Awaab's Law for Social Landlords — Single Module

The Call

Calder Reach Housing — D&M Response Desk

22,000 homes — Greater Manchester housing association

Statutory D&M function — newly-created role under Awaab's Law

Regulator-watched — Calder Reach has had no Cat 1 breaches in the past 12 months and intends to keep that record

You are the new Damp & Mould Response Officer at Calder Reach Housing — a 22,000-home housing association in Greater Manchester. The role exists because of the Social Housing Regulation Act 2023. Section 10A is the part everyone calls Awaab's Law. It runs on three statutory windows: 10 working days to assess a Category 1 hazard from the moment of written notification, 3 working days to communicate the assessment in writing to the tenant after the assessment is complete, and 5 working days to commence remediation works. Miss any window without a documented reason and you are in breach.

It is Friday 21:47. The phone is about to ring.

FRIDAY 21:47 — FOXGLOVE COURT, TAMESIDE

21:47:00 AMBER 10WD INVESTIGATE 3WD SUMMARY 12WK WORKS M1 — The Call SCORE0

Situation feed

Out-of-Hours Call — Friday 21:47

Megan Doyle, 14B Foxglove Court

The OOH line lights up. Megan Doyle, 14B Foxglove Court. She is calm. She has done this call before.

Megan Doyle

Damp and mould complaint. Black mould, Caleb's bedroom. He's four, he's asthmatic. Our GP has written you a letter. I have a copy in front of me.

Megan Doyle

I reported it in February and March. Bleached it down twice. It came back. The GP wants it properly fixed. I'd like this logged formally tonight.

You

Logging it now. Can you read me what the GP letter says?

Megan Doyle

It says: Caleb Doyle, worsening reactive airway symptoms. Bedroom mould exposure a likely contributing factor and a Category 1 hazard under HHSRS. I am writing to formally request remediation under Social Housing Regulation Act 2023 §10A.

Megan Doyle

She's named the law. So I assume you know what to do.

GP letter on file

From: Dr Elena Vukovic <e.vukovic@trinityparksurgery.nhs.uk>
To: complaints@calderreach.org.uk

Caleb Doyle (DOB 12-Apr-2022) — formal request for remediation under Social Housing Regulation Act 2023 §10A

I am Caleb Doyle's GP. He has worsening reactive airway symptoms; persistent black mould in his bedroom was previously reported to Calder Reach without remediation, and is in my judgement a likely contributing factor.

On HHSRS methodology the conditions are a Category 1 hazard. I formally request remediation under Social Housing Regulation Act 2023 §10A. The statutory windows are 10 working days to investigate, 3 working days to confirm the findings in writing, 5 working days to make the home safe, and 12 weeks to complete the works.

Please copy your assessment outcome to this practice.

Dr Elena Vukovic MBChB MRCGP — Trinity Park Surgery

21:54:00 AMBER 10WD INVESTIGATE3WD SUMMARY12WK WORKS M1 — Decision 1 SCORE0

Situation feed

Action required — case classification

How do you log this case?

Megan is still on the line. Two written notifications now exist — the GP letter and Megan's verbal-then-logged contact tonight. The case-management system will record what you classify it as. How do you log it?

21:55:00 RED 10WD INVESTIGATE3WD SUMMARY12WK WORKS M1 — Consequence SCORE0

Situation feed

Decision 1 outcome

Routine repair classification

The case sits in a 28-day inspection queue. Megan calls back on Day 8 asking for an update. There is none to give.

Dr Vukovic writes a second letter — this one to the Regulator of Social Housing — copying Calder Reach. The regulator opens a pre-investigation file.

By the time Ben Halliday gets on site, the 10wd investigation window has already closed without an investigation having been done. The breach has begun and is documented in two written notifications, both of which named the statute.

Why this is the wrong call

Section 10A of the Social Housing Regulation Act 2023 attaches to written notification of a damp and mould condition, not to a landlord's classification decision. Once Dr Vukovic's letter arrived, the 10 working day investigation clock had started — regardless of how Calder Reach chose to log it.

Logging as a routine repair does not pause the statute. It only delays the landlord's awareness of its own obligations. By the time the case is correctly reclassified, the window has run out.

