Safer buildings policy

SAFER BUILDINGS POLICY

1 Introduction

1.1 We recognise that protecting the health and safety of anyone that uses or visits any of our properties is paramount. This includes residents and their guests, staff and external contractors. To achieve this, the Association has challenging but deliverable regular inspection and planned maintenance regimes in place to cover asbestos, gas installations, electrical installation, fire protection, water management and Radon.

1.2 Castles & Coasts Housing Association (CCHA) is regulated by the Regulator of Social Housing (RSH) and, in relation to compliance, under the Homes Standard. Any significant failure in managing the key risk areas of compliance is likely to be considered as a case of serious detriment. The RSH has been clear that Boards must make sure that they have proper oversight of all health and safety issues, including gas servicing, fire safety and other issues such as asbestos.

1.3 Meeting health and safety requirements in respect of residents is a fundamental responsibility and this policy sets out the Association’s approach to meeting health and safety requirements through effective property related compliance activities.

1.4 This Safer Buildings Policy has been written to help promote efficient and effective approaches to regulatory inspections and compliance, and to improve regulatory outcomes without imposing unnecessary burdens.

2. Purpose of this Policy

2.1 The purpose of this policy is to outline and communicate our policy in respect of how we deal with compliance. It will be made accessible to officers within the Association who have specific compliance responsibility. All operational managers will be required to formally sign to confirm they have read and understood this policy, as it requires an organisational approach to ensure its aims are achieved.

2.2 Those officers will ensure they have a good working knowledge of this policy and any subordinate policies, procedures and associated guidelines.

2.3 This policy, and/or subordinate policies, will also be brought to the attention of contractors working on behalf of the Association, where it is deemed necessary.

3. Relevant Legislation

3.1 CCHA, as a landlord, has a number of legal obligations it must satisfy to ensure the health, safety and welfare of its customers. These obligations form part of an ongoing cyclical inspection and maintenance regime to ensure key elements in the homes we manage do not pose undue risk.

3.2 These obligations are well represented in statute, as set out below:

• Health and Safety at Work Act 1974

• The Landlord and Tenant Act 1985

• The Housing Act 2004

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Safer Buildings Policy - Version 5

Date approved by Board: 29.11.22 Page 1

• Management of Health and Safety at Work Regulations 1999

• Environmental Protection Act 1990

• The Regulatory Reform Fire Safety Order 2005

• Electricity at Work Regulations 1989

• The Gas Safety (Installation and Use) Regulations 1989

• Construction (Design and Management) Regulations 2015

• Control of Substances Hazardous to Health Regulations 2002

• Control of Asbestos Regulations 2012

• Fire Safety Act 2021

• Building Safety Act 2022

• Smoke and Carbon Monoxide Alarm (England) Regulations 2022

3.3 In addition to the above mentioned, there are a number of Approved Codes of Practice (ACOP) and guidance notes that must be adhered to, to ensure compliance. Those additional documents are, but not limited to, the following:

• Government Risk Assessment - Fire Safety in Sleeping Accommodation

• Local Government Guide - Fire Safety in Purpose Built Flats

• Approved Code of Practice - Water Hygiene (L8)

3.4 Officers of the Association are to ensure they have all the necessary documentation, including ACOP or specific guidance notes, where they have specific regulatory responsibilities.

3.5 The statutory instruments mentioned above set out the minimum standard which must be met. Specific compliance policies will be developed from the legislation governing the health, safety and welfare of residents and are viewed as appropriate to ensure CCHA discharges its duties as a social housing landlord.

4. Responsibilities

4.1 CCHA has a responsibility to meet all requirements in relation to property compliance. The organisational roles and responsibilities set out below cover CCHA in general terms.

4.2 Specific roles and responsibilities are required through statutory documentation to ensure compliance within each property compliance area. These responsibilities are detailed in the individual procedure for each area, as detailed in section 5 of this policy.

The organisational roles and responsibilities are as follows:

4.3 Duty Holder – Chief Executive

4.3.1 The Duty Holder has overall responsibility for all matters relating to property compliance. This responsibility includes ensuring that all property compliance matters are seen as an important priority for the organisation and are addressed through comprehensive policies and procedures that are effectively implemented and appropriately resourced.

4.3.2 The Duty Holder will appoint a Responsible Person for property compliance.

4.3.3 The Duty Holder will ensure that financial resources are made available to support this Policy, based upon a Risk Assessment of priorities.

Castles & Coasts Housing Association

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Date approved by Board: 29.11.22 Page 2

4.4 Responsible Person – Property Services Director

4.4.1 The Duty Holder has appointed the Property Services Director as the Responsible Person in relation to Property Compliance. As such, the Responsible Person is responsible for the implementation of this policy and for ensuring that the aims and objectives contained within it are met.

4.4.2 The Responsible Person is responsible for overseeing the assessment of risks and implementation of precautions and control measures.

4.4.3 The Property Services Director, as the Responsible Person, will ensure that reasonable enquiries are made to ensure that organisations and consultants, together with CCHA employees and agency employees who carry out any routine monitoring or maintenance, are competent and suitably trained and have the necessary equipment to carry out their duties in a safe and adequate manner.

4.4.4 The Responsible Person will provide the Compliance Team with sufficient resources and support to take the necessary actions and will ensure that they receive sufficient training.

4.5 Deputy Responsible Person – Head of Maintenance

4.5.1 The Head of Maintenance is designated as the Deputy Responsible Person in relation to Property Compliance and will act for the Responsible Person in their absence.

4.5.2 The Deputy Responsible Person will facilitate and coordinate all aspects of Property Compliance in conjunction with the Responsible Person, Surveyors, external consultants, external contractors and any internal member of staff.

4.5.3 The Deputy Responsible Person is responsible for the implementation and monitoring of the Safer Buildings Policy, ensuring that:

• Appropriately qualified and experienced contractors are appointed to undertake Risk Assessments, draw up control schemes, carry out repairs and maintenance and undertake property compliance related activities at CCHA’s request

• Risk Assessments, where needed in relation to property compliance, are recorded and reviewed regularly

• Works identified through Risk Assessments and testing/servicing are carried out

• Safe procedures and safe working practices resulting from Risk Assessments are documented and implemented

• Arrangements with regards to property compliance are included in local induction, where appropriate, and regular refresher training for staff with responsibilities under this policy

• Any works required to maintain or repair compliance related systems, such as water distribution, electrical and heating distribution, in CCHA premises are ordered from suitable providers, as necessary

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• Property compliance risks are taken into account when works, either by CCHA or by others, are undertaken

• Any incidents or cases of disease or injury associated with CCHA properties are reported to the Responsible Person

5. Safer Buildings Policy Areas and Reporting

5.1 The Safer Buildings Policy will be reviewed and approved annually by CCHA’s Board, as part of its annual review of asset management. The Board and Audit & Risk Committee has reviewed and approved a new suite of KPIs, for the monitoring of health and safety and safer buildings. These new KPIs were implemented from Q2 2021/22.

5.2 The Audit & Risk Committee receive regular reports from the Head of Maintenance and the Health & Safety Manager on matters relating to safer buildings This includes any legislative changes or emerging issues within the sector.

