4. Improving Quality Assurance
Consumer protection through robust quality assurance and redress is critical to both our decarbonisation efforts and consumer confidence, and it is important that consumers have a clear and accessible path to redress in the event of a problem with their installation.
As it stands the complaints process can be unclear for consumers with the roles and linkages between industry bodies lacking clarity and levels of enforcement varying depending on the specific circumstances of the installation.
Quality assurance through a robust approval mechanism coupled with a simplified route to for redress when needed are required to instil consumer confidence and this chapter outlines our proposals for achieving this.
Fuel poverty programmes and quality assurance
The Scottish Government is committed to a whole house approach to the retrofit of homes in support of our Fuel Poverty Strategy. We are therefore already implementing a PAS 2035 approach to our assessment, planning and delivery of retrofit measures as part of our fuel poverty programmes. This builds upon our longstanding adoption of the industry recognised PAS 2030 installation standard and reflects our aim that every householder will be satisfied with the appropriateness, effectiveness and quality of the energy efficiency improvements they make to their home.
We require projects delivered as part of the Area Based Schemes (ABS) and Warmer Homes Scotland (WHS) programme funded by the Scottish Government to comply with all relevant building regulations, retrofit standards and guarantee requirements.
In most cases, householders referred or invited to participate in an ABS project will receive separate technical advice about energy efficiency measures that is specific to their property as part of a PAS 2035 approach to retrofit. Households receiving support from the Warmer Homes Scotland scheme will also receive technical advice about the measures installed during their retrofit process. The recommendation to install an energy efficiency measure will typically be based upon the relevant Energy Performance Certificate (EPC) recommendations and conform with advice on building standards. Householders participating in our ABS projects are also advised to contact our Home Energy Scotland service for impartial and expert advice about how to improve the energy efficiency and warmth of their home.
Energy efficiency measures delivered as part of our ABS projects must conform to the quality standards required to obtain a guarantee, such as those from the Solid Wall Insulation Guarantee Agency (SWIGA). Typically this requirement will be delivery to the PAS 2030 and PAS 2035 standards. Councils will only invite householders to agree to works that are technically appropriate, protected by a guarantee scheme (if available) and compliant with building regulations.
To help ensure they benefit from any measures installed through ABS/WHS projects, householders will also usually receive information about maintaining their energy efficiency improvements along with relevant product guarantees. Councils must set out the quality assurance and also a complaints process for all their ABS projects. WHS has a similar set up, including a service visit at the end of the initial 12 month warranty period. Typically the contracted installer and/or the manufacturer of the measure delivered as part of our ABS/WHS programmes will also provide a helpline service for follow up enquiries.
The Scottish Government is procuring a new enhanced successor to the Warmer Homes Scotland Scheme, due to go live when the current contract expires. The new scheme will deliver a quality assured retrofit process, adopting PAS 2030/2035 standards.
Heat in Buildings Strategy
Our Heat in Buildings Strategy builds upon the recommendations from the Quality Assurance Short Life Working Group through the chapters on People and Place covering quality assurance and consumer protection.
When we analysed the responses from the draft Strategy consultation relating to quality assurance, most of those who expressed a clear view were in favour of adopting the use of TrustMark for energy efficiency work. Respondents also stated that for microgeneration the Microgeneration Certification Scheme (MCS) already offers a quality assurance and consumer protection regime for microgeneration systems and there was a view that if there is a good existing standard there is no need to, or value in, creating another.
Based on the reports and feedback outlined above, it is clear that a robust quality assurance framework for energy efficiency is required with adequate consumer protection. Consequently we propose the following action:
We will work with TrustMark to develop a quality assurance scheme for Scotland which will enable domestic consumers including private sector landlords to access approved suppliers in accordance with the principles of the British Standards Institution (BSI) Publicly Available Specification (PAS) 2035/30 standards.
We want to build upon the existing TrustMark scheme to create a new scheme for Scotland, one which is bespoke for Scotland's needs and goes further in terms of quality and consumer protections. We will continue recommending MCS in Scotland but will seek to work with MCS to ensure alignment between their scheme and TrustMark's.
Any supplier approved under this TrustMark scheme and/or MCS will be subjected to a thorough screening process, including checks against Trading Standards systems. Once approved, the installations and customer service will be closely monitored, and if a high number of customer complaints are received, swift action will be taken to investigate the situation and, if necessary, proportionate sanctions will be imposed, which may include suspending or removing the company from the scheme.
While the TrustMark and MCS procedures currently provide redress for consumers, we recognise that this area requires improvement, and we are committed to working with TrustMark and MCS to achieve this. Both have launched reviews of their consumer standards and redress processes, and we will aim to ensure that the process is reflective of the requirements of consumers in Scotland by bringing together industry and consumer organisations through the consumer oversight group we outline later in this statement.
