RAAC and Structural Safety in Schools

The issue of reinforced autoclaved aerated concrete, commonly known as RAAC, has changed how structural safety is understood within school premises management. While structural integrity has always sat within the general duty to maintain safe premises, the response to RAAC has effectively introduced a new and more explicit compliance expectation. Structural safety is no longer treated as a background estates issue. It is now a front line safeguarding responsibility.

The Legal Position on Structural Safety

Under the Health and Safety at Work etc. Act 1974, duty holders must ensure that workplaces are maintained in a condition that is safe and without risks to health and safety. This overarching duty applies equally to structural elements of buildings. Where a structural risk is known or suspected, there is a clear legal expectation that it is addressed. The HSE has long been clear that risks arising from the condition of premises must be identified, assessed and controlled, including where those risks arise from building fabric or structure (HSE). What has changed with RAAC is not the law itself, but how that duty is being interpreted and enforced in practice.

RAAC as a Compliance Issue

RAAC has moved structural safety from a condition management issue into a monitored compliance category. The Department for Education has taken a central role by issuing specific guidance to schools and responsible bodies. Where RAAC is suspected or confirmed, schools are instructed to take immediate action to prevent any risk to occupants (DfE). This includes:

• Restricting access to affected areas
• Implementing temporary mitigation such as propping
• Commissioning further surveys and engineering advice
• Planning for long term remediation such as roof replacement

Unlike many other premises risks, the expectation is not to manage RAAC through monitoring alone.

Identification and Survey Requirements

As part of a national identification programme, the DfE required responsible bodies to assess whether RAAC was present across their estates. By 2025, every responsible body was expected to have completed a RAAC survey and submitted information to the DfE where RAAC was suspected or identified (DfE). This marked a significant shift. Structural surveys moved from good practice to a defined expectation, supported by national oversight. Where RAAC is identified, schools are required to report this via a dedicated DfE process and follow prescribed guidance.

The Zero Risk Approach

In August 2023, the DfE adopted a zero risk position on RAAC. The guidance makes clear that where RAAC is confirmed, affected spaces should not be used unless mitigation or remediation is in place, regardless of whether the element appears to be in acceptable condition (DfE). This represents a departure from previous approaches where some structural risks might have been tolerated under monitoring regimes if engineers assessed the risk as low. For RAAC, the expectation is hazard removal or isolation, not continued occupation. This effectively raises the bar for duty holders and sets a precedent for how other structural risks may be treated in future.

Monitoring and Oversight

The DfE has confirmed that it is actively tracking schools affected by RAAC to ensure that mitigation measures remain in place and that longer term solutions are planned. Funding has been made available to support immediate safety works, reinforcing the expectation that risk control must not be delayed due to cost concerns (DfE). This level of central oversight is unusual in premises management and underlines the seriousness with which RAAC is being treated.

Implications for Wider Structural Compliance

RAAC has highlighted a broader issue. Structural safety cannot sit outside routine compliance arrangements. Going forward, schools should expect increased scrutiny of:

• Building condition data
• Structural surveys and inspection cycles
• Interim control measures
• Decision making and escalation routes

The National Audit Office has already raised concerns about ageing school buildings, incomplete condition information and the risks associated with deferred maintenance (NAO). RAAC may not be the last structural issue to receive this level of attention. Other construction methods and ageing systems may follow.

Integrating Structural Safety Into Compliance Systems

For schools and responsible bodies, the lesson from RAAC is clear. Structural safety should be embedded within estates and compliance frameworks, not treated as an occasional capital issue. This includes:

• Periodic condition surveys by competent professionals
• Prompt investigation of cracks, movement or deterioration
• Clear records of inspections and advice received
• Documented decisions and interim controls
• Oversight by leadership and governors

Where construction or refurbishment work is undertaken, compliance with Building Regulations and associated guidance remains essential. This includes ensuring structural and fire safety standards are met through appropriate professional input (DfE).

The Role of NASPM

NASPM supports schools and responsible bodies to understand how emerging risks such as RAAC sit within existing legal duties and compliance expectations. This includes helping premises professionals and leaders interpret guidance, structure records, and prepare for inspection, audit and external scrutiny. RAAC has demonstrated that structural safety is no longer an implicit assumption. It is an explicit responsibility.

Sources

• Health and Safety Executive, Managing Health and Safety in Schools, HSE https://www.hse.gov.uk/services/education/schools.htm
• Department for Education, Reinforced Autoclaved Aerated Concrete in Education Settings, GOV.UK https://www.gov.uk/government/collections/reinforced-autoclaved-aerated-concrete-raac
• Department for Education, Identification of RAAC in Schools and Colleges, GOV.UK https://www.gov.uk/government/publications/identification-of-raac-in-schools-and-colleges
• Department for Education, Guidance on Managing RAAC in Education Settings, GOV.UK https://www.gov.uk/government/publications/guidance-on-managing-raac-in-education-settings
• National Audit Office, Condition of School Buildings, NAO, 2023 https://www.nao.org.uk/reports/condition-of-school-buildings/