Electrical Safety Policy

This policy is applicable to all fixed electrical installations within all buildings and properties that YHG has a defined maintenance and repair responsibility for. This includes residential dwellings, common areas of houses of multiple occupation, specialised housing such as sheltered, retirement living, extra care, supported housing and offices.  

In addition, the policy will outline YHG’s approach to undertaking Portable Appliance Testing (PAT) on appliances provided by YHG for use employees, customers, and visitors. 

It will also outline YHG’s requirements to maintain Lightning Protection Systems (LPS).

Where properties are owned by YHG but the maintenance and repair responsibility is managed by a third party, seeking knowledge of the existing compliance record will also fall under the scope of this policy. This is in-line with the technical reporting requirements of the Tenant Satisfaction Measures (TSMs) as specified by the regulator and in addition to any responsibilities detailed within the terms of the management agreement. 

Periodic Electrical Inspection – an inspection of the condition of an existing electrical installation, to identify any deficiencies against the current national standard for electrical installations. 

Portable Appliance Testing (PAT) – the process of checking electrical appliances for safety through a series of visual inspections and electronic tests. 

Lightning Protection Systems (LPS) – a system of external earthing and internal surge protection designed to prevent lightning strike damage to buildings. 

Electrical Installation Condition Report (EICR) – a formal document produced following a periodic electrical inspection which evidences the condition of the electrical installation. 

Electrical Installation Certificate (EIC) – a safety certificate issued to confirm that a new electrical installation or addition is safe to use at the time it was put into service. Additions may include new consumer units or additional circuits. 

National Inspection Council Electrical Installation Contractors (NICEIC) – a voluntary body that regulates the training and works of electrical contractors and organisations across the UK. 

Consultation has taken place with the following. Their feedback has been considered and the policy update:

• Equality Impact Assessors Group
• Customer Scrutiny Panel
• Customer Connect Panel
• Chief Property Officer 
• Director of Housing & Customer Service.

Fixed electrical installations should be regularly tested and inspected as they can deteriorate due to a number of factors such as damage, wear, tear, corrosion, excessive loading, aging and environmental issues. There may also be incidences of unauthorised electrical alteration being carried out by, or on behalf of the customer. Unsatisfactory electrical installations could lead to hazards such as fire and electrical shock. They should therefore be tested and inspected at regular intervals to check whether they remain in satisfactory condition for continued use.  

In order manage the risks resulting from the exposure to unsafe electrical installations and equipment Landlords should implement and maintain a periodic fixed electrical installation inspection regime which results in the issue of an Electrical Installation Condition Report (EICR).  

YHG’s duties in relation to the completion of EICRs include:

• The frequency of testing should be in line with British Standard and the Guidance Notes, which states that the maximum period between testing should be no longer than 5 years and for domestic dwellings, should also be carried out at every change of occupancy. YHG plan to fully move all homes to a 5-year cycle by April 2025 subject to access being achieved
• For properties that are having a change of tenancy the following should apply, all void properties will receive a full EICR carried out unless an EICR has been completed in the 
  last 12 months then a visual certificate will be produced whilst referencing the full EICR details. For mutual exchanged all properties will receive a full EICR shall be produced on the day of exchange
• To have robust processes in place to ensure a full and accurate record of all electrical installations requiring testing, together with the last test date and next test due date
• Where completion of an EICR requires access to a customer’s home, YHG should have a formal access procedure in place that is followed to gain access, evidencing that all reasonable and practical steps have been made to complete the test
• Upon completion of a fixed electrical installation test an EICR should be produced as evidence of the inspection and to confirm that the installation is in Satisfactory condition. The EICR should state the testing electricians’ recommendation as to when the installation should be next inspected, up to an interval of no more than 5 years. They should make this decision based on their assessment of the overall condition of 
  the electrical installation
• In some instances, the electrician may identify defects with the electrical installation. Defects should be classified by the electrician as one of the following and they will detail within the EICR their recommended rectification:

1. Classification code C1 - Danger present. Risk of injury. Immediate remedial action required. EICR will state that the installation is Unsatisfactory
2. Classification code C2 - Potentially dangerous. - Urgent remedial action required - EICR will state the installation to be Unsatisfactory
3. Classification code C3 - Improvement required. - EICR will state the installation to be Satisfactory.