5.3 As a social housing landlord, CCHA has a statutory duty to satisfy the requirements of the legislation above. The supporting policies and procedures set out the framework under which the duties contained within the statutory instruments are discharged.

5 4 The Safer Buildings Policy covers:

5.4.1 The Association’s Gas Servicing and Protection from Carbon Monoxide Policy (Appendix 1) sets out the Association’s statutory obligation as a landlord for gas and fossil fuelled heating appliances within its stock, to ensure these are tested and inspected at least annually. The current servicing contract also includes the annual inspection of smoke, heat and carbon monoxide detectors installed in the Association’s housing stock.

5 4.2 The Fire Management Policy (Appendix 2) aims to define the Association’s risk based approach to fire management in its housing stock and offices.

5 4.3 The Control of Asbestos Policy (Appendix 3) aims to ensure all housing stock, where asbestos is likely to be present, is inspected regularly and, where possible, asbestos is removed. Under normal circumstances, this removal will be undertaken when a property becomes void, where planned maintenance is being undertaken or where asbestos had been damaged due to unforeseen circumstances. The Association will inform residents of the presence of asbestos within their property by appropriate means.

5 4.4 The Association’s Electrical Testing Policy (Appendix 4) provides specific guidelines which enable the Association to be assured it is fully compliant with its legislative responsibilities in relation to its fixed electrical installations. All fixed electrical installations within the Association’s portfolio, which includes commercial and residential accommodation, are subject to regular inspection and testing. In addition, the policy aims to ensure all portable equipment is tested and inspected regularly.

5.4.5 The Water Management Policy (Appendix 5) applies to all premises where hot and cold water systems are directly managed by the Association. The Association will also give guidance, via suitable media, to leaseholders and residents of general needs housing accommodation on how to ensure water clarity within their properties.

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Date approved by Board: 29.11.22 Page 4

5 4.6 The Radon Gas Policy (Appendix 6) shows the process of managing properties within geographical areas affected by the odourless naturally occurring gas, Radon. This is a newly emerging risk following emphasis from Public Health England (PHE). We are working closely with PHE to assess the risk that Radon could have on the Association and its residents.

5.4.7 The Fire Evacuation Strategy (Appendix 7) sets out that higher risk properties follow a Stay Safe Strategy, with lower risk properties following an evacuation strategy

5 5 The Association manages gas servicing and asbestos through bespoke modules within the OPENHousing IT system. This system holds data on installations technical data including, locations, next required inspection date, remedial works, certification, access records and communication with residents. All other key areas of property compliance are monitored by the OPENHousing Property Compliance Module, which provides integrated coverage of all areas of property compliance The gas servicing and asbestos management modules, along with the Property Compliance Module, are now linked to our new reporting system, Power BI We are working on the addition of secondary compliance areas, such as automatic doors and smoke and carbon monoxide detectors, and all other property compliance areas. The Property Compliance Module, along with Power BI, allow significantly improved monitoring and reporting on all areas of compliance.

5.6 The increased scrutiny and enhanced regulation placed on property compliance following the Grenfell Tower disaster, meant that the OPENHousing System, without the Property Compliance Module, was not suitable for the amount of data required to be both held and reported on. The implementation of the Property Compliance Module and Power BI has enabled us to obtain real time and manageable reporting and has significantly reduced the level of risk to the Association.

5.7 Although we are still to implement some of the secondary compliance areas to this system, the Association holds appropriate records and management information to manage its obligation under this policy.

6. Independent Audit and Validation

6.1 An important element in providing assurance that the Association is meeting its obligations in relation to providing safe buildings, is the use of independent bodies and accreditations to demonstrate compliance.

6.2 The table below sets out how this assurance is achieved for each of the key areas of compliance:

Area of Compliance Independent Method of Assurance

Gas

Annual internal audit and work quality check of our contractors by a third party (5-10% checks). All Gas Engineers must be Gas Safe registered.

Fire Annual internal audit and Fire Risk Assessors are both Institute of Fire Safety Managers (IFSM) and Institute of Fire Engineers qualified. Key members of staff are trained to IFSM Fire Risk Assessor level and all contractors must have accreditation with British Approvals for Fire Equipment (UK) or similar.

Castles & Coasts Housing Association

Safer Buildings Policy - Version 5

Date approved by Board: 29.11.22 Page 5

Asbestos

Electrical

Water

Annual internal audit and contractors are accredited to both the UK Asbestos Training Association and the UK Accreditation Service who undertake regular audits.

Annual internal audit and independent check by Castles & Coasts Services’ Electrical Supervisor. NICEIC undertake audits of qualified Electricians.

Annual internal audit and contractor is registered with the Legionella Control Association who renew accreditation on an annual basis.

Radon Annual internal audit and we are working with Public Health England who issue surveys, collect test results and analyse results on our behalf.

7. Policy Communication

7.1 This policy, along with supporting policies and procedures, will be communicated to all officers and interested parties by a number of ways. These include:

• Team briefings - for those who need to be aware of, but not actively involved, in the delivery

• On the job training - for those who need to use the procedures in their daily roles

• Regular refreshers - for those using the procedures

• Peer training - for those being trained by their managers or other persons deemed competent

• Mentors briefing - for those involved in the monitoring of performance, but not involved in the day to day delivery

8 Legal Implications

8.1 This policy assists the Association to discharge its statutory health, safety and welfare duty associated with social housing landlord compliance. Failure to comply with these duties could result in formal prosecution against the Association as the landlord or the officers who have specific compliance responsibility.

8.2 The Association acknowledges and accepts its responsibilities for property compliance under the relevant legislation, as set out in 3.2 above and recognises that failure to properly discharge these responsibilities may result in:

• Prosecution by Health and Safety executive under Health and Safety at Work Act 1974

• Prosecution under Corporate Manslaughter and Corporate Homicide Act 2007

• RSH serious detriment judgement

9. Review

9.1 This policy, and all subordinate policies, will be reviewed annually to ensure they remain suitable and sufficient

Castles & Coasts Housing Association

Safer Buildings Policy - Version 5

Date approved by Board: 29.11.22 Page 6

GAS SERVICING AND PROTECTION FROM CARBON MONOXIDE POLICY

1. Policy Statement

1.1 We recognise the potential hazard that poorly or incorrectly maintained gas and fossil fuel heating systems and equipment can cause. The Association will use its best endeavours to ensure the correct servicing and maintenance of all relevant installations to ensure their continued safe operation.

1.2 The Association has a legal obligation to ensure the continued safety of its residents in respect of gas equipment installed in dwellings that it owns.

1.3 It is the Association’s intention to fulfil its responsibility by employing the services of a gas service and maintenance contractor, who is registered on the Gas Safe Register, operated by Capita and who will perform the duty of gas installer as defined in the current Gas Safety (Installation and Use) Regulations 1998. The Association must undertake a gas safety check within 12 months of the previous one.

