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www.parliament.uk/commons-library | intranet.parliament.uk/commons-library | [email protected] | @commonslibrary BRIEFING PAPER Number 8471, 8 January 2019 Q&A: Cavity Wall Insulation By Suzanna Hinson and Lorraine Conway Contents: 1. What is cavity wall insulation? 2. Consumer redress 3. Cavity wall insulation guarantees 4. Consumer legislation 5. Parliamentary debate 6. Where to go for further help

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www.parliament.uk/commons-library | intranet.parliament.uk/commons-library | [email protected] | @commonslibrary

BRIEFING PAPER

Number 8471, 8 January 2019

Q&A: Cavity Wall Insulation

By Suzanna Hinson and Lorraine Conway

Contents: 1. What is cavity wall

insulation? 2. Consumer redress 3. Cavity wall insulation

guarantees 4. Consumer legislation 5. Parliamentary debate 6. Where to go for further help

2 Q&A Cavity Wall Insulation

Contents Summary 3

1. What is cavity wall insulation? 4 1.1 What support is available for installing cavity wall insulation? 4

Energy Company Obligation 4 Green Deal 4 Previous schemes 5

1.2 Have there been issues with cavity wall insulation? 5

2. Consumer redress 6 2.1 Background 6 2.2 How to make a complaint? 6

3. Cavity wall insulation guarantees 8 3.1 What is CIGA? 8

How to make a complaint to CIGA? 8 What if CIGA don’t resolve the problem? 8

3.2 Are there other possible guarantees? 9

4. Consumer legislation 10 4.1 Consumer Rights Act 2015 & Supply of Goods and Services Act 1982 10 4.2 Consumer Protection from Unfair Trading Regulations 2008 11 4.3 Contract law and misrepresentation 12

5. Parliamentary debate 14 5.1 Parliamentary questions 14 5.2 Debates 15 5.3 Reviews 15

6. Where to go for further help 17

3 Commons Library Briefing, 8 January 2019

Summary Cavity wall insulation (CWI) can improve energy efficiency and lower customer bills and as such has been encouraged by several Government schemes. For more information about insulation and other Government energy schemes, see the Library briefing paper on Help with Energy Bills.

Although the majority of installations are successful, in cases where CWI is installed incorrectly, or in unsuitable properties, it can lead to damp. Customers who have problems with CWI should first try and resolve the issues with the original installer. When the issue cannot be resolved, or the installer has gone into liquidation, the customer can check if they have a guarantee, such as with the Cavity Insulation Guarantee Agency (CIGA). Guarantee agencies should assess damage and find a resolution; there is an independent arbitrator for CIGA decisions.

In some cases, consumers with a CWI issue may be able bring a claim for misrepresentation or breach of contract or under specific consumer protection legislation. Much would depend on the terms of any written agreement, representations made, and the facts of the case. Professional legal advice should be sought.

The issue of poorly installed CWI causing damp and mould has previously been raised in Parliament. The Each Home Counts review was published in December 2016 and looks into home energy efficiency schemes. There is no Government compensation scheme for problems with CWI.

Concerned constituents may wish to contact the Energy Saving Trust, Citizens Advice, or seek professional legal advice.

Cavity wall insulation is an effective way to improve energy efficiency with the potential to reduce bills and carbon emissions, and the majority of installations occur without issue. However, the Library is aware of reports of constituent interest in CWI and the issue is raised in Parliament regularly. This briefing has been published to support these reasons and outlines some of the ways issues can be resolved. However, this is general information rather than specific advice for an individual.

Cover page image copyright: Attribution: Cavity wall insulation by Knauf Insulation. Licensed under CC BY-NC-SA 2.0 / image cropped.

4 Q&A Cavity Wall Insulation

1. What is cavity wall insulation? Cavity walls have been common in construction since the 1920s and involves building a gap between the external and internal wall. Cavity wall insulation (CWI) involves filling gaps in cavity walls to prevent heat loss and increase energy efficiency. Current new builds are constructed with insulation, but older, un-insulated properties can also be retro-fitted by drilling small holes into the external wall and pumping insulation (mineral wool, polystyrene beads, or foamed insulants) into the gap before the holes are refilled.