• YHG should have documented procedures as to how each classification of defect will be managed. These procedures should also detail the requirements for the re-issue of testing paperwork following completion of rectification works,including those instances where a partial or full new installation is required. YHG should also ensure complete and accurate evidence is retained of testing and of any remedial works carried out
• Electrical testing and remedial works should only be carried out by suitably qualified and competent electricians. YHG should ensure there are processes in place to verify that only appropriately qualified and accredited electricians and businesses are carrying out works to their properties. This should be supported by a framework of ongoing quality assurance and performance management arrangements. 
  Some YHG buildings will be installed with a Lightning Protection System and where these are present there is a requirement for them to be maintained in accordance with BS EN 62305. 

The following section details the actions taken and measures that are in place to ensure fixed and portable electrical installations are appropriately tested and maintained.  

These actions and measures demonstrate YHGs commitment to ensuring a safe environment within which our customers can live and within which our staff can work, as well as satisfying our obligations under British Standards industry guidance.  

The Electrical Safety Policy will be supported by an Electrical Safety Procedure.

Access Procedure 

Access to properties for the completion of an EICR will be managed in line with a documented access procedure, with access attempts starting approx. 10 weeks ahead of the EICR expiry date to ensure that all reasonable and practical efforts have been made to complete the test before the expiration date, with a full and detailed audit trail maintained.  

Access efforts will include appointment letters, phone calls and property visits by the contractor and their Tenant Liaison Officer, with further support from Housing Management if required. The procedure should allow sufficient flexibility to accommodate customer requests and circumstances. 

The access procedure will largely mirror the gas access procedure however currently YHG will not take formal action to gain access (e.g., injunction application, or entry via clause 11.2 of the tenancy agreement) as is done with Annual Gas Safety Checks.  

For those buildings where an EICR is required to be carried out to the electrical installation within the communal areas access is not required to individual properties however, orders will be issued to a contractor to allow sufficient time for the completion of the EICR ahead of the certificate expiry date, with support from the Compliance Team and on-site staff to ensure access is gained to all necessary areas.  

Defects 

Where a test deems that the electrical installation is not satisfactory then timely action should be taken to bring the installation up to a satisfactory standard, with every effort made to ensure all necessary work is completed before the current EICR expiry date. 

Testing defects will be classified by the electrician as one of three classifications and YHG will instruct contractors to manage defects as per below:

• Classification code C1: Danger present/ Risk of injury - Immediate remedial action should be undertaken to rectify the defect at the time of the inspection. If it is not possible for the electrician to complete the work and deem the electrical installation to be in a safe condition, the electrician should seek to isolate the parts of any circuit, which is deemed unsafe and report the findings to YHG immediately
• Classification code C2: Potentially dangerous. - Urgent remedial action should be undertaken. Where possible this will be done at the time of the inspection however if this is not possible the contractor should ensure the work is completed within 28 days
• Classification code C3: Improvement required. – These pose no risk to the electrical installation but are improvements that could be made to bring the installation in line with current standards. YHG will ensure that all code 3 faults are analysed using its certificate software system TCW. Where trends and common faults are identified, these shall be considered as part of future electrical upgrade programmes. 

Where any further works are required by the contractor to address code 1, 2 or 3 faults these should be carried out before the EICR is issued to YHG so that the EICR issued states the installation to be Satisfactory. 

Should defects be considered to be due to a tenant installing electrical equipment or apparatus YHG should be informed immediately, and where possible the defective installation isolated and “made safe” (in accordance with the Classification code) and the tenant notified of this. 