The policy will also work within the context of the following legal frameworks:

• Health and Safety at Work Act 1974

• Control of Substances Hazardous to Health Regulations 2002

• Control of Pollution (Oil Storage) (England) Regulations 2001

• Management of Health and Safety at Work Regulations 1999

• Workplace (Health Safety & Welfare) Regulations 1992

• Landlord and Tenant Act 1985

• Leasehold Reform, Housing and Urban Development Act 1993, (section 121)

• Compliance with HETAS guidance (solid fuel systems)

• Compliance with OFTEC guidance (Oil fired systems)

• Construction (Design & Management) Regulations 2015

1.4 Systems powered by other fossil fuels will also be subject to a 12 month service to ensure they are safe.

1.5 All information will be accurately recorded and maintained primarily within OPENHousing and Alchemy IT systems, to ensure the service is delivered in line with this policy. The methods and procedures of record keeping, to be followed, are contained within the Gas Safety Procedures.

1.6 The Association will ensure the performance of the contractor undertaking gas servicing by appointing an independent Gas Safe qualified contractor to complete quality assurance audits of a sample of properties with completed services. The sample subject to an audit will be 10% in the first year which can be reduced to 5% if no issues with compliance or workmanship are found.

1.7 The Association will operate a gas servicing programme that commences at the 10 month anniversary date of the most current Landlord’s Gas Safety Record (LGSR) to ensure that sufficient time is available to carry out a service before the expiration of the existing LGSR.

1.8 The Association will, using all reasonable recovery resources, use the landlord powers available to it in law and under the terms and conditions of Tenancy Agreements and Leases

to ensure that it meets its legal obligations with respect to the servicing and maintenance of gas equipment and services.

1.9 The Association will regularly review and utilise good practice advice from the RSH and Health and Safety Executive in formulating its procedural guidance for staff, to ensure it fulfils its responsibilities in respect of heating appliance servicing.

1.10 The Association will target residents who regularly fail to allow access with a view to employing proactive measures to ensure future access. Proactive measures will range from early intensive communications to service interval timers.

1.11 The Association has fit carbon monoxide detectors to all properties which have a system capable of producing carbon monoxide in the living space of the property

1.12 Carbon monoxide detectors are tested annually and replaced, when required.

1.13 This policy and the procedures that support it will be the subject of a mixed platform of training across the Association and include all stakeholders. This training will be bespoke to the individuals and specific gas safety and refresher training will be provided, as appropriate. Training will also include:

• Team briefings – for those who need to be aware of, but not actively involved in, the delivery

• On the job training – for those who need to use the procedures in their daily roles

• Regular refreshers – for those using the procedures

• Monitors briefing – for those involved in the monitoring of performance, but not involved in the day to day delivery.

FIRE MANAGEMENT POLICY

1. Policy Statement

1.1 We recognise the potential consequences of a fire in any of our dwellings, and the potential hazard for our residents. We identified, through the process of reviewing our approach to Fire Risk Assessment (FRA), the need to have a robust Fire Management Policy.

1.2 The Association has a legal obligation to ensure the continued safety of its residents in respect of fire safety in dwellings with communal areas that it owns. We also recognise that some of our independent living properties can be considered high risk reflecting the variance in residents’ circumstances.

1.3 It is the Association’s intention to fulfil its responsibility through the work of the Head of Maintenance, Compliance Manager and Health & Safety Manager supported by external consultants, who are qualified and experienced in fire safety issues, who will perform the duty of a Competent Person as defined in the Regulatory Reform (Fire Safety) Order 2005. The position of Responsible Person, in accordance with the same order, will be retained by the Chief Executive Officer of the Association.

1.4 A new FRA will be undertaken for a property if any of the following occur:

• If a fire occurs in the scheme

• If a near miss involving fire occurs within the scheme

• If a change of key staffing level occurs in the scheme

• If the annual fire management audit finds significant shortcomings which need addressed

• Following any significant change to its layout, structure or its construction

1 5 A risk based approach will be adopted for undertaking FRA reviews, and will reflect the Association’s approach for the management of risk. FRA reviews will be undertaken in accordance with the timescales mentioned below by the Association’s appointed Fire Risk Assessors. The Health & Safety Manager will undertake health and safety audits of high risk schemes, which will include a review of fire management between FRA reviews.

• High risk - independent living accommodation (see 2) - annual FRAs

• Medium risk - Purpose built flats and office accommodation - FRA every 2 years

• Low risk - General needs living accommodation and commercial properties not residential - FRA every 3 years.

1.6 Properties within all risk categories have been assessed and categorised as part of CCHA’s Fire Evacuation Strategy. Higher risk properties follow a Stay Safe Strategy, with lower risk properties following an evacuation strategy Further detail of this can be found in the CCHA Fire Evacuation Strategy (Appendix 7).

1.7 To ensure competency in the completion of risk assessments, Fire Risk Assessors will hold the following qualifications and be deemed competent by the organisation they are working for, as set out in the table below:

Qualification Essential Desirable

Qualified Building Surveyor ✓ Fire Protection Association/ Institute of Fire Safety Managers (IFSM) Risk Assessment Trained (or recognised equivalent)

Chartered Institute of Building qualified (CIOB)

Royal Institute of Chartered Surveyors (RICS) ✓ Letter of competence from employer

1.8 We will also ensure that measures to control the spread of fire and smoke are maintained to limit spread to a single compartment and that all dwellings which have a fire detection system fitted will be serviced regularly by a competent contractor. Fire detection systems include all alarms, emergency lighting and fire fighting apparatus provided at a property. Buildings will be maintained to the standard they were constructed.

1.9 The Association will regularly review and utilise good practice advice from the Institute of Fire Engineers, local area Fire Service and the Health & Safety Executive in formulating its procedural guidance for staff and residents, to ensure it fulfils its responsibilities in respect of fire safety management.

1.10 The Association will undertake health and safety audits for every property that requires one within a 12 month cycle. The Health & Safety Manager, supported by the Property Services Team, will undertake these audits. The foundation of the health and safety audit, in relation to fire safety, will be to ensure that a FRA is in place for all offices and dwellings with a communal area. In addition, each high risk scheme will have on-site records containing (see attached list of such schemes):

• An up-to-date FRA

• CCHA Fire Management Policy

• An up-to-date fire evacuation plan

• Record tables for fire alarm checks

• Tables for recording checks to emergency lighting, fire exits, fire extinguishers and fire door self closers

• Call out information for contractors in the event of an emergency

• Scheme plans with key information

1.11 The Association will carry out a Personal Emergency Evacuation Plan (PEEP) on each resident in a high risk scheme to identify residents who are potentially vulnerable in the event of a fire happening. Proactive measures will range from moving residents with mobility issues to ground floor flats, to communications via the Wellbeing & Compliance Assistants etc., on information such as fire safety advice.

1.12 The Association will fit fire information lockers to all high risk schemes. The location of each locker will be communicated to each fire service Fire Protection and Technical Manager. This will aid the Fire Service in the event of a fire happening when no Wellbeing & Compliance Assistant is present.

1.13 Following the Hackett Review, post the Grenfell Disaster, we have completed the installation of fire action notices into all schemes in order to communicate to residents the evacuation procedures in place.

1.14 The Association will regularly review its training for staff in relation to fire safety management, record keeping and checks of fire equipment. All staff will undergo training in fire safety measures on a 12 monthly basis. All new members of staff will undergo training during induction to their post.

1.15 All other properties will be fitted with at least one smoke detector per floor, which is regularly inspected and replaced, in line with the 10 year lifecycle or relevant expiry date.

