20 Years on – Haven’t we heard all this before?
By Liam Gratty, Director of Strategic Services
Health and safety within the social housing sector has long been framed as a matter of compliance; a statutory obligation to be met, evidenced and defended. Yet the homes managed within the sector are not simply assets requiring regulatory compliance, but environments that directly shape health, dignity and quality of life.
Over time, competing pressures, financial constraints, increasing demand, ageing housing stock and organisational risk management have influenced how health and safety responsibilities are interpreted in practice. Sometimes this has resulted in a culture where minimum standards are prioritised over meaningful risk reduction and where compliance can unintentionally replace professional curiosity and preventative action.
In this context, the challenge facing the sector is not a lack of regulation, guidance or technical knowledge. Rather, it lies in collective attitudes toward risk, accountability and the lived experience of residents. A genuinely health led approach to housing safety requires moving beyond reactive responses and toward a culture that recognises resident wellbeing as central to good housing management.
Understanding and addressing these attitudes is essential if social housing is to fulfil its wider role, not only as a provider of accommodation, but as a foundation for public health and social stability.
With the recent publication of the New Decent Homes Standard Policy Statement we have an opportunity to regroup and really focus on meaningful health outcomes in housing and consider how this sets a foundation for residents to live in healthy homes.
Governing Housing Standards to achieve health outcomes and not statistics
Having operated the Housing Health and Safety Rating System (HHSRS) since its inception, it’s evident that the framework itself is sound and whilst a review of the system is important, what isn’t necessarily working is the way it is viewed from a social landlord perspective. It is too often reduced to a minimum compliance exercise. Free from Cat 1 hazards = a decent home…. really?
Those who were involved in the launch of HHSRS in 2006, certainly within the Environmental Health profession, will be aware HHSRS was never intended to be a box ticking tool. The whole purpose of moving away from a fitness standard was to provide focus on health and safety, how defects and deficiencies directly impact on residents and importantly, the severity of the risk and harm outcomes. The system was designed to assess risk to people, not defects in buildings. Yet in practice, it is frequently treated as a technical hurdle. Attitudes towards reporting and demonstrating that homes are free from hazards over environments that are free from harm is holding the sector back.
We Talk About Health – Then Ignore It
We openly acknowledge that housing is a major determinant of health, yet housing decisions are still routinely separated from health outcomes. Financial constraints, organisational pressures and at times challenging resident behaviour all play a role, but they do not change the underlying reality.
Cold, damp and poorly ventilated homes are not abstract risks. I continue to see the same hazards recur: respiratory illness, excess winter morbidity, anxiety and long term deterioration in wellbeing. These outcomes often emerge from homes that technically “pass” assessment because no single hazard crosses the Category 1 threshold.
If HHSRS tells us anything, it is that thresholds are not the same as safety. Treating them as such represents a professional shortcoming, not a regulatory one.
The Culture of Minimum Intervention
I am increasingly concerned by how often HHSRS assessments are used to justify doing the bare minimum. If a hazard can be reduced just enough to avoid action, then intervention frequently stops there. This approach may satisfy short term legal requirements, but it creates predictable long term consequences:
- Repeated complaints
- Escalating enforcement action
- Increased financial cost
- Fractured landlord tenant relationships
- Lists of planned repairs – “planned on demand” (a controversial term in itself)
More concerning still, it normalises poor housing conditions by framing them as “acceptable risk”. From a health perspective, that position is difficult to defend.
When HHSRS Works Well
Rightly so the application of HHSRS in the private sector, in my experience, is effective – where I have seen HHSRS applied effectively in social housing the approach looks very different. It is used to:
- Identify patterns across housing stock
- Inform planned investment while enabling proportionate reactive intervention
- Flag vulnerability early, before harm occurs
- Support decisions that are evidence based, defensible and humane
When landlords and housing providers engage with HHSRS honestly, it stops being perceived as a threat and instead becomes a strategic tool. In my experience, organisations that fear it most are often those operating within outdated, short term decision making models.
Skills Gaps?
HHSRS relies on professional judgement; and judgement depends on experience, confidence and training.
If you’ve been fortunate enough to work across both the Environmental Health and Construction sectors you will know this is a space where building pathology and housing health and safety complement one another superbly, in fact they are interdependent. That combined perspective is not always present across the sector.
I have seen markedly inconsistent assessments of the same property, driven not by evidence but by risk aversion, workload pressure, or lack of confidence in applying the system. Such inconsistency undermines credibility and weakens trust in HHSRS itself.
Skills gaps are by no means a reflection on the people serving our residents, its another indicator that Health and Housing Maintenance still hasn’t been fully integrated within organisations.
It must be clearly noted that this is not a blanket statement that applies across the sector, there are many examples where this is done well. We also have a strong presence of highly skilled, competent consultancy practices which hold the social principles and understanding in support making this shift.
If the system is to carry weight, investment in practitioners is essential. Ongoing training, peer review and organisational support for professional decision making must form part of its future. Particularly when those decisions are uncomfortable.
Looking Forward
With fuel poverty rising, housing stock ageing and increased scrutiny of retrofit practices, the risks HHSRS was designed to capture are becoming more common, not less.
The future of HHSRS lies in early intervention, cross sector collaboration and predictive use of data, not enforcement or retaliatory remediation after harm has already occurred. Housing, public health and social care should be working from a shared understanding of risk.
Early practitioners recognised this potential, using health outcome models to demonstrate how housing intervention could reduce demand on public services and contribute to savings within the NHS. HHSRS still provides the framework to achieve this if we choose to use it fully.
With the revision and updating of HHSRS underway, there is a real opportunity for a genuine culture shift: renewed ownership, clearer accountability and a return to the systems original purpose of continuing the work of pioneers such as David Ormandy. Most importantly, it offers a chance to move the focus away from the asset and back to the resident. While we may all talk about this in principle, the challenge now is ensuring it is reflected in practice.
The question is how we support our housing organisations at all levels to drive the message and instil a culture that prioritises the health and well being of residents
If we continue to treat HHSRS purely as a measure of compliance, we will continue delivering homes (“compliant” ones) that fail the people living in them. If instead we treat it as the health led risk framework it was intended to be, it can drive better housing, better decisions and better outcomes.
The choice is not about regulation – It is about whether we are willing to take professional responsibility for risks we already know exist.
So, what should housing leaders ask themselves?
1. Are we managing risk to residents or managing organisational and reputational risk?
2. Would you live in these conditions yourself?
3. Are our asset strategies designed around buildings or people?
4. Are we using HHSRS as a strategic tool or as a measure of compliance?
5. Are we learning from harm or waiting for the next crisis?
Closing Reflection
These questions are not intended to assign criticism or blame.
They are intended to challenge the sector to consider whether its current systems truly reflect the principle that safe, healthy housing is fundamental to public wellbeing. Because if housing is genuinely recognised as a determinant of health, then the standard we hold ourselves to cannot be minimum compliance, it must be maximum prevention.
It’s been widely accepted that the extent of poor housing conditions that are seen in the private rented sector fall way short of the standards provided in social housing. However, is the measurement of quality against a poor standard something to shout about? With the New Decent Homes Standard emerging and reforms to housing regulation continuing under the Social Housing (Regulation) Act 2023, the sector has an opportunity to reset its approach.
The opportunity is to move from:
‘Housing as asset management‘ to ‘Housing as a public health intervention’.
When this shift happens, housing providers are no longer just maintaining buildings, they are preventing illness, protecting dignity, and improving life chances.
