Electrical safety policy

1. Aims and objectives of the policy

1.1 The health and safety of tenants, leaseholders, residents, visitors, staff and contractors is of paramount importance to the council. Poorly maintained electrical installations increase the risk of fire and electric shocks occurring, which can lead to fatal accidents, and costly damage occurring to both council, and residents' own property. This policy sets out the approach to managing electrical safety and the maintenance of fixed electrical installations to all council owned building's, which are within the management responsibility of Housing Leeds.

1.2 This policy aims to demonstrate that the Council has appropriate measures in place to comply with relevant legislation, regulation, and other relevant codes of practice, and good practice guidance.

1.3 The main aims and objectives of this policy are to ensure that Housing Leeds are:

protecting the safety of residents and other building users, through the robust management of electrical safety in council homes, and reducing the risks of fires, electrical shocks, and damage to property occurring
meeting our legislative and regulatory duties around health and safety and the provision of safe and quality homes
making all services relating to electrical safety accessible to residents and providing transparency around our responsibilities as landlord and the responsibilities of tenants and other stakeholders

2. Legislative context

2.1 Relevant legislation and guidance:

Building Safety Act 2022
Defective Premises Act 1972
Landlord and Tenant Act 1985
Housing Act 1988
Environmental Protection Act 1990
Fire Safety Act 2021
Homes (Fitness for Human Habitation) Act 2018
Equalities Act 2010
Electricity at Work Regulations 1989
Health and Safety at Work Act 1974
Management of Health and Safety at Work Regulations 1999 Responsibility for Electrical Safety
Electricity Safety Quantity Continuity Regulations 2002 (amended 2009)
Utilities Act 2000
Construction (Design and Management Regulations) 2015
Building Regulations (England) 2010 (Amended 2023)
Workplace (Health, Safety and Welfare) Regulations 1992
BS 7671: (Latest edition including Guidance notes)
The provision and Use of Work Equipment Regulations 1998
Plugs and Sockets Regulations 1994
The Electrical Equipment (Safety) Regulations 2016
The Supply of Machinery Regulations 2008
Smoke and Carbon Monoxide Alarm (Amendment) Regulations 2022
British Standards

2.2 Relevant social housing regulations:

The Consumer Standards (in particular the Safety and Quality standard)
The Decent Homes Standard
Tenant Satisfaction Measures (TSMs)

3. Strategic context

This policy supports the Leeds City Council 'Best City Ambition' of tackling poverty and inequality and improving quality of life for everyone who calls Leeds home, through our three pillars of Health and Wellbeing, Inclusive Growth and Zero Carbon.

This policy also contributes to the key themes of the Housing Strategy and in particular:

Improving housing quality
Child and age friendly housing
Thriving and inclusive communities
Safe and strong communities
Health and housing

3.3 This policy also contributes to the delivery of the Housing Leeds Asset Management Strategy and Health and wellbeing strategy.

3.4 This policy should be read in conjunction with the Leeds City Council tenancy agreement.

4. Scope of this policy

4.1 The policy covers all fixed electrical installations and infrastructure within buildings and common areas; inclusive of residential dwellings, communal and circulation areas, Retirement Life and Extra Care schemes, and other ad-hoc buildings such as communal rooms and plant rooms which are within the management responsibility of the council's Housing Leeds service, including residential properties, community centres, garages, and boiler houses.

4.2 The policy does not apply to non-council owned dwellings or other non-council housing assets such as schools, care homes, offices. or commercial properties.

4.3 This policy does not apply directly to buildings and homes under PFI management or the Belle Isle Tenancy Management Organisation (BITMO). However, in these service areas, Housing Leeds have a responsibility to ensure that the minimum standards set out in this policy are in place and are sufficiently robust across all council managed homes.

4.4 All employees of the council, who are involved with the management and maintenance of Housing Leeds managed housing, including contractors or all persons visiting the buildings for the purpose of carrying out their work duties on behalf of the council, are required to adhere to the standards set out within this policy.

