Building safety policy

Date approved: May 2026
Review date: May 2027

See below for the full policy, but please be aware this may include acronyms or technical jargon used internally within Raven. If you have any questions, please contact us.

1. Purpose of the policy

1.1. It is the policy of Raven to ensure, so far as is reasonably practicable, that its operations and services are conducted in a manner that safeguards the health and safety of employees, residents, contractors, visitors, and all persons likely to be affected by our official activities, by managing all building-related risks to as low as reasonably practicable with suitably reduced risk to the environment.

1.2. Raven acknowledges its duty to comply with legislation and regulations, to consider official guidance, best practice, and accident reports, continuously review its policies, management plans and procedures and to make proactive improvements in Health and Safety standards. However, the aim of Building Safety at Raven is to go beyond simply achieving compliance with legislation. We aim to ensure our buildings are genuinely safe for our residents and users.

1.3. For the purposes of this document a building is defined as – a building’s structure, its’ grounds up to the boundary and any Raven-owned fences, walls, etc that define that boundary. This includes commercial premises, residential and communal areas, outbuildings, standalone pieces of land and other properties which Raven manages or controls including properties Raven leases to others who act as Landlord.

2. Scope of the policy

2.1. This policy sets out the management steps and actions Raven will take in relation to design, installation, management, and maintenance of key risks to ensure the safety of the buildings and its users.

2.2. Raven confirms acceptance of its Duty Holder responsibilities under the Health & Safety at Work, etc Act 1974 (HASAWA74) to ensure the safety of all persons likely to come into contact with their properties and undertakings. Raven’s Chief Executive shall be the named Duty-Holder. In addition to HASAW74, Raven’s acknowledgement extends to the legislation, regulations and official guidance listed in the individual sections below and, in greater detail, the associated management plan documents referred-to herein, including its duties under the Building Safety Act 2022.

2.3. The below areas of risk 1-10 have been identified by Raven as having significant potential impact to the business and therefore, whilst discussed in this policy, they each have their own management plan and / or procedure.

1. Asbestos Safety
2. Electrical Safety
3. Fire Safety
4. Gas (and Other Heating) Safety including CO detectors & smoke detectors.
5. Lifts and Powered Access Safety
6. Water Safety
8. Decent Homes Standard
9. Damp, Mould, and Condensation Management
10. Stock Condition Survey procedure which includes the Housing Health & Safety
Rating System
11. Construction Design and Management (CDM) Procedure

2.4. The following are further risks associated with Raven building compliance. They will be addressed within the Miscellaneous Building Safety Contracts Management Plan.

• Structural and General Safety of Properties
• Communal Balconies
• Disabled Living Adaptations
• Door Entry Systems and Call Systems
• Scheme Call Systems
• Fall Arrest Systems/ Scaffolding and Working at Height
• Playgrounds
• Radon

2.5. Raven acknowledges that, whilst the above, as defined under point 2.4, are either not specifically building-related or sufficiently major risks to warrant their own dedicated Policies and Management Plans / Procedures, they are identified as general Health & Safety risks relating to our properties and / or activities which require management to an As Low as Reasonably Practicable level (ALARP).

3. Policy statement (including key policy principles and compliance with legislation)

3.1. LEGISLATION (including associated acts, regulations, codes of practice, and British / EU standards, require management of the risk areas detailed in section 2.)

Raven meets legislative requirements by developing compliant management plans and documentation, planned preventive maintenance (PPM) routines, periodical external and internal audit, and inspection of key areas, employing competent staff, consultation with appropriate, competent external advisers, appropriate skills/work allocation, training, and knowledge.

Raven shall effectively manage data to ensure it is both accurate and timely for the purposes of monitoring, controlling, and reporting for the purposes of compliance. The detail of responsibilities for this is set out in the job descriptions for the roles below.

3.2. Keeping up to date with legislative changes and best practice

3.2.1. Raven’s Head of Corporate Health and Safety & Building Compliance (HHSBC), Health and Safety Manager (HSM), and management plan owners are responsible for monitoring legislative and regulatory changes and updating the policy owner to enable policy review with:

• Any aspect of Raven management, system or control that fails to comply with current legislation, regulation, guidance or accepted best practice.
• Any change in legislation, regulation, guidance or accepted best practice.
• Anything else sufficiently significant to warrant review of this Policy or the associated, subordinate management plan documents.

3.2.2. Raven also appoints specialist competent external advisors to assist in this respect where required.

3.2.3. Raven’s Leadership Team (LT) has oversight of this policy, with lead ownership held by the Director of Homes.

3.2.4. The H&S Committee is a consultative forum that enables members to raise staff related health and safety concerns and address matters that may require further review, consultation, and amendment of the policy.

3.2.5. The H&S Committee shall escalate, where deemed appropriate, any areas of emerging staff related health and safety risk to Leadership Team.

3.2.6. Business Management Team has a role in coordinating across the business, ensuring that delivery happens.

3.2.7. Raven also has a dedicated Fire Safety Committee, chaired by the Head of Corporate Health and Safety & Building Compliance. Its purpose is to deal with fire related issues within Raven supported by the specialist fire safety consultant, and it escalates any issues to LT.

3.2.8. Raven works in partnership with relevant authorities, agencies, consultants, enforcement bodies, resident forums, key stakeholders, and interested groups in all areas of this policy.

3.2.9. Raven recognises that our properties are also our residents’ homes, but where we have the right of access and if this is obstructed, Raven and its contractors shall not hesitate to take action to gain entry to our residents’ homes in accordance with the Access Procedure. We acknowledge the rights and responsibilities set in tenancy agreements / leases and we will take appropriate steps in accordance with the contract with customers and relevant legislation.

3.3. Roles and responsibilities

3.3.1. Detailed roles and responsibilities will be documented within each specific Management Plan and associated Operational Guidance. The overarching roles and responsibilities are as follows:

3.3.2. The Raven Board has overall responsibility for approving this policy, delegating responsibility for its implementation, monitoring its effectiveness at high level, and receiving assurance of compliance. The Raven Board will also ensure that there is a system in place that provides adequate protection from detrimental treatment or victimisation for anyone making disclosures that they genuinely believe to be necessary in the interests of safety.

3.3.3. The Audit Committee will be responsible for ensuring that the Raven Board receives the assurance it requires.

3.3.4. The Chief Executive Officer (CEO) is the accountable person for H&S at Raven, and for ensuring there is a Building Safety Policy in place and that responsibility for review and delivery is clearly allocated. The CEO will ensure that there is adequate resourcing to implement the policy, and that current performance and any issues in implementing the policy have adequate visibility at LT and Board. The CEO will also ensure that the strategic risk register reflects associated risks.

3.3.5. The Executive Director of Homes (DoH) will have overall responsibility for the delivery of the policy commitments described. The DoH will also monitor PIs and KPIs and ensure that these remain relevant, aligned to the risk and that areas of non-performance are recorded, reported, and escalated where required. All potential, material non-compliances will be reported to the CEO / LT irrespective of whether this relates to a KPI scrutinised by the LT or other groups. The DoH is also responsible for maintaining the departmental risk register and informing the CEO of changes to risk profile. The DoH will take responsibility for ensuring that new stock is adequately constructed, that all H&S compliance requirements are met during the period of Development team ownership, and handed over to Health & Safety & Compliance to ensure that the commitments in the policy can be met.