Smoke, Heat and CO Alarms 

YHG will, at the same time as the undertaking of the EICR, ensure that a check is made of any installed Smoke, Heat and Carbon Monoxide (CO) alarms. The electrician will test that each appliance is sounding and working in line with manufacturer’s instructions and 
industry best practise.   

The engineer will replace any existing defective alarms with a battery-operated replacement until such time as a hard-wired alarm can be installed. Sufficient battery operated alarms shall be installed so as to fulfil legal and statutory obligations, This includes Smoke, Heat and Carbon Monoxide Alarms where fixed gas appliances exist. 

Portable Appliance Testing 

YHG is not responsible for the maintenance of electrical appliances unless the appliance has been supplied by YHG, e.g. YHG is not responsible for appliances within homes that have been purchased by the customer. YHG does however have a responsibility for electrical appliances issued or used by staff, e.g., laptops, monitors, mobile phone charges and also electrical appliances within communal areas that may be used by staff or customers, e.g. audio equipment and white goods such as kettles and microwaves. YHG may also have some instances where appliances have been supplied within domestic dwellings, e.g. integral white goods installed in a new development, and YHG retain responsibility. 

Where YHG is responsible for electrical appliances a PAT will be carried out in line with IET Code of Practice for In-service Inspection and Testing of Electrical Equipment guidance. 

The frequency of testing should be determined based on a risk assessment which considers how often equipment is used, who is using it and the environment it is used in. Currently, YHG carry out a PAT to all applicable appliances either yearly or biannually however will work towards reviewing this and ensuring evidence of risk-based approach. 

Lightning Protection Systems 

Where LPS are installed to buildings that YHG has a maintenance and repair responsibility an annual safety inspection will be carried out by lightning specialist and in line with BS EN 62305. Most YHG buildings with LPS will have had the system installed as part of the build having given consideration to the size and height of the building and the environment, e.g. frequency of lightning strikes in the area. There may be occasions where YHG are guided to install a LPS to an existing building following a Fire Risk Assessment. 

Asset Data & Reconciliation  

YHG is required to ensure a valid certification is in place for all fixed electrical installations and portable appliance within all buildings and properties that it has a defined maintenance and repair responsibility for.  

YHG will hold and maintain an accurate record within the Orchard Housing Management System of all buildings and properties that require an EICR, PAT, LPS safety inspection, together with the last test, testing frequency (as recommended by the last testing  engineer) and the next due date.    

Processes will be in place to ensure testing schedules are updated to reflect any property divestments, acquisitions (including new builds) and any changes to maintenance and repair responsibility. 

In addition, on an annual basis a full EICR property reconciliation will be carried out. This will reconcile the information within Orchard against Keystone Asset Management System to ensure all applicable building and properties remain captured in the EICR schedule.  

As part of this reconciliation process YHG will work toward ensuring that where the responsibility for electrical safety to a third party (e.g., Agency Managed Supported Scheme, PFI Schemes) action is taken to ensure evidence is obtained that all necessary electrical tests have been undertaken and this is in accordance with the requirements of the Tenant Satisfaction Measures. 

Certification & Documentation 

Upon completion of an inspection and test, YHG will obtain from the contractor the EICR, PAT record or LPS safety certificate, which will be then used to update Orchard with the testing date and the next test due.  

For EICRs the next test due date will be as per the testing electrician’s stated recommendation on the EICR as to when the installation should be next inspected, up to an interval of no more than 5 years. Where EICR’s are outside of this policy, YHG are  working towards inspecting these and bringing them in-line with this policy. 

In addition to the scheduled regime, an EICR will be completed as part of the void works before any property is re-let. The contractor carrying out the test will ensure a copy of the EICR is issued to the Compliance Team so that the EICR details in Orchard can be updated accordingly. 

If any properties require adding to the testing schedule, evidence of a current valid EICR or in the case of new developments an Electrical Installation Certificate (EIC), must be obtained.  

