Riverside

The Riverside Group Electrical Safety Management Policy
September 2023

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The Riverside Group Limited (TRGL) aims to proactively manage the potential risk associated with the electrical fixed wiring and electrical portable appliances (owned by TRGL) in buildings owned or managed by TRGL and its subsidiaries. This policy and the associated management plan set out the steps TRGL will take to maintain an effective safety testing, installation and maintenance and servicing regime to all installations as far as is reasonably practicable.

The purpose of this policy is to ensure TRGL:

• Customers, contractors, staff, and visitors remain safe in our premises (both domestic and non-domestic).
• Identifies its specific responsibilities for each of its assets.
• Communicates internally and with customers and other stakeholders.

Meets its obligations under legislation and regulations (including but not limited to):

• The Health and Safety at Work etc. Act 1974.
• The Electricity at work act 1989
• Gas Safety (Installation and Use) Regulations 1998.
• The Management of Health and Safety at Work Regulations 1999.
• Control of Substances Hazardous to Health (COSHH) Regulations 2002.
• Building Regulations 2010 Part P
• Building Regulations 2010 Doc J
• The Housing Act 2004 which introduced the Housing Health and Safety Rating System (HHSRS) and the Housing Health and Safety Rating System Regulations 2005.
• The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR).
• Workplace (Health Safety & Welfare) Regulations 1992
• Landlord and Tenant Act 1985
• The requirements of both the Regulator for Social Housing’s (RSH) Homes Standard and the requirements of the Care Quality Commission (CQC).

TRGL will also refer to the following specific Electrical technical guidance and advice on how to comply with the above legislation and regulations.

• Requirements for Electrical Installations: IET Wiring Regulations BS 7671 Current Edition.
• IET Code of Practice for In-Service Inspection and Testing of Electrical Equipment Current Edition.
• IET Guidance Note 3: Inspection & Testing Current Edition.
• Protection Against Lightning. Physical Damage to Structures and Life Hazard BS EN 62303 Current Edition.
• HSG85 Electricity at Work: Safe Working Practices.
• GS38 Electrical Test Equipment for Use on Low Voltage Electrical Systems.
• HSG107 Maintaining Portable Electrical Equipment.
• The Electrical Safety, Quality and Continuity Regulations (2002).

The application of this Policy ensures that TRGL meets compliance with the outcomes of the Regulatory Framework for Social Housing in England introduced by the Homes and Communities Agency as outlined below:

(Registered Providers must) meet all applicable statutory requirements that provide for the health and safety of the occupants in their homes.

And the Scottish Housing Quality Standard (SHQS).

• Element 45 of the SHQS requires that electrical systems must be safe and not present a danger to occupiers.

This policy applies to all fixed electrical installations and fixed or portable equipment installed domestic and non-domestic buildings owned or managed by TRG, where the responsibility for maintenance and management of the building fabric is under the control of TRG. This specifically includes domestic dwellings, communal area to residential buildings, offices, shops, commercial units and community centres.

Building specific lease or management agreements may define legal responsibility. Where clear responsibility cannot be defined, the default position for any non-domestic buildings owned or managed is that TRG will actively manage that risk until a time when clearly defined legal responsibility can be evidenced.

The following equipment is within scope of this policy:

• Fixed wired electrical installation
• Portable appliances
• Integrated Warden Call
• Domestic social alarms
• Door Entry Systems (domestic)
• Door Entry Systems (commercial)
• Communal Digital Aerials
• Specialist electrical equipment i.e. lightning conductors

This following equipment is out of scope of this policy:

• Any fire safety electrical equipment such as fire alarm, AOV, emergency lighting. Fire safety electrical equipment is in scope of TRG fire safety policy.

UK regulations place an explicit duty on owners of buildings with electrical installations or equipment is installed. TRG are required to take reasonably practicable measures to ensure that all buildings, including installations or equipment associated of access or egress from that building, are safe and without risk to health.

The guiding principles of what TRG intends to accomplish through implementation of this policy are as follows:

• Prepare a management plan that’s sets out exactly how TRG will manage risk and deliver compliance.
• Identify all fixed electrical installations and metered installations.
• Identify all electrical equipment and assess the nature and level of risks.
• Take proportionate to manage risks and reduce them as far as reasonably practicable.
• Provide information, instructions and training to the people who use the equipment.
• Deliver an effective inspection and testing programme of all installations and equipment.
• Appoint persons with clear roles and responsibilities to manage the risk associated with electrical installations and equipment.
• Assess risk within our portfolio against qualifying building criteria to identify presence of electrical equipment within our assets.
• Establish and keep up-to-date records of the location, condition and type of all known electrical equipment.
• Prioritise & complete corrective actions identified within defined timeframes and promptly repair or renew any defective part of an installation.
• Ensure electrical work is only carried out by persons that are competent and ensure any unauthorised and defective alterations or additions to electrical installations are rectified or removed on discovery.
• Keep records of the control measures and activities.
• Implement appropriate training for all staff responsible for administering the controls.

