How Scotland is gearing up for Awaab’s Law - podcast transcript

Kieran Findlay (00:13)

Hello and welcome to the Scottish Housing News Podcast. I’m Kieran Findlay and today with Jimmy Black we’re diving into the introduction of new statutory duties around damp and mould, inspired by Awaab’s Law.

Jimmy Black (00:26)

Set to come into force in October, the Investigation and Commencement of Repairs Scotland Regulations 2026 will introduce new duties on landlords to investigate reports of damp and mould and start any repairs needed within a set timescale. Now might question why we need new legislation to enforce basic tenancy rights, but the tragic death of Awaab Ishak is a convincing argument for change.

Now, powerful stories told by tenants and the lawyers in courtrooms are evidence of our collective failure to understand and resolve the causes of dampness, mould and condensation. So maybe we can use technology and qualified contractors to predict and prevent problems before they escalate.

Kieran Findlay (01:11)

So to help us unpack what this means in practice for residential social landlords across Scotland, we’re joined by two guests who sit right at the heart of this transition. Gregor Morrison is National Contractor Manager at AICO, a provider of home safety systems and environmental monitoring. And we’re also joined by Bob Cairney, Director of Technical Services at SELECT, who are the trade body representing Scotland’s electrical contractors.

Gregor, thanks for coming to Dundee today. AICO has been working with Scottish housing providers on environmental sensors and data platforms for years now, so could you describe what the sensors are telling you about the conditions in people’s homes?

Gregor Morrison (01:53)

So we introduced the sensors back in 2021 and, to give a bigger picture on it, we have so far from 2021 to 2026, over 115,000 homes connected UK wide. Now that’s over 150,000 environmental sensors in the homes and over 500,000 devices connected. So that’s including fire alarms and accessories as well. And that’s spread across 400 landlords. So what the sensor will give you is various insights. So it’s using carbon dioxide,

temperature and humidity and that will then generate eight different insights, one of which is obviously a damp and mould risk and that’s then spread across into a low, medium and a high risk from there as well. So that gives landlords full visibility of what’s going on within their properties.

Kieran Findlay (02:36)

See before that you said it was 2021 that you did that. What was it like before in people’s homes? Was there any sort of sensor in technology? Were you the guys to kind of break through that? And what was it like to introduce Big Brother into people’s homes?

Gregor Morrison (02:50)

The only thing, listen Big Brother is a thing that comes up quite a bit, especially with tenants. We’ve worked at the heart of social housing for the last pretty much 30 years, three decades, through home life safety, predominantly through fire and safety alarms. Going back to 2017, 2018, this abbreviation of IOT kept on coming up.

So as an organisation, obviously we’re owned by a company called the Ei Electronics, based in Ireland. Everything we do is driven by social housing demand or client demand through the housing sector and again come back to IOT kept on coming up. This abbreviation of IOT sorry and we had to look at different technology.

Jimmy Black (03:28)

You have to actually tell us what IoT means. Because it was fashionable a few years ago and nobody says that now.

Gregor Morrison (03:30)

Internet of Things.

They don’t say it anymore because again there’s more and more providers now. So I wouldn’t say we’re a late to party, we definitely weren’t the first. But because we’re so heavily involved and still are of course, with the social housing sector, we have to look at different technology to not just increase the safety, but obviously potentially better the conditions for the homes as well.

Jimmy Black (03:52)

But what are you finding? I mean, are you actually finding there is a problem, a widespread problem, or are you finding that things are better than people thought?

Gregor Morrison (03:59)

Bit of a mixture of both to be honest with you, I think it’s a mixture between environmental and structure. I think that’s what landlords are finding as well. It’s not just down to potentially tenants, it should be the potential structure of the buildings. A lot of it can’t be environmental led, so the condition within the property and through tenant behavioural changes, that can obviously improve from that. But it comes back to that transparency between the tenants and the housing providers as well.

Jimmy Black (04:27)

Now you’re putting kit in, electronic kit into various houses. Does that require an electrician? Are you involved in the installation side of it? Or are your members?

