Registration for Regulation
The HHA favours the compulsory registration of self-catering holiday accommodation. There are already powers to do this in the 1969 Development of Tourism Act. But why would an industry association favour more bureaucracy? The answer lies in our desire for fair regulation and a “level playing field” of competition.
Registration would mean that it would be illegal to let a property for holiday use without letting an authority, either the British Tourist Authority or the local council, know about it. At present anyone can let a property without telling anyone and nobody knows for sure how many owners do that. There is nothing to prevent the owner of a property letting it without doing any sort of safety checks, risk assessments, or putting any fire precautions in place. There has been a growth in recent years of properties advertised on online accommodation-finding websites that do not have staff on the ground, do not visit properties, and do not check whether safety or quality standards are managed properly or indeed at all. Typically such sites rely on self-declaration, if they ask any questions at all.
Responsible owners, represented by reputable agencies or members of the HHA, have to carry out all sorts of work to ensure that their properties are safe for guests. A fire risk assessment – and any actions arising from that, is first on the list. Then there is a more general risk assessment looking at hazards ranging from loose carpets to the rottweiler dog in the neighbours’ garden. They must ensure the right checks are made on gas and electrical systems, water systems, rickety steps and any other hazards that can be identified in a thorough review. Any it is quite right that they should do that.
However, there is very little enforcement by local authorities or fire brigades and what enforcement there is falls largely upon those owners who are sufficiently conspicuous to be known by the enforcing authorities. That’s unfair. Our members want to maintain high standards, but they don’t want others to operate without any standards at all, cutting corners and costs, in the knowledge that Fireman Fred won’t be round to inspect the non-existent smoke alarm because Fireman Fred simply does not know that the property exists.
HHA wants fair competition and fair enforcement where enforcing authorities will be able to devote their limited resources on a rational basis and not exclusively to those who advertise their own existence. Properties on many websites don’t give an address until the customer has made the booking, so this information isn’t public.
Registration might also involve proof of insurance, and perhaps some other safety essentials such as gas safety certificates.
Compulsory registration is the key to a level playing field of competition and regulation that will protect the public from irresponsible owners as well as being fair to all.
The HICCOP Goes Public
The HHA has decided to make the Holiday Home Industry Code of Practice available free of charge to everyone in the industry. It is available to download from this website.
HHA wants as many agencies and owners as possible to embrace the standards set out in the HHICOP, which set responsible owners and agents apart from sections of the industry that take a less careful approach to their customers’ wellbeing on holiday.
Some online-only services through which holiday accommodation can be booked make no checks on properties at all. Whilst paying lip-service to safety standards, they don’t ask to see the fire risk assessment, they don’t require any proof that for example gas safety has been certified by a qualified person, and they certainly don’t visit the property physically to see it for themselves. Properties can be listed online even if the owner is very irresponsible and does not meet health and safety standards or behave ethically. There is no compulsory registration in England, Scotland, or Wales, so local authorities may not even be aware that a property is offered for rent, never mind able to devote their slender resources to enforcement.
The HHICOP is a benchmark for responsible, ethical management. Owners and agencies that adopt the Code are making a statement of the standards they work to. Whilst the HHICOP is not an inspection regime, an owner or agent claiming to meet the standards set out in the HHICOP could be in breach of consumer protection law if that were to be a false claim.
Owners and agents are encouraged to reassure customers of their high standards by putting the logo on their own websites – it can be downloaded from our HHICOP page.
Burn-out for fashionable wood-burning stoves?
During May it was widely reported that Michael Gove, Secretary of State for Environment, Food, and Rural Affairs, wanted to ban wood-burning stoves. The reality, as is so often the case with exciting headlines, is a bit more complicated! Some of the sensational news reports were exaggerated. Charles Moore, a writer in The Spectator, claimed somewhat hyperbolically that Michael Gove wants to punish those who use wood-burning stoves and possibly even open fires. It would be hard to think of a more direct attack on country life. All houses in the country are cold, and impossibly expensive to keep warm by central heating alone. The cheapest and most cheerful way of heating individual rooms is by burning wood in them.
The reality is that a consultation has been launched by DEFRA and the Department of Health about a long-term strategy for improving air quality. It is a detailed, scholarly work, that examines the causes of air pollution and the ill-health effects of it, which are considerable. The document looks at all forms of transport, industry, agriculture and event cleaning products used in the home. Of greatest interest to holiday home operators will be the proposals for “domestic burning”. Holiday homes are not mentioned but we can assume that they will be included. This is what is actually proposed:
• We will legislate to prohibit sale of the most polluting fuels.
