Thermostatic mixing valve campaign

On April 6, 2010, the amendments to The Building Regulations 2000, Approved Document G – Sanitation, hot water safety and water efficiency, which were originally due to be introduced in October 2009, finally came into effect.

The postponement happened after the European Commission issued a "detailed opinion" on the draft document, under a Directive which gave the Commission and Member States the opportunity to comment on whether a proposed regulation has the potential to create a technical barrier to trade.

A communication from the Department for Communities and Local Government (DCLG) said: "The Department is required under the Technical Standards Directive (98/34/EC) to notify the European Commission of the guidance contained in the draft Approved Document G. On 3 September we received a "detailed opinion" from the Commission with a number of comments on the draft Approved Document. This creates a three month standstill period which prohibits us from introducing the final Approved Document before 2 December 2009."

The Royal Society for the Prevention of Accidents has welcomed victory in a long-fought campaign to prevent horrific bath water scalds in homes across the UK.

An amendment to the Building Regulations means that all new-build homes across England and Wales will have devices fitted to baths to limit the temperature of the water to 48°C. That temperature is still more than hot enough for domestic use, but it removes the potential for the most serious scald injuries to happen. Northern Ireland will also adopt the amendment, but at a slightly later date. The move comes three years after such devices - called thermostatic mixing valves (TMVs) - became a requirement in new homes in Scotland.

The change, which was announced by housing minister Iain Wright, proves that sustained campaigning on home safety can bring about results that will have a real impact on saving lives and reducing injuries.

It also shows the value of organisations with a common interest working together.

The campaign

TMVs blend hot water, which is heated before use to a temperature of 60°C or above in order to kill legionella bacteria, with cold water to ensure water comes out of the tap at a safe temperature.

Already commonly used in showers, as well as in baths in hospitals and care homes, it has proved harder to raise awareness of the need for TMVs in baths in people's own homes, even though that is where the most severe scald injuries happen.

RoSPA had called for a number of years for TMVs to be fitted in homes across the UK. can take a matter of seconds for the injury to be sustained, but the suffering can endure for many, many years.

Action on hot water safety was needed in light of accident figures which showed that nearly 600 people were suffering the devastating and enduring effects of a severe scald injury in the UK each year. Three-quarters of the victims were under the age of five-years-old.

Older people were shown to be at particular risk of dying as a result of hot tap-water scalds, with an average of 15 pensioners dying each year as a result of such accidents. In fact, the latest mortality figures show that, in 2007, 21 people died in the UK after contact with hot tap-water, of whom 14 were over the age of 65.

Tom Mullarkey, RoSPA chief executive, said: "Young children and older people are most at risk from bath water scalds because their skin is thinner and therefore less able to withstand higher water temperatures than other age groups. Because of this, they can suffer a scald more quickly, at lower water temperatures, and often the burn is much deeper.

"We have heard of cases in which young children have fallen into hot baths or in which they have been left alone in the bath and have turned on the hot tap, unable to turn it off again. Sometimes their parents had left them alone for just a matter of minutes, perhaps to get clean clothes or a towel. We also know that older people have been severely scalded when they have got into a bath that has been too hot and have been unable to climb out quickly.

"What is particularly poignant about a serious scald is that it can take a matter of seconds for the injury to be sustained, but the suffering can endure for many, many years. In water at 60°C, for example, a child could suffer a third-degree burn in just one-and-a-half seconds. Some children require numerous skin grafts as they grow, and the lifetime costs of treating a scald have been put at £250,000."

In 2003, the fitting of TMVs was among 10 recommendations in RoSPA's pioneering policy document, called "Can the home ever be safe?" (PDF 455kb)

The document recommended measures which could be included in the design and construction of new homes, as well as at the time of refurbishment. It was based on the principle that including a package of simple safety measures in new homes would have colossal payback potential in terms of cost savings for the NHS.

Such a cost-saving potential has remained a key theme of the campaign to have TMVs fitted as standard in new homes.