21:55:00 AMBER 10WD INVESTIGATE3WD SUMMARY12WK WORKS M1 — Consequence SCORE0

Situation feed

Decision 1 outcome

Cat 1 logged — clock running

The case system flips the statutory-clock HUD on: 10wd investigate, 3wd summary, 12wk works. The clock is visible to you, Rebecca, Jonathan, and — through the quarterly return — the Regulator of Social Housing.

Ben Halliday is booked for Tuesday morning. You email Megan the case file and next steps before midnight.

Saul Goldberg replies five minutes later despite it being a Friday night. One line: Correctly classified. Well done.

What you got right

Section 10A runs from written notification, not from the landlord's decision to act. Tagging as a Cat 1 D&M hazard surfaces the obligation to everyone in the chain and creates the audit trail the Regulator of Social Housing will look for on escalation.

HHSRS grading is provisional — the surveyor confirms or downgrades. The clock starts on notification, not confirmation. That is the load-bearing point.

21:55:00 AMBER 10WD INVESTIGATE3WD SUMMARY12WK WORKS M1 — Consequence SCORE0

Situation feed

Decision 1 outcome

Surveyor first, classification later

Ben Halliday gets on site on Day 4 and confirms Cat 1. By the time the case is reclassified under §10A, four working days of the 10wd investigation window have already elapsed without the clock having been formally started in the system.

The reclassification is back-dated to the date of Dr Vukovic's letter — which is what the statute requires — but the audit trail now shows a four-day gap during which Calder Reach was on notice and had not formally engaged with the statute.

Saul flags it in his Monday compliance report. Not a breach. Not clean either.

Why this is the half-right call

Dispatching the surveyor was correct. Waiting for the surveyor's findings before tagging the case under §10A was not.

The HHSRS Operating Guidance is a methodology for confirming and grading hazards — it is not a gate on whether the statutory clock has started. The clock is started by written notification from a tenant, GP, or third party. Both notifications were already on file.

14:20:00 AMBER 10WD: 6 LEFT3WD SUMMARY12WK WORKS M1 — Day 5 site report SCORE0

Situation feed

Activity 1 — HHSRS Hazard Classifier

Day 4 — Ben Halliday's site report

Ben Halliday's report has just landed. Six findings, each with a photograph, a measurement reading, and a one-line tenant quote from his site visit. You need to classify each as HHSRS Cat 1 Hazard, Cat 2 Hazard, or Defect Only. The classifications drive both the case priority and what gets listed on the assessment letter to Megan in 3 working days. Get them wrong in one direction and you allocate budget to non-hazards. Get them wrong in the other direction and you leave Megan and Caleb at risk.

Scoring

Correct = +2. Under-classifying a Cat 1 (logging it as Cat 2 or Defect) = -3 each — this is the regulator-relevant failure mode. Over-classifying a Cat 2 or Defect as Cat 1 = -1 each — misallocates remediation budget. See HHSRS Operating Guidance.

Classified: 0 / 6 Cat 1 found: – Cat 1 missed: –

17:40:00 GREEN 10WD DONE3WD: OPEN12WK WORKS M1 — Day 5 17:40 SCORE0

Situation feed

Day 5 — Saul's office

Saul reviews your classifications

Saul reviews your classifications without comment for two minutes, then pushes the report back across the desk. He taps the case file with the back of his pen.

Saul Goldberg

Cat 1 confirmed in two locations. The 10 working day investigation window closed in compliance — your investigation is dated within the window and the methodology stands. That's the first hurdle.

Saul Goldberg

Now you have three working days from the close of the investigation to confirm the findings to Megan in writing. The statute is specific — written. Phone call is not enough. Voicemail is not enough. A WhatsApp screenshot is not enough.

Saul Goldberg

I'll watch you draft this one. Don't make me write it for you.

09:12:00 AMBER 10WD DONE3WD: OPEN12WK WORKS M1 — Decision 2 SCORE0

Situation feed

Action required — written-summary window open

Communication strategy

The 10wd investigation window closed yesterday in compliance. The 3wd written-summary window is now open. How do you communicate the findings to Megan?