We have also considered the costs associated with TrustMark approvals and compliance with the PAS 2035/30 standards both in terms of costs to the supply chain and delivery costs to households through our Business and Regulatory Impact Assessment. We estimate there will be an increase in costsassociated with this but we believe the value of ensuring that work is completed to high standards and that consumers are protected from rogue operators outweighs this. Moving to a requirement for TrustMark accreditation provides a consistent approach for suppliers operating across the UK and avoids the costs and inconvenience that would be incurred by having different regimes.
We want to ensure any costs are proportionate and not cost prohibitive and we will work with TrustMark to ensure this is the case. Some areas being considered for change include: reviewing the need for retrofit coordinators for low risk work and developing an alternative pathway for suppliers, particularly installers to get approved potentially offering lower up-front certification costs balanced with higher audit and inspections frequency to ensure consumer are still protected.
For our forthcoming successor to the Home Energy Scotland loans and cashback scheme, we will introduce a new requirement that applicants must use approved suppliers through Scotland's TrustMark scheme for energy efficiency work. Microgeneration work will retain the current requirements for Microgeneration Certification Scheme (MCS) approved suppliers. This requirement will also apply to future schemes and programmes where appropriate.
We believe this new requirement will significantly improve the quality assurance for our successor to the Home Energy Scotland loans and cashback scheme and make it simpler for consumers to find suppliers. For renewables funding under this scheme, we will continue to require installers and products to be certified under the Microgeneration Certification Scheme (MCS).
We will also consider applying the actions described in this document, including the new TrustMark scheme, more broadly in any future domestic energy efficiency programmes to directly support householders. However, we recognise that depending on the goals and mechanisms of each scheme, a different approach may be required, and any deviations from the approach outlined in this statement will be made clear when the respective scheme is launched.
Currently, a householder can apply to use an unaccredited installer in exceptional circumstances where no local installer can be found who meets our HES loans and cashback scheme requirements.
We recognise that some householders, particularly those in rural areas, will find it difficult to find an improved installer to carry out work. This is something we want to avoid but we accept this may happen, particularly in the early stages of supply chain development. Consequently, we will consider what options are available for those who are unable to find a TrustMark or MCS accredited installer for our new schemes, while also working to develop Scotland's energy efficiency and zero emissions supply chain through our Supply Chain Delivery Plan.
We will also work with TrustMark to develop alternate routes to approval which can reduce cost or administrative burdens for those suppliers who wish to carry out retrofit work but are not yet ready to undertake full TrustMark accreditation. This should help improve the overall pool of suppliers available to consumers.
We will set up a Scottish Quality Assurance Consumer Oversight Group to oversee the implementation of the Scottish TrustMark energy efficiency approval scheme and oversee changes and improvements to the existing MCS scheme in support of our Heat in Buildings Strategy.
The membership and role of the group is to be determined but we expect that the group will be made up of consumer organisations, industry representatives with TrustMark and MCS also having representatives on the group. The group's remit may be to:
- Monitor and promote continuous improvement of the framework's effectiveness
- Advise on technical quality of installation
- Facilitate clear and effective redress pathways for consumers
- Promote best practice and suggest areas of improvement
- Advise on the avoidance of mis-selling and scams
- Coordinate consumer advice provision to improve the consumer journey.
- Share data and improve joint working across the sector
We would also expect TrustMark and MCS to share with this group consumer insight reports covering complaints with proposed actions on how to ensure these are avoided in future. TrustMark will establish a dashboard access to their Data Warehouse to allow the working group to have visibility of their processes and outcomes to aid this process.
The new National Public Energy Agency which we committed to in the HiBs will provide the leadership and coordination required to accelerate delivery of transformational change in the decarbonisation of heat in Scotland. Given this strategic remit, there is the potential for the Agency to take on oversight of associated quality assurance standards – this could also include development and/or ownership of the Scottish Quality Assurance Consumer Oversight group. This has not yet been decided, and will form part of the wider considerations of the independent Strategic Board that is currently being developed to steer the overall development work of the virtual Agency, from September 2022.
For non-domestic support schemes we will work with key stakeholders, including BES, to look at quality issues experienced by businesses and to consider the role of BSI PAS 2038 retrofit standards in overcoming these and considering an appropriate approval mechanism for this.
The primary focus of this policy statement is on quality assurance for retrofitting domestic properties, however we acknowledge that further work is required to develop quality assurance for non-domestic buildings as well. A key development in this area is the new British Standards Institution (BSI) Publicly Available Specification 2038 standards for non-domestic and we will consider these standards and how they will apply to Scottish Government programmes. Significantly unlike PAS 2035/30 there is currently no approval mechanism for these standards - TrustMark covers domestic only. More broadly, support schemes for heat networks, community generation, industrial sites, social housing and other areas will also have unique considerations and may require modified requirements or bespoke solutions for their quality assurance.
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