• We will ensure that only the cleanest stoves are available for sale by 2022
• We will give new powers to local authorities to take action in areas of high pollution, bringing legislation into the 21st century with more flexible, proportionate enforcement powers.
• We will work with industry to identify an appropriate test standard for new solid fuels entering the market.
• We will ensure that consumers understand what they can do to reduce their impact from burning.
In other words, there is no proposal to ban all wood-burning stoves, rather it is envisaged that there will be a new set of standards for them that require all new ones to be of an efficient design that minimises pollution, and fuel sold for these stoves will have to be cleaner.
Also, biomass boilers, used at some self-catering properties, are to be the subject of an awareness campaign to encourage good practice and efficient design and installation. These boilers are already much less polluting than open fires. They are to be removed from the renewable heat incentive scheme for properties in urban areas on the gas grid.
Wood for use in stoves will need to be dry wood. The woodsure scheme run by the wood fuel industry badges wood as ready to burn if the water content is 20% or lower. It is less than well-known to consumers (although bonfire-makers will recognise this factor immediately) that wet, unseasoned wood contains a lot of water and the burning of unseasoned wet wood causes vastly more particle pollution than dry wood. Nothing is said in the plan about gathering wood for burning, but new powers for local authorities over smoke emissions may impact on this too.
The Stove Industry Alliance has created a standard for stoves called “Ecodesign Ready” in anticipation of new standards, due to be introduced in 2022.
When is a Mattress Old?
Your Chief Executive recently became involved as peace-maker in an argument about mattresses. Just how old can they be?
According to The Sleep Council, a branch of the body representing the bed manufacturing industry, we should all replace our mattresses every seven years.
But this figure does not seem to take account of:
- The quality of the mattress in the first place
- How often it has been used (e.g. every night or just 250 nights a year)
- Whether the sleeper weighs 20 stones or is a lightweight
Enter the website “ask for evidence”, which asked for the scientific basis of the seven-year claim in 2016. It turns out that the research is distinctly patchy and not peer-reviewed, and there is little direct evidence that 7 years is the right milestone. Indeed, one of the studies, carried out in France, concludes unsurprisingly that a new mattress is better than one that’s 10-12 years old, for promoting a good night’s sleep. That study was also industry-led and the recommendation in France is to change the mattress every 10 years, not 7.
Patchy as it may be, the evidence tends to support the obvious in that a new mattress is better than an old one but the deadline of 7 years seems to have been chosen by the UK bed industry without much hard evidence in support.
So what is a self-caterer to do? The answer would appear to be simple – have a good bounce on your mattresses yourself and assess their condition. People will expect then to be in good condition and we should most probably be changing them more often than at home – after all we do not really know the people who have been sleeping on them, or if you are not too squeamish to think about this, what they have been doing in bed.
There is some evidence from the French study that older peoples’ sleep is more disrupted by an older mattress than that of youth and there are some obvious reasons why older guests may often prefer firmer mattresses, such as creaking joints or back pain. Many self-catering guests are not in the first flush of youth.
So the evidence seems to suggest that, rather than simply changing them at seven-year intervals, the best course of action is to thoroughly examine them at least once a year and look out for signs that sagging mattresses need replacing.
Welcome to the new blog! As from March 2018 we’ll be adding selected extracts from our monthly newsletter to this blog, but the first entry is about our change of name.
EASCO is not the first name for the Association. Once we were the British Self-Catering Federation. The decision was taken in late 2017 that we should change the name once again. There were two reasons for doing this:
- The term “self-catering” is a little old-fashioned and may not be the term used by young people today when they are thinking of holiday cottages or flats. There are several other terms that are used. “Vacation Rentals” is the term used in American English, which translates as “Holiday Rentals” in British English, but we felt that “Holiday Home” was at the same time very easily understood and reflective of the home-from-home standard of today’s self-catering holiday home. We are not, however, proposing to represent second home owners whose main reason for owning an extra property is to use it for themselves.
- Membership of the Holiday Home Association is to be opened up to businesses outside England that wish to join. It is not our intention to be proactive in recruiting outside England but we know that some agencies would like to take advantage of this.
The change will be implemented around the end of March 2018. It may not be possible to make all changes at the same time and a new logo may take a little time to develop.