Riverside

The Riverside Group Water Safety Policy
September 2023

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Riverside aims to proactively manage the potential risk to health arising from water systems in buildings owned or managed by The Riverside Group (TRG) and its subsidiaries. This policy and the associated management plan sets out the steps TRG will take to identify, assess and control water hygiene risks and scalding risks from hot water installations.

This purpose of this policy is to ensure TRG meets its obligations under the following legislation and regulations (as amended):

• The Health and Safety at Work etc. Act 1974;
• The Management of Health and Safety at Work Regulations 1999;
• Control of Substances Hazardous to Health (COSHH) Regulations 2002;
• 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);
• The Water Supply (Water Fittings) Regulations 1999;

In developing a robust management plan TRG will also refer to the following specific guidance and advice on how to comply with the above legislation and regulations:

• HSE Approved Code of Practice (ACOP) L8 – ‘Legionnaires Disease: The Control of Legionella Bacteria in Water Systems’

This policy applies to all non-domestic buildings owned or managed by TRG where the responsibility for water systems is under the control of TRG. This specifically includes 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 policy applies to domestic dwellings to the extent of control measures during vacant tenancy periods, when the property is under TRG control, as well as portfolio level risk identification and controls in line with the management plan.

UK regulations set out an explicit duty to preventing or controlling the risk from exposure to water borne bacteria. The risks vary with circumstances, ranging from the occupation of a building to activities associated with the repair, refurbishment, and demolition of premises.

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.
• Appoint a competent person or persons to manage risk.
• Take reasonable steps to identify and assess sources of risk.
• Prepare a written scheme to prevent or control the risk of exposure to water borne (legionella) bacteria.
• Implement appropriate management and monitoring arrangements for water systems.
• Keep a written record of assessments and monitoring activities.

This policy is to be read in conjunction with:

• TRG Water Safety Management Plan

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.
• Responsible for designing and implementing suitable and sufficient operational procedures, including approval of the Water Safety Management Plan.

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

• Responsible for the development and implementation of the Water Safety Management Plan.
• Ensure all appointed individuals have the appropriate levels of skills, knowledge, education and training.
• Legal responsibility for compliance with landlord requirements in relation to water safety management.

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.

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 are 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.