Electrical Inspection Condition Reports [EICRs]

TRG has carried out an assessment of risk as recommended by Guidance Note 3 to IET Wiring Regulations BS7671 and duly decided on the following intervals of testing:

Dwellings are to be tested and a satisfactory EICR produced:

• Every five years maximum for communal area installations.
• Every six years maximum for domestic installations.
• Policy aim to review approach and implement five year maximum reinspection period for domestic installations from March 2025, or earlier if required to comply with changes in legislation brought about by amendment to Housing and Planning Act 2016 that may introduce mandatory checks on electrical installations for social housing at least every 5 year.
• During major upgrade works where electrical installations are affected.
• After any significant work is carried out to the electrical installation.
• At every change of occupancy (exceptions may apply within Management Plan for short-term lets in certain properties)
• At the time of any mutual exchange (exceptions may apply within Management Plan for short-term lets in certain properties).

All EICRs shall be held in electronic format, centrally stored and logged to the compliance register, linked to the relevant property record by Asset ID. Only certificates denoted “satisfactory” are acceptable.

The Electrical Safety Management Plan provides further information regarding TRG’s approach to managing electrical safety and provides further detailed requirements on key roles and responsibilities.

Executive Director of Asset Services

• Responsible for overall policy implementation.
• Ensure that adequate resources are made available to enable the objectives of the policy to be met.

Director of Building Safety

• The Accountable risk lead with responsibility to appoint a responsible person and to ensure a Heating & ventilation Policy and Management Plan is in place and a strategic risk register is in place which documents the key risks, controls and assurance required.

TRG Head of Shared Spaces/Compliance Director of Property Services (OHG)

• Legal responsibility for Compliance with landlord requirements under Gas safety regulations.
• Define risk Controls through operational management plan.
• Determine appropriate Assurances and document within our Risk Map.
• Management of legal compliance and for delivery of the key policy objectives, ensure the implementation of the policy, implementing the Heating & ventilation management plan, procedures, staff training, and communication to customers and colleagues.

Legal Entity Responsible person (Director compliance, AD Compliance) or equivalent

• Act as the Groups lead advisors.
• The named Responsible Person “competent person” for the purposes of the Electrical Safety Regs.
• Establish & maintain NICEIC registration
• Maintain a process for dealing with unsafe situations or incidents.

Head of Business Management

• Implement TRG assurance framework utilising 3 lines of defence in accordance with risk management framework.
• Governance reporting of statutory compliance.
• 3rd Party quality assurance and testing.

Head of Health Safety & Environment

• Liaising with and monitoring enforcement actions from Health & Safety Executive (HSE) or any other enforcing authority responsible for regulating health and safety law.

Compliance Manager (Fire Strategy & Delivery)

• Manage the risk with compliance with gas safety regs,
• Monitor the controls and compliance with management plan.
• Develop risk reduction strategy and setting our management response to our legal requirements.
• Management of Legal action/ tenancy enforcement.
• Keep up-to-date a record of all installations and equipment and landlord gas safety records (LGSR)
• Management of commercial heating servicing and safety checks.

Operations Head of Heating & Electrical or equivalent

• First line Quality Assurance testing of landlord gas safety records.
• Monitoring/allocation of resources.

Head of Business Management

• Implement the groups assurance framework through 3 lines of defence.
• Governance reporting. through Independent Reporting through Business Intelligence
• 3rd Party quality assurance testing.

3rd Party Consultant

• Provide independent / 3rd party competent person advise.
• Undertake periodic reviews of management plans.
• Complete 3rd party quality assurance reviews of LGSRs.

Whilst the strategic approach to Building Safety is not risk averse in terms of adopting innovation and striving to be a leader in the sector, the safety of Riverside customers and colleagues is a key priority for the organisation. Therefore, there is no appetite for risk in terms building safety and compliance with the law.

There is however a tolerance for risk in adopting a proportionate approach to building safety activities, risk assessment and the controls implemented.

Key risks are monitored through a set of monthly Key Performance Indicators (KPI’s). The suite of KPI’s is embedded with the executive management and governance reporting structure.

A building safety risk register is maintained and regularly reviewed to ensure a proactive approach to risk identification, reduction, and control.

We aim to meet all our obligations to keep our buildings, customers and colleagues safe. To maintain an effective safety testing, installation, maintenance, and servicing regime as detailed in this policy. We will respond to complaints regarding safety concerns in line with our Complaints Policy and Customer Feedback Procedure.

Riverside is committed to Equality, Diversity & Inclusion. We strive to be fair in our dealings with all people, communities and organisations, taking into account the diverse nature of their culture and background and actively promoting inclusion. This policy aligns with Riverside’s Equality, Diversity and Inclusion Policy and has been subject to an Equality Impact Assessment.