WHQS and Equality

This element requires that at change of tenancy all habitable rooms (bedrooms and living rooms), staircases and landings located within the home should have suitable floor coverings. When planning delivery and implementing, consider the following:

• Equality impact is likely to be positive for many groups but especially those tenants on lower incomes and tenants with small children (our research found that bare flooring affects safety of small children)
• Consider what flooring to offer disabled/older tenants with mobility issues e.g. carpets may not be appropriate in some spaces for wheelchair users
• Our FLOORED: 3 Years On guide (with TPAS Cymru) offers multiple good practice and suggestions from organisations which have already introduced or piloted this element including: tenant choice, timescales, ownership, health and safety, suitability etc.). Flooring report from Longleigh Foundation and Altair is another source of guidance.

Although this element states broadly that ‘As far as possible, homes should suit the specific requirements of the household’, its main focus has been on cultural adequacy, e.g. cultural needs of the tenants, family structure, religious practices and the homes internal layout, security and external spaces. The element also mentions bathrooms and kitchens. Culturally appropriate design and retrofit can not only increase tenancy success, but also improve housing conditions long term: reducing wear & tear, reducing issues such as damp and mould and preventing costly maintenance & repairs.

Consider the extent to which the below could be delivered as part of WHQS retrofit process: 

• Check out our guide to culturally inclusive design (member password needed) and our ant-racism resource pages on culturally inclusive design and housing conditions/overcrowding
• Kitchens: consider more hard wearing materials, appropriate ventilation, size & number of sinks, grease traps, placement of washing machine, storage for large pots and bigger sacks of food provisions; consider separate entrance rather than passing through living area
• Bathrooms: consider wet room type environment, water resistant flooring and tiling, increased ventilation and windows which open, orientation of toilets, distance between basin and toilet (or provision of hose); consider providing bath and shower as running water is a preference in some cultures
• Hallway: consider separate hallway (without open access to living space)
• Rooms: consider flexibility of room design to cater for usage for more than one purpose
• Living areas: consider more than one living area with interconnecting doors if possible to allow for male/female separation where required
• This element can be seen as overarching e.g. in planning for delivering element 3e (adequate ventilation), it is important to consider different requirements of e.g. large households and/or cultural groups are more likely to spend much more time cooking – see Cardiff University research

This element asks providers to ensure that Lifetime Homes and higher accessibility requirements and standards are properly considered during the refurbishment process and implemented if and where achievable, in accordance with the duty for reasonable adjustments. This includes
requirements of people with physical, sensory, learning or other impairments. Access requirements will therefore need to be considered and, where reasonable, addressed in the course of retrofit. Consider the below:

• Do you hold data on access requirements profile of your tenants and on homes with adaptations? (e.g. numbers of wheelchair users, people with sensory requirements etc). Do you map/plan those properties which have adaptations against the plan for works?
• Do you inspect current adaptations or facilities to ensure any upgrades do not negatively impact accessibility?
• More time and resource may be needed for engagement with disabled/older tenants with specific access requirements to consider their needs and decide what is reasonable and feasible in the course of retrofit to meet their needs
• More time and resource may be needed for the delivery of specific elements e.g. where adaptations already exist or could be delivered.
• Adaptations: Where you are unable to replace ‘like for like’ ensure that you discuss alternative options with tenants and service users making sure you take account of their needs and preferences
• Consider how to manage disruptions at home while the work is ongoing as any disruption might have more negative impact on disabled/older people (e.g. through access being restricted, electricity/water needed for health related machines, noise and work’s impact on people/children with autism or other neurodivergent people)
• Accessible communication: Do your staff/contractors know about the accessible communication requirements of various tenants (e.g. via coding or pre-engagement). See good practice on accessible communication here. 
• See advice on what is ‘reasonable’ in relation to reasonable adjustments.