YHG will only accept EICRs that are stated as “Satisfactory”. If a test is carried out and defects deem the installation to be “Unsatisfactory” all necessary remedials works should be carried out before the EICR is issued to YHG so that the EICR issued states, the installation to be Satisfactory. YHG will not accept “Unsatisfactory” EICRs supported by a minor works certificate. In the case of an EIC, these will be accepted as an inspection record 
if either the full installation has been replaced or if only a partial replacement has taken place, all remaining elements of the installation have been tested.  

Before issue to YHG all EICRs (and EICs) must be reviewed and signed by the contractors Electrical Qualifying Supervisor. For added assurance a percentage desktop audit will also be carried by the Compliance Contract Manager. All gas certification is checked/validated by YHG’s Document Reader System – CDMS. YHG will look towards developing this system further to allow for the checking and validation of EICRs. 

All EICRs (and EICs), EICR, PAT records and LPS safety certificates will be saved against the property/building within Documotive. 

Contractor Competence, Quality Control and Performance YHG must be able to satisfy themselves that all those carrying out electrical testing within its buildings and properties are competent to do so.  

All contractors procured to undertake electrical testing must be accredited an approved 3rd party certification scheme such as  The National Inspection Council Electrical Installation Contractors (NICEIC). The electricians undertaking the testing on behalf of YHG 
will as a minimum hold the following qualifications:  

• NVQ level 3 Electrical Installation or recognised equivalent
• City & Guilds 2382-18 Level 3 Award in Requirements for Electrical Installations BS7671:2018
• City & Guilds 2391 or 2394 & 2395 Inspection and testing.

The Compliance Team will maintain a register of all electrical contractors and electricians carrying out testing works for YHG. This will include the specific qualifications of the electricians and if applicable the expiration date. Processes will be in place to ensure that the register is kept up to date, e.g., new electricians are added, and that evidenced is obtained of any renewed/updated qualifications. 

The performance of electrical testing contractors will be managed by the Compliance Contract Managers, supported by a suite of internal metrics and KPI dashboards. Monthly Operational Meetings are held with Contractors within which performance is discussed 
and documented, with procedures in place to take more formal action to address performance issues if required.  

To support performance management and to provide assurance on the quality and safety of work YHG will work towards employing a Quality Assurance consultant to carry out a percentage audit of completed EICRs. The Quality Assessors will provide technical and 
corrective advice as well as monthly reporting and trend analysis to YHG regarding the performance of the contractor and its electricians.  It is envisaged that YHG will commission a 5% assurance check, with the opportunity to increase if the factual evidence points towards a lack of reputable workmanship being undertaken. 

The roles and responsibilities for key stakeholders across YHG is detailed below. 

Note - these are the roles and responsibilities in specific relation to the delivery of this policy only. The Electrical Safety Procedure will provide further details on the roles and responsibilities of all staff with day-to-day responsibility for electrical safety.

• Chief Executive will need to ensure that resources are made available to allow the actions and measures detailed in this policy and any associated procedures to be effectively delivered. They will discharge their responsibilities for the for the delivery of services in line with policy and procedures to the  Chief Property Officer and Head of Compliance & Building Safety however will retain an oversight on progress/performance
• Board Members will review reports and/or performance indicators that provide progress updates to ensure that YHG is meeting the requirements of its obligations under industry guidance and the policy measures
• Executive Director of Property will work closely with the Head of  Compliance to seek assurances that obligations under industry guidance and the policy measures are being adhered to and services are delivered in line with budget. They will 
  carry out quarterly strategic performance reviews of contractors to ensure compliance with their contractual obligations
• Head of Compliance & Building Safety is responsible and accountable for the overall implementation, and regular review, of this policy and ensuring its objective are 
  achieved. They are also responsible for compliance performance reporting to the Chief Property Officer, Board and the Chief Executive. They will ensure that any compliance 
  and/or H&S related issues are brought to the attention of the Chief Property Officer and provide regular updates on service delivery against budget
• Head of Housing/ Supported Housing/Older Persons Services will ensure Housing Management staff’s adherence to the access procedure, ensuring appropriate and timely action is taken to secure access to properties, ultimately maximising the number of properties accessed ahead of EICR expiry date
• Compliance Contract Manager (Electrical) will be responsible for the day-to-day operational delivery of all electrical testing. They will effectively manage the performance of the service delivery contractors, including their ongoing competence, 
  and proactively monitor service delivery against targets. They will be responsible for monitoring the quality of work undertaken by the contractor and ensuring all certification is received and verified. They will act as the organisations technical lead for electrical safety, ensuring that YHG continue to work in line with the most up to date regulations and industry guidance. 