Bob Cairney (04:35)

Our members are, certainly we’ve been working proactively with associate members, SELECT’s got a number of associate members including AICO and we have been trying to spread the message about Awaab’s Law for the last couple of years, particularly through things like our branch meetings. AICO have kindly come along and informed the members about 

Awaab’s Law in England and the potential rollout in Scotland and also highlighted their home link sensors and again SELECT over the years has been, how long have we been involved with AICO? At least 20 years since the requirements came into place for things like fire detection and carbon monoxide detection and properties.

Kieran Findlay (05:30)

Gregor, you’ve had a front row seat to how Awaab’s Law is played out in England. So how do you think the providers in Scotland are prepared for the shift to evidence driven compliance? And in other words, having to justify their actions in court, should I ever come to that?

Gregor Morrison (05:44)

I must say, speaking to my colleagues in England and various landlords,  I definitely think the sector needs a pat on the back. I think over the last few years there has been a proactive approach shifted away from reactive since this technology was made available, not just AICO’s technology but various other providers as well.

Bob Cairney (06:04)

Yeah, they’re going to have to move from reactive maintenance to preventative maintenance basically.

Gregor Morrison (06:11)

That’s been one of the biggest things. Scotland’s definitely in a good position. For whatever reason that may be, we’re we’re where where just a bit different up here compared to everywhere else. There’s 600,000 social housing homes in Scotland compared to 4 million in England. We always seem to be ahead of the curve. That’s prior to any Awaab’s Law coming in or the changes in annual return last year that was introduced as well.

Kieran Findlay (06:35)

Is it fair to say, maybe Scotland had a standing start in these regulations where England are starting from behind the blocks.

Gregor Morrison (06:44)

If I look at stats and I look at funding, if I look at again from a sensor perspective, if I look at social housing decarbonisation fund that was introduced in England over the last few years, £1 billion worth of investment, which part of that was sensor technology. There’s 2%, again these are the AICO stats, 2% of England’s social housing homes are connected. Scotland hasn’t had any national funding, 2.5 % of Scotland’s social housing homes are connected.

So again, does show you there is a shift in their willingness to adapt. The ORP funding came into Wales over the last couple of years, or 18 months, and there’s been 6 % of Wales’ social housing homes connected. So again, it shows how much of an impact funding can have, but even without funding, Scotland’s social landlords are definitely working in a proactive manner. We work alongside over 150 RSLs and 32 local authorities in Scotland

and there’s definitely a big drive. Again, there’s 400 RSLs UK wide that are installing this technology. I definitely think we’re in a good position in terms of the sector’s in a good position to deal with it. Obviously Awaab’s Law has  been phased in, in both England and in Scotland. So obviously by 2025 in England it’s focused on damp and mould, Scotland 2026, and then phasing in other hazards. Wales, which I just found out prior to starting today, is introducing all 28 hazards.

Kieran Findlay (08:11)

Who are the other hazards?

Gregor Morrison (08:13)

Like electrical, so carbon monoxide, electrical, fire, you’ve got radon on as part that as well. You need to look at various others to go through every 28 hazards.

Kieran Findlay (08:25)

So conceivably there could be a bit of smoke in the tenant’s home and somebody will be alerted to that. That, you know, eventually.

Gregor Morrison (08:31)

Yeah, from that. I would say overall, I think we are in a pretty good position, good place with it.

Jimmy Black (08:39)

I used to be involved with Angus Housing Association and two or three years ago, that’s when they cottoned on, I think, to the potential use of sensors and started putting those into houses where there had been reports of damp and gathering the data. But it wasn’t always the case that the sensors were linked in real time to the housing association.

They would go out, put them in, get them, bring them back, download the data. So that seems to be not quite, I think they’ve moved on to better stuff now, it’s not quite the same thing as having real-time monitoring, it?

