actions are identified from FRAs, these are followed up promptly with repairs instructed where required. In addition to the internal FRAs, Scottish Fire and Rescue Service aim to carry out quarterly inspections of all high-rise blocks providing us with any notifications of defects for consideration. There were 7 defects outstanding at the end of March all of which have been instructed for repair and will be completed to ensure full compliance. Along with the EICR programme, the rollout of the fire safety detection interlinked alarms in domestic properties has been ongoing with only those with outstanding EICRs still to be completed. Robust processes have been introduced to ensure that these are checked during the annual gas service and that expiry dates are updated to enable future replacement programmes to be programmed. The Head of Housing Services chairs a quarterly meeting with Strathclyde Fire and Rescue Service and other Council teams to discuss fire safety. The compliance team are currently reviewing the Grenfell recommendations from the UK Government’s response to the Grenfell Tower Inquiry published in February 2025 to consider any actions that may be required. There are major capital investment works planned within the multi storey blocks over the next five years, which will include considering what, if any, further fire safety measures should be introduced. A cross departmental thematic group is being established to consider and prioritise the future investment requirements. The compliance team have assisted in developing a fire safety ILearn module for staff which has been rolled out across the Council. They also deliver fire safety training to staff across Housing Services. Lift Safety All lifts within multi storeys have recently been upgraded. The compliance team have been pro-active in ensuring that access is ensured for all regulatory lift examinations carried out by our appointed insurance contractor. Examinations and maintenance are ongoing, up to date and fully compliant.
Page 6
Water Safety Statutory legislation requires Legionella Risk Assessments (LRAs) to be in place with water safety management plans and monitoring in place for those identified as high risk. This includes carrying out temperature checks where communal water tanks or heating cylinders are present such as in sheltered complexes and multi-storeys. Responsibility for management of water safety responsibilities was transferred from Facilities Management Services to Housing Services in April 2025. Current performance indicators show full compliance with water safety management and a review of the data held on remedial works will be undertaken. There is a contract in place for water sampling and LRAs. Building Services carry out the monthly, quarterly, six-monthly and annual monitoring of all sites as prescribed within the guidance. The water safety policy is undergoing review and will be brought to a future Policy Board. Asbestos Management Landlords managing common areas have a responsibility to ensure there are comprehensive surveys, routine monitoring, safe management practices and good record keeping to comply with UK asbestos regulations. Surveys are in place for common areas and where asbestos has been identified and is in good condition or encapsulated routine checks must be carried out. A contract for common area asbestos management is in the process of being procured which will engage a suitably qualified contractor to carry out the common area asbestos monitoring. To mitigate any risks whilst this contract is procured, Housing Services have ensured that common areas known to have asbestos containing materials have been visited and checked to ensure appropriate measures are in place to maintain safety such as restricting access and labelling. For domestic properties Housing Services have contracts in place with specialist and suitably qualified contractors for the provision of asbestos surveying, asbestos removal and analytical services within domestic properties. Properties due to have internal or external investment works and all void properties that do not have an existing suitable refurbishment survey have a survey arranged prior to works commencing. The surveys are held on a database accessible to all staff that require them. Asbestos removals are arranged where required and survey data updated accordingly.
Page 7
The Housing Innovations Project (HIP) to replace the housing management ICT system will incorporate a new asbestos management database which will assist in streamlining the internal asbestos processes and it is anticipated this will be available mid-2027. In advance of this, an action plan is in development to identify where there may be scope for improvements in relation to asbestos management. Housing Services participate in a corporate Health and Safety-led asbestos working group which oversees the Council’s approach to asbestos to ensure consistency and good practice. The housing compliance team have assisted in developing a corporate online ILearn course for staff on asbestos awareness. There is an ongoing training programme to ensure that staff who are likely in the course of their duties to encounter asbestos, or who may have responsibility for managing it, are appropriately trained. The asbestos safety policy is undergoing review and will be brought to a future Policy Board. 5. 2025/26 Key Actions 5.1 The Scottish Housing Regulator engagement plan for 2024/25 required us to provide regular updates on progress with domestic EICRs and fire detection. We have provided this monthly and have met with representatives from the Scottish Housing Regulator to discuss progress. 5.2 The 2025/26 Scottish Housing Regulator engagement plan notes that in October 2024 in our annual assurance statement that we said were taking steps to review and consolidate our tenant and resident safety responsibilities. In addition to further updates on EICR and fire detection compliance, the Regulator is seeking further information and assurance about our asbestos management processes and planned improvements. Further information will be provided to the Regulator during 2025/26 in line with their requirements. 5.3 Key priority actions for landlord compliance during 2025/26 include: The Water Safety and Asbestos Safety Policies will be brought to a future Policy Board in 2025. Procurement of suitably qualified contractor for common area asbestos management. Completion of all common areas electrical checks Establishment of an asbestos management action plan. Completion of the outstanding EICR and smoke detection installations.