4.5 Electrical installations and equipment within leaseholder properties is outside of the scope of this policy.

4.6 Electrical equipment not owned or managed by Housing Leeds, including tenants own electrical equipment, is outside of the scope of this policy.

5. Sanctions

5.1 Housing Leeds accepts its responsibilities in accordance with the regulatory standards and legislation relating to electrical safety.

5.2 Failure to comply with these statutory obligations may result in:

Prosecution by the Health and Safety Executive under Health and Safety at Work Act 1974
Prosecution under Corporate Manslaughter and Corporate Homicide Act 2007
Regulatory Notice from the Regulator of Social Housing

6. Main policy

6.1 Overview

6.1.1 Fixed electrical installations should be regularly tested and inspected as they can deteriorate due to several factors which include, wear and tear, corrosion, excessive loading, aging and environmental issues. Dangerous installations can also occur due to incidences of unauthorised electrical alteration being carried out by, or on behalf of the tenant, vandalism, and neglect.

6.1.2 Unsatisfactory electrical installations can lead to hazards such as fire and electrical shock and therefore they should be tested and inspected at regular intervals to check whether they remain in satisfactory condition for continued use. An effective responsive repairs programme is also important to ensure that hazards and defects can be inspected and rectified on an ad-hoc basis.

6.1.3 Where electrical installations are reaching the end of their life, planned programmes should be in place to upgrade and replace these, and often it is appropriate to coordinate this work alongside elemental improvement work such as kitchen replacements and void refurbishment work.'

6.2 In order to eliminate and reduce the risks resulting from the exposure to unsafe electrical installations and infrastructure, the council have a periodic inspection and testing programme in place which is carried out by appropriately qualified electrical engineers.

6.3 The maximum period between inspection and testing of electrical installations for both houses and flats, and communal areas, should be no longer than five years.

6.4 Housing Leeds have adjusted the inspection and testing programme and are working towards full compliance with this timescale following a change from the previous recommended period between testing of no longer than ten years.

6.4 Inspection and testing is also carried out at every change of occupancy, including prior to the reletting of empty and homes and as part of Mutual Exchanges.

6.5 Upon completion of each test/inspection, an Electrical Inspection Condition Report (EICR) is completed and will be made available to residents upon request. The EICR will state the testing engineers' recommendation as to when the installation should be next inspected, up to an interval of no more than five years. The engineer will make this decision based on their assessment of the overall condition of the electrical installation.

7. Defects

7.1 In some instances, the engineer may identify defects with the electrical installation. Any defects are highlighted on the EICR and are classified by the electrical engineer with one of the following classification codes:

C1 - Danger present - risk of injury. Immediate action required. The EICR will state that the installation is unsatisfactory
C2 - Potentially dangerous. - Urgent remedial action required. The EICR will state the installation to be unsatisfactory
C3 - Improvement required. The EICR will state the installation to be satisfactory
FI - Further investigation required. The EICR will state the installation to be unsatisfactory

7.2 Timescales for remedying defects are:

C1 codes will be rectified during the inspection visit. Where this is not possible, the electrician will isolate part of or all of the installation until the defect can be remedied
C2 codes are ordinarily undertaken through a follow-on visit if not able to easily rectify during the inspection visit
C3 codes are ordinarily addressed as part of future upgrade and improvement works
FI codes are requested to be undertaken during the inspection visit but if unable, the electrician will assure safety and arrange to undertake on a follow-on visit

7.3 Where defects or classification codes require remediation work, this will be completed with one of the following certificates issued for the works.

Minor Works Certificate - Whereby an alteration or addition to an electrical system has taken place. This will be added to the existing EICR to complete requirements
Electrical Installation Certificates - Whereby new electrical infrastructure is installed. If a consumer unit is installed this would supersede the EICR. All other new installation works would provide an EIC alongside the current EICR

7.4 In the event that a C1 defect cannot be rectified in a timely manner, meaning that the home will be left in an unsafe situation such as no power for a prolonged period, it may be necessary to provide temporary accommodation until the defect can be satisfactorily repaired.

