The Government’s Regulator of Social Housing has recently highlighted health and safety as a key strategic risk facing housing associations. Stephen Flounders investigates.

In its annual sector risk profile, the regulator states that boards are ultimately responsible for ensuring the health and safety of their tenants and staff, and that they must have appropriate controls in place to ensure compliance with all their health and safety responsibilities.

Housing associations: five steps to manage health and safety risks

  1. Secure board-level commitment

    The regulator is clear in its report that boards are ultimately responsible for their tenants and staff. It’s therefore important that board members demonstrate effective commitment to health and safety and lead from the top.

    It is essential that board members allocate enough resources to health and safety to enable housing associations to effectively manage the risks to their tenants and staff. But they can show commitment to health and safety in many other ways, including:

    • ensuring health and safety is not only a standing agenda item at board meetings, but is also a meaningful agenda item with discussion, challenge and engagement with the health and safety function

    • attending training and workshops to enable them to understand their health and safety responsibilities and what they are accountable for

    • participating in monitoring activities, such as audits, site inspections and incident investigations

    • seeking regular assurance on health and safety issues, and providing challenge when necessary, in the same way as other governance issues.

  2. Have a clear strategy

    All too often, health and safety is something that’s carried out in isolation rather than being embedded into the way an organisation operates. Housing associations can overcome this by having a clear strategy setting out their approach and commitment to health and safety.

    A clearly defined health and safety strategy can support innovation, productivity and growth in housing associations while ensuring they manage their significant health and safety risks. An effective health and safety strategy should, among other things:

    • be prepared following consultation and engagement with a range of internal and external stakeholders to ensure it is a worthy strategy that will deliver improvement

    • clearly establish the commitment of board members and executives to health and safety, and describe how they are held accountable for health and safety performance

    • set clear objectives to improve how health and safety is managed, and describe how this will be achieved, for example by innovation and embracing technology

    • be clearly understood and embraced by all stakeholders so that everyone is committed to achieving the strategy rather than simply seeing it as words on paper.

  3. Profile all your risks, not just “the big five”

    There’s often a temptation to focus solely on “the big five” risks in housing: gas safety, fire safety, electrical safety, asbestos and legionella. While these risks are clearly significant, housing associations should not neglect other significant health and safety risks.

    When profiling their health and safety risks, housing associations should examine the:

    • nature and level of the threats they face

    • likelihood of adverse effects occurring

    • level of disruption and costs associated with each type of risk

    • effectiveness of controls in place to manage those risks.

    It’s important to consider all possible health and safety risks to ensure that the right risks have been identified and prioritised for action, and minor risks have not been given too much priority. A comprehensive risk profile also informs decisions about what risk control measures are needed.

  4. Have access to competent health and safety advice

    The regulator states that housing associations must demonstrate that they understand their statutory responsibilities and, if necessary, take professional advice to ensure that they are clear about their responsibilities.

    It’s a legal requirement for organisations to have access to competent health and safety advice and housing associations, particularly larger ones, will often have an internal team of health and safety professionals. An internal health and safety team can play a key role in embedding health and safety into the culture of a housing association. Their role should be to set a management system framework to enable functions to effectively manage the risks they create.

    Housing associations shouldn’t limit their source of health and safety advice to their internal teams. There are times when specialist advice may be required, for example on issues such as fire safety, asbestos management, and employee health and wellbeing. It’s important to ensure that those who provide health and safety advice, whether internal or external to the organisation, have the necessary knowledge, skills and experience, and are competent to advise on the matters they are asked to consider.

  5. Seek assurance across your risk profile

    We’ve already discussed the importance of housing associations managing health and safety across their entire risk profile. It’s also important to seek assurance across the risk profile to ensure significant risks are being managed.

    Housing associations should adopt a risk-based approach when planning their health and safety audit activities. The “three lines of defence” model can provide a robust method for seeking assurance, and will most likely align with wider audit and assurance activities across the organisation.

The three lines of defence

The three lines of defence in relation to health and safety are outlined as follows.

  • First line of defence: operational management. This has ownership, responsibility and accountability for directly assessing, controlling and mitigating risks, eg an asset compliance team would seek assurance on how electrical safety is being managed across the organisation.

  • Second line of defence: activities covered by the health and safety function. This line of defence monitors and facilitates the implementation of effective risk management practices by operational management and assists the risk owners in reporting adequate risk-related information up and down the organisation.

  • Third line of defence: internal audit. The internal audit function will adopt a risk-based approach and provide assurance to the board, executives and other senior management. This assurance will cover how effectively health and safety risks are being assessed and managed and will also evaluate the effectiveness of the first and second lines of defence.


The sector risk profile highlights the increasing significance of health and safety as a strategic risk for housing associations to effectively manage. The regulator stresses that compliance with statutory requirements is a basic minimum to provide assurance that tenants are safe, and that housing associations do whatever is necessary beyond this to demonstrate that health and safety risks are effectively managed.

Further information

Last reviewed 18 December 2018