Housing Health & Safety Rating System: Review Outcomes and Next Steps
The Department for Levelling Up, Housing & Communities has recently issued a policy paper outlining the outcomes of a review into the operation of the HHSRS. This will likely lead to significant changes to the system, which could impact everyone involved with housing standards. Here we will look at what the review has found and how the HHSRS could be changed in future.
The HHSRS – the story so far
It is now almost two decades since the Housing Health & Safety Rating System was introduced by the Housing Act 2004, subsequently coming into use in 2006. Since that time it has become the focus of how local authorities assess, and enforce, housing standards. Broadly it is well understood by housing professionals, but often less so by landlords and rarely by tenants.
As many readers will know, the HHSRS does not set a minimum standard as such. Rather it is a risk based assessment system. It covers 29 potential hazard categories or profiles which are scored and banded from A-J using a fairly complex system. It identifies both category 1 and category 2 hazards with local authorities being compelled to act where the former are found.
Notably, the HHSRS is a key part of the Decent Homes Standard in the social sector with properties being required to be free of category 1 hazards.
Reforming the rented sector and reviewing the HHSRS
The review of the HHSRS is part of a wider government move to reform the rental sector.
These include a review of the Decent Homes Standard under the charter for social housing residents, as well as the 2022 white paper on creating a fairer private rented sector. This included a proposal to extend the Decent Homes Standard into the private rented sector.
Background to the review
The government commenced what was known as a scoping review in 2018 to look at whether the HHSRS should be updated, and to what extent. This included a consultation exercise in 2019.
The recent policy paper suggests this process revealed that stakeholders in the housing sector held mixed opinions about the HHSRS. That it links health and housing was broadly supported, as was the way it allows properties to be assessed on their merits. However, local council officers said they found the system complicated to apply and full assessments demanding in terms of resources. Housing providers and tenants found it difficult to understand the outcomes of assessments and felt that there was a discrepancy between the assessment process and other regulatory regimes in housing.
The policy paper says that there was majority support for setting actual standards that could be met to supplement the assessment of risk-of-harm basis of the current HHSRS. It said that all stakeholders would like to see a simplification of the assessment process.
Subsequently the government undertook a review of the operation of the HHSRS. The aims were not only to update it, but to empower landlords and tenants to engage with the system, ensure alignment with other rules and regulations (including the Building Safety Act) and aid the enforcement of housing standards.
Very significantly, with a view to introducing an additional standards-based approach, the review defined what are being called indicative baselines – more information on these later.
The review also looked at possible barriers to the use of digital technology in assessments.
External researchers RH Environmental (RHE) were contracted to undertake the review which lasted two years and concluded in 2022. RHE retained outside expertise including academics. Over a thousand stakeholders with specialist experience and relevance to the HHSRS and housing sector contributed to the process which included local councils, landlords and tenants.
It is important to note that the enforcement of housing standards was not within the scope of this review.
Findings of the review into the HHSRS
The findings of the review are known as review outputs and cover four separate areas:
Key changes
The paper proposes some key changes to make the Housing Health & Safety Rating System assessment process more efficient and more accessible:
Reducing the number of hazard categories from 29 to 21 by amalgamating some categories.
Introducing a simpler way of banding the results of the HHSRS assessment.
The introduction of baselines to help landlords and tenants understand the system. These can be used to make an initial assessment as to whether a property has serious hazards. They will be used alongside rather than replace risk assessments.
Producing new statutory guidance for assessments and enforcement, to aid consistency and timeliness. This will include new case studies.
Developing the use of digital assessment methods.
Reviewed training requirements and competency frameworks for professionals.
Changes to make sure hazards in tall buildings can be assessed effectively. (A change driven by the 2017 Grenfell Tower tragedy).
Improving access to the system
New indicative baselines
To make it easier for landlords and tenants and other non-experts to understand the system it is proposed a checklist could be used to make an initial assessment. This would not replace risk assessment, but make it easier to see ‘at a glance’ that a property is free from the more serious category 1 hazards.
Reviewed guidance
Reviewed and updated HHSRS operating and enforcement guidance for landlords and property-related professionals will be published. This will be done in the form of three Housing Health and Safety Inspection and Assessment Manuals.
There will also be separate guidance for tenants to help them understand the system and empower them to make use of it.
New case studies and worked examples will be issued, including in digital format.
Improving the system for use by local councils and other property professionals
Simpler means of banding
The policy paper proposes a simpler means of banding the results of HHSRS assessments. The aim is to make the assessment process both more efficient for local authorities and more accessible to landlords and tenants.
Very significantly, the proposals suggest removing scoring ranges for each representative scale point to simplify the assessment process.
The review found that colour coding and the use of so-called descriptor terms aided both in an assessment and in the understanding of the scoring report by non-experts. It proposes replacing the way the severity of a hazard is described (currently Class I-IV) with descriptions ranging from ‘extreme’ to ‘moderate’. It proposes the use of colour coding to grade the seriousness of the hazard score with a traffic light system.
Reviewed HHSRS training requirements and competency frameworks
This will include a review of Environmental Health degree programmes, accredited HHSRS-specific short courses, ongoing HHSRS courses and the development of a graduated scale of competency framework.
Improving the underlying system
Amalgamation/removal of hazard profiles
A thorough process was followed to decide how hazard profiles could be streamlined without compromising them. It is suggested that the following categories will be combined:
Collision and Entrapment and Position and Operability of Amenities
Uncombusted Fuel Gas, Biocides, Carbon Monoxide and Fuel Combustion Products and Volatile Organic Compounds
Fire and Explosions
Falls Associated with Baths and Falls on Level Surfaces
Food Safety and Domestic Hygiene, Pests and Refuse plus Personal Hygiene, Sanitation and Drainage
The fire safety hazard
Again, a review of the Fire Safety Hazard was conducted in light of the Grenfell tragedy to ensure the risk of fire in tall buildings can be assessed effectively. The recommendation is to amalgamate it with Explosions in Dwellings.
What happens next
When they come into force the proposed changes will represent a shift change in assessments under the HHSRS.
It is important to note that none of the proposed changes are in force yet, nor is there a target date to do so. What is called a new affirmative statutory instrument will be needed before that can happen.
The DLUHC has said that changes to the HHSRS will not take place until the conclusion of the review of the Decent Homes Standard.
Summary
It is likely that the proposed changes to the Housing Health & Safety Rating System will be welcomed overall. Rather than changes which have just been handed down the proposals are based on many years of what has been found to work well, and what has not. The changes will mean some considerable relearning will need to be done in the housing sector, and some time will be needed for adjustment. Ultimately though they could offer benefits both in terms of efficiency and in raising housing standards.
Lastly, the impact of the planned extension of the Decent Homes Standard into the PRS alongside the new HHSRS shouldn’t be overlooked. While the social sector will be impacted by changes to the HHSRS this extension of the standard to cover both sectors will represent a significant change for the PRS.
A copy of the full policy document can be accessed here: Summary report: outcomes and next steps for the review of the Housing Health and Safety Rating System (HHSRS)
How Surrey Property Licensing can help
HMO landlords are most likely to come into contact with the Housing Health and Safety Rating System when the local authority conducts a compliance inspection of their HMO or, potentially, if someone complains about the rented property. You can instruct us to inspect your property and produce a report that identifies the necessary steps (including the identification of Category 1 Hazards) to be taken to reduce specific or inherent risks to a minimum and comply with specific standards.
To book in an inspection please call 01483 608975 or use our contact form and a member of the team will come back to you.