09:13:00 GREEN 10WD3WD12WK WORKS M1 — Consequence SCORE0

Situation feed

Decision 2 outcome

Letter sent — clock honoured

The letter goes out on Day 5 — well inside the 3wd written-summary window. Megan replies the same evening confirming receipt and asking two clarifying questions about the contractor's working hours. You respond.

Saul forwards the letter to Rebecca with a one-line note: This is the template now.

The 5wd make-safe window and the 12-week works window both run from the close of the investigation.

Why this is the right call

Section 10A requires the assessment outcome to be communicated to the tenant in writing within 3 working days of the investigation concluding. The statute is explicit about the form — written. A phone call is not sufficient under the Act, regardless of how thorough the conversation is.

Confirming receipt also matters. Megan's reply email becomes part of the audit trail Calder Reach will rely on if the case is later reviewed.

09:13:00 AMBER 10WD3WD: TIGHT12WK M1 — Consequence SCORE0

Situation feed

Decision 2 outcome

Phone call logged — but not in writing

You call Megan on Day 5. Four minutes. You explain Cat 1, the plan, the timeline. She says she'll pass it to Dr Vukovic.

Day 6, Saul stops you in the corridor. The phone call doesn't count.

You scramble a written letter on Day 7. It lands inside the 3-working-day window by hours. No breach, but the audit trail now shows a phone-call-then-letter sequence Saul will have to defend at the next regulator return.

Why this nearly cost you the window

§10A says communication in writing for a reason. Phone calls produce no audit trail. The Regulator of Social Housing's 2024 guidance is explicit: telephone communication does not satisfy §10A.

You salvaged it by writing within the window. Next case may not give you that grace.

09:13:00 RED 10WD3WD BREACH12WK M1 — Consequence SCORE0

Situation feed

Decision 2 outcome

Deferred to await contractor — clock did not pause

You wait for Trentham to confirm the works start. They do not come back with firm dates until Day 8. By the time you write to Megan, the 3wd written-summary window has closed. You are in breach by one working day.

Dr Vukovic writes a second letter — this one to the Regulator of Social Housing. Saul logs the breach in the quarterly return and copies you on the email. He does not say anything otherwise. He does not need to.

Why deferring did not help

The 3wd written-summary window in §10A does not pause for contractor scheduling. The Act expects landlords to confirm the assessment findings and an indicative plan — even if contractor dates are still being firmed up. A subsequent letter can confirm dates once they are known.

Waiting for certainty looks responsible from inside the operation. From the regulator's seat, it looks like a missed window.

11:00:00 AMBER 10WD3WD12WK: DAY 22 M1 — Day 22 timeline SCORE0

Situation feed

Activity 2 — Awaab's Law Timeline Composer

Day 22 — Mapping the case to the statutory windows

Saul has asked you to map the case to the statutory clock for the quarterly compliance return. Take the six events from Megan's case file and place each one under the correct statutory window. The over-declaring penalty applies — placing a window-1 event into window 2 or 3 (treating a follow-up email as a fresh notification, or pre-judging the breach) costs more than just leaving it untagged.

Window 1

Investigation

10 working days from notification

Window 2

Written summary

3 working days from end of investigation

Window 3

Make safe + works

Make safe 5 working days; works 12 weeks

Window 4

Breach

When any window closes without action

07:14:00 AMBER 10WD3WD12WK: DAY 28 M1 — Day 28 SCORE0

Situation feed

Day 28 — Megan's second email

Caleb — getting worse

Megan's second email has landed in your inbox before you have taken your coat off.

From: Megan Doyle <megan.doyle.84@gmail.com>
To: you@calderreach.org.uk

Caleb — getting worse

I know you said the contractor would be in this week but Caleb's chest is worse. He was up coughing till 1 a.m. last night. He had to use the inhaler twice.

Dr Vukovic wants to refer him to the children's respiratory clinic. I'm not sure if she will write to you again or write to the regulator this time. I'd rather she didn't have to do either.

Could someone tell me what the actual remediation plan looks like? When does it start? When will it be done? I'll cooperate with anything you need but I need to know what is happening.

Megan

Rebecca Holt

I just saw Megan's email. We need to make a budget call this week. Jonathan's asking for a cost-benefit before he signs off.

