RAAC and school collapse risks: DfE guidance
The revelation that more than 150 schools around England have been identified as being at risk of collapse due to the use of reinforced autoclaved aerated concrete (RAAC) and will potentially need to close, or partially close, until the problem is fixed was probably not the start of term that many expected.
Yet the risk from RAAC is not new and today’s guidance for schools had been expected at some point after the Department for Education began a process of working with schools to identify those with RAAC in their buildings.
Given that the DfE guidance notes that this year there have already been “a small number of cases where RAAC failed with no warning”, it is clear that this is an issue schools must take seriously. So what does the new guidance say? And what should schools do if they suspect they have RAAC in their buildings?
School buildings guidance on RAAC risk
1. Prepare to vacate
If a school is told by a DfE case worker that it has RAAC then action must be taken. This will require the school, college or nursery to “vacate and restrict access to the spaces with RAAC and ensure that they are out of use”.
The DfE says that if the area impacted is only small then schools can hopefully use the rest of their estate to provide education as normal.
It also says schools can use “structural supports to make safe areas with RAAC”, where it is possible to do so, and that a case worker can advise on this.
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2. Alternative accommodation
However, if the closure of buildings means there is “insufficient accommodation” across the rest of the estate then schools can use emergency accommodation or temporary accommodation for the first few weeks until the building has been made safe.
Classroom and other facilities, such as sports facilities, can be relocated in either:
- A nearby school, college or nursery that the school can use for a period of time.
- Semi-rigid temporary structures that can quickly be brought in.
- A space in a community centre or empty local office building.
3. What if you don’t know whether you have RAAC?
Many schools will still be waiting for a DfE survey to confirm whether they have RAAC. For these, the advice is to put together a contingency plan in case it is confirmed.
Those that have already filled in the questionnaire that can lead to a visit should wait to be contacted.
Anyone who has not yet filled in the questionnaire but suspects their site does have RAAC - or are unsure - is advised to fill the questionnaire in as soon as possible here.
4. Funding issues
The guidance confirms that any mitigation works that are capital-funded will be covered by the DfE.
However, local authorities or trusts, or non-maintained nurseries, will have to use their own funding to cover any additional revenue costs, such as rental costs for emergency or temporary accommodation or additional transport costs if pupils have to travel elsewhere.
Any setting with a commercial insurance provider should talk to them about covering this work, or consult the Risk Protection Arrangement (RPA) if it is a member.
5. Business as usual where possible
While the impact of closing areas of a school, or a whole school, are huge, the guidance says schools should consider the “educational, safeguarding and wellbeing impacts for pupils and students before taking any mitigating actions”.
This includes ensuring that you follow “any statutory safeguarding guidance that applies to you and your setting” and ensuring that “face-to-face, high-quality education to all pupils and students” continues.
The guidance says schools should consider a ”whole-institution approach to safeguarding” as part of any risk assessments to ensure that any changes to how the school is run during disruptions caused by closures do not undermine children protection policies.
It also says school meals, extracurricular activities and wrap-around care should continue as normal whenever possible, but if RAAC issues force closures that impact these areas, schools should consider alternative arrangements, such as by using other areas of the school or other nearby venues.
6. Remote education
While it stresses that this should only be a last resort, the DfE says schools can use remote education if required to maintain education. It adds that experience gained in the pandemic will help with this.
The DfE does advise, though, that any remote-education policies from the pandemic should be reviewed to ensure they are still relevant - and again, it reiterates that children should return to face-to-face education at the earliest possible moment.
7. Exams contingencies
Although exam season is over, schools will still face assessments this term, such as the Reception Baseline Assessment in primary schools, and resits in late autumn, such as for English and Maths GCSEs.
The guidance says schools must have plans in place for exams in case their usual venues are out of action, as per usual emergency planning guidance. It adds that this should be revised to ensure that it remains relevant amid the ongoing RAAC situation.
8. Ofsted inspections
The guidance document confirms that the DfE is “working closely with Ofsted” about how RAAC is impacting schools, so this information can be taken into account for the watchdog’s inspection schedule.
If a school does receive notification of an inspection but is facing restricted attendance, or substantial disruption due to RAAC, it is advised to contact the lead inspector at Ofsted and discuss its deferral options under the heading of “exceptional circumstances”.
9. Special school and AP advice
The document also details what special schools and alternative provision settings should do - with the advice chiefly that leaders in these settings will know best and can liaise with a DfE case worker for additional support.
“If pupils or students in a special school need to be taught in emergency or temporary accommodation, school leaders and staff are best placed to know how their needs can most effectively continue to be met,” the guidance says.
Furthermore, if the pupils affected have an education, health and care plan (EHCP), the setting must inform the body that commissioned the EHCP - likely the local authority - about the impact on their education so they can be involved in mitigating the impact, too.
“The responsible commissioner will need to consider the impact and duration of the disruption and whether alternative arrangements should be made in the short or long term,” the guidance states.
Regardless of the impact, the guidance also states that pupil access to any specialised healthcare workers, such as speech and language therapists, physiotherapists, occupational therapists, educational psychologists and specialist teachers, should continue as usual.
If, as a last resort, a pupil is required to remain at home due to any closure then there must be multi-agency collaboration to decide how to deliver the EHCP, including visits at home or video or telephone calls.
10. Boarding schools
Any boarding school that is affected by RAAC must also have a plan to ensure that pupils can either be moved to alternative accommodation or parents can be contacted in order to “consider alternative boarding and educational arrangements”.
11. Recording absences
Finally, the DfE guidance acknowledges that some schools may choose to tell some pupils not to attend in order to facilitate the on-site education of others.
If so, then schools can use the Y code to record these pupils as “unable to attend due to exceptional circumstances” - which does not count towards the pupil’s or school’s absence record.
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