Fire Safety Policy

This policy relates to all gas and non-gas heating systems, appliances, and pipework that YHG has a maintenance and repair responsibility for, this is including those within residential dwellings, common areas of houses of multiple occupation, specialised housing such as sheltered, retirement living, extra care, supported housing and offices.

The policy does not apply to appliances owned by tenants (e.g., cookers) as YHG have no responsibility for those appliances.

Where properties are managed by third parties (e.g. Agency Managed Supported Schemes, PFI Schemes) the heating systems will fall under the scope of this policy so far as the YHG statutory responsibilities detailed in the terms of the management agreement.

Landlords Gas Safety Record (LGSR): a certificate issued by a Gas Safe engineer as a record of their inspection of a gas installation. These are issued for gas installation in domestic properties only.

Commercial Gas Service Record: a certificate issued by a Gas Safe engineer as a record of their inspection of a gas installation. These are issued for commercial gas installation (e.g., district heating boiler, catering equipment).

Gas Industry Unsafe Situations Procedure (GIUSP): this is the gas industry-agreed document which classifies unsafe gas fittings. The procedure indicates different categories of danger for defective fittings and provides guidance for the repair, making safe or disconnection of defective fittings.

Gas Safe Register: the official gas registration body for the UK. To carry out gas works legally in the UK businesses and engineers must be on the Gas Safe Register.

Nationally Accredited Certification Scheme (ACS): The ACS Scheme is the industry recognised and accepted route for gas engineers to gain a certificate of competence, needed to become a member of the Gas Safe Register.

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

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

Gas is a convenient and effective fuel used for space heating, cooking, and other applications. If gas fittings, appliances and flues are however not properly installed or maintained they can pose health and safety risks, including carbon monoxide poisoning, fire, and explosion.

YHG duties to ensuring that all gas installations and heating systems are appropriately maintained and remain safe for continued use can broadly be considered to be:

• To manage the risk from gas, Regulation 36 of the Gas Regulations places a requirement on YHG as a Landlord to carry out an Annual Gas Safety Check (AGSC) on all gas systems, gas fittings, appliances, and flues that they have a maintenance and repair responsibility for. There must robust processes in place to ensure a full and accurate record of all gas installations requiring an AGSC and they must be carried out no later than 12 months after the previous check.
• Where completion of the AGSC 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 check
• Upon completion of an AGSC the Gas Safe engineer will produce an LGSR or a Commercial Gas Service Record as evidence of their inspection of the gas installation. These records should be retained and where applicable shared with the customer
• In the event of the Gas Engineer being unable to fully complete the AGSC they should take all necessary steps to ensure the gas installation is left safe. If any part of the installation is found to be unsafe the Gas Engineer should take action in line with the Gas Industry Unsafe Situations Procedure (GIUSP)
• In some instances, on a AGSC it may also be necessary to turn off (cap) the gas supply, e.g., if there is insufficient gas credit, property and/or full gas installation cannot be accessed. This is done to ensure that the gas installation cannot be used until tested for safety
• The AGSC only must include those gas appliances YHG has a maintenance and repair responsibility for. It is however considered good practice to as a minimum to carry out a visual risk assessment on tenants’ own gas cookers
• In addition to the AGSC YHG should have processes in place to manage the risk of a gas leak or explosion in empty properties and to also ensure the gas installation is checked for safety when a new tenant moves into a property. This is most commonly done through a “Gas Cap Off” (empty property) and a “Turn on and Test” (new tenant) process
• Some other non-gas heating systems may also require periodic servicing/safety checks, (e.g., Solid Fuel and Oil Fuel). These should be carried out in line with relevant industry guidance, e.g., HEATAS guidance for solid fuel appliances
• YHG has an obligation to ensure that any reported faults or failures of a heating system are attended to and rectified in a timely manner. There should be defined time periods for attendance, and these should be determined by the severity/impact of the fault or failure and the circumstances of the customer. In instances where heating cannot be restored alternatives should be offered (e.g., a fan heater)
• Gas works must only be undertaken by appropriately qualified Gas Safe Registered engineers. To be Gas Safe registered engineers must have completed as a minimum an ACS initial assessment. To work on certain type of gas installations further ACS assessments are required, e.g., commercial heating and catering. Landlords should ensure they have processes in place to verify that only appropriately qualified Gas Safe engineers and businesses are carrying out works to their properties. This should be supported by a framework of ongoing quality assurance and performance management arrangements.

The following section details the actions taken and measures that are in place to ensure YHG appropriately carries out safety checks and repairs to all heating systems.

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 regulatory obligations.

The Gas Safety & Heating Policy will be supported by a Gas Safety & Heating Procedure.