Page 8
Ongoing engagement with the HIP team to ensure the new ICT system reflects the requirement for more electronic record keeping linked to each property Review of the Grenfell recommendations and participation in the Housing Asset and Investment Thematic group reviewing multi-storey investment. Ongoing review of policies, procedures and processes including the identification of new policy requirements such as a Damp and Mould policy which will be developed in 2025. ___________________________________________________________________ Implications of the Report 1. Financial – Compliance costs are met from the HRA budget. 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. 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 - Failing to meet KPIs 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.
Page 9
12. Climate Risk – None. 13. Children’s Rights – None. 14. COSLA Policy Position – None. _____________________________________________________ List of Background Papers (a) Appendix A – Housing Landlord Compliance Performance Report 2024/25 ___________________________________________________________________ Author: Karen Sillars, Housing Asset & Investment Manager Email: karen.sillars@renfrewshire.gov.uk
Page 10
P a g e | 1 Performance Monitoring Report Housing Landlord Compliance 2024/25
Page 11
P a g e | 2 Contents 1. Position summary at year end 2024 - 2025. ........................................................................................................................................................................... 3 2. GAS .......................................................................................................................................................................................................................................... 4 3. ELECTRICAL .............................................................................................................................................................................................................................. 5 4. ASBESTOS ................................................................................................................................................................................................................................ 7 5. FIRE .......................................................................................................................................................................................................................................... 8 6. WATER ..................................................................................................................................................................................................................................... 9 7. LIFTS ...................................................................................................................................................................................................................................... 10
Page 12
P a g e | 3 1. Position summary at year end 2024 - 2025. Category Total Number of KPI’s Gas 3 3 0 0 Electrical 8 5 2 1 Asbestos 3 1 0 1 Fire 4 1 2 1 Water 4 4 0 0 Lifts 5 4 1 0 26 18 5 3 >99% Pass rate 85-99% Pass rate <85% Pass rate
Page 13
P a g e | 4 2. GAS Cat Indicator Q1 Q2 Q3 Q4 24/25 23/24 Notes KPI G.01 Number of times in current reporting year Housing 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) 1 0 1 3 5 11 Q1 Decant Property Q3 Police Crime Scene Q4 Dog behind door Q4 Barricaded door to prevent access. Q4 Eng attended wrong property KPI G.02 Landlord’s Gas Installations with a valid LGSR (CP12) within its due date in the last 12 months as a % of Total Landlord Requirement 99.9% 99.9% 99.9% 99.9% 99.9% 99.9% KPI G.03 Number of Communal / District Boilers with valid certification as a % of Total Landlord Requirement 100% 100% 100% 100% 100% 100%
Page 14
P a g e | 5 3. ELECTRICAL Indicator Q1 Q2 Q3 Q4 24/25 23/24 Notes KPI E.01 Domestic properties with a satisfactory EICR within its due date as % of total dwellings requiring an EICR.(Electrical Installation Condition Report) 80% 80% 89% 94% 94% 82% Of those outstanding, 3% are due for demolition, 2% are tenanted properties and 1% are void properties. All tenanted properties due for completion by end of May. All void properties will have EICR carried out during the void period. KPI E.02 Non-domestic properties (including Common Areas) with a satisfactory EICR within its due date as % of total non-dwellings requiring an EICR - - 4% 21% 21% 0% Programme commenced in November 2024 and is scheduled for completion by March 2026. KPI E.03 Percentage of domestic properties with No outstanding C1, C2, F1 works. 99.9% 99.9% - Data only available from Quarter 4. 2 properties have outstanding C2s. KPI E.04 Percentage of non-domestic properties with no outstanding C1, C2, F1 works 100% 100% 100% 100% 100% 95% Sheltered Housing, High Rise and Laundrettes.