3.3.6. The Director of Resources and Deputy CE (RD) will take overall responsibility for planning and implementing the assurance activities described in this policy and for the effective upward reporting of performance. The RD will ensure that any issues arising from assurance activities are discussed, and that areas of non-performance are reported and escalated where required. The RD will also ensure that the resources needed to deliver the policy – as agreed by the Leadership Team – are included within the Business Plan.

3.3.7. The Executive Director of Customer Experience (EDCE) will take responsibility for ensuring that appropriate and proportionate tenancy enforcement action is taken to gain access where it is required to meet the commitments in this policy.

3.3.8. The Assistant Director of Asset Management (ADAM), Assistant Director of Property and Estate Services (ADPES), Head of Corporate Health & Safety and Building Compliance (HHSBC) and Assistant Director of Development & Sales (ADDS) are responsible for the day-to-day delivery of the policy and for the dissemination of information, problem solving and decision making for matters regarding delivery. They will ensure that any issues arising are escalated to the DoH.

3.3.9. All Directors will take responsibility for ensuring that the staff and contractors they employ have the skills, knowledge, and expertise necessary to deliver the commitments outlined in the policy. Directors will identify Competent Person(s) (internal or external) suitable for the delivery of specific tasks.

3.3.10. Competent Person(s) are required to carry out certain types of works or tasks within their area of work. The levels of competency differ from one area to another for example the competency of an Electrician will be different to that of the Building Compliance Surveyor. The competent persons will have a responsibility to identify any concerns about their own competency for the task that they being asked to undertake and recommend additional competency is procured where required.

3.3.11. Head of Corporate Health and Safety and Building Compliance (HHSBC) will ensure H&S policies, management plans and procedures are up to date and comply with current legislation and regulations and deliver a 3 yearly H&S action plan to The Board.

3.3.12. Health and Safety Manager (HSM) will ensure all health & safety procedures, risk assessments, method statements, COSHH Assessments comply with current legislation and are up to date, auditing, leading, checking and coordinating with other staff where necessary.

3.4. Data

3.4.1. Data management is acknowledged as a key risk in relation to meeting the requirements identified in this policy. Raven acknowledges that to meet its obligations it must maintain a robust approach to identifying the assets and components for which it has responsibility.

3.4.2. Raven will:

• Maintain an appropriate core property list and operate a controlled environment relating to additions, removals and amendments to key fields.
• Effectively bring new units into the stock and maintain a process that ensures appropriate handover.
• Develop attributes within the core property database for all properties that will indicate where it does and does not have a responsibility for the key activities described in the policy (e.g. landlords gas safety) and a controlled environment to maintaining them.
• Where a responsibility exists, maintain reportable and auditable information including, but not limited to, the unique property reference (UPRN); date of last test; date of next test, where required dates and evidence of attempts to gain access at each stage of the access procedure. Hold evidence (e.g. certification) to demonstrate the completion of any activity.
• Maintain up to date, reportable and auditable records of remedial works arising from an activity. The records will include: UPRN; detail of the work item required; if an unsafe situation was recorded and link to associated evidence; target completion date; person responsible; completion date and associated sign off; and evidence of completion.
• Document the approach to data management control in the Data Management Protocol and management plans relating to each specific area.

3.5. Competence

3.5.1. Raven will ensure that all persons engaged to undertake Building Safety activity are confirmed as competent to do so. It is however not possible to succinctly define competence requirements for all roles and activities outlined in this policy. In many areas, competence will be assessed based on skills, knowledge and experience as opposed to a single qualification or standard.

3.5.2. Raven has a system of Directors evaluating competence within their areas of responsibility and Competent Person(s) are required to highlight the limits of their competence. Specific detailed requirements will be set out in each individual Management Plan. We will confirm that these standards are met and hold evidence of persons being properly trained, experienced, and accredited in accordance with our minimum standards. The relevant Management Plan will also contain procedural detail as to how competency will be checked and how evidence of this will be retained.

3.5.3. For certain key activities highlighted in this policy overarching requirements are detailed in the commitments, but these are not intended to be exhaustive.

3.6. Training

3.6.1. All relevant staff involved in managing, overseeing, delivering, or administering this policy will be given appropriate training in their role. The People Team are responsible for maintaining a training matrix and will liaise with the HSM and managers to ensure appropriate training is provided and that refresher training is provided at regular intervals.

3.6.2. The CIOB Building Safety Manager training has been completed by the HHSBC to ensure Raven has competency in this area.

3.7. Assurance and performance monitoring

3.7.1. Robust management plans have been developed to ensure that Raven’s Board, as Duty Holder, will receive assurance of statutory, legislative, and regulatory compliance and to ensure that Building Safety performance, covered by this policy, is appropriately and transparently reported.

3.7.2. Assurance

3.7.2.1. Specific detailed arrangements for each individual policy area are provided within the attendant Management Plan that sits beneath this policy. Our overarching approach to providing assurance is outlined below:

• Consistent and effective contract management arrangements will be in place across Building Safety contracts.
• Where necessary Permit to Work systems will be operated to adequately control operations.
• Internal checking independent of the Operational Teams (second line of defence) will be used to provide additional assurance around the accuracy of data and associated performance reporting. This will be carried out in several ways including checking of data by the Health and Safety Manager and the Building Compliance Officer and partly through internal audits. The gas and electrical delivery teams who manage contracts have separate reporting lines to the H&S team who oversee data and compliance assurance to assist with providing assurance.
• In exceptional circumstances it may not be feasible to complete a remedial action following inspection within the specified timescale. In such circumstances the Building Compliance Surveyor will discuss with the HHSBC to seek approval to discuss with the Competent Person who identified the remedial action, to identify whether it is possible to extend target timescales (for example by completing alternative, reasonably practicable measures to manage the risk in the interim), or to identify whether it is possible to address the issue identified by alternative means. Any amendments of either nature will only be made with the written agreement of the Competent Person which will be retained on file. Where this occurs, it will be reported as contextual narrative as part of the KPI process.
• Work-based assurance activity will be undertaken which will include checks on work-in-progress, post-inspection of completed work, and checking of certification produced. A proportion of such checks will be carried out by an independent 3rd party.
• A comprehensive internal audit programme (third line of defence) will be operated across Water, Fire, Asbestos, Lifts, Electrical, Gas and Damp & Mould activities covered by this policy. The Audit and Risk Committee and Leadership Team will decide on the appropriate level of assurance required through the internal audit programme in relation to each area of risk. This will provide independent assurance on the operation and effectiveness of controls. Findings will be provided to the Audit and Risk Committee.

3.7.3. Performance Monitoring

3.7.3.1. A comprehensive suite of Key Performance Indicators (KPIs) and other Performance Indicators (PIs) will be in operation across all Building Safety activity. KPIs and PIs will be reported to various forums and levels within the organisation in accordance with the table below.

Note on KPIs and PIs – KPIs are Key Performance Indicators and are usually reported more broadly and to a more senior level and tend to be geared around statutory or regulatory issues. PIs represent other performance indicators which may include operational and management performance indicators used to inform the management of a particular service.

Performance indicator type	Homes Directorate	Business Management Team	Leadership Team	Board
PI	Monthly	Monthly	Monthly	Annually (unless requested or escalated by LT)
KPI	Monthly	Monthly	Monthly	Quarterly

3.7.3.2. The Leadership Team will review KPIs monthly and consider if any PIs need to be upward reported to Board. The full list of indicators (PIs and
KPIs) will be reported annually to Board.

