Updates to the HHSRS scoring system and operating guidance

Dr Henry Dawson, author of the draft Housing Health and Safety Rating System (HHSRS) operating guidance, provides a summary of the forthcoming changes to the system. He will be discussing them further, along with the implications for enforcement, at our housing and health conference on 13-14 May 2026.

We have been waiting a long while for the update of the HHSRS. Aside from the fire addendum, the system has remained in its original form since its introduction through the Housing Act 2004.

The Government commissioned RHE Global to undertake a scoping review to determine the options for updating the system. RHE made recommendations for a 12-18 month, 2-3 year or 3-5 year update. The Ministry of Housing, Communities and Local Government (MHCLG) chose the medium-term review option.

The brief from MHCLG required various changes to the HHSRS:

1. Review and update the operating guidance
2. Produce updated worked examples
3. Review and update assessor training and develop a competency framework
4. Provide a simpler approach to banding and illustrating the outcomes of the HHSRS assessment process
5. Provide new minimum standards to incorporate into HHSRS assessments
6. Amalgamation of some hazards
7. Identify what a digital HHSRS assessment tool would achieve
8. Review and update guidance for landlords and tenants
9. Review and update the enforcement guidance
10. Review of the fire safety hazard and development of supplementary fire safety guidance

RHE was also commissioned to carry out the update. Its project director, Alan Davies MCIEH CEnvH, and its project manager, Ali Thomas MCIEH CEnvH, headed a consortium of universities, legal practices and consultants to take on the above workstreams. RHE launched a major consultation using surveys, interviews and focus groups, gathering approximately 1,000 responses to inform the changes to the system.

The team at Cardiff Metropolitan University was given responsibility for updating the operating guidance and scoring. The members of the team included Dr Henry Dawson (Lead), Professor Peter O’Donoghue, Dr Sophie Grinnell and Dr Fahmida Khandokar. Dr Grinnell undertook 29 literature reviews to update the content of the hazard profiles. Professor O’Donoghue and Dr Khandokar drew from national and hazard specific data sets to update the national average likelihoods for each hazard profile. The medium-term review did not include updating the spread of harm outcomes. The team were able to update the harm outcomes for the ‘Fire and Explosions’ hazard, however, due to the quality of the data captured by the fire and rescue services. The work on this hazard provides a good example of the processes involved in updating the national averages. You can read about it in an academic article the team produced for Next Research.

In the updated HHSRS, the hazard rating process remains essentially the same, but some of the scoring has changed to help simplify it and to make it more comprehensible to a wider range of people. Baseline indicators have been introduced into the risk assessment process. Anything regarded as less than the baseline indicator (or optimum condition for any matter relevant to the hazard) should be regarded as a deficiency. Baseline indicators can also be used as a checklist to permit those not qualified in the use of the HHSRS to self-audit their properties.

Many consultation respondents reported the size of the existing operating guidance (185 pages) to be off-putting, preventing people from even opening the document. The updated guidance comes in three separate parts. The first describes the system and how to do an assessment, the second provides technical guidance for assessors and the third replaces the fire addendum to provide detailed guidance for assessing the risk from the amalgamated hazard of ‘Fire and Explosions’.

The scoring updates retain the 16 likelihood and 11 harm outcome scale points but remove the reference to the scoring ranges. The updated scales contain a more intuitive range of scoring values, accompanied by descriptor terms. The classes of harm outcomes 1-4 have been renamed with their descriptor terms ‘extreme’, ‘severe’, ‘serious’ and ‘moderate’ and the bands of risk A-J have been replaced with three bands ‘low’, ‘medium’ and ‘high’. Reducing the use of technical terms will make assessments more meaningful and accessible for a wider range of people. The underlying principles of the HHSRS and its scoring methods and formula remain the same.

A concern of HHSRS users was that some hazards (for example ‘Damp and Mould Growth’) do not score as highly as others. The updates are unlikely to change the scores from these hazards significantly, but the new banding will help address feedback that stakeholders found it difficult to argue for action on a category 2 hazard. Although survey respondents engaged as part of the HHSRS review indicated that hazards scoring below 100 could be described as ‘low risk’, those between 100 and 999 have now been banded as ‘medium risk’. This makes arguing for action against such hazards a more intuitive step for those using the system than it is currently.

Some hazards have been amalgamated. There are now 21 hazards with ‘Falls on the Level’ now including ‘Falls Associated with Baths etc’. ‘Fire’ and ‘Explosions’ have been combined. ‘Collision and Entrapment’ and ‘Position and Operability of Amenities etc’ have now become a hazard titled ‘Collisions, Entrapment and Ergonomics’. ‘Uncombusted Fuel Gas’, ‘Volatile Organic Compounds’, ‘Biocides’ and ‘Carbon Monoxide and Fuel Combustion Products’ have now become a hazard titled ‘Indoor Air Pollutants’. ‘Domestic Hygiene, Pests and Refuse’, ‘Food Safety’ and ‘Personal Hygiene, Sanitation and Drainage’ have become a hazard titled ‘Domestic Hygiene’.

The hazard profiles in the new operating guidance contain similar content to those in the previous operating guidance, updated through the 29 literature reviews. New national average tables have been produced with the updated scoring process and likelihood scores. There is also a new summary box providing ‘quick glance’ information on each hazard. Each hazard profile includes a list of relevant baseline indicators alongside the relevant matters affecting the likelihood and harm outcomes.

The expanded part 3 on the assessment of ‘Fire and Explosions’ can be read with reference to other areas of risk assessment / legislation including PAS9980.

The updates made across the 10 review areas set out by the Government will require training for existing users to fully understand. The draft operating guidance and draft enforcement guidance have been laid before parliament and are due to come into force in June 2026.