2. Identified Higher Risk Schemes

2.1 Independent Living/Extra Care schemes to be considered high risk

Hadleigh Court, Shiney Row

Burn Promenade, Houghton le Spring

Carisbrooke Court, Sunderland

Wadham Court, Sunderland

Balmoral Court, Sunderland

Pembroke Court, Sunderland

Brownsea Place, Gateshead

Tindale Drive, Gateshead

Castle Close, Gateshead

Cragside Court, Gateshead

Caroline Street, Hetton le Hole

Catherine Mill, Whitehaven (combination of leaseholders and rented)

Upperby Court, Carlisle

Bishops Close, Carlisle

Dickinson Court, Whitehaven

Trinity Court, Whitehaven (leasehold scheme)

Ellen Court, Maryport – currently bi-annual, based on the FRA

Victoria Court, Cockermouth – currently bi-annual, based on the FRA

Castle Gardens, Cockermouth – currently bi-annual, based on the FRA

Firth House, Workington

Laybourn House, Workington

Greta Gardens, Keswick (extra care facility)

2.2 Supported accommodation considered higher risk

11 Appletree Gardens, Newcastle

11 Balmoral Terrace, Newcastle

53 Craythorne Gardens, Newcastle

96 Hillhead Parkway, Newcastle

6 Holly Avenue, Newcastle

3 Larchwood Avenue, Newcastle

1 Lynnwood Avenue, Newcastle

4 Oliver Avenue, Newcastle

351 & 353 Wellbeck Road, Newcastle

CONTROL OF ASBESTOS POLICY

1. Statement of Intent

1.1 We recognise that the Association has a duty to ensure that residents, employees, contractors and visitors to its premises are protected from exposure to the harmful effects of asbestos in its buildings and during any work-related activities. CCHA will take all the necessary steps to expeditiously discharge this duty of care under the Health and Safety at Work Act and the Control of Asbestos Regulations L143 (2012) ‘Managing and working with asbestos’, in particular Regulation 4 ‘The Duty to Manage’.

1.2 Asbestos is the common name applied to a number of naturally occurring, inorganic silicates and is internationally recognised as being hazardous to health. The medical effects of accidental exposure to asbestos through disturbed materials can be serious and in some cases fatal – though the latter is usually as a result of exposure over a prolonged period of time.

1.3 CCHA has a legal duty to prevent the risk of exposure to asbestos to employees, residents and visitors to its properties and it is recognised that failure to comply with this duty could result in criminal prosecution and/or civil claims against those held responsible for any such breaches.

1.4 This policy aims to:

• Communicate and promote our commitment to prevent exposure to asbestos

• Ensure that effective systems are in place to prevent any exposure to asbestos

• Ensure that information is provided as necessary to all relevant parties

• To build an up-to-date Asbestos Register for all our premises and ensure it is maintained and available for inspection

• Ensure that an appropriate Asbestos Management Plan is put in place, which is understood by everyone who manages and/or works on CCHA’s properties

• Ensure that suitable and sufficient risk assessments have been undertaken and provided by Property Services through a data management system and any HSE Licensed Contractor working on behalf of CCHA

• Ensure that a robust re-inspection regime is in place for all known and presumed Asbestos Containing Materials (ACMs)

2.1 The Association’s Asbestos Register will be maintained via a central electronic database. Extracts in hard copy of the main register, containing the relevant asbestos information on dedicated premises, will be maintained and located at nominated premises where it is appropriate for the stock type. The register will be used to forewarn employees, contractors and emergency services, of the presence of asbestos and these registers will be regularly updated.

2.2 All contractors are notified of the possible presence of asbestos on their Works Order and they have access to the CCHA Portal, to access copies of any survey data held. If necessary, these surveys will be issued as hard copies to contractors and staff.

3. Asbestos Management Plan

2. Asbestos Register

3.1 The Association will maintain procedures, known as its Asbestos Management Plan, to deal with any unforeseen situation that results in accidental asbestos exposure and for the safe disposal of any ACMs to ensure compliance with all legal obligations placed upon the Association.

3.2 The Asbestos Management Plan will ensure the Association maintains a system to deal with the safe inspection, handling and disposal of asbestos found in CCHA’s properties. This system will be used by Property Services’ staff and delivered using approved HSE licensed contractors.

3.3 The Association will undertake asbestos surveys to all void properties and properties receiving planned maintenance works as set out in the Asbestos Management Plan.

3.4 All CCHA’s employees potentially at risk from exposure to asbestos will be provided with information, instruction and training in order to raise awareness.

3.5 The Association will ensure that any contractors they engage to work on asbestos materials are competent and licensed (where appropriate, or necessary) to do so.

4. Policy Implementation

4.1 The implementation of this policy will be achieved through the following measures:

• Ensuring that all employed contractors, as part of the new procurement exercises, are both competent and take the necessary steps to protect their employees, residents or occupants who may be affected by their work activities

• The production and maintenance of the Asbestos Register(s) and Risk Assessments for the Association’s premises and the communication of this information to those who may be affected by exposure to asbestos

• Ensuring that Property Services and Housing Services staff involved in ordering or carrying out works are aware of their obligations with regard to ACMs and that they must inspect and check the Asbestos Register(s) provided for the premises in which they are working or are responsible for

ELECTRICAL TESTING POLICY

1. Statement of Intent

1.1 We recognise the potential hazard that poorly or incorrectly maintained electrical installation and equipment can cause. The Association will use its best endeavours to ensure the correct servicing and maintenance of all relevant installations to ensure their continued safe operation.

1.2 The Association has an explicit duty to assess and manage the risks resulting from the exposure to unsafe electrical installations and equipment under the Electrical Installation Wiring Regulations BS 7671 (as amended) 2018

1.3 The Association will manage electrical systems and equipment which includes:

• Periodic fixed wire inspections

• Portable appliances testing (PAT)

• Servicing & Maintenance of electrical equipment

• Planned electrical upgrades (to eighteenth edition)

• Vacant property, upgrade & inspections

Frequency of Testing

1.4 There are no prescribed frequencies for periodic electrical testing and, therefore, the Association’s policy is based upon a risk assessment approach, determined by the type of accommodation/installation as set out in the table below.

Accommodation / Installation

Domestic dwellings - self-contained

Domestic communal areas – all fixed circuitry from landlord’s consumer unit providing benefit to residents/public, including, although not exhaustive:

Lighting

Power outlets

Fixed equipment, e.g. laundry facilities

Warden control

Door Entry Systems

Heating systems and circuitry

Lifts

Offices and other places of work, including offices within housing schemes and those within independent living housing schemes not accessible to residents/public.

Maximum Period between Inspections

Change of occupancy/mutual exchangeAction Plan Target 5 years

5 years inspection and testing with annual routine/visual inspections

5 years inspection and testing with annual routine/visual inspections

Offices and other places of work, including offices within housing schemes and those within independent living housing schemes accessible to residents/public 5 years inspection and testing with annual routine/visual inspections

1.5 The Association will implement a testing regime looking at oldest properties first on a 5 year rolling programme. New proprieties are tested first at year 10 after construction.

1.6 Recognising that non-access issues cannot rely on the same legal remedies for access such as gas, the Association will aim to ensure 100% of properties have a current electrical test certificate.

1.7 The Association will undertake a periodic electrical test to all void properties before re-let and all planned work that involves change to the electrical installation, including kitchens, bathrooms and heating replacements.