3.7.3.3. The calculation methodology for reporting will be clearly defined and documented within the relevant Procedural Document. All KPIs will report the total number of actions or building requirements and the total number within target as well as a percentage figure. In addition, reporting will be accompanied by commentary for all cases where the initial Building Safety activity or arising actions have become overdue.

3.7.3.4. This will include the risk rating (where available), the date they became overdue, days overdue (banded as appropriate) and their position within the access legal process to bring them back into a compliant position. Additional contextual commentary will also be included.

3.7.3.5. In line with the assurance section above, performance reporting will be subject to both internal checking independent of the Operational Teams, and the Internal Audit Programme. Associated data controls will be described in detail within the Data Management Protocol, Detail of current Building Safety KPIs are provided within Appendix 1.

3.8. Policy detail

3.8.1. Landlord Compliance – Preamble & Overarching Commitments

3.8.1.1. In line with the wider commitments of this Policy, this section sets out Raven’s commitment to maintain an effective system to plan and deliver Landlord Compliance activities, to manage risk to our customers, staff, contractors and third parties within the premises that we own and/or manage.

3.8.1.2. Raven will comply with all relevant legislation including those specifically referenced within each of the individual Landlord Compliance areas below. Raven takes the view that delivery of the commitments within this Policy will ensure that the requirements of other legislation, such as the Health and Safety at Work Act (HASAWA) 1974, Building Safety Act 2022, Landlord Tenant Act 1985 and the Housing Act 2004 will also be met. In addition, as a landlord and provider of Social Housing, Raven must meet the requirements of the Regulator of Social Housing’s (RSH) Safety and Quality Standard.

3.8.1.3. This section sets out our overarching commitments in respect of Landlord Compliance as such these apply to all areas of Landlord Compliance. These overarching commitments are further supplemented with clear Compliance area specific policy commitments that relate to each individual area of

Landlord Compliance as listed below:
1. Asbestos Safety
2. Electrical Safety
3. Fire Safety
4. Gas (and Other Heating) Safety including CO Detectors
5. Lifts and Powered Access Safety
6. Water Safety
7. Damp, Mould & Condensation Management

3.8.1.4. Raven will maintain a Management Plan and associated Operational Guidance for each of the above Compliance areas, which shall:

• Provide additional guidance on how the commitments outlined within this Policy will be implemented.
• Provide clear lines of responsibility for the management of safety beyond the high-level roles and responsibility that are outlined below.
• Set out key operational processes.
• Ensure that a clear and consistent process is in place to obtain access to properties where this is required. This will include pro-active assessment of available data for relevant information about the customer to help gain access (disability, vulnerability, local connections, etc.). Tenancy enforcement action will be used where required.
• Maintain a process for dealing with unsafe situations.

3.8.2. 3rd Party Arrangements

3.8.2.1. Where properties are leased from, and managed on behalf of, third party property owners, statutory responsibility will be detailed within the Terms of the Lease / Management Agreement. Although we hold satisfactory agreements that we have operated under satisfactorily for many years, Raven is currently working towards more clarity in agreements as contracts come up for renewal. Where the statutory responsibility lies with the property owner, Raven checks that the appropriate certifications and any other relevant Landlord Compliance documentation is in place and must be given assurance that they are safe in advance of occupation and use.

3.8.3. Additional Safety Measures

3.8.3.1. Raven requires that tenant alterations that may have an implication regarding health and safety and Landlord Compliance should be subject to prior notification, agreement and appropriate landlord’s permission to proceed before they are undertaken – as is required by our Tenancy Agreements. Permission will not be unreasonably withheld and when given will be on the proviso that certain requirements are met e.g. the tenant arranges for relevant Risk Assessments to be undertaken and that work is undertaken by suitably qualified contractors.

3.8.3.2. Any work carried out by tenants that is deemed unsafe will be rectified at the tenant’s own cost and by Raven’s appointed contractor.

3.8.4. Residents

3.8.4.1. Raven will ensure that we provide relevant Landlord Compliance related information to our residents/customers in an appropriate format. Information provided to residents will be accurate, appropriate and of benefit. We will comply with all statutory and regulatory requirements where we are obliged to provide specific information and go beyond this to an open and transparent approach. We will ensure easy routes for complaints and reports of concerns from customers and members of the public. Our approach to each individual Landlord Compliance area is detailed within the attendant Management Plan. Our approach to building- and person-specific safety, such as personal emergency evacuation plans, is also detailed in the Management Plans. Our Customer Charter sets out expectations for services we provide and what we expect from customers.

3.8.5. Asbestos Safety

3.8.5.1. Large amounts of asbestos were used in new and refurbished buildings before Year 2000. Blue (crocidolite) and Brown (amosite) asbestos were banned by law in 1985. Manufacture and supply of all asbestos was banned by the end of 1999. Many premises and older plant and equipment still contain some asbestos. Workers most likely to encounter asbestos containing materials (ACMs) are in the construction, maintenance, refurbishment and related trades. Tenants may also come into contact, particularly when undertaking DIY work. When ACMs are damaged or disturbed, they may release dangerous fibres which, if breathed in, can cause serious diseases.

3.8.5.2. The key objective of this section is to describe how we will meet the required statutory, legislative, and regulatory requirements in relation to Asbestos Safety management. Here we will outline how we will prevent or minimise the exposure to asbestos fibres to the lowest level reasonably practicable to protect customers, colleagues, contractors, and visitors on Raven property.

3.8.5.3. In summary we will:

• Take reasonable steps to assess if asbestos is present.
• Record the Location, Type and Condition of any asbestos.
• Assess the Risk/s of anyone being exposed to the asbestos.
• Prepare a Plan on how to Manage the Risk/s.
• Put the Plan into Action, Monitor, it and keep it up to date.
• Provide information to anyone likely to work on, or disturb, ACMs.

3.8.5.4. Owner: Head of Corporate Health and Safety and Building Compliance

3.8.5.5. Regulatory standards we are required to meet and advisory bodies whose guidance we observe:

• Control of Asbestos Regulations 2012 (CAR 2012)
• ACOP L143 (second edition) (Managing and Working with Asbestos)
• Health and Safety Executive (HSE) Guidance – HSG264 and HSG227

3.8.5.6. How we meet these standards:

Raven will:

• Maintain up-to-date electronic records of the Type, Location and Condition of the ACMs (or presumed ACMs) within the definitive Asbestos Register, which is held within IPC. The register will be kept updated to reflect any removals, encapsulation and/or new survey information. The transfer of data as part of Ravens digital transformation project
• Ensure that the asbestos register is made available to those that require access to it in accordance with CAR 2012.
• Maintain survey, location, type, condition information in the IPC database.
• Make Asbestos Survey Reports, and Asbestos Removal information, available via our Asbestos Consultant’s secure web portal (this information is also reconciled with IPC) to those who need them.
• Hold up to date Management Surveys of all Non-Domestic Properties constructed prior to 2000.
• Ensure that appropriate asbestos survey information is available prior to work being undertaken that may disturb asbestos including all works of an intrusive nature. Where existing information is not sufficient, or where work is planned for previously un-surveyed areas, targeted Refurbishment and Demolition type surveys of the localised area and a Management Survey to the rest of the property will be carried out prior to work commencing.
• Complete asbestos surveys to un-surveyed dwellings prior to re letting.
• Conduct Refurbishment and Demolition type surveys prior to any demolition work taking place.
• Undertake Re-inspection Surveys of all asbestos containing materials in communal (non-domestic) areas. These will be undertaken annually or on such an earlier date which will be determined by the Location, Condition and Risk of Disturbance by the Competent Person carrying out the survey.
• Validate existing asbestos data and condition of materials within individual dwellings as part of stock condition surveys carried out within each dwelling every 5-years, so far as is practicable.
• Use survey information to identify and manage the risk from asbestos containing material in communal areas and individual properties to as low as reasonably practicable.
• Ensure that remedial works or removals recommended within Asbestos Survey Reports are completed in accordance with the timescales prescribed the survey.
• Presume materials contain asbestos unless it is confirmed that they do not.
• Ensure that relevant employees of Raven receive Asbestos Awareness training. This will include, but will not be limited to, all trades and technical staff. Further information will be provided within the Asbestos Management Plan.
• Have in place an emergency plan by which we will manage unplanned asbestos incidents, such as accidental damage to ACMs and/or uncontrolled/unintended release of fibres. This is included in the asbestos management plan based on current operating methodology.
• Retain copies of the communal area asbestos surveys for leased properties on Raven’s asset database.
• Make asbestos safety advice available on Raven’s residents’ portal / website.
• Provide property specific information to residents on request or where otherwise appropriate and at sign-up of new tenancy.