According to the Energy Saving Trust, a Government funded independent advice service, about a third of all heat loss in homes is through walls. Effectively insulating walls can make homes warmer and reduces energy bills by reducing consumption.

The Committee on Climate Change (CCC), who advise the UK Government on decarbonisation, have advocated for more incentives for insulation, as reduced consumption of energy will also reduce carbon emissions. The CCC estimate that the absence of cavity wall insulation adds around £115 a year to bills.

1.1 What support is available for installing cavity wall insulation?

In the UK, there are two main schemes to support insulation, the Government’s Energy Company Obligation scheme, and the now privately funded Green Deal. In addition, the devolved nations have their own support schemes. Further information about all insulation schemes, and support for energy bills in general, is available from the Library briefing paper on Help with Energy Bills.

Energy Company Obligation The Energy Company Obligation (ECO) began in January 2013. Under the current stage of ECO (known as ECO 3), suppliers are required to install energy efficiency measures, including CWI, in the homes of eligible customers in receipt of certain benefits. The costs of the scheme are passed on to all bill payers through energy bills. The grants may not cover the full cost of the installation, so the customer may need to contribute part of the sum.1

Consumers wishing to have measures installed are not limited to their own energy supplier. Consumers can contact any obligated supplier, as they all have targets to meet, however not all suppliers are required to take part in the scheme. A list of obligated suppliers is available from Ofgem.2

Green Deal The Green Deal was an energy efficiency scheme launched by the Coalition Government to incentivise and help fund energy efficiency

1 HoC Library, Energy Company Obligation, 29 March 2017 2 Ofgem, Supplier contact details [accessed 29 November 2018]

5 Commons Library Briefing, 8 January 2019

and renewable energy technologies for homes. The Government stopped funding the Green Deal in 2015 citing low uptake. Green Deal loans secured before it was closed are still being repaid as per the original agreements.

The Green Deal Finance Company (GDFC) was publicly funded to provide Green Deal loans. GDFC was acquired from the Government in January 2017 by Greenstone Finance, Aurium Capital Markets and Honeycomb Investment Trust. As of May 2017, it has begun financing loans again through Green Deal providers under the same format as the original Government scheme but without public funding. More information is available on the Green Deal Finance Company website.

Previous schemes The Warm Front scheme provided grants for heating and insulation including CWI until 2013 when it was replaced by the Green Deal. Earlier schemes include the Energy Efficiency Commitment (2002-2008), Caron Emissions Reduction Target (CERT 2008-2013) and Community Energy Saving Programme (CESP 2009-2013).

More information on the details of previous Government energy efficiency schemes is available in the Library briefing paper on the Energy Company Obligation.

1.2 Have there been issues with cavity wall insulation?

The vast majority of homes that install CWI do not experience problems and instead attain warmer homes and lower bills.

However, there have been problems reported relating to the selling of CWI, and the suitability and quality of the installation.

If installed incorrectly, or in unsuitable properties, insulation can act as a bridge for moisture to move from the external to the internal walls of a property, which can result in damp. Damp walls can result in higher energy bills and can contribute to some health issues. According to the consumer group Which?, homes that can be at risk include those exposed to high levels of wind driven rain, in unsheltered positions, and with walls in a poor condition.3

The issues relating to CWI have been covered by the press. For example, see this BBC article (Cavity wall insulation ‘a scandal’, Arfon MP claims) from April 2017.

In addition, there is a group called the Cavity Insulation Victims Alliance which helps to support those affected.

3 Which? Cavity wall insulation: damp problems [accessed 29 November 2018]

6 Q&A Cavity Wall Insulation

2. Consumer redress

2.1 Background This section is concerned with consumers who have entered into CWI agreements. Consumer complaints tend to focus on: faulty product or installation; mis-selling; or the difficulty of accessing a guarantee in circumstances where the installer is no longer trading.

In any CWI issue, the consumer should have to hand copies of all relevant documentation. Questions that a consumer should be thinking about include:

• Who installed the CWI and are they still in business?

• Is there a valid guarantee?