The risks of not following this policy are that YHG will not comply with industry guidance and will fail to appropriately maintain electrical installations, leading to a potentially detrimental impact on the safety of customers and staff. This may result in:

• Prosecution by the Health and Safety Executive under Health and Safety at Work Act 1974
• Prosecution by the Local Authority under the Housing Act 2004
• Prosecution under Corporate Manslaughter and Corporate Homicide Act 2007
• A judgement of serious detriment by the Regulator of Social Housing
• Reputational damage
• Loss of confidence by stakeholders in the organisation. 

All completed EICRs and EICs will be stored at a property or building specific level within Documotive.  

EICRs and EIC will be retained for a minimum of 6 years.  

Certification will include the full property address along with the current tenant’s name. Access to Documotive is however login restricted.  

A full audit trail of all EICR access attempts will be held in Orchard, including details of communication with the contractors and customer etc. Access to Orchard is however login restricted.  

This Policy will be applied in a way which ensures equality of treatment for all customers without discrimination, or victimisation on account of any protected characteristic as defined within the Equality Act 2010. In drafting this policy YHG has had regard to its public sector equality duties under s149 of the Equality Act 2010, namely the need to:  

• eliminate discrimination, harassment, victimisation, and any other conduct that is prohibited under the Act
• advance equality of opportunity between people who share a relevant protected characteristic and persons who do not share it
• foster good relations between persons who share a relevant protected characteristic and persons who do not share it.  
  The policy pays regard to diversities around access to and delivery of any services.  

On request YHG will provide translations of all its documents, policies and procedures in various languages and formats including computer disc, braille, large print, and tape. 

An Equality Impact Assessment (EIA) has been undertaken on this policy and a copy is available upon request. 

This policy will be communicated internally to staff via the intranet, Youggle. Key stakeholders and  key staff where this policy has specific impact will be briefed individually or collectively as required. 

The policy will be shared with customers upon request, together with the access procedure if required. 

YHG will work towards doing more to promote and raise awareness of electrical safety to customers, including an understanding of electrical safety issues and the importance of the EICR test. 

All staff with operational involvement with electrical testing will need to have and maintain suitable and sufficient system training, e.g., Orchard and Documotive. 

The Compliance Contract Manager responsible for the day-to-day operational delivery of electrical testing and safety will be required to hold and retain a recognised electrical training qualification along with completing training in relation to any updates to the British Standard BS7671. They will also be expected to proactively maintain their Continued Professional Development to keep up to date and abreast of relevant industry and legislative changes. This will be in part achieved through membership and participation with the Association of Electrical Safety Managers (AESM).

The completion of EICRs in communal areas in line with their due date forms part of the “Health & Safety – Customer’s Homes” balanced scorecard KPI. This is reported monthly to Board, ELT and SLT.  

Update on progress on the domestic EICR programme is presented monthly to Risk & Compliance and quarterly to Customer Services Committee.  

Several KPI dashboards are available and used to monitor the performance of the contractors in relation to electrical testing, including 1st time access rate and visits completed in line with the access procedure.

This policy will be reviewed every two years, or sooner if required by statutory, regulatory, best practice, emerging developments, or circumstances arising from reviews of other Group wide policies.  

The policy will be reviewed by the Head of Compliance & Building Safety.