3.8.5.7. Competence

• Asbestos Management Surveys required under CAR and pre-works Refurbishment and Demolition Surveys will be undertaken by UKAS accredited Consultants to ISO/IEC 17020 Standard.
• Persons appointed to measure the concentration of asbestos fibres will be ISO:17025 accredited.
• All ACM samples will be tested by a UKAS accredited laboratory.
• All non-licensed work involving ACMs will be carried out with the appropriate Method Statements and Controls in place.
• Contractors appointed to undertake remedial work or removal of ACMs shall be competent and listed on Raven’s list of Approved Contractors. They shall hold a Licence issued by the Health and Safety Executive (HSE) and be members of an appropriate trade association such as the Asbestos Removal Contractors Association (ARCA) or the Thermal Insulation Contractors Association (TICA) (where appropriate).
• Additional requirements and the framework by which competence will be managed is set out within the Asbestos Safety Management Plan.

3.8.6. Electrical safety

3.8.6.1. The key objective of this section is to describe how Raven will manage Electrical Safety Risk so far as is reasonably practicable. The scope of this section includes:

• Fixed Wire Testing
• Electrical Equipment Testing (previously Portable Appliance Testing)
• Lightning Protection Systems.

3.8.6.2. Owner: Assistant Director of Property Services

3.8.6.3. Regulatory standards we are required to meet and advisory bodies whose guidance we observe:

• The Electricity at Work Regulations 1989 (EAWR)
• The Building Regulations 2010
• The current edition of the IET Wiring Regulations – BS7671
• The Electrical Safety Standards in the Private Rented Sector and Social Rented Sector (England) Regulations 2020
• BS EN 62305 Protection against lightning

3.8.6.4. How we meet these standards:

Raven will:

• Use the completion of Electrical Installation Condition Reports (EICRs) to provide a record of the condition of an Electrical Installation at the time of the Inspection and to assess the risk of the installation remaining in service.
• Test fixed electrical installations in dwellings and relevant non-domestic properties. Accordingly, Electrical Installation Condition Report (EICR) will be issued for each relevant premises. We will seek to undertake EICRs prior to the date recommended by the Competent Person undertaking the previous test but, in any event, at intervals not exceeding 5 years.
• Where practicable resolve any C1, C2 or FI observations noted within the EICR prior to leaving the premises. Where this is not reasonably practicable, as a minimum, the installation will be made safe temporarily and follow up work will be completed in line with timescales outlined within the Management Plan.
• Where C1, C2 or FI observations are recorded on an EICR as outstanding, the EICR will be unsatisfactory. The Asset will not be considered compliant and will be reported as such until such time as there is appropriate evidence that the observations identified have been adequately resolved. This evidence will be in the form of an Electrical Installation Certificate (EIC) or Minor Electrical Installation Works Certificate (MEIWC) which will be retained with the EICR.
• Test void properties and properties that are subject to mutual exchange. We will ensure that either a satisfactory EICR is provided or that all remedial work necessary to consider the installation satisfactory (i.e. to resolve C1, C2 or FI observations) has been undertaken and is evidenced prior to allocation and prior to new residents moving into the property.
• Have the Electrical Team Leader validate all EICRs and other certificates to ensure all C1 and C2 remedial works identified by testing have been completed before certification data is uploaded into IPC.
• Maintain an Electrical Testing Specification. This will establish the extent and limitations of Inspection and Testing and help to ensure that clear and consistent EICRs are produced.
• Ensure that appropriate action is taken to remove or remedy non compliant work that has been undertaken by an occupier and identified by a Raven representative. The cost of doing so may be recovered from the resident.
• Ensure that a valid EIC is held for new Assets or Installations that have been entirely replaced. This will indicate the start of an Installation’s life, and the EIC shall state when the first EICR should take place. This would not exceed a period of 5-years in accordance with this Policy.
• Ensure that appropriate and accurate certification is provided for all applicable electrical repairs and remedial works.
• Carry out Electrical Equipment Testing (EET), on all Raven owned portable electrical tools annually, and replace defective appliances if they fail the test.
• Carry out Electrical Equipment Testing (EET) annually on all relevant Raven owned equipment deemed of sufficient risk and replace defective appliances if they fail the test.
• Will use IPC as a central database to manage, schedule and record cyclical servicing and provide monthly compliance reporting.
• Make Electrical Installation Condition Reports (EICRs) available to residents using the Raven portal or upon request.

3.8.6.5. Competency:

• Raven is a NICEIC accredited approved contractor. The Electrical Manager is responsible for ensuring we maintain our accreditation.
• Only qualified electricians carry out work and qualified managers and supervisors oversee electrical work.
• Only NICEIC contractors, as checked by Raven prior to appointment, are utilised for work not being completed by the in-house team. Reasonable assurance shall be sought to confirm that any contractor undertaking Electrical Work has suitably qualified staff.
• Additional requirements and the framework by which competence will be managed are set out within the Electrical Management Procedure

3.8.7. Fire Safety

3.8.7.1. The key objective of this section is to describe how Raven will manage Fire Risk so far as is reasonably practicable. The scope of this section includes:

• The undertaking of Fire Risk Assessments (FRA) and the Remedial Works and Actions arising from the FRA
• Cyclical Maintenance of Fire Safety Systems and Equipment including but not limited to:
  • Automatic Fire Detection and Alarm Systems
  • Emergency Lighting
  • Automatically Opening Smoke Vents or Smoke Control Systems
  • Portable Fire-Fighting Equipment
  • Dry or Wet Risers
  • Sprinkler/Mist Systems.
• Will Inspect and Test Lightning Protection Systems in accordance with the current edition of BS EN 62305:3 on an 11-month cycle to allow for Testing under varying climatic conditions.
• Complete any remedial actions identified during the Inspection and Testing of Lightning Protection Systems in line with the recommendations of the Competent Person who identified the action.

3.8.7.2. Raven has adapted its fire safety procedure to incorporate the requirements of the Fire Safety Act 2021 and the Building Safety Act 2022.
The Fire Safety Act requires us to ensure we have competent persons carrying out fire risk assessments which take account of flat entrance doors and external wall systems within a block. Raven employs the services of an external provider to complete fire risk assessments on our behalf. This Act also requires us to carry out annual flat entrance door inspections, communal door inspections and to have wayfinding signage in high-rise, high-risk blocks.