1.8 The Association recognises robust regime of periodic electrical inspection, including undertaking required remedial works, should help to reduce the number of responsive electrical repairs. Electrical safety also links with the important issue of fire safety.

1.9 This policy does not cover emergency lighting, fire alarms or specialist detecting systems which are managed under the Fire Management Policy.

2. Portable Appliance Testing

2.1 For all portable electrical items, the Association will utilise the guidance table in the Health and Safety Executive document INDG236 (rev3) to maintain portable electrical equipment in low risk environments. In addition to this guidance, all electrical items procured by the Association will undergo a visual inspection before first use; the item will then fall into the inspection regime as per the table below.

2.2 For clarity, the definition of the person undertaking the checks are as follows:

• User checks - the person using the portable equipment - with training and guidance

• Annual email to remind all staff of the responsibility to report and check equipment being used

• Combined inspection and test - this requires the use of specialist testing equipment and could be performed by internal, suitably qualified persons, or an external competent organisation

2.3 Portable Appliance Testing Intervals

Extra low voltage items (less than 50 volts AC)

telephone equipment, low voltage desk lights

Desktop computers, VDU screens

Photocopiers, fax machines (not handheld, rarely moved)

Yes

Double insulated class II equipment recognised by this symbol (not handheld, moved occasionally) Yes

Double insulated class II equipment (handheld) e.g. some floor cleaners, kitchen equipment

Earthed equipment such as kettles, some kitchen equipment, irons

Cables (leads, plugs etc. connected to the above), mains voltage extension leads and battery charging equipment

Yes

Yes 3 years

Yes 3 years

Yes 3 years

No if double insulated, otherwise every 5 years

No if double insulated, otherwise every 5 years

Yes, every 2 years

Yes

Yes

Yes, annually. More often depending on where it is used.

Yes, annually. More often depending on where it is used.

Yes, maximum 3 years depending on the type of equipment mentioned above

Yes, every 2 years

Yes, every 2 years

Yes, maximum 5 years depending on the equipment mentioned above

WATER MANAGEMENT

1. Policy

1.1 The Association’s policy is to control, prevent and minimise the risk from legionella and ensure the quality of water to our residents is the best it can be. Additionally, the Association endeavours to ensure a safe and healthy working environment for all staff members, visitors and contractors.

2. Water Management Plan

2.1 The Water Management Plan that accompanies this policy clearly details the following:

• Roles and responsibilities of duty holders within the Association

• Details on how to prevent or minimise the risk of legionella in the Association’s water systems

• Details of contractors used by the Association to assist in achieving their water management goals

• Details on what records are to be kept, where they are to be kept and who is responsible for recording the information

• Test and inspection regime of Association and contract staff

3. Statutory Provision

3.1 The Health and Safety at Work Act sets out the broad legal requirements for health and safety which the Association will follow; however, the Control of Substances Hazardous to health is more specific to the control of legionella.

3.2 The HSE's Approved Code of Practice (ACOP) L8 "Legionnaires' Disease: the control of Legionella bacteria in water systems" is taken as the main source of guidance on matters relating to legionella risk management. There are additional documents available where vulnerable persons may be present

4. Risk Assessment

4.1 Legionella is more of a risk where elderly and generally unhealthy people reside; therefore, the Association’s extra care scheme and all independent living accommodation will be classed as high risk environments.

4 2 Risk assessments will be undertaken on all the above properties and a scheme of works will be located at each one. The scheme of works will be the recording location of all water temperatures and recordings taken of little used outlets and details on shower head cleaning etc. Such elements of tank inspection and cleaning will be undertaken by the retained water management contractor. These risk assessments will be reviewed by the water management contractor every 2 years unless something changes with the property or the occupants, when the risk assessment will be reviewed as a matter of course.

4.3 All general needs residential properties will be subject to a model risk assessment for the type of property It is accepted that general needs properties that do not store water and are mains fed are relatively low risk, as long as the water is used regularly, and hot water is delivered above 50 degrees. It is essential, therefore, that gas servicing is undertaken regularly to ensure boilers are efficient.

4.4 Where general needs properties have stored water, these will be classed as medium risk properties and a specific risk assessment will be produced on these properties.

5. Communication

5.1 Regular communications will be produced advising residents to run their water to ensure the clarity of the water running through their system. This will be done by various means, but the main communication route will be via social media and our website.

RADON GAS POLICY

1. Purpose

1.1 The purpose of this policy is to outline and communicate our policy in respect of how we deal with Radon Gas. It will be made accessible to officers within the Association who have specific compliance responsibility. All operational managers will be required to acknowledge the Radon procedure.

1.2 The Head of Maintenance and Compliance Manager are responsible for ensuring that they have a good working knowledge of this policy and any subordinate policies, procedures and associated guidelines.

1.3 This policy, and subordinate policies, will also be brought to the attention of contractors working on behalf of the Association, where it is deemed necessary.

2. Relevant Legislation

2.1 CCHA, as a landlord, has a number of legal obligations it must satisfy to ensure the health, safety and welfare of its customers. These obligations form part of an ongoing cyclical inspection and maintenance regime to ensure that key elements in the homes that we manage do not pose undue risk.

2.2 In respect of Radon Gas these obligations are represented in statute in the Housing Act (Duty of Care) 2004 which states the importance of providing a safe home.

2.3 CCHA will employ the Check, Measure, Act method towards Radon Gas, as recommended by Public Health England (PHE).

3. Identifying and testing of effected properties

3.1 PHE has been engaged to carry out a postcode indicative search; this has provided us with the worst case Radon potential for any property sharing a specific postcode. The results of this initial test have dictated the approach we have used to assess the risk of Radon and, in turn, will inform the remedy of any potential issues.

3.2 These searches have highlighted 288 properties, that which fall within the two highest Radon risk bandings. Of which, 3 properties have had remedial works carried out.

3.3 There are 810 properties which fall in the lower risk bandings. These properties will be tested over a 5 year period using a methodology agreed by PHE 199 properties fall within risk banding 3 and will be tested during 2020/21 We are awaiting further engagement from PHE, which has been delayed as a result of PHE being focused on managing the COVID-19 pandemic.

3.4 When testing is required, this will be carried out by measuring the Radon Gas levels in the living area and bedroom of a property, for 3 months. These results will be used to calculate an estimated annual average. This estimated annual average value can then be compared to the action level on which the decision to take further action can be based. Testing equipment and analysis of results will be carried out through PHE and will follow their approved guidelines.

3.5 In blocks of flats, we will not monitor the upper storey flats. If the Radon levels on the ground floor are low then it is most likely that the upper storeys will also be low. If there are high Radon levels on the ground floor, any remediation should also fix the Radon levels for the upper storey flats.

4. Remedial Measures

4.1 There are several approaches to choose from when implementing remedial measures to affected properties. Depending on the results of the Radon testing, and the confirmation of the number of properties affected, one, or a combination of the options, as agreed through CCHA’s Audit & Risk Committee will be implemented.

4.2 Lowering Radon levels is achieved by either reducing the amount of gas being drawn into the property (under floor ventilation, sumps) or by diluting the gas within the building (positive ventilation). Each property will be assessed individually and advice will be sought from PHE and the Building Research Establishment, as required.