In 2004, the campaign received a boost when the Office of the Deputy Prime Minister announced it was to consult on bringing water temperature safety within the scope of the Building Regulations. RoSPA welcomed the announcement, stating that thermostatically-controlled bath taps could "end needless pain and suffering faced by hundreds of children each year". National and regional radio stations and newspapers picked up the story.

It was hoped that new rules on bath taps would be implemented by 2006, although, in line with "Can the home ever be safe?", RoSPA continued to press developers to include TMVs in new properties and conversions before a regulatory amendment.

However, although a regulatory change was introduced in Scotland in 2006, the rest of the UK didn't follow suit.

The campaign, therefore, continued in earnest.

The campaign gains momentum

Mary Creagh MP.

Mary Creagh MP, speaking at the
RoSPA Home Safety Congress 2006.

In 2006, RoSPA became a member of the Hot Water Burns Like Fire campaign which was set up specifically to focus attention on the issue. The campaign, launched by Mary Creagh, MP for Wakefield, brought together a range of organisations, which also included the Children's Fire and Burn Trust, the British Burn Association, older people's charities, the Child Accident Prevention Trust and trade associations, to work on the issue.

In the same year, the prevention of burns and scalds featured strongly on the programme at RoSPA's National Home Safety Congress, and in 2007, RoSPA and Home Accident Prevention Northern Ireland launched the Hot Water Burns Like Fire campaign in Northern Ireland. Excellent media coverage of the launch was made possible by the willingness of a Newtownards mother to speak about a hot bath water accident in which her son was severely scalded.

Also in 2007, the effort to raise awareness of TMVs and hot water safety in general was designated RoSPA's "key campaign". Around 3,000 guests at gala dinners held as part of RoSPA's Occupational Safety and Health Awards heard about the campaign. There was interest immediately after one of the presentations, including from a Bahraini managing director who was keen to call for TMVs to become compulsory in Bahrain.

Tom Mullarkey said: "Addressing thousands of representatives of RoSPA Award-winning organisations about the importance of TMVs was too good an opportunity to miss.

"We were thrilled with how the presentations were received, and particularly that the campaign even struck a chord with our overseas guests."

Parliamentary developments

Amanda Redman, Holly Devonport, and Mary Creagh MP.

Amanda Redman, Holly Devonport,
and Mary Creagh MP.

Mary Creagh was the lynchpin of efforts to get hot bath water scalds taken seriously in Parliament after the issue came to her attention in 2006.

Her subsequent contact with the burns unit at Pinderfields General Hospital and Holly Devonport, who was five-years-old when she was severely scalded after falling into a hot bath, were the catalysts behind her commitment to the campaign.

She said: "I was horrified to learn that 600 people a year were getting third degree burns over a significant part of their bodies and that three-quarters of them were children under the age of five.

"These are life-time injuries, occurring on the hands, head, scalp, legs, buttocks. They have devastating effects.

"I just decided that I was going to change things. I do not give up very easily and I do not take 'no' for an answer. I had to overcome a lot of scepticism among my parliamentary colleagues – they thought it was trivial and did not see the nature and extent of injuries."

In 2006, Mary used the opportunity provided by a House of Commons' 10-Minute Rule Bill to call for a change to the Building Regulations. During the session, she outlined the human costs of a severe scald, but also the economic justifications, citing that a one-off payment of £80 was needed to buy a TMV, but £150million could be saved to the NHS in a single year if severe bath water scalds were eradicated.

A conference at Parliament and then a photocall featuring Holly and actress Amanda Redman, who also suffered a scald as a child, attracted further attention among her parliamentary colleagues and the media.

"The media angle began to change," recalled Mary. "It went from being about the 'nanny state' to preventing senseless injuries to young children."

Last year, Mary asked a question of the Prime Minister and entered into a Westminster Hall debate with minister Iain Wright.


Thermostatic Mixing Valve.

Thermostatic Mixing Valve
Used with kind permission of
Reliance Water Controls Ltd.