Gregor Morrison (09:13)

No, it’s 100% not. The solution that we offer, so again every solution does vary, but we went down the route of, again, purely down to our social housing coverage within the UK. Ours is driven by a gateway, so the gateway is installed by an electrical contractor, fixed in next to the consumer unit on an unswitched spur, only mains isolation. That then links up obviously to environmental sensors and it’s gathering real-time information over a 10-year period pretty much. And it’s constant as well.

Bob Cairney (09:42)

It is maybe worth highlighting that it’s not when you use the term electrical contractor it might not necessarily be an electrical contracting business as it may just be electrician as in the DLOs electrician or the housing association’s own operatives.

Gregor Morrison (09:58)

Yeah, and that as well. So yeah, so that’s why we went down the route of the gateway being a one fix property by property basis because it gives you a long term solution like you were saying there. The other solutions, like data tags previously beforehand, it wouldn’t sort the data out for you, it wouldn’t give you an accurate reading and it could be quite messy essentially. Whereas this one fixed solution gives you that over a 10 year period and that includes obviously if there is a change in tenancies as well.

Jimmy Black (10:26)

So the data that you collect with an environmental sensor, it might show that in the same street in an identical house, families will have different, entirely different experiences of dampness, condensation, even if they live next door to each other. So is this necessarily about the way that residents behave and the kinds of issues that can be prevented before they become a health risk?

Gregor Morrison (10:50)

I think it’s just educating tenants, that’s one of the biggest things. So again, going back to the software side of things, we don’t just offer a platform for the social landlords or installers, we offer a platform for residents as well through an app on the phone. As part of that, it will give you the last seven days reading, so it give you raw data as well as the most up-to-date readings per room where sensors are installed. Part of that will give you hints and tips. So say for instance, there’s a tenant’s room that’s over above 60 % humidity for a certain period of time.

that app will tell you hints and tips what you can do to reduce that as well as carbon dioxide. Readings are too high within that as well. So what can you do? could be something simple as open up a window. You do find again, speaking to social landlords, one of the biggest issues they’ve got is tenants sometimes turning off extractor fans. Not opening windows over-crowding the properties. Sometimes you can have properties becoming void over a period of time, as Bob says, we’re in the middle of a housing crisis.

So these are all valuable information for the social landlord. But I go back to the tenant that again that information is very transparent.

Kieran Findlay (11:52)

How were the results with that then? Because we had a Dundee company, Alator Data Services, on the podcast just last year and they were telling us how the data helped them. They were that bridge between the housing association and the tenants saying, look, if you just open your door a couple of inches, we could tell you that this will be improved. I mean, if you had any good experiences with that and bad experiences with that.

Gregor Morrison (12:17)

I can actually give you two, off the top of my head, can give you two examples, two good examples, one from a small housing association and one from a local authority who rolled this out in West Dunbartonshire Council. So when they first started installing the sensors, obviously as I said before, it’s broken down to low, medium and high risk.

At a point in the first year, they had over 700 high risk properties. Within that, they then built a damp and mould team within the building service team and they then did forward meetings and obviously part of that was to review the property, review the terms that in the property, was there any structural issues. Within a 12 month period, the high risk dramatically halved and that wasn’t due to changing weather that was between, say for instance October 2024 and October 2025 and that they halved. So again that transparency and discussion with tenants, that has had a massive impact by having the sensors in. If they never had the sensors in, how would they know what was going on in the property?

It’s a question that we always ask people that have been little bit reluctant to maybe go with technology. How else would you know?

Jimmy Black (13:21)

But then how do do they how do the tenants dry their clothes?

Bob Cairney (13:25)

So it’s changing habits isn’t it? It’s driving a, I suppose, putting sensors in, it’s focusing their minds on changing their habits.

Gregor Morrison (13:33)

It’s changing habits. I always go back to the time when I first bought my first other house, it was a new build. And within that, you sleep in your bed at night and you see this little thing that’s sitting on the wall and it’s going from 400 ppm to 700 ppm to 1000 ppm. Then it’s got a traffic light system that’s going from green to amber to red and you’re going, why is that red? Red can’t be good. I don’t know where it is. But at end, Google it or research a bit more and see exactly where it is and realise you just need to open the window.