8. Wider testing, servicing and inspection programmes

8.1 Lightning protection systems receive an annual safety inspection. Any defects found are repaired as required by a lightning specialist contractor in line with BS EN 62305

8.2 Fire alarm systems to building communal areas have a quarterly safety inspection undertaken. Any defects found are repaired as required by external and internal service providers in line with BS5839-1

8.3 Emergency lighting systems are inspected monthly, and an annual full safety inspection is completed. Any defects found are repaired as required by external and internal service providers in line with BS5266.

8.4 Mechanical ventilation and heat recovery systems to individual dwellings have an annual safety inspection carried out. Any defects found are repaired as required by external and internal service providers in line with IET approved codes of practice for in-service inspection and testing of electrical equipment and manufacturer's instructions.

8.5 Automatic opening ventilation systems to communal areas of buildings receive a bi-annual safety inspection. Any defects found are repaired as required by external and internal service providers in line with BS7346-8 and/or manufacturer's instructions.

8.6 Communal ventilation systems receive an annual safety inspection. Any defects found are repaired as required by external and internal service providers in line with Building regulations and/or manufacturer's instructions.

8.7 Communal laundry equipment receives an annual safety inspection. Any defects found are repaired in line with IET approved codes of practice for in-service inspection and testing of electrical equipment and manufacturer's instructions.

8.8 Portable appliance equipment (Housing Leeds owned equipment only) has an annual safety inspection. Any defects found are repaired as required in line with IET approved codes of practice for in-service inspection and testing of electrical equipment and manufacturer's instructions.

8.9 Electrical installations and infrastructure replacements are carried out at the end of usable lifecycles in line with manufacturer recommendations, and assessment by qualified and competent engineers.

9. Responsive repairs

9.1 The council operates a responsive repairs service 24 hours a day, 365 days of the year. The service undertakes repairs based on urgency and includes provision for qualified electrical engineers to assess and fix electrical hazards on an emergency priority.

10. Replacements and capital investment programme

10.1 Replacement electrical installations (rewires) and equipment are undertaken on planned programmes of work through the council's capital investment programme, unless the installation or equipment has become immediately dangerous, and the work is required urgently. In these circumstances, the replacement may be undertaken through the responsive repairs programme.

10.2 In order to minimise disruption for residents, and where there are available resources to do so, the replacement of electrical infrastructure and equipment may take place at the same time as other improvement works. For example, an electrical rewire may take place during the replacement of a kitchen.

10.3 Electrical rewires are carried out to homes where the electrical installation is reaching, or has reached, the end of its life, and where replacement or upgrade is required in order to ensure continued safe use. Factors determining a rewire include the following:

we will consider a rewire if a property is more than 25 years old and hasn't been upgraded to bring it up to the current requirements
If major remodelling work is required that constitutes a material alteration, as defined by the Building Regulations. This could include upgrading the consumer unit
If a property is being extended or modified and the existing wiring will have to be improved to ensure it can carry the additional loads safely
If during an electrical test it is discovered that deterioration of the installation, or presence of hazards, means that the safety of the installation can no longer be maintained

10.4 Electrical rewires are also carried out as part of empty home refurbishment work where a property cannot otherwise be re-let with a satisfactory installation.

11. Tenant responsibilities

11.1 The Leeds City Council Tenancy Agreement sets out a tenant's responsibilities in relation to electrical safety and the repair and maintenance of fixed electrical installations in the tenancy conditions. Tenants must:

provide access for the council to carry out inspections of installations and Infrastructure, and for any repairs that are required, provided that reasonable notice is given
immediately report any repairs, defects or damage that is the council's responsibility
obtain written permission from the council before making any electrical alterations, and only use appropriately qualified and competent people to carry out work on electrical installations
not complete mutual exchanges without agreement from the council and the completion of an electrical inspection
not tamper with any electrical equipment, wiring or meters

11.2 Residents who are wanting to report a non-urgent safety concern can do so by sending an email to buildingsafety@leeds.gov.uk

11.3 All emergency and urgent safety concerns should be reported by telephone on 0800 188400 or 0113 376 0410.

12. Access

12.1 Access to individual homes to complete inspections, servicing, replacements and repairs will be via and agreed appointment and after a reasonable period of notice. This is generally a minimum of 5 working days-notice but may longer for more disruptive work such as rewires. Access procedures include reasonable flexibility to allow residents to be able to rearrange appointments at a time more suitable to themselves.