Page 15
P a g e | 6 Indicator Q1 Q2 Q3 Q4 24/25 23/24 Notes KPI E.05 Percentage of Sites with Portable Appliance Tests (PAT) completed. 100% 100% 100% 100% 100% 100% Covers Housing owned appliances in Sheltered Housing & High Rise. KPI E.06 Percentage of properties with Lightning Protection Systems (LPS) inspected and tested. 100% 100% 100% 100% 100% 100% KPI E.07 Percentage of properties with automated doors, gates, and barriers with a valid Risk Assessment. 100% 100% 100% 100% 100% 82.14% FRA takes account of equipment KPI E.08 Percentage of properties with automated doors, gates, and barriers where Maintenance visits have been completed. 96% 96% 96% 96% 96% 96% One domestic property outstanding – tenant engagement ongoing.
Page 16
P a g e | 7 4. ASBESTOS Cat Indicator Q1 Q2 Q3 Q4 24/25 23/24 Notes KPI A.01 Non-Dwellings (common areas) with a valid asbestos survey and re-inspections of all Asbestos Containing Materials (ACMs) where required, within its due date as a % of non-dwellings requiring one. 75% 75% 75% 75% 75% 72% Common area surveys have been undertaken and are in place for all sites. Re-inspections are required for some sites and will be undertaken on appointment of a suitably qualified contractor. KPI A.02 Number of safety occurrences - including any reported asbestos related occurrence reporting (e.g., to the HSE or Regulator) during the reporting period. 0 0 0 0 0 0
Page 17
P a g e | 8 5. FIRE Cat Indicator Q1 Q2 Q3 Q4 24/25 23/24 KPI F.01 % Of Properties with a Completed and In Date Fire Risk Assessment (FRA) where required. 99% 99% 99% 99% 99% 100% All High flats, Sheltered, and common areas for all blocks are completed and reviews ongoing. Access being arranged for 2 outstanding Homeless Person units. KPI F.02 Total No. of Fire Risk Assessment Actions Outstanding 2 2 9 15 15 (94%) 252 258 repair actions were identified through the fire risk assessments during 2024/25. Of these 243 are complete with 15 still in progress. KPI F.03 % of Buildings with Fire Safety Systems/Equipment present where all Systems/Equipment has been Tested/Maintained in accordance with Policy 100% 100% 100% 100% 100% All fire safety equipment tested by certified appointed contractors. KPI F.04 Number of Notices received from the Fire and Rescue Services Actions outstanding. 3 1 20 4 2 0 3 2 28 7 10 75% of defects have been rectified. Repairs have been raised for the remainder and are targeted be completed within the first quarter of 2025/26.
Page 18
P a g e | 9 6. WATER Cat Indicator Q1 Q2 Q3 Q4 24/25 23/24 KPI W.01 % of Priority Scheme Properties (against the stated Total Landlord Requirement) with a valid Legionella Risk Assessment 100% (41/41) 100% (41/41) 100% (41/41) 100% (41/41) 100% 100% KPI W.02 % of General Needs Properties (against the stated Total Landlord Requirement) with a valid desktop Risk Assessment. 100% 100% 100% 100% 100% 100% `KPI W.03 % of Properties (against the stated Total Landlord Requirement) with a valid Written Scheme where a requirement has been identified. 100% 100% 100% 100% 100% 100% KPI W.04 % of Properties (against the stated Total Landlord Requirement) within a Legionella Maintenance Regime 100% (41/41) 100% (41/41) 100% (41/41) 100% (41/41) 100% 100%
Page 19
P a g e | 10 7. LIFTS Cat Indicator Q1 Q2 Q3 Q4 24/25 23/24 KPI L.01 Assets with a Passenger Lift having valid Thorough Examination within its Due Date as a % of total assets with a Passenger Lift 100% 100% 100% 100% 100% 100% KPI L.02 Assets with a Passenger Lift where all Maintenance and Inspection activity is within its Due Date as a % of total assets where a Passenger Lift is present 100% 100% 100% 100% 100% 100% KPI L.03 Assets with Vertical Through Floor Lifts having valid Thorough Examination within its Due Date as a % of total assets with other Lifts 100% 100% 100% 100% 100% 100% KPI L.04 Assets with Vertical Through Floor Lifts where all Maintenance and Inspection activity is within its Due Date as a % of total assets where other Lifts are present 100% 100% 100% 100% 100% 100% KPI L.05 Assets with Actions arising from Thorough Examinations, Inspection or Maintenance activity that are Overdue as a % of total assets where a Lift is present 10% 33/34 97% 32/34 94% 32/34 94% 94% 20.5% Contractor awaiting materials to complete outstanding actions