FIRE EVACUATION STRATEGY

1. Introduction

1.1 Castles & Coasts Housing Association (CCHA) employs a Fire Evacuation Strategy that takes into account the individual needs of each resident and scheme to ensure that we maintain the best possible safety standards for our residents.

1.2 As CCHA owns and manages a number of different schemes with communal areas, with regards to fire evacuation procedures, these have been grouped into categories to ensure that the most suitable strategy is assigned to each. These decisions and categorisations are based upon the resident demographic and their ability to evacuate in an emergency situation.

2. Definitions

2.1 Simultaneous Evacuation

2.1.1Strategy in which all parts of a building are evacuated in the event of fire at one time.

2.2 Stay Safe Evacuation

2.2.1A Stay Safe Strategy involves the following approach:

• When a fire occurs within a flat, the residents alert others in the flat, make their way out of the building and summon the Fire and Rescue Service

• If a fire starts in the common parts, anyone in these areas makes their way out of the building and summons the Fire and Rescue Service

• Any residents not able to descend from the upper floors should have access to a place of safety, usually located within a protected stair, where they can temporarily await assistance in exiting the building

• All other residents, not directly affected by the fire, would be expected to ‘stay put’ and remain in their flat unless directed to leave by the Fire and Rescue Service or become directly affected by the fire

2.2.2A Stay Safe Strategy does not imply that those not directly involved should be prevented from leaving the building if they wish to do so. Nor does the strategy preclude those evacuating a flat that is on fire from alerting their neighbours so that they can also escape if they feel threatened.

2.3 Personal Emergency Evacuation Plan

2.3.1A Personal Emergency Evacuation Plan (PEEP) is a plan to identify any specific needs of residents to allow them to evacuate if required in the event of an emergency. These are required for all individuals who may have difficulties evacuating a building in an emergency situation. These are to be carried out in person, within the specific flat, so that any potential other factors such as smoking and hoarding can be identified and risk assessed.

2.3.2Appendix 1 details the procedure to be followed when carrying out a PEEP.

2.4 Fire Action Notices

2.4.1Fire Action Notices are designed to clearly inform what actions should be taken during an emergency event of a fire. Fire action signs should work in conjunction with other emergency signage to let residents and visitors know the fire evacuation procedure.

2.4.2Examples of Stay Safe and simultaneous Fire Action Notices can be seen at Appendix 2 and 3.

2.5 Fire Risk Assessment

2.5.1A Fire Risk Assessment (FRA) is a review undertaken of a scheme in order to assess its fire risk and offer recommendations to make the building safer, if necessary. This must be reviewed on a regular basis.

3. General Needs blocks with no lifts

3.1 Strategy

3.1.1Simultaneous Evacuation

3.2 Justification

3.2.1Given the nature of the schemes and assumed resident demographic the evacuation strategy for these schemes is to be simultaneous evacuation. This assumes that all residents will have the ability to self-evacuate in the event of an emergency, given their occupation of the building requires no additional measures such as stairlifts or passenger lifts.

3.3 Control Measures

3.3.1The following control measures will be implemented in all these schemes to maintain a Simultaneous Evacuation Strategy:

• Fire Alarm - The fire alarm will be regularly maintained and serviced in line with current standards and regulations to ensure that all residents will be notified in the event of an activation

• Emergency lighting – Emergency lighting will be provided to all communal areas and exit routes. These will be maintained and serviced in line with regulations to ensure that safe evacuation from the building is possible during non-daylight hours

• Fire Action Notices – Notices will be strategically placed around the communal areas of the schemes, generally by fire alarm call points and exits to ensure that residents and visitors are aware of the strategy for the scheme

• FRA – FRAs will be carried out to ensure the ongoing safety of all residents and will also confirm that the evacuation strategy for the scheme is suitable and sufficient

• Resident Communication - Annual communication will be made to residents to confirm the strategy for the scheme and request residents contact us with any concerns

3.4 PEEPS

3.4.1Given the assumption that all residents within these schemes can self-evacuate, no PEEPS will be routinely carried out. However, as part of the annual confirmation of the evacuation strategy residents will be asked to contact CCHA should they feel they would not be able to abide by the evacuation strategy. This will also include an agreement that they are able to identify/hear the fire alarm to allow the evacuation to take place when required. Should any staff be notified or identify residents who may need additional support these are to be notified to the relevant Lettings & Neighbourhoods Officer to confirm if a PEEP is required to be undertaken. Appendix 4 includes a draft letter template for this communication. In these instances, a PEEP will be carried out on the specific resident and Personal Action Plan agreed, which may be re-housing to more suitable accommodation or additional safety measures.

4. General Needs Blocks with a Lift

As the design and occupation of each of these schemes differ a strategy has been designated for each.

4.1 Derwent Close

4.1.1Strategy

Currently the scheme is Simultaneous Evacuation but as scheme design and current resident needs dictate, Stay Safe may be more suitable. To enable a Stay Safe policy, further confirmation on the extent of fire protection behind the cladding system is required. The following will apply once confirmed satisfactory, until then, the scheme will remain Simultaneous Evacuation.

4.1.2Justification

Given the nature of the design of the scheme and that several residents are currently unable to self-evacuate in the event of an emergency the evacuation strategy for this scheme is to be Stay Safe evacuation.

4.1.3Control Measures

The following control measures will be implemented to all the scheme to implement a Stay Safe Evacuation Strategy:

• Fire Alarm - The fire alarm will be regularly maintained and serviced in line with currently regulations to ensure that all residents will be notified in the event of an activation. Remote

monitoring to be investigated to ensure prompt notification to Fire and Rescue Services in the event of activation

• Emergency lighting – Emergency lighting will be provided to communal areas and maintained and serviced in line with regulations to ensure that safe evacuation from the building is possible during non-daylight hours

• Fire Action Notices – Notice will be strategically placed around the communal areas of the schemes, generally by fire alarm call points and exits to ensure that residents and visitors are aware of the strategy for the scheme

• FRA – FRAs will be carried out to ensure the ongoing safety of all residents and will also confirm that the evacuation strategy for the scheme is suitable and sufficient

• Refuge Points – Refuge Points are to be maintained as sterile and the emergency voice communication is connected to a remote monitoring station. Also monitored to ensure that the number of residents per floor unable to self-evacuate downstairs does not exceed the allowance of the refuge area

• Compartmentation Surveys – Surveys will be carried out to ensure that the building allows residents to stay safe in the event of an emergency. Each flat is to provide a minimum of 60 minutes protection in the event of a fire

• Fire Drills - An annual evacuation strategy will be carried out on all schemes to confirm that residents are able to abide by the strategy. This will be monitored to ensure the strategy is followed, if not additional communication will be made to residents to reiterate the strategy

• Fire Document Box – Boxes are installed at the entrance to all schemes and contain a ‘traffic light’ coding of the PEEPS so that the Fire and Rescue Service are able to promptly identify resident who may require additional assistance

• Resident Communication - Annual communication will be made to residents to confirm the strategy for the scheme and request residents contact us with any concerns

4.1.4PEEPS

PEEPS will be carried out in person for all residents by Housing Services, annually or sooner, should there be any substantial changes in residents which may affected their ability to evacuate or increase the fire risk in the scheme. Each PEEP will provide a rating for the resident of red, amber or green. Any amber or red rated residents will be subject to a collaborative review by Compliance, Lettings & Neighbourhood and Health & Safety Teams, to ensure that any additional safety measures are implemented, and any outcomes documented.