12.2 To help residents in making convenient appointments, a limited number of weekend and evening appointments are available and may be made available. These will be considered upon request.

12.3 For periodic testing to individual homes, we will undertake three separate pre-booked appointment visits, in order to achieve access and complete the inspection. A minimum of five working days' notice will be provided between appointments.

12.4 Where access is not achieved on either the first or second appointed visits, the contactor will leave a 'no access' notice which includes details on how to re-arrange the appointment.

12.5 Where access is not achieved to complete the inspection on the third appointment a no access card will be left and we may make other attempts to arrange access which may include phone calls, liaison with support workers and advocates, 'cold call' visits, and visits outside normal working hours.

12.6 If access remains outstanding after the third appointment, and the electrical inspection is overdue or at risk of becoming overdue, appropriate formal action will be considered in-line with the Tenancy Agreement and available legal provisions.

12.7 Communal area inspections and service programmes will be undertaken during daytime hours with access given to service providers through the operational management team.

12.8 Access for urgent and routine repairs will be arranged via a pre-arranged appointment.

12.9 In an emergency, it may not be possible to arrange access through a pre-arranged access due to the severity of the situation and the risk to health and safety or significant damage to property. Wherever possible, we will try to give at least 24 hours' notice of our intention to access a property. However, in-line with the Councils Tenancy Agreement and Leasehold Agreements, the council or any person authorised by the council may enter a tenant or leaseholders home without giving any notice whether they are at or not. This includes for instances where suspected tampering with meters and other electrical equipment is believed to have taken place.

12.10 Any suspected tampering, interference or unauthorised alteration of metering equipment will be reported to the supplier as fraud and tenancy action may also be taken.

13. Smoke detectors

13.1 Smoke detection is provided to individual homes to provide a means of alerting residents to the presence of fire and facilitating safe escape.

13.2 Interlinked smoke and heat detectors are installed in accordance with British Standard 5389 part 6 as part of electrical rewires and refurbishment work.

13.3 Where it is identified that there is no detection, temporary battery detection will be installed as a matter of urgency until mains detectors can be installed through upgrade.

13.4 The minimum standard for temporary smoke detection is one detector per storey level.

13.5 Residents are regularly reminded to test detection weekly and report any defects immediately.

13.6 As a landlord, we will test smoke detection prior to re-occupation of homes and also during annual gas safety checks and periodic electrical inspections. In high rise properties, Fire Safety Officers will test domestic smoke alarms whilst carrying out annual front door inspections inside the home.

14. Definitions

14.1 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.

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

14.3 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.

14.4 Potable Appliance Testing (PAT) - The checking of portable electrical appliances for safety.

14.5 Minor Works Certificate (MWC) - A certificate for electrical engineers to certify that they have tested and are happy with the safety of the existing circuit they are adjusting. The certificate also demonstrates that the alterations they have made are safe and ready to be used by the customer.

14.6 The IET Wiring Regulations (IET) - The national standard for electrical installations in domestic, commercial, and industrial settings.

14.7 My building safety hub - Portal platform accessible through the Leeds.gov.uk website which makes key building information available in-line with the Golden Thread reporting requirements for buildings in scope of the Building Safety Act 2022.

14.8 Golden Thread - Requirement for the availability of key building safety information as set out in the Building Safety Act 2022.