Annual Gas Safety Checks

Access Procedure

YHG will operate a Domestic Annual Gas Safety Checks (AGSC) programme that commences at the 10-month anniversary date of the most current LGSR to ensure that sufficient time is available to gain access to properties before the expiration of the existing LGSR. In line with Regulation 36A YHG will adopt a MOT style service meaning if the service is completed within 2 months of the due date, the anniversary will be kept for the following year.

Access to properties will be managed in line with a documented access procedure. The aim of which is to ensure that most properties are accessed within no more than 3 attempts. The procedure will allow sufficient flexibility to accommodate customer requests and circumstances. There will be instances where access is not gained within 3 attempts, if after further Housing Management intervention access is still not gained, it may be necessary to take more formal action to gain access/make safe the gas. This may include:

• Application to the Magistrates Court for an injunction for access
• Access to the property carried out under clause 11.2 of the tenancy agreement
• Capping the gas supply at the external meter.

The above should only be considered once all other attempts and options have been exhausted. In all cases approval to proceed with any of the above must be obtained by the Director of Housing & Customer Service and the Chief Property Officer. This request for approval will be supported by a full chronology of all access attempts and a declaration of any known resident vulnerabilities. Residents will be notified in writing before the above action is enacted.

In those cases where the gas supply is capped at the external meter, the Tenancy Management Officer (TMO) will ensure details are left to explain to the tenant the action to be taken to get the meter uncapped and will also make every effort to leave an electric fan heater. Follow up action will also be taken – see “Gas Supply Capping Off”.

Due to the court waiting times for an injunction application in most cases it will not be possible to apply for and obtain an injunction application before the AGSC expiry date. It is therefore likely that other action will also be taken in conjunction with the application to ensure the AGSC is completed in time, e.g., entry via 11.2 or capping the external meter. The injunction application may however still be pursed so that the injunction can be used if there are access issues in subsequent years.

For those buildings that require an AGSC to a commercial gas installation (e.g., district heating boiler, catering equipment) access is not required to individual properties however orders will be issued to contractor to allow sufficient time for the completion of the AGSC 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.

Gas Supply Capping Off

There will be instances where access is gained to a property however the AGSC cannot be completed. The most common reason for this is that there is no or insufficient gas and/or electric credit available to carry out the safety check.

In these instances, the engineer will be required to turn to off the emergency control gas valve and cap the gas supply on the Landlord’s side of the meter. This is necessary to ensure that the gas installation is left in a safe condition and cannot be used until the AGSC has been completed. The engineer will note on the LGSR that the supply has been “capped off . The engineer will ensure the customer is offered 1 or more electric fan heaters.

YHG will have processes in place to ensure an up-to-date record is maintained of all properties that have been “capped off” (physically capped or disc inserted into the meter where access issues exist, or for other safety reasons). The TMOs will actively contact all affected residents and offer all necessary support to assist the resident in getting the gas supply restored and the AGSC completed. Regular progress updates will be provided to the Director of Housing and Customer Service and Director of Asset and Building Safety.

Unsafe Installations

During the AGSC the engineer may identify gas appliances and/or installation which are defective. The engineer will take action in line Gas Industry Unsafe Situations Procedure (GIUSP), with the appliance/installation falling into one of three types of unsafe categories:

• Immediately Dangerous
• At Risk
• Not to Current Standards (NCS)

In some instances, if the fault is a risk to life or property, the engineer may be required to turn off an appliance at the user control to prevent harm. Should the customer refuse the engineer permission to disconnect the installation or appliance the engineer will be required to report the situation to the gas network provider, Cadent. Cadent have legal powers of entry to make the situation safe and are also able to disconnect the gas supply to the property.

Tenants Own Appliances

Under the Gas Regulations YHG has no responsibility or obligation for the safety, replacement, or repair of tenants’ own gas appliance.

As a duty of care however, as part of the AGSC a visual safety check will be performed on any tenants’ own gas appliance, most notably gas cookers. Any defects identified will be managed as an Unsafe Installation, as detailed above.

Smoke, Heat and CO Alarms

YHG will, at the same time as the undertaking of the AGSC, ensure that a check is made of any installed Smoke, Heat and Carbon Monoxide (CO) alarms.

The gas engineer 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.

In line with expected amendments to the Smoke and Carbon Monoxide Alarm (England) Regulations 2015, YHG is working to ensure all properties have an installed smoke alarm and where there are fixed gas appliances a CO alarm.

Safety Checks to Non-Gas Heating Systems

YHG does have a small number of non-gas heating systems, that though have no regulatory safety check requirements, Landlords are guided towards carrying out certain safety and/or operational checks. These systems include Solid Fuel, Oil Fuel, Biomass, Air & Ground Source and Solar Thermal.

