INVEST in our housing
At the heart of our ambitions lies our responsibility to provide safe, high quality, and well-managed housing for our residents. As the largest social housing landlord per capita in the East of England, with over 9,000 homes, we hold a position of both privilege and responsibility with nearly one third of residents living in one of our homes.
However, our residents are clear that we have underinvested and the judgement from the Regulator of Social Housing has confirmed that we must do better. We accept that challenge without hesitation. We are reshaping our housing services from the ground up, with a renewed focus on quality, accountability, and outcomes.
In respect of the council’s corporate mission to ‘Invest in our housing’, the Building Harlow’s Future Plan states that this year, the council will:
- Enact, in full, our Consumer Standards Improvement Plan. This will address past compliance failings and restore confidence in our housing services.
- Ensure full compliance with all regulatory and legislative requirements as a social housing landlord. This will embed a culture of accountability and high standards that will safeguard residents, strengthen trust, and position Harlow Council as an exemplary housing provider.
In line with that stated outcome, these policies demonstrate progress the council is making in respect of the actions agreed with the Regulator of Social Housing following the Regulatory Judgement of 2024, and our Consumer Standards Improvement Plan.
Councillor Dan Swords Leader of the Council.
Contents
Definitions and legal framework
Preventative and proactive approach
Prevention through planned investment programmes
Identifying issues and dealing with reports of damp and mould
Escalating issues and customer feedback policy
Introduction
As a landlord, Harlow Council is responsible for the maintenance and repairs of our homes. Making sure our tenants can live safely and comfortably in their homes and delivering high quality housing services is a key priority.
This policy and our operational processes complement the measures already taken to enable self-reporting of potential incidents of damp, condensation and mould, and closer alignment of those who diagnose, provide recommendations, and ultimately commission and deliver remedial works.
It outlines to all our tenants and stakeholders how we intend to meet our legal and regulatory damp and mould obligations. It ensures we have a proactive, prompt, and supportive approach to damp and mould interventions, which minimises risk to our tenants and the integrity of their homes.
In accordance with Awaab’s Law, social landlords are required to investigate and fix dangerous damp and mould in set time periods. The government introduced this vital legislation in honour of two-year-old Awaab Ishak who tragically died following prolonged exposure to damp and mould. This policy details how the council will comply with its duties under Awaab’s Law.
The Housing Ombudsman and Regulator of Social Housing have identified the impact that damp and mould can have on the respiratory, physical, and mental health of tenants, and it is important that we deal with issues quickly and effectively to minimise any impact on health and wellbeing.
Purpose
The purpose of this policy is to:
- Make it clear how we enable and support our strategic aims.
- Set out timescales and key performance standards to manage damp and mould.
- Make clear our approach for dealing with damp and mould across our housing stock.
- Take a pro-active approach to damp and mould interventions, ensuring that it is easy for our tenants to report issues to us.
- Work with tenants to ensure that they live in a safe environment and are treated in a fair and consistent way, with respect and dignity.
Scope
This policy relates to the council's approach towards the prevention and management of damp and mould in the housing properties that it owns and manages.
Definitions and legal framework
Damp' in this context can be defined simply as the presence of moisture within a home that can cause a detrimental effect to the building or its occupants. Dampness is a symptom, and identifying its cause and source should be a holistic approach. The main types of damp are often identified as:
- Rising damp – movement of moisture from the ground rising through the structure of the building though capillary action.
- Penetrating damp – water penetrating the exterior of a structure or internal leaks causing damage to the internal surfaces or structure.
- Condensing damp – moisture held in warm air encountering cold surfaces, subsequently condensing, and causing water droplets.
Mould is defined as a natural organic compound that develops in damp conditions and will normally only grow on damp surfaces.
The following is a list of legislation that is applicable to this policy.
- S42 of the Social Housing (Regulation) Act 2023Defective Premises Act 1972 (s4)
- Occupiers Liability Act 1957
- Landlord and Tenant Act 1985, Section 11
- Environmental Protection Act 1990 (s79 Statutory Notice)
- Commonhold and Leasehold Reform Act 2002
- Housing Act 2004 which introduced the Housing Health and Safety Rating System (HHSRS)
- Hazards as identified in Social Housing (Prescribed Requirements) (England) Regulations 2025
- Equality Act 2010
- Building (Amendment) Regulations 2013
- Approved Document C - Site preparation and resistance to contaminants and moisture (2004 Edition incorporating 2010 and 2013 amendments)
- Homes (Fitness for Human Habitation) Act 2018.