15. Key roles and responsibilities

15.1 Chief Officer - Housing Leeds

Is responsible for:

supporting the Director of Communities, Housing and Environment in setting the strategic direction and effective planning and management of safety activity within the councils owned housing portfolio
for ensuring the effective planning and management of safety compliance across the councils owned housing portfolio which includes:

ensuring that adequate resources are in place across the service to enable the effective delivery of these policy requirements
ensuring that a culture of strong governance arrangements is in place in relation to safety compliance, including reporting progress against key compliance activity and the escalation of significant risks to the directorate risk register

15.2 Heads of service and Senior Management Team (SMT)

Are responsible for:

ensuring that actions from fire risk assessments for their service areas are completed within timescale and completions recorded in a timely manner
ensuring that all staff complete safety training appropriate to their roles
ensuring that all activity within the service area is given due consideration to safety and contributes to a strong fire safety culture within the organisation
review reports, and providing effective governance around safety compliance

15.3 Head and Deputy Head of Asset Management (Housing)

Has responsibility for:

appointing a designated Electrical Safety Service Manager and Electrical Safety Team to lead on Electrical Safety activity and day-to-day delivery across the Housing Leeds portfolio
providing assurance through effective governance and risk management, that the controls in this Policy are working and that the approach complies with legislation
working collaboratively with other Heads of Service and Service Managers to ensure that adequate operational processes and procedures are in place to manage electrical safety risk pertinent to their areas of service
ensuring that sufficient information in relation to electrical safety performance is shared with staff, contractors and residents through an effective communications strategy
ensuring that a program of training for staff with designated electrical safety duties is adequate and kept up to date
ensuring that an adequate capital improvement programme is in place to deliver safety improvements to the councils housing stock
ensuring that works being undertaken are designed and constructed competently and safely
ensuring that cyclical maintenance and servicing arrangements are in place, as well as an effective repairs service for responding to repair reports
ensuring that electrical safety is appropriately considered as part of all procurement and commissioning activity
ensuring that emergency procedures are in place to respond to electrical hazards and damage caused to electrical installations
ensuring an effective resident engagement and communication strategy linked to building safety

15.4 Electrical service manager is responsible for:

developing and keeping this policy under review
ensuring the day-to-day operational delivery of all electrical testing and remediation programmes
ensuring that systems and resources are in place for managing and monitoring the performance of service and the quality of work undertaken
ensuring that all certification and completion data is correctly stored within the council's systems
providing expert specialist expert safety support and advice across the Housing service
ensuring that the service remains up to date with developments to electrical safety legislation and that the Housing Leeds Senior Management Team are appraised of change requitements
inputting into the design of new build developments, refurbishments and new mechanical and electrical installations

15.5 Service managers - Asset management (Housing) and Health and housing are responsible for ensuring that:

robust electrical inspection, testing and repairs programmes are in place across their respective work streams
monitoring is in place to ensure that electrical tasks are completed within a timely manner, to acceptable standards and are correctly recorded
any risks relating to electrical safety are recorded and escalated appropriately and in a timely manner

15.6 Service managers - Housing management, Retirement Life and Extra Care, and Leeds Housing Options are responsible for ensuring that their teams:

follow empty property and mutual exchange procedures in order that appropriate electrical checks are undertaken at the change of occupancy
support access to homes to complete electrical testing, inspection, and repairs, where access from residents is not permitted
know how to identify and report hazards and report repairs

15.7 All staff are responsible for:

reporting any electrical hazards that they come across during their duties and reporting repairs accordingly
Undertaking training that they have been allocated and following safety procedures

15.8 Service providers and external contractors Are responsible for:

completing all repairs, maintenance, improvements, and servicing and inspection in-line with the standards set out in this policy
reporting any electrical hazards that they come across, to the council, via the agree procedures

16. Data protection, record storage and retention

16.1 An electronic system is in place to record the details of all electrical installations and infrastructure. The system records the last test/inspection date, and the next due date, as well as a copy of any relevant test certificates/reports.

16.2 The system is regularly updated to reflect any changes because of Right to Buy sales, demolitions, new build properties, and acquisitions.