So something small as that, so if somebody’s got access to a smartphone in they’re hand 24 hours a day or however many hours a day, you can obviously see all the hints and tips you can do obviously to resolve the issues.

Jimmy Black (14:13)

Now, a wee follow up question, who does the data belong to? Because I wonder if landlords are going to be threatened with a court because the house is damp and they haven’t sorted it, the tenant is going to be very interested in that data. Are you finding any reluctance on the part of landlords to share the data with their tenants? And you’ve said that actually your app already does that.

Gregor Morrison (14:34)

There’s not been any reluctance at all. Some landlords have offered, so again go back to West Dunbartonshire Council, they have offered the tenant app to every single tenant who gets sensors installed. So there’s been an email address set up, tenants can then email in and ask for a request of a login. The landlord’s fully in control of who gets access to that app. If a tenant was to move out of a West Dunbartonshire property and go to another local authority, they would just change the tenancies and then they’d be kicked off the app.

Essentially, because that’s information. The information generated within the property is property information. So its the carbon dioxide levels within the property. It’s the temperature levels within the property. It’s the humidity levels within the property. It’s technically not tenant information. That’s why it’s not been such a push back on it. But again, that’s something that’s been explained to the tenant at point of install. So when the contractor goes in, contractor obviously explains to the tenant what this technology is and why it’s been installed as well as a follow up with a building service officer who are focusing on the damp and mould side.

Kieran Findlay (15:38)

So a lot of work could be down the pipeline for electrical contractors in Scotland. Is the sector ready for, does it have the capacity and the skills to cope with the increased demand that this legislation will create?

Bob Cairney (15:55)

I would say there’s a lot of quality electrical contractors out there who would be able to provide services readily off the shelf at the moment. There are others out there who may need to develop knowledge and the sort of skills that might be required. I mentioned for instance introduction of ventilation training for our members.

Remembering that members aren’t necessarily all electrical contractors. Some of them could be operatives from housing associations or local authority building services. So if the guys need some sort of training to build up their knowledge, we are in the sort of business of providing that sort of backup. With regard to other contractors, electrical contractors and membership SELECT have as I mentioned 1240 approximately members.

We assess our members to a strict membership criteria and within that criteria there are various work categories. Electrical installation obviously for the Electrical Contractors Association of Scotland would be the preeminent one but we also have work categories for instance for fire detection and fire alarms, you know, in dwellings, we have fire detection, fire alarms, all buildings.

And we also have a scheme for those who may undertake building warrant work. Now, the guys who are in the scheme for building warrant work are called approved bodies, and the guys who verify compliance for building warrant work are called approved certifiers of construction. And I would highlight these guys as having particular knowledge of, for instance, statutory regulations like the building regulations and the technical handbooks that the Scottish Government’s Building Standards Division provide. These guys, approved certifiers of construction, if they’re in that scheme and they satisfy that requirement, they would be particularly useful when it comes to ventilation issues, I would say.

Kieran Findlay (18:12)

You’ve mentioned that the well one of the differences in Scotland these legislation is going to be extended to the private sector and You know some of them may use properly qualified contractors for this electrical work some of them might have a go themselves yeah and is that is that a risk and Are you seeing any you know private landlords get in touch with you and say we need help?

Bob Cairney (18:39)

Yeah, I mean since I mentioned the rollout of the repairing standard 10 years ago, initially we did get a lot of contact from private landlords querying, you know, condition reports, periodic inspection and tests carried out, which is a kind of subjective inspection and test, I have to say, and the reports can be subjective and they can be limited in quite a lot of ways depending on what the person or doing the work asks for, to be honest.

I think it’s imperative in a selector at the forefront of trying to push for professional recognition of properly qualified electricians, that a properly qualified electrician is used. And it would mainly be on the basis of the knowledge and skills and experience they have to carry out electrical work safely. You don’t want, with all respects to joiners, somebody who’s, you know, not got a knowledge of electrical work carrying out that work. Is it being installed safely? Is it to the correct standard? There are industry standards that we refer to, particularly in the UK, the national standard is BS 7671, which is the IET wiring regulation, also known as the IET wiring regulations.