- The Regulator of Social Housing's Consumer Standards
Preventative and proactive approach
To ensure we have a proactive approach for dealing with damp and mould, we will:
- Offer a wide range of information, advice remedies, and support to our tenants.
- Work with tenants to help them understand small changes they can make to reduce the risk of damp and mould in their homes.
- Have regular campaigns on social media, and on our website and push positive advice messages, updating our communication channels regularly.
- Investigate to determine the cause of damp using a holistic process.
- offer advice, guidance, and take all reasonable steps to eradicate damp including managing and controlling condensation via reasonable ventilation and insulation improvements to our homes.
- Provide support on energy charges, advice on fuel efficiency, and sign-post to any grants or funding that may assist with the same for those who are suffering fuel poverty.
- Provide all new tenants with information as to how they can access a detailed handbook regarding repairs to their homes.
- Require all contractors who visit homes to carry out work on our behalf, to report damp and mould issues as a duty of care.
- Educate and support officers who enter tenants' homes to identify and report any damp and mould issues.
- Identify potential hazards through the re-validation of stock condition surveys (20% of our housing property assets per annum)
- Identify trends and insights as learning events through data collected by advanced technology and monitoring devices, and amend our processes and approaches to the symptoms appropriately.
- Utilise all tools and legal remedies to access our properties or neighbouring properties that impact on ours, to ensure all necessary work is completed in a timely manner.
Prevention through planned investment programmes
It is important to utilise effective planned maintenance programmes to prevent damp and mould. To achieve this we will:
- Ensure that data gathered from our stock condition surveys and from the day-to- day repairs and empty homes re-instatement, are fed into future investment plans.
- Identify wider issues relating to damp across property types as part of any inspection carried out by officers. This information will then be fed back to the Housing Operations (Property) team for consideration for future investment plans.
- Prioritise works within the asset management strategy where decent homes data indicates the building fabric and construction details contribute to, or provide the conditions for, damp and condensation.
- Identify damp and mould as part of our annual re-validation of our stock condition survey data. This will profile risk properties and areas and identify future priority programs of work as well as higher risk homes.
Identifying issues and dealing with reports of damp and mould
When damp or mould is reported to us, or is identified by an employee or representative of the council, it is important that we act to deal with the issues as quickly as possible while supporting the tenant throughout the process. We will therefore:
- Respond sensitively and keep tenants informed throughout the repairs process.
- Provide information in a format that suits the needs of the tenant.
- Consider the circumstances under which homes should be temporarily decanted to protect tenants' health and safety.
- Record and take photographs of any damp or mould before removal, to help us to identify causes.
- Review any work requests or work carried out to ensure that if the issues are repeated, we can quickly understand where alternative remedies need to be investigated through re-inspection and if necessary, referral to a specialist surveyor.
- Agree any proposed remedial works with tenants before they begin.
- Following an inspection from a competent building surveyor, confirm in writing the repairs required along with expected timescales for the works to complete.
- Check to ensure that completed repairs have rectified issues of damp and mould.
- Provide justification if delays to repairs are unavoidable.
- Not allow planned maintenance to delay urgent repairs.
- Provide clear safety instructions for tenants until hazards are resolved, even if the hazard cannot be fully addressed, should tenants refuse temporary relocation.
- Install remote monitoring components within the property, that provides environmental insights of temperature, humidity, CO2 and air quality, and enable assessment of the success of any remedial works
- re-visit properties with symptoms of damp and mould at 3, 6, 12 and 18 months post remedial works; if the case is determined as HHSRS ‘Severe’, the property is recorded as Non-Decent until the hazard has been resolved or is determined by a competent person that the hazard can be re-categorised.
Assessment of damp and mould
All damp repairs will be assigned a hazard category and dealt with accordingly.
Each hazard's risk level will be assessed on a case-by-case basis, we will not apply a universal threshold.
Damp and mould warranting emergency repairs would, for example, be a significant level of mould growth on all walls of the property including in a risk room where a tenant is struggling to breath.
Damp and mould that would not trigger Awaab’s Law and require routine repairs is for example, small patches of mould above a radiator under the window in both bedrooms as well as on the ceiling which is unsightly and unpleasant with no reported health impact.
Timescales
We must act quickly to adhere to the timescales detailed in Awaabs Law and endeavour to carry out required remedial works as soon as reasonably practicable and in line with legislation.
Where requested by a tenant, we must complete a physical inspection as soon as reasonably practicable and within 10 working days of becoming aware of the damp or mould.
Following a building surveyor's inspection, tenants must be provided with a written summary of findings within 3 working days of the investigations concluding. If no hazard is found, tenants must be provided with a report detailing this.