• Who would be making the claim? The original contract would have been between the CWI installers and the homeowners at the time, but the property may have been sold on many times. It should be noted that most CWI guarantees are automatically transferred after the sale of a property, regardless of whether documentation changed hands between the seller and buyer.

• Has the property been adequately maintained? Have any alterations or extensions been undertaken?

There is no regulator of CWI; Ofgem (the energy regulator) does not regulate the cavity wall installation industry. Ofgem has no oversight of the contractual arrangements between the energy companies and those organisations that install energy efficiency measures on their behalf.

If a large sum of money is involved in removing or replacing CWI, a complainant might wish to seek proper legal advice based on a full appraisal of the facts. In addition to a solicitor, advice might be sought from their local Citizens Advice Bureau (CAB) (see below). The Library’s briefing paper, Legal help: where to go and how to pay (CBP 3207) may also be relevant.

2.2 How to make a complaint? There are several steps involved in pursuing a complaint.

• The first step is for the consumer to find all relevant documents and contact the installer responsible for the work. If the insulation was installed under schemes such as the Energy Company Obligation, the consumer can contact their energy supplier to ask for details of their installation.

• If the installer hasn’t (or wasn’t able to) resolve the issue, then the consumer’s second step is to contact the relevant oversight body, as they may also be a part of an accreditation and/or certification body, and/or trade association that maintains industry standards.4 For example, the National Insulation Association has its own procedures for complaints against registered members. If installed

4 All installers must be registered by a certification body to be eligible under the Energy

Company Obligation Scheme

7 Commons Library Briefing, 8 January 2019

under the Green Deal, details of an installers’ certification body might be found by searching the Green Deal Oversight & Registration Body website.

• Matters become more complicated if the installer has gone out of business. In this case, the constituent’s third step is to check the documentation to see if the CWI was covered by a guarantee (see Section 3 below on how to complain to the guarantee agency).

• According to Ofgem, if the consumer knows who the guarantee provider is but is unable to get in touch with them, they could contact the Financial Ombudsman Service (FOS). The FOS is a statutory body set up to resolve individual complaints between financial businesses and their customers.

• If, after taken all three steps, the consumer remains dissatisfied, they could contact the Consumer Ombudsman (CO). The CO is an independent body that can (in certain circumstances) investigate disputes where there is evidence of consumer detriment. However, this is only relevant for complaints about goods or services purchased after 1 January 2015.

• The consumer’s complaint might also be referred to independent arbitration. If the dispute remains unresolved, the installer (or the guarantee provider) might be able to provide the consumer with details of an alternative dispute resolution (ADR) body, relevant to their sector and the nature of the specific complaint. The aim of ADR is to provide an easier, quicker and cheaper settlement than court proceedings.

It should be noted that the Consumer Rights Act 2015, requires all tradesmen supplying goods or services to provide a simple and low-cost resolution service should things go wrong. However, the provision does not have retrospective effect and a trader cannot be compelled to use ADR.

8 Q&A Cavity Wall Insulation

3. Cavity wall insulation guarantees

A CWI guarantee is designed to put things right for consumers if something covered by the guarantee goes wrong, and when the installation firm itself is not able to provide redress.

In some cases, guarantees may not be applicable if the damage is not thought to be linked to the CWI, but is instead a more general property issue, for example linked to poor maintenance of the property or condensation. In addition, some guarantees are only valid if the consumer can meet certain criteria.

It is important to note that rights under any guarantee are in addition to a consumer’s statutory rights against the trader under both the Consumer Rights Act 2015 and Supply of Goods and Services Act 1982 (see section 4).

3.1 What is CIGA? There are a number of agencies providing guarantees for CWI. One of the main organisations is the Cavity Insulation Guarantee Agency (CIGA), who provide 25 year guarantees for CWI fitted by CIGA registered installers. All registered members of CIGA are assessed for competence and must follow the technical guidance for the material used and CIGA Best Practice Guidance.