A golden opportunity to make the detailed case for TMVs was presented when a consultation on proposed amendments to Part G of The Building Regulations 2000, the section which includes hot water safety, was published in May 2008.

The consultation provided a glimmer of hope for campaigners, although it did not go as far as they had wanted.

While it stated: "The Government would very much like to support a provision that would help to reduce the risk of scalding incidents from sanitary appliances," it then went on to say: "However, our initial analysis suggests that the cost of requiring the installation of TMVs are considerably out of proportion to the benefits that would be realised, even if we were to only limit the provision to baths in new homes. Unfortunately, this means that it is not currently possible for us to include this provision as a definitive proposal in this document."

The consultation, launched by the Department for Communities and Local Government (DCLG), did, however, call for more information on the likely costs and benefits of installing protective measures such as TMVs. It stated that the department would reconsider its position if evidence changed the analysis of costs and benefits "favourably".

The Hot Water Burns Like Fire campaign rose to the challenge, and detailed costs and benefits of TMVs were researched and included as part of the partners' official response. The crucial point to make was that victims do not recover from a severe scald quickly – its effects can last a lifetime, requiring ongoing treatment such as skin grafts, and causing immense suffering for the victim, as well as their loved ones.

Mary said: "What was critical was getting the NHS and plastic surgeons to establish accurately the true costs – not just of acute hospital treatment, but of the lifetime costs of treating a burn.

"Set against the cost of a tap valve, there was absolutely no economic rationale not to do it [to amend the Building Regulations]."


When Iain Wright made his announcement that the Building Regulations would indeed be amended to require TMVs in new-build homes, it was proof that change really can be achieved when a campaign is based on robust evidence.

Mary's delight with the amendment is well-founded. "The response that the Hot Water Burns Like Fire campaign put together for the consultation was the thing that changed the day - this was our masterpiece," she said. "I am absolutely thrilled.

"What this will do is change plumbing practice and make it [fitting a TMV] the norm. It really is a very big milestone in the home safety campaign and it will bring in a change that will be as significant as putting fuses in electrical appliances."

And she is grateful for the efforts of all the campaign partners, whose work was crucial in maintaining momentum on the issue.

"It was wonderful to work with so many great partners on this issue - so many great partners who have worked for so long," she said. "And, of course, there is Holly. This is 'Holly's law'. It was her courage and willingness to speak out to show the devastation that scalds can cause which resulted in a major shift in attitudes."

Continuing efforts

Even though the long-fought-for regulatory change has now been achieved, efforts to raise awareness of the danger of hot water must continue.

"This is the magic bullet, but it will take 20 years to be fully implemented," said Mary. "We still need to keep up with the messages around hot water safety. People think hot water in a bath is a benign environment. The danger is not noticeable to many people. But some water comes out of bath taps at 70-80 degrees. So the safety messages must continue: never leave children unattended and never put hot water in the bath first. You wouldn't leave your child next to a boiling kettle or a boiling hot cup of tea, but people are simply unaware of the risks that very, very hot baths carry for young children."

...children and older people will be less likely to suffer the horrific and enduring consequences of a hot bath water scald.

For RoSPA, a safety charity which has been campaigning on a range of accident prevention issues for 92 years, the Building Regulations amendment proves that sustained pressure really does pay off.

Tom Mullarkey said: "This has been a long-fought campaign and RoSPA is absolutely delighted that the Government has committed itself to such a positive step forward in home safety. The amended Building Regulations are testament to all the campaign partners who have worked for so long to change attitudes towards hot bath water safety. We particularly thank Mary Creagh for doing so much to bring this issue to attention.

"The change will obviously take time to be implemented, but RoSPA is delighted that, as TMVs begin to become commonplace in UK homes, children and older people will be less likely to suffer the horrific and enduring consequences of a hot bath water scald.

"The regulatory amendment also sends out a clear message: hot bath water is a serious issue. RoSPA will continue to raise awareness of this and share the practical steps that people can take to prevent further cases of needless suffering."