14:30:00 AMBER 10WD3WD12WK: DAY 28 M1 — Decision 3 SCORE0

Situation feed

Action required — remediation budget

Remediation budget under pressure

Three quotes are on the system. Jonathan is waiting for a cost-benefit recommendation. The home was made safe inside the 5-working-day window; now the significant works must begin within the 12-week window. What do you recommend?

15:00:00 GREEN 10WD3WD12WK: DAY 51 DONE M1 — Consequence SCORE0

Situation feed

Decision 3 outcome

Full remediation — recommendation accepted

Your memo lands one line: £8,500 closes this case in compliance. £1,800 reopens it under regulator scrutiny.

Jonathan signs off the same afternoon. Trentham start on Day 32, finish Day 51. Megan sends a photo of Caleb's repainted room. He sleeps through the night without coughing for the first time in two months.

The 12-week works window closes with the works signed off. Saul's return goes to the regulator marked CLOSED — IN COMPLIANCE.

Why the right answer was also the cheapest

§10A requires the home to be made safe within 5 working days and the significant works that fix the cause — to a Cat 1 standard defined by HHSRS Operating Guidance — to begin within 12 weeks. A patch repair that ignores the cold-bridge isn't remediation; it's a stop-gap that resets the clock when the mould returns.

£8,500 closes the case. £1,800 looks cheaper today and costs far more once the regulator opens enforcement.

15:00:00 RED 10WD3WD12WK: BREACH M1 — Consequence SCORE0

Situation feed

Decision 3 outcome

Patch repair authorised — breach risk live

Trentham send a painter on Day 31. Two weeks later, Megan emails: the mould has bloomed back through the new paint at the cold-bridge corner.

Dr Vukovic writes a third letter, copied to the Regulator of Social Housing and Megan's MP. The regulator opens an enforcement file.

The works on file don't meet the Cat 1 standard, so under §10A the hazard was never remediated. Material breach.

Why the cheap fix was the most expensive

Remediation under §10A is defined by outcome, not spend. A repaint that leaves the hazard in place is a cosmetic delay, not remediation.

The Regulator of Social Housing has been explicit: under-remediation of a confirmed Cat 1 hazard is the failure mode the statute was passed to prevent. It's the pattern that killed Awaab Ishak in Rochdale.

15:00:00 AMBER 10WD3WD12WK CLOSED M1 — Consequence SCORE0

Situation feed

Decision 3 outcome

Family decanted — over-budget but tenant-safe

Jonathan reluctantly agrees to the decant. The family move into a serviced apartment for three weeks. Trentham finish on Day 49 with no occupant disruption.

The case closes in compliance. Clean regulator return. £5,500 over the £8,500 baseline. Rebecca thanks you for keeping the family safe, then adds quietly that next time you should make the §10A case for in-place remediation — the standard option, not the safety option.

Caleb's symptoms resolve.

Why this is the half-right call

Decanting during Cat 1 remediation is permitted under §10A but not required. The standard expectation is in-place works where it is safe to do so.

Decanting fits where works are unsafe to live alongside, or where the hazard is acute. For three-phase D&M remediation, in-place is the standard answer. You spent £5,500 the statute didn't ask for.

16:20:00 GREEN 10WD3WD12WK CLOSED M1 — Day 49 evidence bundle SCORE0

Situation feed

Activity 3 — Audio Evidence Composer

Day 49 — Assembling the evidence bundle

Saul is preparing the case file for the quarterly compliance return. He needs the voicemail evidence assembled in chronological order and tagged for criticality. Six voicemails are in the pool. Three are critical — they go directly to the §10A audit trail. Three are decoys — routine scheduling messages that belong in the case file but do not carry statutory weight. Place the critical clips in the timeline in chronological order. Decoys you may include or omit; chronology errors and missing critical clips both cost.

Placed: 0 / 6 Critical placed: 0 / 3

Voicemail clips pool

Evidence timeline (chronological order)

No clips placed yet. Add critical clips first, in date order.

Final module complete. Take the end-of-course quiz to finish. Take the Final Quiz →

17:00:00 GREEN 10WD3WD12WK M1 — The Quarterly Return SCORE0

Day 56 — Friday 17:00 — Quarterly return

Case status

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Stakeholder outcomes

Megan & Caleb

Calder Reach Housing

Your career

Replay module