3.8.7.3. The Building Safety Act 2022 requires accountable persons under the act to register any building of 18 metres or more with the Health and Safety Executives (HSE) Building Safety Regulator (BSR).

3.8.7.4. Registration of high-rise buildings took place between April 2023 and October 2023 and the BSR will start to assess buildings from April 2024. Part of the assessment process requires submission of a Building Safety Case report which is a summary of how we ensure the building is safe for occupation. At the time of writing the HSE have provided some guidance on what they expect to see within a Building Safety Case, but they have also advised that further guidance will be issued when they start to assess and sign off Building Safety Cases over the next 12 to 18 months. Raven employed the services of a third party to review and test the Building Safety Case for Raven’s one in scope block, The Dome. The HSE have not yet published further guidance on Building Safety cases.

3.8.7.5. The Safety Case will need to demonstrate how Raven has identified the hazards, evaluated the risks, decided on, and implemented control andmitigation measures and has an on-going process in place for monitoring. This is consistent with the approach that should be undertaken for FRAs under the Fire Safety Order and other commitments made in this Policy.

3.8.7.6. Raven will ensure that any additional guidance from the Building Safety Regulator is added to this policy and the relevant procedures when it becomes available. This will include reporting of mandatory and voluntary occurrences where required once this scheme is established.

3.8.7.7. Owner: Head of Corporate Health and Safety and Building Compliance

3.8.7.8. Regulatory standards we are required to meet and advisory bodies whose guidance we observe:

• Regulatory Reform (Fire Safety) Order 2005 (RRO)
• Building Regulations
• Relevant British Standards for individual building components
• Local Government Association Guidance “Fire Safety in Purpose Built Flats”
• Fire Safety (Residential Evacuations Plans) (England) Regulations 2025
• Fire Safety Act 2021
• Building Safety Act 2022

3.8.7.9. How we meet these standards:

Raven will:

• Ensure that all premises requiring a Fire Risk Assessment (FRA) have been identified.
• Undertake suitable and sufficient FRAs in accordance with the Regulatory Reform (Fire Safety) Order 2005 and record the significant findings.
• Will conduct Type 1 FRAs by default, but these will be escalated to a Type 2, 3 or 4 based on the recommendations of the Fire Risk Assessor. For a full definition of ‘Type 1-4’ refer to the Local Government Association Guide ‘Fire Safety in Purpose-Built Blocks of Flats’. Additionally, Raven is conducting annual FRA’s to all ‘higher risk’ buildings (defined as >11m tall, Sheltered schemes and TA).
• Undertake recommended Remedial Work within the timescales set by the Competent Person who completed the FRA and post inspection of completed works prior to acceptance monitored by the Building Compliance Surveyor Undertake new FRAs in line with the recommendations in the latest FRA. FRAs will be renewed on or before the date recommended by the Competent Person undertaking the previous Assessment. These will not exceed the following frequencies:
  • Higher risk buildings (as defined within the management plan or by the competent person carrying out the FRA) – Annual
  • Other premises – within 3 years
• Review FRAs, no matter what the risk category, following any of the events below:
  • A fire, near miss or threat of arson
  • The introduction of new work practices
  • Works affecting the Means of Escape or Alarm Systems
  • Structural or material changes to the building, or its use
  • Changes in legislation (or significant changes to guidance).
• Produce annual ‘workflows’ using IPC database to plan and organise FRA inspections.
• Raven will adhere to PAS 9980 guidance where required. The need for such inspections will be identified through the FRA programme. At the time of writing six of Raven’s blocks have been identified as requiring a PAS9980 inspection of its external wall system. It is not currently anticipated, based on advice from our external fire risk assessment contractor, that Raven will have any more blocks which will require a PAS9980 inspection. Five out of the six required no remedial actions and the other, Delta House has had remedial actions completed.
• Raven will comply with its duties under the Fire Safety Act 2021.
• Raven will comply with its duties under the Building Safety Act 2022.
• Inspect Communal Fire Doors as part of the FRA process and at regular intervals as recommended within the FRA.
• Pro-actively undertake further investigations to the buildings for which it is responsible, where required. This may include, but is not limited to, investigations into External Wall Systems, Balconies, Compartmentation and Fire Doors. Such further investigations will be recommended by the FRA, the Fire and Rescue Service or initiated where Raven is not satisfied it has appropriate assurance around the design, installation, or maintenance of a building component.
• There are no current requirements, guidance or advice which requires Raven to retrofit sprinkler installations into any of its blocks of flats. If legislation, guidance, or advice from our fire risk changes Raven will adhere to these changes accordingly.
• Ensure each building has an Evacuation Strategy stated clearly within the FRA. The Evacuation Strategy will be agreed with the Competent Person undertaking the FRA. Evacuation procedures will be appropriate to the building type/use and will be communicated to residents. General guidance on Strategy by Building Type is provided within the Fire Safety Management Plan.
• Provide advice and guidance to assist residents in General Needs properties in developing their own Means of Escape Plan where practicable and should assistance be requested. This will not involve the assistance of staff in the evacuation. Details of this are included in Raven’s Building Safety Resident Engagement Strategy.
• In the case of Specialist Housing, use appropriate staff, to carry out an assessment of individuals. In some cases, this will require Person Centred Fire Risk Assessments (PCFRAs). Residential Personal Emergency Evacuation Plans (RPEEP) requirements will be determined on a case-by-case basis. These will be checked on a regular basis and amended on review of support plans.
• Residential PEEPs will be completed for occupants with information stored in the premises information box (PIB) at the following properties
  • In buildings at least 18m above ground level or 7 storeys which contain 2 or more sets of domestic properties
  • In buildings over 11m that have simultaneous evacuation strategies in place.
• Where appropriate provide equipment to aid evacuation which should only be used by appropriately qualified or trained persons e.g. the Fire and Rescue Service.
• Raven will not let homes to prospective residents in a building that is not suitable for their needs with regards to their safety in the event of a fire.
• Ensure that all Fire Safety Equipment within the scope of this Policy, as detailed below, is tested, and maintained in accordance with regulatory and statutory requirements and considering manufacturer’s requirements and the recommendations of relevant British Standards. Details of the frequency of the testing and inspection programmes are included in Ravens Fire Safety Management procedure.
  • Dry Risers
  • Automatic Openable Vents (AOVs) in partnership with Fire Alarms and Smoke Detectors
  • Fire Alarm Call Points
  • Fire Alarm Panels
  • In-flat Smoke Detectors
  • Communal Fire Doors
  • In-flat Front Doors
  • Emergency Lighting
  • Fire Extinguishers
  • Tumble Dryer Filters
  • Fixed Water Sprinkler Systems
  • Mist Systems
  • Fail to Safe Access Systems
• Smoke, CO, and heat detectors will be checked in all properties annually. This will be undertaken when completing the landlords gas safety record in gas properties or the equivalent visit for other serviced heating systems. For properties where no heating service visits are necessary, smoke and heat detectors are remotely tested on an annual basis.
• Ensure that arising remedial works and other actions associated with the above equipment – identified during test and maintenance visits – are completed in line with the timescales recommended by the Competent Person carrying out the test. Where no such timescales are provided, we will complete repairs as soon as practicable and within the priority timescales set out within our repairs and maintenance policy.
• Retain copies of FRAs for leased properties (both to us and by us) on Raven’s asset database IPC. The Head of Corporate Health and Safety and Building Compliance will review these FRAs to confirm that they are satisfactory, and that remedial works are completed.
• Implement the Managed Use Procedure, periodical testing of all active fire systems including monitoring and alarms, regular preventive maintenance of warden call systems in Sheltered Blocks, and evacuation procedure notices in communal areas.
• Provide residents with fire safety information and advice.