How to make a complaint to CIGA? The Cavity Insulation Guarantee Agency (CIGA) has a published complaints procedure which aims to settle disputes directly with the CIGA member. The CIGA member is invited to investigate the complaint, report their findings and if required, suggest a solution. If any proposed solution does not satisfy the customer, then CIGA itself may investigate and offer a conclusion and advice to the customer.

CIGA say they will respond to concerns, even if the installer is no longer trading. Further information on the process is available from the CIGA webpage on ‘How to report a concern’.

What if CIGA don’t resolve the problem? In cases where a customer is not happy with the outcome of a decision, the CIGA consumer complaint procedure allows the party complaining to refer any appeal against their decision to an independent arbitrator within 12 months. The independent arbitrator in this case is the Centre for Effective Dispute Resolution (CEDR). The CEDR webpage states that their final decision is legally binding:

Arbitration is a formal, legally binding process where the dispute is resolved by the decision of a nominated third party called an arbitrator. Once the arbitrator issues their award it is legally binding under the Arbitration Act of 1996 and can only be appealed in the courts on very limited grounds.

9 Commons Library Briefing, 8 January 2019

The CEDR webpage also has Guidance for Consumers and Arbitration rules.

In May 2015, CIGA employed a new Consumer Champion as part of the ‘Change Programme’ to improve the way CIGA worked with customers. In June 2015, the champion launched a review into the way that CIGA and its registered installers handle consumer complaints about CWI. The review was published in December 2015 and CIGA also published a response in December 2015, accepting all of the proposals.

In addition to specific targets, the Change Programme led to CIGA publishing annual reviews. Their 2018 review has the most up to date information on their plans for case resolution.

3.2 Are there other possible guarantees? Insulation standards are set by the British Board of Agrément (BBA). The BBA is an independent non-profit body which conducts testing, inspection and certification services. They also have a complaints page which states:

If you have a complaint about a BBA certified product or a BBA approved installer we recommend that you first contact the company that either sold or installed the product. If you do not receive a satisfactory response, as part of our monitoring role, we will assist by taking the matter up directly with the certificate holder or BBA approved installer. We will investigate product or installer performance and compare this with the published Certificate or Installer Scheme. What we cannot do is resolve individual complaints or provide arbitration.

The National Insulation Association (NIA) is an industry trade body whose members sign up to a Code of Professional Practice. Not all insulation installers are members of the NIA and therefore some installers do not follow this code. The code of practice covers installation, complaints and guarantees. The Code states:

If you think a company has broken the code, you should complain to them first. They must have a written complaints procedure in place. All our members work to the highest level of customer care and will try their best to sort out your complaint.

In addition, the NIA have a complaints procedure if a consumer thinks an installer has broken the code. The complaints page of their website states:

The purpose of this procedure is to assist consumers who have a query in relation to the workmanship or service that has been carried out by a member of the National Insulation Association.

The National Insulation Association are unable to resolve complaints between consumers and a member company directly but will mediate between both parties to obtain a satisfactory resolve.

10 Q&A Cavity Wall Insulation

4. Consumer legislation A consumer who has a problem with CWI will want to know what their rights are. This is a difficult question to answer and would require proper legal advice. Set out below is key consumer legislation but its relevance, in respect of a CWI claim, would depend on the terms of any written agreement, any representation made, and the facts of the case. It follows from this that other legislation may also be relevant.

4.1 Consumer Rights Act 2015 & Supply of Goods and Services Act 1982

The main provisions of the Consumer Rights Act 2015 (“the CRA 2015”) are set out in the Library’s briefing paper, Consumer Rights Act 2015 (CBP 6588). Specifically, page 14 of this Paper deals with faulty goods (including faulty installation materials) and page 15 deals with faulty services (including faulty CWI).

The CRA 2015 came into force on 1 October 2015 and does not have retrospective effect. This means that if a consumer’s complaint is about CWI undertaken before 1 October 2015, then they will have to rely on the Supply of Goods and Services Act 1982 (“the SOGASA 1982”) as amended by the Sale and Supply of Goods to Consumer Regulations 2002.