Where these systems exist YHG will carry out safety and/or operational checks in line with industry guidance document, manufacture’s instructions and best practice advice.

For example, for properties containing a Solid Fuel burning installations/appliances, YHG will arrange for a HEATAS qualified engineer to sweep and carry out the relevant safety checks to the chimney that serves the appliance and, where appropriate, on the appliance itself on a 6-monthly basis.

Air & Ground Source Heat Pumps and Solar Thermal manufacture instructions recommend an annual service and clean of the equipment and a check/replenishment of Glycol levels.

Gas Fires

YHG aims to proactively reduce the number of open flued gas appliances within its portfolio to mitigate the possible production of Carbon Monoxide fumes within our customers’ homes. As such, YHG will cap off the supply and remove gas fires from all void (empty) properties during the void process.

YHG will also not permit the installation of a gas fire within its properties. Any customer requests to install a gas fire will be denied other than those instances where any such appliance is required under proven medical grounds.

Voids

YHG will ensure that at tenancy turnover/voids any live gas supply is “capped off” within 48 hours of the keys being received from outgoing tenant.

During the engineers visit they will turn off the gas supply at the meter (either external or internal), label the meter to state that this is now ‘capped’ and physically cap the gas pipe at the meter. They will also inspect the property and complete an LGSR, clearly noting down any faults found and that the gas supply to the property has been capped.

During the winter months, to minimise the risk of damage from burst frozen pipes, the cap off may also include isolating the water supply to the property and drain of all water from the system. During the void works any gas cooker bayonet fittings or gas fires installed by a previous customer will be removed and capped before re-letting.

New tenants moving in will be advised to make arrangements with an energy supplier and to then contact Your Response to arrange a “Turn on and Test”, i.e., to have the gas supply turned back on and an AGSC completed. This will be carried out within 1 working day of the customer request being made and an LGSR produced.

Heating and Hot Water System Repairs

Target Response and Fix Times

YHG have an obligation as a Landlord to ensure that any reported faults or failures of a heating system are attended to and rectified in a timely manner.

A job will be raised for all reported faults or failures and allocated to the appropriate heating contractor. The contractor will be advised of the Target Response Time and the Target Fix Time. These will be determined by the nature of the fault, the impact, and the vulnerability of the customer, as detailed below.

Staff raising reports of faults or failure will have guidance to refer to in order to make an informed decision and judgment as to the required response and fix time. This will include specific guidance on the action required should a customer report concerns of a smell/leak of gas and/or CO alarm activation/symptoms.

The Compliance Team will have processes in place to monitor that contractors are adhering to Target Response and Fix Times, with action taken to address service failures.

Temporary Heaters

Some faults may mean that it is not possible to restore the heating on the initial visit, e.g., if parts are required. In these instances, the gas engineer will ensure the customer is offered 1 or more electric fan heaters. Compensation for the increased utility costs for the use of these heaters will be offered to customers in line with the YHG Compensation Policy.

Replacement Heating System

Planned replacement of heating systems will form part of the Planned Investment Programme, to ensure where possible heating systems are proactively replaced and upgraded before they go beyond economic repair and start to suffer high rates of failure. Programmes will be determined based upon stock condition survey information held within Keystone, supported by repairs data and suggestions from the Compliance Team (e.g., appliances with obsolete parts).

It is however recognised that outside of any planned replacement programme there will be instances where a heating appliance fails and cannot be repaired. YHG will ensure that they’re processes in place to accommodate urgent reactive component replacements.

Certification & Documentation

Upon completion of an AGSC the contractor will provide a copy of the relevant certification to YHG, i.e., the LGSR or Commercial Gas Service Record. LGSRs will also be posted by the contractor to the customer within 28 days of the AGSC being undertaken.

All AGSC certification will be saved against the property/building within Documotive.

Asset Data & Reconciliation

YHG will hold and maintain accurate records against each property and scheme, details of the heating system, the requirements for servicing along with the associated due and completion dates. This will be held with the Orchard Housing Management System.

Processes will be in place to ensure records 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 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 relevant servicing schedule.

As part of this reconciliation process YHG will work toward ensuring that where the responsibility for the safety checks falls to a third party (e.g., Agency Managed Supported Scheme, PFI Schemes) action is taken to ensure evidence is obtained that all necessary safety checks have been undertaken.

In addition, it is the intention that to provide assurance that all properties with a gas supply are included within the AGSC programme, all properties identified as not having a current gas supply will be subject to review, which is likely to include a physical property inspection.