3.8.7.10. Competence

• Raven only uses competent internal and external suppliers to perform fire detection and prevention installation, risk assessment, inspection, and planned/ responsive maintenance activities.
• We will ensure that FRAs are undertaken by BAFE SP205-1 accredited organisations and all FRAs are subject to validation.
• We will appoint an external Competent Person to provide retained support and advice in relation to Fire Safety. This will be (or include access to) a Chartered Fire Engineer and experienced Fire Risk Assessor – with particular experience on complex Residential Properties – who is listed on an Approved Register.
• Additional requirements and the framework by which competence will be managed is set out within the Fire Safety Management Plan.

3.8.8. Gas (And Other Heating) Safety

3.8.8.1. This Section covers both domestic and commercial (e.g. communal heating systems) appliances including Gas-Fired, Air and Ground Source Heat Pumps, Heat Interface Units (HIUs), Solar Thermal hot water and Unvented Cylinders. It also covers properties with a gas supply or a readily available gas supply (but no gas appliances) and other activities that are undertaken at the same time as servicing / inspection of the above appliances. Raven has no oil or solid fuel installations within our homes.

3.8.8.2. Raven has a responsibility to maintain all installations and appliances owned by it within its homes to the required statutory, legislative, and
regulatory standards. This Policy explains how the safety and maintenance requirements for Gas Appliances and Installations (and those of other fuel types covered by this Policy) within Raven’s homes will be met.

3.8.8.3. Owner: Assistant Director of Property Services

3.8.8.4. Regulatory standards we are required to meet and advisory bodies whose guidance we observe:

• Gas Safety (Installation and Use) Regulations 1998 (specifically Regulation 36) and associated code of practice
• Gas Safety (Management) Regulations 1996
• Gas Safety (Management)(amendment) Regulations 2023
• Approved Code of Practice L56 (Fifth Edition) ‘Safety in the Installation and Use of Gas Systems and Appliances’ 2018
• British Standards
• Building Regulations

3.8.8.5. How we meet these standards:

Raven will:

• Complete an annual Landlords Gas Safety Record (LGSR) in all domestic properties that contain gas which are Raven’s responsibility. This will include all properties that have been identified as having a capped off gas supply.
• At the time of the annual Safety Check, Raven will also check all tenant owned gas appliances for safety even though we have no legal responsibility to do so. This will be done by means of:
  • A visual risk assessment check in line with Gas Safety (Installation and Use) 2018 – Regulation 26(9).
  • Application of Raven’s Gas Safety management procedure. Note that any safety critical faults found on a tenant-owned appliance will result in the appliance being isolated and disconnected from the gas supply and the tenant informed.
• Utilise the additional flexibility afforded by the provisions of Regulation 36A of the Gas Safety (Installation and Use) Regulations when managing the domestic LGSRs programme.
• Raven does not have any domestic Solid Fuel or Oil-Fired appliances.
• Inspect all properties with Air Source & Ground Source Heat Pumps, Solar Thermal Heating/Hot Water annually and obtain appropriate documentation (where applicable).
• Inspect all Raven owned Solar Photovoltaic panels and associated batteries annually and obtain appropriate documentation.
• Unvented cylinders will be inspected and serviced annually either alongside other equipment covered by this section of the policy or separately where no other relevant equipment is present.
• Carry out remedial works identified in the LGSR or other equivalent inspection certificates within appropriate timescales as detailed within the Gas (and Other Heating) Safety Management Plan.
• Undertake maintenance and repairs to gas and other appliances covered by this section of the Policy in line with timescales set out in the Gas Safety Management Procedure
• Ensure that all appliances in rented homes covered under this section of the policy have relevant safety checks undertaken when they are void, and that valid certification is provided prior to the property being relet. In the case of void gas properties – gas supplies will be disconnected, capped off at the meter and made safe upon a property becoming void. When the property is then re-let, the gas supply is reconnected and a new Gas Safety Inspection will take place, with the issue of a new Gas Safety Certificate (LGSR) before the gas system or appliances are used.
• Ensure that all appliances covered under this section of the policy in new-build homes have relevant safety checks undertaken and that valid certification is provided prior to the appliances being live. A new Gas Safety Certificate (LGSR) is issued before the gas system, or appliances are used and to the customer on sale or let.
• Ensure, where required, that Commercial Systems and Pressure Vessels have a Written Scheme of Examination.
• Target that all Commercial Systems are inspected and serviced in accordance with manufacturer’s requirements and the Written Scheme, but in any event at intervals of not more than 12-months and have a valid Landlord Gas Safety Record (LGSR).
• Ensure that any other gas fired equipment is serviced and maintained in line with manufacturers and legislative requirements.
• Ensure that, as with other areas of compliance, a clear and consistent process (including front-line engagement and enforcement) is in place to obtain access to properties to conduct the Safety Checks and works, which shall include appropriate legal action (consistent with the Tenancy Agreement) when required in the face of persistent tenant refusal to allow such access. In the case of gas this is particularly important to satisfy the requirements of Regulation 39.
• Maintain a process for dealing with gas safety unsafe situations in accordance with the Gas Safety Regulations (IGEM/G/11+A:2018) and associated guidance.
• Provide and maintain CO detectors in all properties with gas or solid fuel supply.
• Test Smoke, Heat and CO Alarms, where fitted, in conjunction with the annual Safety Inspection visits and record this test on the Landlord Gas Safety Record (or other applicable Record/ Certification). Defective alarms will be replaced.
• Provide residents with gas safety information and advice (e.g. Raven’s resident website)
• Provide hard copies of LGSRs within 28-days of them being completed.
• Commercial Gas Safety Records will be displayed in common parts where applicable.

3.8.8.6. Competence:

• Raven is a Gas Safe accredited organisation. The Operational Compliance Manager is responsible for ensuring we maintain our accreditation.
• Raven only uses competent internal resources and external suppliers to perform gas installation and maintenance activities.
• Raven will only engage with suitably qualified contractors to undertake work on Gas Installations, in accordance with the obligations of the Construction (Design and Management) Regulations 2015 Regulation 4 (6) – Gas Safe Registered Companies and Gas Safe Registered Engineers, with the appropriate Nationally Accredited Certification Scheme (ACS) to undertake any Gas-Related works.
• Additional requirements and the framework by which competence will be managed is set out within the Gas (and Other Heating) Safety Management Plan.

3.8.9. Lifts And Powered Access Safety

3.8.9.1. The scope of this section includes Passenger Lifts, Lifting Equipment, Stair Lifts, Vertical (‘Through-Floor’) Lifts, Ceiling Track Hoists, Mobile Hoists, Bath Lifts and Slings. It also covers powered access equipment, namely Power-Operated (Automatic) Gates, Barriers, and Doors. This section applies to all premises including, individual dwellings, common areas, offices, and other non-domestic locations.

3.8.9.2. Raven has a responsibility to ensure that all lifts and lifting equipment that it is responsible for are subject to a scheme of independent thorough inspection and adequate maintenance, and ultimately to ensure that so far as is reasonably practicable the equipment is safe for continued use. Power-Operated (Automatic) Gates, Barriers and Doors require regularly reviewed Risk Assessments and like most machinery need to be maintained to remain safe. This section will set out how Raven will ensure the safety and maintenance of equipment covered within this section and how statutory, legislative, and regulatory standards will be met.