The SOGASA 1982 applies different standards to the two halves of the contractual obligation. On the first half (i.e. the provision of the building materials) there is strict liability under section 4 in respect of quality and fitness for purpose of the goods supplied. The goods must be:

• of satisfactory quality;

• fit for its purpose; and

• as described

In respect of the second half of the contract (i.e. the provision of work) there is an implied duty to:

• carry out the work with reasonable care and skill; and

• finish the work within a reasonable time unless a specific date for completion has been agreed

The 2002 Regulations amended the SOGASA 1982 by adding a provision that manufacturers’ guarantees are a contract between consumers and manufacturers.

If a trader’s workmanship is unacceptable, they may be in breach of the implied terms of the contract (legal advice should be sought). Normally, the consumer would make a formal complaint to the trader and offer them the opportunity to solve the problems. If the trader cannot repair the faults properly, the consumer may be entitled to compensation (much would depend on the facts). However, this may involve legal proceedings.

11 Commons Library Briefing, 8 January 2019

The crucial point to note is that a consumer’s statutory rights against a trader under both the CRA 2015 and SOGSA 1982 apply irrespective of whether there is a valid guarantee.

4.2 Consumer Protection from Unfair Trading Regulations 2008

There is a duty on businesses to trade fairly. This duty applies to all businesses, including one involved in CWI.

In brief, the Consumer Protection from Unfair Trading Regulations 2008 (“the CPRs”), prohibit traders in all sectors from engaging in unfair commercial practices (mainly marketing and selling) against consumers and set out rules that determine when commercial practices are unfair. Traders are expected to act honestly and fairly towards their customers. Unfair or misleading trading practices, aggressive selling and misleading omissions are all covered by the CPRs. There are three main sections in the CPRs 2008, these are as follows:

• A general ban on unfair commercial practices.

• Misleading and aggressive practices are assessed in light of the effect they have, or are likely to have, on the average consumer.

• A ‘black list’ of those practices which are unfair and thus banned. In other words, in addition to tackling misleading and aggressive behaviour in general, the 2008 Regulations prohibit 31 specific practices.

In practice, if a trader is accused of misleading consumers (e.g. on the suitability of a property for CWI), it is not enough to simply demonstrate the activity. It also must be shown that the practice influenced the consumer's decision. This doesn't necessarily mean that the consumer must have entered into a contract, just that their actions were influenced in some way.

The 2008 Regulations are enforced by Trading Standards.

On 1 October 2014, amendments were made to the 2008 Regulations to give consumers new rights of redress if they have been the victim of misleading actions or aggressive selling. The amendments were made by the Consumer Protection (Amendment) Regulations 2014. The new redress rights break down into three key areas:

• A right to undo the contract – the consumer may be able to end the contract (without penalty). To get a refund the consumer would have to exercise their right to unwind the contract not more than 90 days from when they received the goods.

• A right to a discount on the price paid – the consumer may be able to seek a discount in respect of past or future payments due under a contract. Much would turn on whether the trader's breach is minor, significant, serious or very serious.

• An entitlement to seek damages - if the consumer incurs a financial loss that he/she wouldn't have done if it weren't for the trader's actions, the consumer may be able to make a claim for damages.

12 Q&A Cavity Wall Insulation

4.3 Contract law and misrepresentation Some consumers complain about the mis-selling of CWI. Whether they have grounds for making a claim for breach of contract or misrepresentation under common law or the Misrepresentation Act 1967 (“the MA 1967”) would depend on the facts of the case. Again, detailed legal advice should be sought.

In very general terms, a misrepresentation is a statement of fact (not opinion) which is made by a seller before a contract is made. If the consumer relied on that statement when deciding whether to go ahead with the purchase, and this then turns out to be wrong, he/she may be able to claim rescission and/or compensation.

There are three types of misrepresentation. A consumer’s right to redress will depend upon whether the false statement was made fraudulently, negligently, or innocently:

• “Fraudulent misrepresentation” is where a false representation has been made knowingly, or without belief in its truth, or recklessly as to its truth.

• There is “negligent misrepresentation” under the MA 1967 where a statement is made carelessly or without reasonable grounds for believing it’s truth.

• “Innocent misrepresentation” is a false representation that is neither fraudulent nor negligent.