Now, it’s unlikely that an unqualified electrician or electrical contractor will have the knowledge of that standard. If we then look at dwellings, domestic installations, we talked about fire detection and fire alarms, there’s also codes of practice there. You’ve got BS5839 part 6, which is a specific code of practice with regard to fire detection. There’s standards for carbon monoxide detection. There’s standards for just about everything.

And then you’ve got the legislation, as I say, there’s loads of legislation in Scotland. I’ve mentioned the Housing (Scotland) Act, that’s where this new set of regulations is coming in. You’ve got within that existing ⁓ lot of standards, you’ve got the repairing standards, you’ve got the tolerable standard, and you’ve got the Scottish housing quality standard to comply with for housing.

So the guys need to have a knowledge of these sorts of things as well. What is it they need to do to comply? They’re in an ideal position to maybe provide advice to private landlords as well. As well as, I suppose, social landlords possibly will have their own staff to maybe advise them or keep them right, but as I say, private landlords particularly. Yeah, qualified staff is very important if you’re carrying out new work in blocks of flats for instance, going in to install a simple double socket for instance in a flat that requires a building warrant in Scotland. Hence, I then maybe flag up again our scheme certification of construction scheme. Approved bodies, approved certifiers of construction. If you opt to go down the route of applying for the building warrant, which you should be doing if it’s applicable, these guys can help you comply.

Jimmy Black (22:08)

Well, there’s an interesting thing because I’ve had a number of double sockets installed in my flat.

Bob Cairney (22:12)

You never applied for a building warrant. You better keep that under your hat.

Jimmy Black (22:18)

I’m just about to broadcast it to the whole housing sector.

Kieran Findlay (22:21)

I was going to come back, keep on the private landlord issue with yourself, Gregor. On the social landlord side, it’s the social landlord that’s got the data and is looking after that and the tenants have got the apps as well. On the private landlord side, is it a factor, is it a letting agent or is it the, ⁓ who’s got the data, how is it being used?

Gregor Morrison (22:42)

It would be through the private landlord, they would have this information so if a private landlord decided to install this within their home then they would get access to all that information, they may have various properties. They could then pass it on to the agent if the agent was looking after that, essentially it would come under the private landlord to manage that if they wanted to choose to. It’s probably their responsibility to do so, yeah.

Kieran Findlay (23:01)

They are responsible, and it’s an education to be happening there.

Gregor Morrison (23:08)

We train, we offer CBD training to over 15,000 people every single year throughout the expense dollar programme, but we also do various other CBDs for social housing providers and private landlords that look at this technology. So that’s something that we offer across the field of the sector. It’s something we have been pretty proactive with, not just in social but private side as well.

Jimmy Black (23:29)

Well, you think this is a big opportunity for electricians? I electricity is expensive. The legacy systems have got to go. Old fashioned storage heaters are on the way out, I think. There’s still people having to use them. Are you ready to innovate with new technologies? mean, do heat pumps, do heat batteries, solar and heat networks, do they give your members the fear or are they actually really ready to go and put these things in?

Kieran Findlay (23:56)

Can I add electric vehicles to that as well?

Bob Cairney (23:58)

Yeah, well again, the industry to a large extent is catching up with regulations and technology. These things are out there, they’re being installed. And of course, how do you gain the knowledge? There are companies that are set up to specifically install solar PV. There’s guys installing battery systems. Are they suitably qualified?

That’s a good question. SELECT are looking at this ourselves and that’s something that we are trying to evolve going forward. We’re looking at our membership criteria. I mentioned we have 1,240 members. They have to comply with the membership criteria in the first place to join, which revolves around having the suitably qualified staff and operatives and compliance with.

appropriate industry standards, British standards, etc. and ongoing into their membership. that’s important. However, as you mentioned, EV, charge equipment, for instance, we recently, a couple of years ago, decided, do you want to be assessed on that for membership? And around 60 to 70 members have come forward and they specifically want SELECT to come out and check.

that they’re working to the right standard. For instance, there’s no just wiring regulations there. It’d be a 7671. You have IED code of practice that has evolved over time over the last 10 years. We’re looking for compliance with that. We’re now looking at our membership criteria in line with a national standard, a national benchmark for registration and certification bodies, SELECT being a registration body, to include things like solar PV, battery storage, micro wind, there’s another one you could throw into the mix.