4.2 Cedric Walk x 2

4.2.1Strategy Simultaneous Evacuation

4.2.2Justification

The design of the building and all safety features is to accommodate a Simultaneous Strategy.

4.2.3Control Measures

The following control measures will be implemented to all the scheme to maintain a Simultaneous Evacuation Strategy:

• Fire Alarm - The fire alarm will be regularly maintained and serviced in line with currently regulations to ensure that all residents will be notified in the event of an activation

• Emergency lighting – Emergency lighting will be provided to communal areas and maintained and serviced in line with regulations to ensure that safe evacuation from the building is possible during non-daylight hours

• Fire Action Notices – Notices will be strategically placed around the communal areas of the schemes, generally by fire alarm call points and exits to ensure that residents and visitors are aware of the strategy for the scheme

• FRA – FRAs will be carried out to ensure the ongoing safety of all residents and will also confirm that the evacuation strategy for the scheme is suitable and sufficient

• Resident Communication - Annual communication will be made to residents to confirm the strategy for the scheme and request residents contact us with any concerns

4.2.4PEEPS

PEEPS will be carried out in person for all residents by Housing Services, annually or sooner, should there be any substantial changes in residents which may affected their ability to evacuate or increase the fire risk in the scheme. Each PEEP will provide a rating for the resident of red, amber or green. Any amber or red rated residents will be subject to a collaborative review by Compliance, Lettings & Neighbourhood and Health & Safety Teams, to ensure that any additional safety measures are implemented, and any outcomes documented.

4.2.5Residents Unable to comply with strategy

Where it is identified that current residents are unable to meet the requirements of the Simultaneous Evacuation Strategy along with the mitigation options detailed later in this document, specifically for Cedric Walk Close, the following would be required as a minimum to allow a Stay Safe Strategy:

• Design and installation of safe refuge areas on each floor with emergency communication A feasibility study would be required to ensure that the scheme could accommodate

• Improved level of fire compartmentation

• Upgrade of the fire alarm system to ensure correct cause and effect

4.3 Thornbury

4.3.1Strategy

Simultaneous Evacuation

4.3.2Justification

The design of the building and all safety features is to accommodate a Simultaneous Strategy.

4.3.3Control Measures

The following control measures will be implemented to the scheme to maintain a Simultaneous Evacuation Strategy:

• Fire Alarm - The fire alarm will be regularly maintained and serviced in line with currently regulations to ensure that all residents will be notified in the event of an activation

• Emergency lighting – Emergency lighting will be provided to communal areas and maintained and serviced in line with regulations to ensure that safe evacuation from the building is possible during non-daylight hours

• Fire Action Notices – Notices will be strategically placed around the communal areas of the schemes, generally by fire alarm call points and exits to ensure that residents and visitors are aware of the strategy for the scheme

• FRA – FRAs will be carried out to ensure the ongoing safety of all residents and will also confirm that the evacuation strategy for the scheme is suitable and sufficient

• Resident Communication - Annual communication will be made to residents to confirm the strategy for the scheme and request residents contact us with any concerns

4.3.4PEEPS

PEEPS will be carried out in person for all residents by Housing Services, annually or sooner, should there be any substantial changes in residents which may affected their ability to evacuate or increase the fire risk in the scheme. Each PEEP will provide a rating for the resident of red, amber or green. Any amber or red rated residents will be subject to a collaborative review by Compliance, Lettings & Neighbourhood and Health & Safety Teams, to ensure that any additional safety measures are implemented, and any outcomes documented.

4.3.5Residents Unable to comply with strategy

Where it is identified that current residents are unable to meet the requirements of the Simultaneous Evacuation Strategy along with the mitigation options detailed in this document,

specifically for Thornbury, the following would be required as a minimum to allow a Stay Safe Strategy:

• Design and installation of safe refuge areas on each floor with emergency communication. A feasibility study would be required to ensure that the scheme could accommodate given there is only a single escape stair

• Improved level of fire compartmentation

• Upgrade of the fire alarm system to ensure correct cause and effect

• Likely replacement of fire doors on the scheme

5. Independent Living with Flats Opening onto a Communal Area

5.1 Strategy

Stay Safe Evacuation

5.2 Justification

Given the nature of the schemes and assumed resident demographic the evacuation strategy for these schemes is to be Stay Safe Evacuation. This is based on the assumption that residents are likely to be unable to self-evacuate in the event of an emergency and should they do so, would potentially hinder the emergency services.

5.3 Control Measures

The following control measures will be implemented to all these schemes to maintain a Stay Safe Evacuation Strategy:

• Fire Alarm - The fire alarm will be regularly maintained and serviced in line with currently regulations to ensure that all residents will be notified in the event of an activation. Cause and effect to be set-up so that correct notification is given to residents

• Emergency lighting – Emergency lighting will be provided to communal areas and maintained and serviced in line with regulations to ensure that, should it be required, evacuation from the building is possible during non-daylight hours.

• Fire Action Notices – Notices will be strategically placed around the communal areas of the schemes, generally by fire alarm call points and exits to ensure that residents and visitors are aware of the strategy for the scheme

• FRA – FRAs will be carried out annually out to ensure the ongoing safety of all residents and will also confirm that the evacuation strategy for the scheme is suitable and sufficient

• Compartmentation Surveys – Surveys will be carried out on all of these schemes to ensure that the building allows residents to stay safe in the event of an emergency. Each flat is to provide a minimum of 60 minutes protection in the event of a fire

• Fire Drills - An annual evacuation strategy will be carried out on all schemes to confirm that residents are able to abide by the strategy. This will be monitored to ensure strategy is followed, if not, additional communication will be made to residents to reiterate the strategy. It is proposed that these are added to the schemes module within Open Housing to ensure that a reminder is provided and these are completed when required

• Regular safety checks – Wellbeing & Compliance Assistants (W&CA) will carry out regular checks of the communal areas to ensure the scheme still allows the Stay Safe Strategy

• Fire Document Box – Boxes are installed at the entrance to all schemes and contain a ‘traffic light’ coding of the PEEPS so that the Fire and Rescue Service are able to promptly identify resident who may require additional assistance. Procedure and Out of Hours contact details are to be fixed to the box to ensure these are available if required in an emergency

5.4

PEEPS

PEEPS will be carried out for all residents by W&CAs annually, or sooner, should there be any substantial changes in residents which may affected their ability to evacuate or increase the fire risk in the scheme. Each PEEP will provide a rating for the resident of red, amber or green. Any amber or red rated residents will be subject to a collaborative review by Compliance,

Independent Living and Health & Safety Teams to ensure that any additional safety measures are implemented, and any outcomes documented.

6. Independent Living Schemes without flats directly accessing a communal area

6.1 Schemes

Sneckyeat, Upperby Court, Victoria Court, Ellen Court, Castle Gardens

6.2 Strategy

Simultaneous Evacuation

6.3 Justification

The design of the building and all safety features is to accommodate a Simultaneous Strategy. Given that all flats have independent access to outside.