The general remedy for misrepresentation is rescission, this means cancelling or unwinding the contract so that both parties are put back in the position they were in before they made the contract. Damages may also be available in some circumstances, either in addition to or as an alternative to unwinding the contract.5

The availability of the different remedies is largely determined by the type of representation and at what point the consumer discovers the misrepresentation. A bar to ending a contract is if too much time has lapsed from the consumer first discovering the false statement. If this is the case, then it may be evidence of the consumer having accepted the position and may be grounds for rejecting a claim for rescission. Obviously, much would turn on the facts of the case, and would require legal advice.

Finally, if a consumer used a credit card to purchase CWI (in whole or in part), they may be able to pursue a claim against the credit card provider. Under section 75 of the Consumer Credit Act 1974 (CCA 1974), a credit card provider is jointly and severally liable for any breach of contract or misrepresentation by the retailer or trader. This is particularly useful in circumstances where the trader has gone out of business. However, certain limitations apply to section 75, namely:

• The goods or service bought must have cost over £100 and not more than £30,000. (The credit card company may still be liable even if only part payment was made using the card. It is the value

5 Section 2(2) of the Misrepresentation act 1967

13 Commons Library Briefing, 8 January 2019

of the good or service the consumer has paid that is key, not the amount paid on the card).

• The credit card provider and the seller of the goods or service must be different parties. Section 75 will not apply if the lender is also the supplier.

• Section 75 applies only to credit cards (not debit cards).

In respect of CWI complaints, it is fair to say that section 75 is limited in its usefulness. This is because a claim under section 75 must generally be brought within 6 years of buying the service.

14 Q&A Cavity Wall Insulation

5. Parliamentary debate There is no Government compensation scheme for problems with CWI. However, the issues with CWI have been raised in Parliament several times.

5.1 Parliamentary questions In December 2017, Grahame Morris MP asked a number of questions relating to CWI, for example on 5 December 2017 he asked:

Grahame Morris: To ask the Secretary of State for Business, Energy and Industrial Strategy, if he will introduce an independent dispute mechanism for consumers related to companies which have installed defective or unsuitable cavity wall insulation.

Claire Perry: The Cavity Insulation Guarantee Agency (CIGA) is one of the main organisations providing consumer guarantees for cavity wall insulation installations and it has a complaints process including an independent dispute mechanism for consumers where cavity wall insulation may be defective.

Each Home Counts was an independent review, led by Dr. Peter Bonfield, which published its report in December 2016. Implementation of Each Home Counts is being led by industry with the support of Government, in line with the recommendations of the review.

One of the main recommendations from the Review was to establish a quality mark for retrofit energy efficiency and renewable energy measures including cavity wall insulation, and for companies operating in this sector. Those who wish to use the quality mark will need to adhere to a consumer charter and code of conduct, which will ensure all consumers have access to a clear redress process and guarantee protection.6

Mr. Morris also asked about spending on CWI7 and “sub-standard and faulty” CWI.8

In addition, Nick Thomas-Symonds MP asked about sales practices in October 2018 (178331):

Nick Thomas-Symonds: To ask the Secretary of State for Business, Energy and Industrial Strategy, whether he plans to bring forward legislative proposals for compulsory training to tackle the way companies sell cavity wall insulation to vulnerable people; and if he will make a statement.

Claire Perry: There are currently no plans to bring in new legislation relating to selling to vulnerable consumers. Trading Standards Officers can already take action against salesmen who use misleading practices and aggressive pressure selling, such as those that might be used by a seller seeking to exploit the elderly and disabled. Since the implementation of the Consumer Protection (Amendment) Regulations 2014 consumers have been able to take action against such traders to get their money back.

Beyond these regulations, my Department is working with industry to improve consumer protection for cavity wall insulation

6 PQ117684, Insulation: Housing, 5 December 2017 7 PQ 117682, Insulation: Housing, 5 December 2017 8 PQ 117835, Housing: Insulation, 6 December 2017

15 Commons Library Briefing, 8 January 2019

and other energy efficiency work by developing new standards and launching a more robust government endorsed quality scheme through TrustMark. This reflects the recommendations of the independent Each Home Counts review, which identified an important need for an independent, all-encompassing mark of quality that consumers can rely upon and trust.