3.8.9.3. Owner: Assistant Director of Property Services

3.8.9.4. Regulatory standards we are required to meet and advisory bodies whose guidance we observe:

• Lifting Operations & Lifting Equipment Regulations 1998 (LOLER)
• Approved Code of Practice L113 (Second Edition 2014, amended 2018) Safe Use of Lifting Equipment
• Provision and Use of Work Equipment 1998 (PUWER)
• Approved Code of Practice L22 (Fourth Edition 2014, amended 2018) Safe Use of Work Equipment
• Building Regulations
• British Standards
• Health and Safety and Work etc Act 1974

3.8.9.5. How we meet these standards:

Raven will:

• Have a valid Thorough Examination in place, where applicable, for all Lifts and all associated Equipment.
• Ensure that Thorough Examinations are undertaken by a Competent Person independent of any party undertaking maintenance work to the Passenger lifts and all associated Equipment. This is fulfilled by using Raven’s insurers to undertake this activity.
• Ensure Thorough Examinations are undertaken at intervals of no more than 6-months for Lifts that carry people. 12 months, for all other lifting equipment.
• Undertake Thorough Examinations throughout the lifetime of the Equipment, as follows.
  • Before use for the first time (unless the equipment has a Declaration of Conformity less than one year old and the equipment was not assembled on site)
  • After assembly and before use at each location.
  • Regularly, while in service.
  • Following exceptional circumstances (damage or failure/major changes etc.).
• Maintain Lifts and Lifting Equipment appropriately according to
  • The Manufacturer’s Recommendations.
  • The intensity of use.
  • The operating environment (e.g. the effect of temperature, corrosion, weathering), user knowledge and experience.
  • The risk to Health and Safety from reasonably foreseeable failure or malfunction.
• Complete remedial works and corrective actions identified during Thorough Examinations or through Maintenance visits within the timescales indicated by the Competent Person undertaking the inspection. Where no such timescales are provided, we will complete repairs as soon as is practicable and within the priority timescales set out within our repairs and maintenance policy.
• All passenger lifts in blocks are subject to insurance examination every 6-months and servicing monthly.
• All stair lifts and through floor lifts in rented homes will be subject to a service and thorough inspection every 6-months.
• Passenger lifts at Raven House are inspected and maintained monthly with insurance examination every 6-months.
• Ensure the Thorough Examination Report contains information compliant with LOLER Schedule1.
• Undertake Supplementary Testing in accordance with the Safety Assessment Federation (SAfed) Guidance if requested by the Competent Person.
• New Passenger Lifts will be installed in accordance with the BS EN 81 Series of Standards (81-20 and 81-50) and the Equality Act 2010 and as amended.
• Record all inspections on IPC and these will be reconciled by the Building Compliance Officer monthly. The compliance PIs are monitored weekly.
• Ensure copies of lift certification for leased properties are held on Raven’s asset database. Information will be collated by the Home Ownership Team and will be checked by the Electrical Manager to confirm it is satisfactory.
• Hold valid, suitable, and sufficient, Risk Assessments for all Power Operated (Automatic) Gates, Barriers and Pedestrian Doors. Risk Assessments will be reviewed in accordance with the recommendation of the Competent Person undertaking the Assessment.
• Inspect and Maintain Power-Operated (Automatic) Gates, Barriers, and Pedestrian Doors in accordance with regulatory and statutory requirements and considering Manufacturer’s requirements. Frequencies and activities will be specific to the Equipment, but as a general guide:
  • Power-Operated (Automatic) Gates, Barriers and Pedestrian Doors will be inspected and maintained 6-monthly.
  • Powered-Doors will be inspected and maintained annually.
• Prioritise remedial actions identified either through maintenance visits or the Risk Assessments process according to risk and ensure these are undertaken within the timescales recommended by the competent person who identified the action. Where remedial actions cannot be undertaken within the specified timescales the installation will be decommissioned. Where no such timescales are provided, we will complete repairs as soon as is practicable and within the priority timescales set out within our repairs and maintenance policy. Any immediately dangerous faults will be made safe at the time of inspection.

3.8.9.6. Competence:

• Raven will only use competent internal resources and external suppliers to perform lift and lifting equipment inspection, statutory and periodical testing, installation, and maintenance activities. All Engineers working on lifts and lifting equipment will be appropriately trained and qualified.
• For all Thorough Examinations and Supplementary Testing, we will use companies that are UKAS Accredited to ISO/IEC17020 Standard.
• All Lifting Equipment Works will be undertaken by trained and competent contractors with appropriate practical and theoretical knowledge and experience of the Lifting Equipment and have an element of independence and impartiality.
• We will use Lift and Escalator Industry Association (LEIA) affiliated contractors for all Repairs, Servicing and New Installations.
• Additional requirements and the framework by which competence will be managed is set out within the Lift and Powered Access Management Plan.

3.8.10. Water Safety

3.8.10.1. Legionella bacteria can cause several diseases including the Legionnaires’ disease. The bacterium is common in natural water sources such as rivers, lakes, and reservoirs, but usually in low numbers. They may also be found in purpose-built Water Systems such as Cooling Towers, Evaporative Condensers and Hot and Cold-Water Systems and sprinklers in high rise buildings. Legionnaires’ disease is a potentially fatal form of pneumonia, and everyone is susceptible to infection, and it is therefore important to control the risks.

3.8.10.2. The key objective of this section is to describe how Raven will meet the required statutory, legislative, and regulatory requirements in relation to Water Safety. The scope includes Legionella Management, Scalding Prevention, and Un-Adopted Water Systems.

3.8.10.3. Owner: Head of Corporate Health and Safety and Building Compliance

3.8.10.4. Regulatory standards we are required to meet and advisory bodies whose guidance we observe:

• HSE Approved Code of Practice L8 (Parts 1-3) The Control of Legionella Bacteria in Water Systems
• HSG 274 Part 2 The control of legionella bacteria in hot and cold-water systems
• The Water Supply (Water Fittings) Regulations 1999 (as amended)
• General duties exist under Management of Health & Safety at Work Regulations 1999
• Control of Substances Hazardous to Health Regulations 2002 (COSHH)
• Approved Code of Practice L5 (Sixth Edition 2013) Control of substances hazardous to health (Sixth edition)

3.8.10.5. How we meet these standards:

Raven will:

• Regularly review existing properties and assess risk within new homes through a desktop review, which will identify those properties at potential High Risk of Legionella. Raven has reviewed and analysed its existing homes regarding Legionella risk. This has been used to
  prioritise our approach. Further information on this is available within the Water Safety Management Procedure
• Produce a standard Legionella Risk Assessment (LRA) for all properties that have been validated as having ‘standalone’ water systems; and a formal LRA of all higher risk properties. The review period for future Risk Assessments is established through a risk-based approach within the initial Risk Assessment carried out by the Competent Person. Typically, intervals are as outlined below:
  • Higher risk properties (e.g. all properties in Sheltered Schemes or Temporary Accommodation and General Needs properties served by communal tanks); review LRA on a two-year cycle.
  • Lower risk properties (e.g. General Needs with standalone systems): provide desktop assessment by archetype, with on-site review at 5 yearly stock condition survey to ensure the home is representative of the stock.
• Implement ‘Written Schemes’ as required for specific water systems as established from the LRA findings.
• Ensure water system cleaning, disinfection and water quality analysis as identified by the Legionella Risk Assessments are undertaken within agreed timescales.
• Complete remedial actions of LRAs on a priority risk basis within the timescales recommended by the Competent Person who carried the LRA. Where no such timescales have been recommended, we will complete actions as soon as practicable and in line with the Water Safety Management Plan.
• Undertake temperature monitoring visits, as per HSE guidance, at communal areas of sheltered and temporary accommodation in line with the frequency recommended by the Competent Person, typically monthly.
• Complete inspection and testing of sprinkler systems in high rise buildings should any be installed in the future. Presently we do not have any sprinkler systems in our buildings.
• Flush through taps and showers at infrequently used communal outlets within Sheltered Schemes and Temporary Accommodation, on a weekly basis. Also flush through at voids.
• Undertake inspections and maintenance to water systems when properties become void. Activity will be completed as detailed within the Water Safety Management Plan and recorded on IPC
• Where appropriate, obtain and retain on Raven’s asset database, copies of the LRAs for properties leased by Raven, or where a Third Party manages a property on Raven’s behalf. These will be obtained by the Home Ownership Team and will be checked by Contract Surveyor (H&S) to confirm if satisfactory and that remedial works have been completed where applicable.
• Implement measures to reduce the risk of Scalding by installing Thermostatic Mixer Valves (TMVs) to High-Risk Properties, as detailed within the Water Safety Management Procedure
• Remove lead pipework that may still exist within our homes, as and when we become aware of its presence. Maintain un-adopted Water Systems to the required standards as defined within the Water Safety Management Plan.
• Provide residents with Water Safety information (e.g. via Raven’s resident website).

3.8.10.6. Competence:

• Raven will only use competent internal resources and external suppliers to carry out water containing equipment, systems and associated ancillaries’ inspection, maintenance, and installation activities. All Engineers will be appropriately qualified/trained (i.e. Legionella Control Association (LCA) certified).
• Only those Legionella/Water Treatment contractors registered with, and licensed by, the Health and Safety Executive (HSE)/Legionella Control
  Association will be permitted to carry out work in our properties associated with Legionella testing.
• Raven employs a water hygiene contractor. They are members of the Legionella Control Association; accredited to ISO/IEC 17020 by UKAS and hold ISO14001 and ISO9001.

3.8.11. Construction, Design and Management:

3.8.11.1. See CDM Procedure for details.

3.8.11.2. Owner: Head of Corporate Health & Safety & Building Compliance

3.8.11.3. Regulatory standards we are required to meet and advisory bodies whose guidance we observe:

• Construction Design and Management Regulations (2015)
• Management of Health and Safety at Work Regulations (MHSWR) 1999

3.8.11.4. How we meet these standards.

• Manage health & safety risks across the business by planning work from design stage to completion of projects.
• Having centralised records, developing pre-construction plans at the design stage, and maintaining a Health & Safety File throughout the life of projects and for future reference.
• Employing competent duty holders.
• Training our employees to perform the Client / Principal Contractor / Contractor roles as applicable. Raven have recognised the changing requirements of CDM 2015 and have therefore produced a CDM Management Plan along with guidance for Managers.

3.8.11.5. Scope of assurance that we are delivering against the standard.

• Health and Safety Manager, Head of Corporate Health & Safety and Building Compliance, Assistant Director of Development, Technical Manager, all Contract Surveyors, Gas Manager, Electrical Manager, Sustainability Manager, and anyone who undertakes and reports H&S compliance site inspections both for new build, retrofit and for maintenance works.
• Relevant performance and issues regarding CDM will be reported to the Head of Corporate Health & Safety and Building Compliance and the Director of Homes and by them to the Health and Safety Committee.

3.8.12. Decent Homes Standard

3.8.12.1. Owner: Assistant Director of Asset Management

3.8.12.2. Specific legislative requirements and advisory bodies whose guidance we observe:

• Ministry of Housing, Communities and Local Government

3.8.12.3. How we meet these standards:

• Undertake comprehensive stock condition surveys of every property every five years by external consultants.
• Raven’s stock condition database (IPC) is updated from those surveys, after desk-top validation by Raven Contract Surveyor (Delivery), so that it can be relied upon to identify those properties, and the specific component(s), which have the potential to fail the Decent Homes Standard on an annual basis. This forms the basis for organising future planned works programmes.
• Raven Contracts Surveyors update IPC to reflect works completed under planned component replacement programmes.
• Raven employees report any HHSRS breaches in accordance with new HHSRS Procedure.
• Raven takes appropriate action upon resident’s reporting building defects.

3.8.12.4. Scope of assurance that we are delivering against the standard:

• Raven’s personnel are competent to undertake reliable stock condition surveys. Bi-annual reconciliation of IPC data will be carried out.
• KPIs are reported regularly to Raven Leadership Team and Board (e.g. Quarterly Performance Reports).
• Formal periodic, and minuted, contract management meetings to monitor progress.
• Contracts in place to deliver planned works programmes.

3.8.13. Resident Engagement

3.8.13.1. Raven has an approach of transparency and two-way communication with residents to ensure we are delivering a service that meets with their expectations and good practice.

3.8.13.2. Residents shall have the means to notify Raven’s H&S team of any health and safety concerns through our website, portal and/or the One Stop Shop / Customer Service Centre and be assured that these will be acted upon.

3.8.13.3. The associated Management Procedure documents will contain details on how we facilitate a transparent approach to our maintenance and improvement works i.e. access to asbestos data, electric installation checks and fire risk assessment information.

3.8.13.4. We will deal with complaints under our normal complaints processes.

3.8.13.5. Responsibility for meeting the new requirements regarding resident engagement for building safety in high-risk buildings fall to the HHSBC and link to the Building Safety Resident Engagement strategy, listening to customers, acting on their concerns and using feedback in decision making/setting priorities.

3.8.14. Publicising The Policy

3.8.14.1. The policy will be shared on our internal portal.

3.8.14.2. The policy shall be circulated to all appropriate staff that are directly responsible for its implementation and will be available in the shared drive of Raven’s document management system.

3.8.15. Monitoring & Compliance

3.8.15.1. This policy will be reviewed annually or whenever any significant incident, structural change, legislative change, or other occurrence takes place that is regarded as sufficient to warrant an immediate review.

3.8.15.2. KPIs have been developed, to give Raven Leadership Team, Audit Committee and Board as appropriate, visibility of performance and any emerging issues or risks. Information on performance is captured, recorded, and analysed as a metric against predefined performance criteria.

3.8.15.3. Each management procedure will reflect the KPI’s required for identified areas of compliance.

3.8.15.4. Raven’s Leadership Team shall have oversight of the policy.

4. Applicability

4.1. This policy applies to all properties owned and managed by Raven Housing Trust, inclusive of all its corporate offices, regardless of size.

5. Definitions

5.1. For the purposes of this document a building is defined as – a building’s structure, its grounds up to the boundary and any Raven-owned fences, walls, etc that define that boundary. This includes commercial premises, residential and communal areas, outbuildings, standalone pieces of land and other properties which Raven manages or controls including properties Raven leases to others who act as Landlord.

6. Related policies and references for more information

6.1. The following documentation should be referred to.

• Building safety policy
• Asbestos management plan
• Electrical management procedure
• Fire safety management procedure
• Gas management procedure
• Lift management procedure
• Water systems management procedure
• No access procedure
• Construction, design and management procedure
• Fire risk – managed use procedure

7. Implementation procedures

7.1. Refer to detailed procedures as detailed above.

8. Policy impact

8.1. This Policy review does not impact negatively on customer, employees and stakeholders including those with certain protected characteristics.