Compliance7 April 202611 min read

HHSRS Assessment: Council Officer's Quick Reference

A concise reference guide for council housing officers conducting Housing Health and Safety Rating System assessments under Part 1 of the Housing Act 2004.

Introduction: The HHSRS in 2026

The Housing Health and Safety Rating System (HHSRS) has been the primary method for assessing housing conditions in England since April 2006. Introduced by Part 1 of the Housing Act 2004, it replaced the old fitness standard with a risk-based approach that considers both the likelihood and severity of harm from housing conditions. Despite being nearly 20 years old, the HHSRS remains the foundation of PRS enforcement. The government has reviewed the system and consulted on updates, but as of early 2026 the original framework remains in force. This quick reference guide is designed for officers conducting assessments, covering the essential methodology, the 29 hazards, and the enforcement actions that follow.

The HHSRS Methodology

The HHSRS assessment involves three stages: Stage 1: Hazard identification. The officer inspects the property and identifies which of the 29 prescribed hazards are present. This requires a thorough inspection of all rooms, communal areas, external areas, and building fabric. Stage 2: Hazard scoring. For each identified hazard, the officer assesses: - The likelihood of an occurrence (an event that could cause harm) over 12 months for the most vulnerable age group - The range of probable outcomes: the spread of harms across four classes (Class I: death or severe permanent injury; Class II: serious injury or chronic condition; Class III: serious fracture or moderate injury; Class IV: moderate harm requiring medical attention) The likelihood and outcomes are combined using the HHSRS formula to produce a numerical score. Scores are banded from A (most serious) to J (least serious). Stage 3: Classification. Hazards scoring in Bands A to C (score 1,000 or above) are Category 1. The council has a duty to act. Hazards scoring in Bands D to J (below 1,000) are Category 2. The council has a power to act. The assessment must consider the most vulnerable likely occupant for each hazard, regardless of who currently lives in the property. For example, excess cold is assessed against persons aged 65+, even if current occupants are younger.

The 29 Hazards: Quick Reference

The 29 hazards fall into four groups: Physiological requirements: 1. Damp and mould growth 2. Excess cold 3. Excess heat 4. Asbestos and manufactured mineral fibres 5. Biocides 6. Carbon monoxide and fuel combustion products 7. Lead 8. Radiation 9. Uncombusted fuel gas 10. Volatile organic compounds Psychological requirements: 11. Crowding and space 12. Entry by intruders 13. Lighting 14. Noise Protection against infection: 15. Domestic hygiene, pests and refuse 16. Food safety 17. Personal hygiene, sanitation and drainage 18. Water supply Protection against accidents: 19. Falls associated with baths etc. 20. Falling on level surfaces 21. Falling on stairs etc. 22. Falling between levels 23. Electrical hazards 24. Fire 25. Flames, hot surfaces etc. 26. Collision and entrapment 27. Explosions 28. Position and operability of amenities 29. Structural collapse and falling elements In practice, the most commonly identified Category 1 hazards in PRS properties are: excess cold (Hazard 2), damp and mould growth (Hazard 1), fire (Hazard 24), falls on stairs (Hazard 21), and electrical hazards (Hazard 23).

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Enforcement Options

For Category 1 hazards, the council must take one of the following actions: 1. Improvement notice (Section 11): Requires the person responsible to carry out specified works within a set timeframe (minimum 28 days). This is the most common response and is appropriate where specific works will address the hazard. 2. Prohibition order (Section 20): Prohibits the use of all or part of the property, or restricts the number or type of occupants. Appropriate where the hazard cannot be remedied by improvement works. 3. Hazard awareness notice (Section 28): Informs the person responsible of the hazard but does not require action. Appropriate only for Category 2 hazards; for Category 1, it is insufficient as the sole response. 4. Emergency remedial action (Section 40): Allows the council to carry out works itself where there is an imminent risk of serious harm. The council can recover costs from the person responsible. 5. Emergency prohibition order (Section 43): Immediate prohibition where there is an imminent risk of serious harm. 6. Demolition order (Housing Act 1985, Section 265): For buildings beyond repair. Failure to comply with an improvement notice is a criminal offence carrying an unlimited fine or a civil penalty of up to £30,000. The council can also carry out works in default and recover costs. For Category 2 hazards, the same actions are available but the council has discretion rather than a duty to act.

Assessment Tips for Officers

Practical tips for conducting effective HHSRS assessments: Prepare before the visit: Check the property's history on your case management system, review any previous assessments, and check EPC data for indicators of potential hazards (e.g., no central heating suggests excess cold risk). Be systematic: Work through each room methodically. Use a checklist or mobile inspection app to ensure no hazard is overlooked. It is easy to focus on obvious issues (e.g., visible mould) and miss less visible ones (e.g., inadequate fire escape routes). Document everything: Take dated photographs, measure room dimensions, record heating system types and conditions, note the presence and condition of safety features (smoke alarms, fire doors, window restrictors). Evidence must support the hazard score if challenged. Consider the whole dwelling: The HHSRS assesses the dwelling as a whole, not individual rooms. A combination of minor issues across multiple hazards can create a significant overall risk. Apply the vulnerable age group: The scoring formula is calibrated to the most vulnerable age group for each hazard. This is not optional. An officer who assesses fire risk against a healthy adult rather than a young child or elderly person will underestimate the hazard score. Seek second opinions: For borderline Category 1/Category 2 assessments, have a colleague review your scoring. Consistency between officers is important and reduces the risk of successful appeal. The £18.2 million enforcement fund can support training and calibration exercises to ensure consistent HHSRS assessment across your team.

HHSRS in the Context of the Renters' Rights Act 2025

The Renters' Rights Act 2025 does not replace the HHSRS, but it changes the context in which it operates: Section 21 abolition means tenants are more likely to allow HHSRS inspections and cooperate with enforcement, knowing they cannot be evicted in retaliation. The PRS Database will provide background intelligence before inspections. Officers can check a landlord's registration status, compliance declarations, and enforcement history before visiting a property. The PRS Ombudsman may refer cases to councils where HHSRS hazards are suspected. Councils should establish protocols for receiving and acting on these referrals. Increased civil penalty powers (up to £40,000 for PRS Database offences) create a stronger deterrent effect that supports HHSRS enforcement. Officers should stay informed about any updates to the HHSRS methodology, as the government has indicated that a revised system may be introduced. Until then, the current framework and Operating Guidance remain authoritative.

Frequently Asked Questions

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