The new quality scheme will be underpinned by rigorous standards and a code of conduct to tackle mis-selling, poor design and installation. This is a voluntary scheme for registered business delivering to households under the existing Government endorsed TrustMark scheme, but Government wants to encourage consumers to choose these trusted traders and for business to get on-board. In future, we intend to incorporate the quality mark as a requirement of Government schemes such as the Energy Company Obligation (ECO).9

5.2 Debates • There was a debate on Home Insulation (vol 648) on 24 October

2018 which focused on specific problems with solid wall insulation installed under the Community Energy Saving Programme in the Fishwick are of Preston.

• Similarly, on 23 October 2018, there was a debate on HELMS and the Green Deal (vol 648) which focused on the insulation and solar panel issues resulting from a specific installer (HELMS) under the Green Deal Scheme.

• There was a debate on Cavity Wall Insulation: Wales (vol 624) on 19 April 2017.

• There was also an earlier debate on Cavity Wall insulation (vol 592) on 3 February 2015.

5.3 Reviews In the October 2018 PQ, the Minister for Clean Growth Claire Perry pointed to the Each Home Counts review published on 16 December 2016. This was an independent review on consumer advice and protection related to home energy efficiency and renewable energy measures. On cavity wall insulation, the review states:

About 5.5 million homes in Great Britain lack cavity wall insulation and 92% of solid walled homes are uninsulated. This may offer opportunities for industry to deliver huge numbers of installations over the coming years. Quantity must not be achieved at the expense of quality or consumer protection. In fact, poor quality installations can cause bigger issues than the problems they seek to solve, potentially creating detrimental health impacts on occupants, possible property damage, short-term remedial costs, and longer-term damage to the industry’s reputation and consumer trust.10

In the next stage, industry will develop detailed plans to implement the vision set out in the report. A website on the Each Home Counts review has been set up that provides updates on progress and implementation.

9 PQ 178331, Insulation: Sales Methods, 11 October 2018 10 The Bonfield Review, Each Home Counts, 2016, page 9

16 Q&A Cavity Wall Insulation

According to the review:

The British Board of Agrément (BBA) and CIGA, the leading guarantee provider for cavity wall insulation installations, have launched a scheme. The scheme requires property assessments to be independently reviewed for compliance with industry specifications to ensure that cavity wall insulation installations are only carried out on suitable properties. The pilot scheme commences in January 2017, with a full introduction in April 2017.11

Some of the recommendations in the review have been incorporated into updated industry standards. Publicly Available Specifications (PAS) are industry standards produced collaboratively by key stakeholders. They are prepared following guidelines set out by BSI (British Standards Institution).

Following the Each Home Counts review, a new PAS 2030:17 was published in April 2017. This included new requirements for pre-installation building surveys and inspections. The BBA12 and CIGA13 have launched schemes to ensure that the PAS requirements are met, and that reviews of property suitability for insulation are independently assessed. This is intended to reduce cavity wall insulation being installed in inappropriate properties.14

The Each Home Counts Review Implementation Board is also developing a quality mark, code of conduct, and customer charter in collaboration with industry and Government.

11 The Bonfield Review, Each Home Counts, 2016, page 26 12 BBA, Cavity Assessment Surveillance Scheme (accessed 2 January 2018) 13 CIGA, Independent Surveillance of Assessments (accessed 2 January 2018) 14 BBA, Cavity Assessment Surveillance Scheme (accessed 2 January 2018)

17 Commons Library Briefing, 8 January 2019

6. Where to go for further help The Government funded Energy Saving Trust provide free and impartial advice.

Citizens Advice (a government funded advice group) have a webpage on problems with building work, decorating or home improvements . The Citizens advice consumer helpline may also be able to help, or they can be contacted online. Citizens Advice can refer matters to Trading Standards, who will then decide whether to take on the case.

Constituents may wish to consider professional legal advice. The Library Briefing Paper on Legal Help: where to go and how to pay, may be of interest.

BRIEFING PAPER Number 8471 8 January 2019

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