Contractor Competence, Quality Control and Performance

YHG must be able to satisfy themselves that all those carrying out gas works within its buildings and properties are competent to do so, specifically they must ensure that all businesses and engineers carrying out Gas works are Gas Safe Registered. In addition, it must be ensured that those individual engineers carrying out works hold the appropriate qualifications (i.e., ACS assessments) for the specific types of gas works they are undertaking.

The Compliance Team will maintain a register of all Gas businesses and engineers carrying out works for YHG. This will include the specific qualifications of the engineers and the expiration date. Processes will be in place to ensure that the register is kept up to date, e.g., new engineers are added, and that evidenced is obtained of renewed qualifications. 

The performance of gas and heating 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.

All LGSRs are checked/validated by YHG’s Document Reader System - CDMS. This system “reads” all LGSRs to verify that all fields have been completed and completed with valid data. The system provides an output confirmation on if each LGSR has Passed or Failed, allowing corrective action to be taken if necessary.

A desktop audit is carried out of all Commercial Gas Service Record by the Compliance Contract Manager.

To support performance management and to provide assurance on the quality and safety of work YHG will employ a Quality Assurance consultant to carry out on-site independent post works, servicing, and installation inspections including validation of AGCS certification as well as ‘Work in Progress’ (WIP) on site audits. Customers will be made aware that they may be contacted to request access for an audit. Quality Assessors provide technical and corrective advice as well as monthly reporting and trend analysis to YHG regarding the performance of the engineers.

YHG commission as a standard a 5% assurance check. These levels may fluctuate depending on the results provided and may rise to 8%, 10% or higher if the factual evidence points towards a lack of reputable workmanship undertaken by the contractor’s engineers.

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 Gas Safety & Heating Procedure will provide further details on the roles and responsibilities of all staff with day-to-day responsibility for fire 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 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 regulatory obligations and the policy measures.

The Chief Property Officer

will work closely with the Head of Compliance to seek assurances that regulatory obligations and policy measures are being adhered to and services delivered in line with budget. They will carry out quarterly strategic performance reviews of heating contractors to ensure compliance with their contractual obligations. Together with the Director of Housing & Customer Service they will approve any requests to take forced measures to gain access/make safe the gas.

Director of Housing and Customer Service

will, together with the Chief Property Officer, approve requests to take forced measures to gain access/make safe the gas. They will maintain an oversight of those properties with a capped gas supply and seek assurances from the Head of Housing that appropriate action is being taken to support effected customers.

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. They will also work closely with the Head of Housing on the reporting of those properties with a capped gas supply.

Head of Housing/ Supported Housing/Older Persons Services

will ensure Housing Management staff’s adherence to the gas access procedure, ensuring appropriate and timely action is taken to secure access to properties, ultimately reducing instances of formal action. In those instances where formal action is required, they will present the case for approval to the Director of Housing and Customer Service and Chief Property Officer. They will be responsible for ensuring Housing Management staff are appropriately supporting those customers with a capped gas supply and provide regular progress updates to the Director of Housing and Customer Service and Chief Property Officer.

Compliance Operations and Contract Manager (Gas & Heating)

will be responsible for the day-to-day operational delivery of all gas and heating related servicing and maintenance. 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 servicing certification is received and verified. They will act as the organisations technical lead for gas safety and heating systems, 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 the requirements of the Regulations and other industry guidance and will fail to appropriately maintain customer heating and hot water systems, leading to a detrimental impact on their safety and comfort. This may result in:

• Prosecution by the Health and Safety Executive under Health and Safety at Work Act 1974
• Prosecution under the Gas Safety (Installation and Use) Regulations 1998
• 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 LGSR and Commercial Gas Service Records will be stored at a property or building specific level within Documotive. LGSRs will also be held within CDMS, YHGs Document Reader System.

LGSR and Commercial Gas Service Records must be retained for a minimum of 2 years.

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

A full audit trail of all safety checks and heating repairs is held with Orchard, together with, where necessary job specific notes regarding access attempts, 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 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 gas access procedure if required.

YHG will work towards doing more to promote and raise awareness of gas safety to customers, including an understanding of gas safety issues and the importance of the AGSC. Specific advice will also be drafted for those customers with solid fuel appliances.

All staff with operational involvement with gas and heating related servicing and maintenance will need to have and maintain suitable and sufficient system training, e.g., Orchard and Documotive.

Compliance Contract Managers responsible for the day-to-day operational delivery of gas and heating related servicing and maintenance will be required to hold and retain ACS assessment and Gas Safe Registration.

They, together with the Compliance Operational Manager 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 Gas Safety Managers (AGSM).

The completion of AGSCs 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.

The completion of non-gas safety checks in line with their due date 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 heating repairs, including % of jobs attended to on time, average days to complete works orders and first-time fix rate.

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.