Decarbonisation and future-proofing for climate change is a key element of WHQS 2023. Decarbonisation provides many opportunities for advancing equality and reducing poverty but it can also present equality pitfalls with some groups being disadvantaged through processes or delivery itself. Below are some key considerations:

• Plans and prioritisation: some organisations are basing their frameworks’ priorities primarily on housing condition. Others are using additional data to prioritise certain homes based on tenants’ vulnerability, e.g. financial situation of the
  household; disability; risk of fuel poverty. Having and using this data can not only help vulnerable tenants but also better protect the asset.
• Digital literacy and inclusion: some groups may be more likely to lack digital skills or internet access necessary to operate some new solutions. Pre-emptive increased communication, awareness, training and automated monitoring can help. Consider other means of controlling the home systems – e.g. apps, wall panels.
• Some disabled and older people may require higher temperatures to stay healthy due to health conditions, likelihood of staying at home etc. You may want to consider this when prioritising solutions, homes and communication.

Delivery of WHQS 2023 will no doubt lead to more and often different people entering tenants’ homes at greater frequency. Respectful and inclusive culture within maintenance and contractor teams is of paramount importance. Consider the below:

• Have the team/contractors delivering the works received equality training tailored to repairs & maintenance staff, anti-racism training or anti-racism e-learning?
• Have you got a planned approach to promote and embed inclusive culture, outside o training? (see examples from our members)
• Are equality, diversity and inclusion on team meeting agendas of repairs and maintenance teams?
• How do you measure and monitor inclusive culture within the organisation? (see Deeds not Words reports with examples of survey questions and results)
• Do staff have access to information about specific access or communication requirements that some tenants might have?
• Do staff know how to access accessible communication aids or assistance (e.g. BSL interpreters, apps etc) and inclusive language guidance 
• Have staff been trained on how to recognise or deal with  safeguarding issues, including domestic violence and hate incidents?
• How will you monitor and safeguard the experiences of diverse staff and tenants during this increased period of activity?
• Do staff have the skills to challenge and respond discriminatory behaviour

Undertaking QED accreditation is the most comprehensive way of reviewing and implementing inclusive staff culture, with proven results. 

The Welsh Government is likely to set a new rule in WHQS 2023 relating to publishing response times to serious hazards, including damp and mould.

• Each landlord will have their own policy outlining response assessment and times. While reviewing and publishing those, it is important to consider vulnerabilities. E.g. Taff Taff has developed a damp and mould policy which uses a dashboard approach whereby problems are assessed by severity and any vulnerability in the households (i.e. chronic health conditions, age, and disability). Based on the rating of both factors, a timeline is established for when repairs must be completed. See our Good Practice Briefing on Housing Conditions and Equality
• Our page on ethnic minority housing conditions and overcrowding may also be helpful

Detailed explanatory statements

A detailed explanatory statement is to be included in the Landlord’s Compliance Policy to provide an understanding of how some elements are being achieved. Two of those elements are equality related, i.e. 6d Specific Requirements and 6e Disabled and Older people. Guidance provided above should help landlords consider their approach to these elements and develop detailed explanatory statements. Please contact us if you would like any support or assistance with this process.

WHQS states that compliance policies should outline how social landlords have engaged with tenants and/or tenant groups in meeting and maintaining the Standard. Key equality considerations here are as follows:

• ensure engagement and information is accessible to disabled people and people with limited English/Welsh (please see disability and older people guidance above).
• ensure that diverse groups of tenants and local communities are part of the engagement. this may involve specifically targeting underrepresented groups
• Provide feedback to people you engaged with e.g. via you said, we did type information

The compliance policy needs to state what kind of database or asset management software is being used.

• Key consideration here is the ability to use such software for equality purposes, e.g. to correlate stock condition, damp and mould etc to the profile of tenants in those homes. Our Anti-racism survey showed that only ca. 50% of social landlords were able to break down their stock data by household characteristic.

Each landlord must set out in their Policy how they plan and measure community benefits generated by the WHQS programme.

• Benefits delivered through WHQS 2023 programme can make a big contribution to advancing equality locally, .e.g. via targetted employment and training of underrepresented groups or engagement of supported businesses, capacity building for local equality advocacy groups through contractors etc.
• See Part 2 of our guide to Procurement and Equality