Compliance should mean more than box-ticking

Tenant safety is very front of mind, especially given recent tragic events. Despite this, the UK housing sector is in a state of denial when it comes to gas safety.

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We recently ran a survey and spoke to 162 people from housing associations, local authorities and gas industry experts across the UK.

What we’re seeing is that many associations still take comfort in being technically compliant. In other words, as far as they are concerned, they are carrying out the necessary tasks to satisfy the HCA and other external bodies.

Gas safety is rightly at the top of their agenda. But there is a worrying trend towards compliance for the sake of it, which in some cases can be little more than a box-ticking exercise.

This is echoed in the Hackitt Review. One of the key points highlighted in the interim findings says that we need to ‘move away move from a culture of doing the minimum required for compliance’, to one of taking ownership and responsibility for delivering safe homes.

Compliance and safety do not necessarily go hand in hand. An association can be technically compliant while also having potential issues with gas safety.

When meeting social landlords, particularly at the senior level, there is a pride and confidence that they are 100% compliant. Unfortunately, this doesn’t always chime as we talk to employees on the front line.

That being said, there is awareness that compliance in the sector could be better with over 40% of respondents estimating that 80% of housing associations are gas safety compliant.

Interestingly over half of RPs surveyed said their current system of managing gas safety compliance could be improved, despite considering there to be high levels of compliance.

The HCA has also suggested that an ‘iron grip on compliance’ is a fundamental responsibility when it comes to gas safety.

How can you be sure that gas safety compliance is more than box-ticking? There are six key questions that all social landlords should ask themselves:

  • What does compliance mean?

Is it simply having a record for every property, or is it being confident that the work carried out has been completed to a high standard by a qualified, competent professional? Unfortunately, for most it appears that just having a record is good enough. The sector needs to challenge itself and go beyond box-ticking.

  • Are we monitoring weekly compliance of properties?

More importantly, do we know which properties aren’t compliant? That’s what we need to be asking.

Don’t accept information from the past. It’s not the last quarter that you should be interested in. It’s this week.

Historic information, even recent monthly returns, is open to data contamination. Information in real-time is ideal as it raises standards of performance through constant transparency.

Remember gas safety is not a race. There is no finish line. It is a continuous process.

  • What stock do we own and which ones have gas boilers?

A simple question but if an association has an issue with data, then it becomes a much trickier question to answer. This should raise a red flag.

No database remains constant. There are always changes. And any changes, such as growth or stock rationalisation, must be accounted for accurately.

You may know when the properties were legally transferred, but do you know when any boiler was installed or last serviced? Who has this level of detail?

Without the total picture, your information is vulnerable to error and your organisation is vulnerable to non-compliance.

  • Have our policies and procedures been independently audited or tested?

Ask for evidence and don’t rely on assurances based solely on existing custom and practice. There must be a reliable audit trail demonstrating successful performance or the genuine potential for continuous improvement.

How much does your gas safety measure the cost of both staff time and money? Is there room for improvement in greater safety as well as value for money?

  • Are we still using paper based systems for completing gas safety records?

Much has been written about the benefits of digitalisation. Why do we continue to use paper based systems for completing gas safety records?

To remain robust for the future, don’t rely on longstanding measures which are often labour intensive or paper driven.

Technology can remove many of the issues surrounding gas safety. We praise the use of technology in other parts of the business but in many cases we revert to paper when it comes to something as important as gas safety.

  • Who is liable for poor performance or gas accidents?

This is the final and most important question to remember. Don’t wait for near misses or accidents before reviewing longstanding practice.

Make sure at every level of gas safety there is accountability.

Ultimate responsibility is with the CEO and board members. Don’t leave it to a crisis to review and refine policy and practice.

It is your responsibility to ask difficult questions – not just rely on box-ticking – to keep tenants safe.

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