HHSRS ATTACKS CO POISONING

Although in its infancy, the newly introduced Housing Health and Safety Rating System (HHSRS) could at last
address carbon monoxide (CO) poisoning in homes – as long as HHSRS is properly understood and applied.
Risks from CO are not just confined to older, rented properties and HHSRS identifies potential risks in brand new homes.

CO poisoning causes an estimated 50 deaths and 200 serious injuries annually in Britain.
But this is just what we know about because CO poisoning is certainly under-diagnosed by doctors and often not recognised by coroners,
as it simulates other conditions.  Carbon monoxide poisoning is identified as 1 of the 29 hazards listed in HHSRS, which is now in operation in
England and Wales – and may apply in Northern Ireland later as well. HHSRS replaces the fitness standard as an element of ‘Decent Homes’.

But if local authorities have reason to think that a hazard exists in any home (for example, complaints from tenants), they should use
HHSRS to make an assessment and, if necessary, take enforcement measures. So, HHSRS applies to both public and
private sector housing – theoretically, new as well as old. Inspections are carried out by Environmental Health Officers
or other surveyors and a score is developed for each hazard, which falls within either ‘Category 1’ or ‘Category 2’.

Local authorities must take action with Category 1 hazards while Category 2 hazards are discretionary.
A ‘decent home’ must not contain a Category 1 hazard

Typical New Build with Garage located below sleeping areas, and subsequent CO risk

For CO, ‘properly sited and maintained carbon monoxide detectors of a suitable type are considered an ‘ideal’ in HHSRS
 and a lack of CO alarms cited as one of the ‘relevant matters’ affecting the likelihood and harm outcome. 

But it is unclear how inspectors will allocate hazard scores and there are real concerns that faults are either not identified or
excluded as being the tenant’s responsibility. The dangers of carbon monoxide are far from obvious,
even to experts: a recent inquest heard how an Oxford woman died the day after British Gas inspected her boiler
following ten previous visits.
And it comes from a surprisingly wide variety of sources - not just gas appliances - so, there are very real dangers in homes,
both old and new. Shared flues can cause unexpected problems and there have been instances of CO from flues discharging
onto common areas effecting neighbouring properties. In multi-occupancy and multi-storey buildings, carbon monoxide produced
in one area may be transported to and leak into another part of the building, e.g. across roof spaces, between floors,
along ducting and in shared flues. In other cases, flue outlets have been interfered with by, for example, ‘pirate radio’
station operators while fixing illegal antennae on apartment blocks and even overheating electric night store heaters have caused
poisoning. CO from cars running within enclosed spaces is also a serious risk.

This is specifically identified in HHSRS, which calls for a ventilated lobby between integral garages and living accommodation.
This requirement is not satisfied by the unventilated hallways in many of the newest homes and could well constitute an
actionable Category I hazard unless CO alarms are fitted!

There is therefore a strong case for high hazard scores in the absence of appropriate alarms, as unseen risks may well be present.
Similarly, installation of CO alarms could substantially reduce a possible hazard (perhaps from Category I to II) at a much
lower cost than other remedial measures, so meeting ‘Best Value’ criteria.

To help landlords, specifiers and housebuilders understand HHSRS and other impacts on their responsibilities for CO
and fire safety, Kidde Fyrnetics has published a new 8-page technical guide, available free of charge via
kiddefyr@ukgateway.net or on www.smoke-alarms.co.uk using the ‘Contact us’ link.