16.3 The recommended maximum period between testing duration is always taken from the most recently completed certificate / inspection report.

16.4 Where access to individual homes is required, sufficient data is passed to the service provider to allow them to arrange access and complete the periodic task. Data sharing agreements are in place with contractors to ensure that data is held securely and only used for this purpose. Data shared with contractors includes:

main tenant's name
address
contact details
any flags or alerts relating to resident's individual needs (i.e., contact via advocate)
any flags or alerts relating to health and safety issues (i.e., dog registered at the property)

16.5 The extent of personal data included on electrical certification and reports is limited to the full property address and the current tenant's name as well as the tenant's signature where provided.

16.6 Access to all council storage systems is restricted to trained staff who require access for the purpose of their role.

17. Certification

17.1 Upon completion of an inspection or test, the certificate or inspection report completed by the engineer is transferred to the council's electronic system. The next test due date is populated once the certificate has been received.

17.2 Some certificates or reports produced prior to 2022 are stored in our contractor's and Internal Service Providers own systems. This will be phased out when the next due inspection for these properties is completed.

17.3 Only electrical installations and infrastructure assessed as 'Satisfactory' are accepted as completed. Where remedial actions are required in order to provide a 'Satisfactory' certificate or report, this will only be accepted once defects are completed, and the appropriate additional certificate or report has been added to confirm that the installation is now satisfactory.

17.4 In the case of new installations and rewires, certificates and reports will be accepted as an inspection record if either the full installation has been replaced, or if only a partial replacement has taken place and all remaining elements of the installation have been inspected and tested.

17.5 Prior to acceptance by the council, all certificates, and reports are quality checked by the contractors Electrical Qualifying Supervisor. A sample of certificates and reports are also quality checked by the councils own electrical engineers.

17.6 For all completed electrical repairs, a 'Minor Works' certificate is produced by the electrical engineer. These certificates are stored on our contractor's own systems.

17.7 The most recent electrical certificate or report for a property is available to residents upon request to Housingleedsinformation@leeds.gov.uk.

17.8 For residents that live in high rise homes, electrical certificates and reports are available through the which is accessible at My high rise building safety hub.

17.9 Data is for timescales as set out in the council's retention schedules.

18. Competence and quality assurance

18.1 All electrical work undertaken by the council is carried out by contractors and engineers who are members of an appropriate recognised regulatory body or Competent Person Scheme (CPS).

18.2 Engineers undertaking inspection and testing programmes are required to hold current and relevant qualifications in line with the service works undertaken. All engineer qualifications and experience are required to be provided upon request for audit and approved before commencement of activities.

19. Equality, diversity and inclusion

19.1 An Equality Diversity Cohesion and Integration assessment (EDCI) has been carried out to ensure that the application of this policy meets the public sector equality duty requirements, under the Equality Act 2010. The EDCI has identified that there are no particular groups who will be unlawfully disadvantaged by this policy.

19.2 Upon request to Housingleedsinformation@leeds.gov.uk, this policy can be made available in other accessible formats including translation to other community languages, braille, and large print.

20. Resident engagement

20.1 Resident feedback gathered through satisfaction surveys and complaints has been considered in the development of this policy. Based on this feedback, specific attention has been given to clarifying the roles of both landlord and tenants within this policy as well as clarifying the access procedures for periodic electrical inspections and other visits.

20.2 Further monitoring of feedback will take place through resident surveys and this intelligence will be used to inform future reviews of this policy.

21. Communication of this policy

21.1 Key content from this policy will be included in the Housing Leeds Tenants Handbook and also made available through the Leeds.gov.uk website. Key content will also be shared regularly with residents through targeted tenant emails, and through ad-hoc social media publications.

21.2 A full copy of this policy will be made available upon request via Housingleedsinformation@leeds.gov.uk.

22. Policy review

22.1 A full policy review will take place in response to any changes in legislation, significant events that may impact on the policy, or at periods not exceeding 2 years.

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