6.4 Control Measures

The following control measures will be implemented to the scheme to maintain a Simultaneous Evacuation Strategy:

• Fire Alarm - The fire alarm will be regularly maintained and serviced in line with currently regulations to ensure that all residents will be notified in the event of an activation

• Emergency lighting – Emergency lighting will be provided to communal areas and maintained and serviced in line with regulations to ensure that safe evacuation from the building is possible during non-daylight hours.

• Fire Action Notices – Notices will be strategically placed around the communal areas of the schemes, generally by fire alarm call points and exits to ensure that residents and visitors are aware of the strategy for the scheme

• FRA – FRAs will be carried out to ensure the ongoing safety of all residents and will also confirm that the evacuation strategy for the scheme is suitable and sufficient

• Regular safety checks - Wellbeing & Compliance Assistants (W&CA) carry out regular checks of the communal areas to ensure the scheme still allows the Stay Safe Strategy

• Fire Document Box – Boxes are installed at the entrance to all schemes and contain a ‘traffic light’ coding of the PEEPS so that the Fire and Rescue Service are able to promptly identify resident who may require additional assistance. Procedure and Out of Hours contact details is to be fixed to the box to ensure these are available if required in an emergency

6.5 PEEPS

PEEPS will be carried out for all residents by W&CAs annually, or sooner, should there be any substantial changes in residents which may affected their ability to evacuate or increase the fire risk in the scheme. Each PEEP will provide a rating for the resident of red, amber or green. Any amber or red rated residents will be subject to a collaborative review by Compliance, Independent Living and Health & Safety Teams to ensure that any additional safety measures are implemented, and any outcomes documented.

7. Extra Care Schemes - Greta Gardens

7.1 Strategy Stay Safe Evacuation

7.2 Justification

Given the nature of the schemes and assumed resident demographic the evacuation strategy for these schemes is to be Stay Safe Evacuation. This is based on the assumption that residents are likely to be unable to self-evacuate in the event of an emergency and should they do so, would potentially hinder the emergency services.

7.3 Control Measures

The following control measures will be implemented to all these schemes to maintain a Stay Safe Evacuation Strategy:

• Fire Alarm - The fire alarm will be regularly maintained and serviced in line with currently regulations to ensure that all residents will be notified in the event of an activation. Cause and effect to be set- up so that correct notification is given to residents

• Emergency lighting – Emergency lighting will be provided to communal areas and maintained and serviced in line with regulations to ensure that should it be required evacuation from the building is possible during non-daylight hours.

• Fire Action Notices – Notices will be strategically placed around the communal areas of the schemes, generally by fire alarm call points and exits to ensure that residents and visitors are aware of the strategy for the scheme

• FRA – FRAs will be carried out annually to ensure the ongoing safety of all residents and will also confirm that the evacuation strategy for the scheme is suitable and sufficient.

• Compartmentation Surveys – Surveys will be carried out on all of these schemes to ensure that the building allows residents to stay safe in the event of an emergency. Each flat is to provide a minimum of 60 minutes protection in the event of a fire.

• Fire Drills - An annual evacuation strategy will be carried out on all schemes to confirm that residents are able to abide by the strategy. This will be monitored to ensure strategy is followed, if not, additional communication will be made to residents to reiterate the strategy. It is proposed that these are added to the schemes module within Open Housing to ensure that a reminder is provided, and these are completed when required

• Regular safety checks - Scheme staff carry out regular checks of the communal areas to ensure the scheme still allows the Stay Safe strategy

• Fire Document Box – Boxes are installed at the entrance to all schemes and contain a ‘traffic light’ coding of the PEEPS so that the Fire and Rescue Service are able to promptly identify resident who may require additional assistance. Procedure and Out of Hours contact details is to be fixed to the box to ensure these are available if required in an emergency

7.4 PEEPS

PEEPS will be carried out for all residents by the Scheme Manager and W&CA annually, or sooner, should there be any substantial changes in residents which may affected their ability to evacuate or increase the fire risk in the scheme. Each PEEP will provide a rating for the resident of red, amber or green. Any amber or red rated residents will be subject to a collaborative review by Compliance, Independent Living and Health & Safety Teams, to ensure that any additional safety measures are implemented, and any outcomes documented.

8. Supported Living Schemes

8.1 Strategy

The responsibility and management of the evacuation strategy for these schemes is with the individual care providers.

8.2 Justification

Given the responsibility for the evacuation of residents is with the care provider they are required to ensure suitable evacuation processes are in place.

8.3 Control Measures

CCHA will implement the following control measures to these schemes:

• Emergency lighting – Emergency lighting will be provided to communal areas and maintained and serviced in line with regulations to ensure that, should it be required, evacuation from the building is possible during non-daylight hours

• FRA – FRAs will be carried annually out to ensure the ongoing safety of all residents and will also confirm that the evacuation strategy for the scheme is suitable and sufficient

• Regular review meetings - Housing Services will carry our regular service review meetings with care providers to ensure that they are abiding by their obligations and that no concerns are highlighted

8.4 PEEPS

The responsibility of the PEEPS will be with the care provider.

8.5 Fire Detection

Given the classification of the detection it will be the service providers requirement to carry out testing monthly, with all results being recorded. Should any defects be identified these are to be notified to CCHA.

9. Possible Mitigations of Risk

9.1 In instances, whereby residents are not able to abide by the evacuation strategy of their scheme Mitigation of Risk is likely to be required and based upon the PEEPS. Possible mitigation options are as follows, and would be decided upon collaboratively between Compliance, Housing Services and Health & Safety Teams:

• Provision of a safe refuge area within a protected stairway or lobby, where possible

• Sprinklers or water-mist systems

• Personal protection water-mist systems

• Ignition resistant bedding

• A Safe Smoking Strategy and provision of metal bins for the safe disposal of cigarettes

• A Safe Cooking Strategy, which might include automatic isolation devices

• Reduction in the quantities of combustible materials in the accommodation of a Hoarder

• Acknowledge that the current building does not support the needs of the resident and requires moving to more suitable accommodation

10. New Residents

10.1 Prior to being granted a new tenancy in a block of flats it is to be confirmed that they are able to meet the evacuation strategy for the scheme.

11. Information which Could Affect Evacuation Procedures

11.1 A major factor on the suitability of the current evacuation strategy of a scheme is the fire alarm activations including any false alarms. Therefore, should staff be notified of these, a T100 near miss form is to be completed which will also be issued to the Compliance Team. This will ensure that these are included in the review of any mitigation factors a scheme may require.

12. Review of Evacuation Strategy

12.1 The evacuation strategy will be continually reviewed to ensure it is maintained suitability for the residents and the scheme, this review will be carried out when:

• Red and amber PEEP reviews take place

• Should any significant fires be reported

• Should any significant remodelling take place within the scheme

The review will include Compliance, Housing and Health & Safety Teams.

13. Leaseholders

13.1 Whether it be full leasehold schemes or leaseholders within a block it is likely that leaseholders will be affected by the strategies to be adopted. In these instances, given the limited jurisdiction, CCHA holds as to how they occupy the property. Any instances whereby it is identified that the leaseholder cannot comply with the schemes evacuation strategy these are to be reviewed on a case-by-case basis by the Leasehold Team to ensure that appropriate action is taken.