Housing Safety: Are we doing enough?
If you are reading this article, you must be interested in ensuring that the homes we build and those we refurbish for people to live in are optimally safe to live in. We are not just talking about fire safety and mould/damp here (which are important), but all other housing safety matters, some of which result in more fatalities/NHS emergency admissions every day.
It is difficult to imagine that in the UK, there are in fact more accidents recorded in our homes than on the roads. The Royal Society for the Prevention of Accidents (ROSPA) stated in its “Safety by Design” publication that : “The home is the most common location for accidents, resulting in around 6,000 deaths annually in the UK. Children under five years old and older adults (especially those over 75) are most likely to have accidents at home”.
ROSPA goes on to state that home accidents account for over 40% of all A&E admissions and that homes are statistically more dangerous than UK workplaces!
Improvements in road safety continue to grow through legislation, enforcement, improved road user awareness, road infrastructure improvements and other road safety measures. However, it is my view that efforts aimed at preventing accidents in our homes remain inadequate, disjointed and at best reactionary.
Take the Building Safety Act for example. Although it suggests the Act is about building safety, but in reality, the Act focuses primarily on fire safety and structural collapse. This perhaps underpins its reactionary nature on the back of Grenfell.
The causes of accidents in homes go beyond fire protection and structural stability defects and/or management inadequacies however – as evidenced by the statistics of accidents in our homes. ROSPA’s research indicates that for every fire-related hospital admission, there are 234 which are due to falls!
ROSPA’s “Safety by Design” Publication distils the Housing Health & Safety Rating System (HHSRS) 29 hazard categories into nine key hazards (five of which are falls related), namely:
Falls on internal stairs.
Falls on external stairs.
Falls on the level.
Falls between levels
Falls in bathrooms.
Carbon monoxide poisoning.
Entrapment with doors.
Contact with hot surfaces.
Poisoning from household chemicals.
Whilst ROSPA’S initiative in attempting to create a framework for building safer homes is laudable, its “Safer by Design” proposals do need to be filtered through updates to the Building Safety Act, or as a minimum filtered through updates to the Building Regulations. The disjoint between legislation and good practice can only be bridged in this way.
Good practice recommendations in housing design and construction should be considered wholesomely and decisions on good practices to be filtered through legislation should be evidence-based. For example, whilst the HHSRS recommends a minimum 1100mm for balcony guarding, ROSPA recommends 1250mm. I would support a 1250mm guarding height as a better risk mitigation initiative.
Although not well publicised, there are planned changes to the HHSRS - linked to the BSA & Updates planned for the Decent Homes Standards (& I suspect the upcoming Future Homes Standard). Some of the likely changes include:
Hazard amalgamation/re-grouping to reduce the total number from 29 to 21 (e.g., amalgamating the ‘Fire’ hazard with ‘Explosions in Dwellings’ to ensure the risk of fire in tall buildings can be assessed effectively.
Changing the current banding system by adding a third category.
New baseline assessment guidance to be provided.
New enforcement guidance with case studies to be published.
My hope is that those changes will include better alignment with ROSPA’s evidence-based proposals.
Another example is the divergence between the Building Regulations approved documents (on the one hand) and the HHSRS and ROSPA’s evidence-based recommendations on the other – with respect to addressing the risk of falls between levels (through windows). Building Regulations stipulate 800mm minimum, whilst 1100mm is recommended in the HHSRS and by ROSPA (in addition to other risk mitigation measures to prevent falling through windows).
Although, still under investigation, the unfortunate recent death in May 2024 of Aalim Ahmed who reportedly fell through a kitchen window of a 15th-storey flat in Plaistow, was a trigger for me writing this article as there are preliminary reports about inadequacies in the window design/safety. As a people, we simply cannot be reactionary in facilitating safety in our homes. It is time to address evident shortcomings in home safety- whether new build or in existing stock….and that goes beyond addressing fire-related risks!
For new developments, Incorporating a provision in Employer’s Requirements for designing out all category 1 HHSRS hazards should be the default, but beyond that Housing Associations, Local Authorities, House Builders and other developers should ensure they have inhouse or have engaged competent consultants to support the design team in achieving this objective. Given the wide-ranging obligations in the BSA requiring a duty of care and compliance with necessary regulations, I think it is important for LA’s & HA’s especially, to ensure their appointed consultants have the competence to provide this service.
For existing stock, your stock condition surveys cannot just be business as usual – i.e. assessing the condition of the stock and proposing remedial/improvement works. To be cost-effective and ensure regulatory compliance, stock condition surveys should be extended to include HHSRS assessments – bearing in mind that the Decent Homes standard incorporates the HHSRS, under the Housing Act 2004. Your estate regeneration projects will equally benefit from this. Compliance is not optional, and all Local Authorities have enforcement powers to ensure compliance with the HHSRS.
Assessing potential hazards under HHSRS requires specific skill sets, which, since my road show delivering talks in 2006/2007 on the application of the HHSRS, still appears lacking in the industry. Some designers are not even aware of it and some clients still think it does not apply to new developments!
Quite simply, it applies to all housing and its application becomes effective once the development is occupiable- so it is prudent to avoid hazard liabilities following completion by ensuring the design addresses these matters prior to build and ensuring compliance throughout the build stage.
Safety in homes is a cause we should not pay lip service to, and the good news is that ensuring optimum safety (beyond fire safety) is commercially viable to achieve. We need to do more.
Worth remembering also that compliance with the Building Regulations does not currently mean compliance with the Housing Act 2004 (including the HHSRS and/or the Fire Safety Regulations).
Airey Miller is well positioned to assist with ensuring your existing stock and new build developments comply with the law and good practice in the provision of safe homes for residents. Clients choose us for a variety of reasons – including:
Our significant understanding of Total Quality Management (TQM)
Our track record in delivering truly successful developments and regeneration schemes and the added value we bring by being able to offer a truly multidisciplinary service to our clients from within the Airey Miller Group.
Our reputation for client care. We work with our clients not just for them. We understand how housing safety is best managed all through the project life cycle, not just at build stage!
’Kunle Awofeso
Director- Airey Miller