Emergency repairs must be addressed as soon as reasonably practicable and within 24 hours. In these circumstances no written summary will be provided before works commence as our priority will be the completion of repairs.
Where we find a significant risk to health and safety we must begin repairs as soon as reasonably practicable and within 3 working days of the written summary being issued. We must act within 24 hours if a medical professional identifies health risks. We do not require formal medical evidence to support this.
Where there are complex issues e.g., structural damp, we must complete our initial investigations as soon as reasonably practicable and within 10 working days or within a reasonably practicable period with written assessment and conclusions as to why. Written findings and timescales must be provided to tenants.
We may begin temporary repairs (e.g., the removal of mould spores) to make the property safe before full remediation of repairs.
At all stages of the process we will endeavour to keep tenants updated on the timescales of their repair. These timeframes will vary based on the complexity of the repair.
A justification must be provided for any delays in repairs.
Access
Tenants will be offered appointment times to suit their availability.
To ensure the safety of tenants and ensure that their health and wellbeing is not impacted, we will act as swiftly as possible to resolve any issues of damp and mould. To achieve this, we will:
- Make at least three attempts to contact tenants to arrange access.
- Work with tenants to find suitable times for access, offering multiple timeslots.
- Leave a notice and offer an alternative time if access is not granted within the agreed timeslot.
- Try additional attempts if access is refused or not provided.
- Use legal remedies available to obtain access where access is not granted.
The tenancy agreement states that the tenant must allow access to the council or its agents, or contractors, access to carry out repairs, alterations, improvements, maintenance, surveys and inspections, usually within 24 hours.
If there are consistent missed or cancelled appointments, the council may consider legal action to gain access to resolve the issues identified, the costs of which will be recharged to the tenant.
Tenant vulnerabilities
By assessing individual resident health needs we will consider how the damp and mould impacts different vulnerabilities.
Each occurrence of damp and mould will be reviewed on a case-by-case basis in an empathetic and supportive way taking full account of any vulnerabilities tenants may have. It will then be assigned a hazard risk level considering individual tenant circumstances; we will not apply a universal threshold.
Information will be provided in a format tenants can understand.
Repair timescales will reflect tenants' vulnerabilities.
Training
We will deliver mandatory training to all appropriate staff.
All council staff who carry out home visits will have basic training on damp and mould and the council's requirements under Awaab’s Law.
We will ensure that all appropriate staff understand that some tenants may be at greater risk of health harm due to damp and mould, depending on any specific medical conditions or vulnerabilities.
Our competent building surveyors will have in depth regular training in relation to Awaab’s Law and damp and mould, its diagnosis and case management.
Monitoring and performance
We will carry out monitoring of cases of damp and mould to ensure cases are dealt with effectively.
Where we have treated with mould wash, if appropriate we will aim to carry out return re-visits on a regular basis to ensure the issues do not reoccur until repairs are complete
Where damp works are required, we aim to contact tenants around 3, 6, 12 and 18 months after the work has been completed.
Damp data is fed into the Housing Operations (Property) team to ensure that programmes of work eliminate possible causes of damp and mould.
We collect and monitor the following information:
- Total number of damp cases reported.
- Number of outstanding damp inspections
- Percentage of damp repairs started within seven days of inspection for Cat 1 HHSRS hazard.
- Percentage of damp inspections carried out within 14 days of notification
We collect and provide monitoring and performance data as required to meet statutory and regulatory requirements. The data is used to monitor our service delivery and to provide openness and transparency to our tenants, residents, senior officers, Executive Leadership Team and Members.
Ourselves or our contractor will request customer feedback at the point of closing a case and will use these responses to shape services and improve.
Escalating issues and customer feedback policy
Customers may telephone our customer service centre and ask to speak to a member of the Housing Operations (Property) team if they have any concerns as this will allow us to resolve any issues in a timely fashion.
We are committed to consistently providing an excellent service to all our tenants.
We value all feedback about our service and the service of our contractors in
rectifying issues of damp and mould. We recognise that occasionally things can go wrong. In these circumstances, we want to make it as quick and simple as possible for our tenants to raise their concerns, so that we can resolve the issues in a timely way.
The council has a robust complaints policy which, after concluding, does not prevent a tenant exercising their right to submit representations to the Housing Ombudsman.
Review
Our approach to managing damp and mould will be supported by operational amendments to our process, based on findings and feedback from our tenants and stakeholders, along with learning across the sector.
We will ask tenants for their feedback on any work, support, and advice we provide on damp and mould as part of delivering our engagement activity with tenants, leaseholders and private landlords across the town.
This policy will be reviewed every 4 years or when a change in legislation is received.