Periodic inspection and testing is a big thing with regard to repairing. So we’re looking at individual assessment. There is a UK concern about the standard and quality of condition reports that are produced ⁓ on the back of periodic inspection and testing and trying to inform landlords and such like, be careful what you’re asking for, you know, and make sure you’ve got the adequate budgets. So we’re looking at our membership criteria to try and align with this national specification called the electrotechnical assessment specification.

And that’s driving up standards, that’s looking at making sure that guys who are doing solar or battery or EV charge equipment or periodic inspection and testing, have suitable and appropriate training and qualifications. We kind of base it on the electrician plus model  where an electrician has to be, we talked about that earlier, suitably qualified people.

The baseline is you’ve got a SVQ level three in electrical installation practice and then you build on that. So it’s about gathering your competence, not every electrician is competent for every task that they’re likely to undertake. So it’s about building up the competence levels by having appropriate training available. Again, as I say, provide services for our members and part of that is training. A lot of our training courses are SQA approved. We’ve got an SQA approved electric vehicle training course, for instance.

We’ve got an SQA approved periodic inspection and test course actually covers the whole range of inspection and testing, initial verification of new installations through to the periodic inspection. And again, that is aimed at driving up the quality of condition reports that our members provide. So yeah, we’ve got a bit of work today going forward, but that’s something we’re conscious of and it’s catching up with advances in technology.

The wiring regulations, I’m not breaking any secrets here by saying, there’s an amendment to the wiring regulations that’s coming out in April, April the 15th, because the IET have already done a press release in the middle of January about that. Now one of the significant changes that’s highlighted in that press release is the inclusion in BS 7671 of specific regulations relating to stationary batteries. The existing regulation book has two regulations relating to batteries.

The new regulation book when it appears will have something like 18 plus regulations relating to stationary batteries. So as I say we’re evolving, we’re catching up, it’s a job just catching up because technology is moving on at such a fast pace.

Jimmy Black (29:10)

Absolutely.

Kieran Findlay (29:12)

Yeah, let’s round this up then. If you could both give one piece of practical advice to a Scottish housing provider who are finding themselves having to prepare for these new duties, Bob, what would it be?

Bob Cairney (29:26)

Well, they have to be proactive and they have to look at the legislation that’s ahead of them and make sure they’ve got adequate processes and procedures in place. If you’re looking at employing electrical contractors, make sure you’ve got systems in place for ⁓ assessing their competence. Part of that might be that you rely on engaging a select member because you’ve then got the confidence that there’s an assessment back.

membership criteria that they’ve had to meet to start with. That doesn’t mean to say that they’re competent for every task. As I say, there’s still an onus as an employer to assess the competency of those coming in. But yeah, I would say be proactive and ⁓ be aware of these things and deal with them early.

Kieran Findlay (30:15)

Okay, Gregor?

Gregor Morrison (30:16)

Collaborate, speak to other housing providers to see what they’re doing. We’ve got a famous saying at AICO that’s ‘share the genius’. So we host a variation of working groups throughout the year. Every area does it, over 28 areas. Or 32 areas now, sorry. Better edit that one out! Yeah, collaborate, definitely collaborate.

Speak to other housing providers, see what they’re doing. That’s been one of successes so far. We’ve seen up and down the country, other local authorities in Scotland are speaking to various in England and we have in Northern Ireland as well, always collaborate.

Kieran Findlay (30:53)

Right, thanks, that brings us to the end of this episode. My thanks to Bob Cairney and Gregor Morrison. Thanks always to Jimmy Black, I’ve been Kieran Findlay. We’ll be back with another episode down the line.