The Building Safety Act and the Golden Thread of Information

If you design, build or manage high risk buildings then the changes from the Building Safety Act and its “Golden Thread of Information” will make you responsible for their safety plans. We take a closer look at what you need to know …

Who can ever forget the horror of the Grenfell Tower fire on our TV screens. It was due in part to a series of errors all contributing to the tragedy. To this day we are still debating who was responsible.

Following on from the “Independent Review of Building Regulations and Fire Safety” review by Dame Judith Hackett, “The Building Safety Act” (BSA) has changed the way that we plan, construct and manage higher risk buildings.
At the heart of this act is a legal obligation for all those involved to be competent to ensure compliance with the Building Regulations in both design and construction. This is for all buildings.

There is also a whole new regulatory framework for high-risk buildings which includes:

• HSE as a statutory consultee for planning applications
• the Building Safety Regulator (HSE) will become the building control authority for high-risk buildings
• duty holders having clearly accountable and statutory responsibilities through design, building, refurbishment and occupation
• a golden thread of information that is identified, stored and updated throughout the building’s life

To enforce this there will be registers of occupied high-rise buildings for building inspectors and building control approvers.

But what does this mean for me?

The BSA will supersede existing regulations and will clarify how high-risk buildings should be constructed and maintained to ensure safety.

These high-risk buildings include those that are:

• 18 metres tall or have at least 7 storeys
• multi-occupied residential buildings
• mixed use buildings with a residential element
• student accommodation
• educational accommodation
• and in the future other buildings where people sleep

If you are involved in the design or build, then you need to know about the Golden Thread of Information and if you are a duty holder then you are responsible for creating and managing this thread.

The Golden Thread of Information

Explaining the concept Dame Judith Hackett states: “There needs to be a golden thread for all complex and high-risk building projects so that the original design intent is preserved and recorded, and… …any changes go through a formal review process involving people who are competent and who understand the key features of the design.”

While at the moment the term “Golden Thread” is not referred to by name, but rather as “prescribed information and documentation which is kept up to date”, we are expecting secondary legislation by the end of 2023 that will do so.

The duty holder responsible for this information thread changes between the design and construction phase and the occupation of the building.

The duty holders during the design and construction will be the principal designer, designers, the principal contractors and the client. The principal designer will have the key role during the design phase of the building. They can be an individual or an organisation, but they must have the skills, knowledge, experience and behaviours across a range of activities.

Typically, it will be an architect, or their organisation, who act as the principal designer and will be responsible for this “golden thread of information”. They need to maintain an account of how the building has been designed and how design decisions were taken that relate to fire and structural safety.

While the designers are responsible for specifying the materials, contractors are responsible for installation so there has to be collaboration and operation of the golden thread through a number of planning gateways.

Planning Gateways

A key part of the regulatory framework for higher risk buildings is the scrutiny by the new Building Safety Regulator before construction starts. To ensure that this happens there will be a three-stage gateway approval system to ensure that building safety risks are considered at each stage of the design, construction and completion before occupation.

There are three gateways to ensure BSA compliance.

Gateway 1 introduced in August 2021 has two key elements. It requires the developer to submit a statement that sets out the fire safety considerations of the development and to establish the Health and Safety Executive as a statutory consultee for the relevant planning applications.

The first step for gateway one is to develop a fire safety design brief with the client, CDM advisor, fire engineer and design team. This must clearly set out the objectives for the project and incorporate any hazards associated with the end use of the building.

The principal designer and the design team must ensure that they record all fire safety design decisions during pre-consultation through a master design risk register and place all key information in the Fire and Emergency File.

Gateway two ensures that the Building Safety Regulator gives building control approval before any relevant building work starts. The architects acting as the principal designer will be responsible for the golden thread before they pass it on to the principal contractor.

When you have gateway 2 approval, you can begin construction. Duty holders must keep robust records and develop and maintain accurate building information during construction before handing over the information to the building owner after gateway three.

And finally gateway three occurs before occupation. It marks the completion or final certificate stage once construction is finished. It will act as another checkpoint and requires further approval and registration from the Building Safety Regulator.

The duty holder must submit plans and documents that reflect the “as built” building as part of the Golden Threads of information so that they can then be passed onto the building owners or operators.

The new Building Safety Act will change how we approach all buildings in the future. It is particularly relevant to high-risk buildings and is there to ensure that we hopefully never witness another tragedy like Grenfell Towers.

As a duty holder the Fire Statement Submission is a vital part of a duty holder’s responsibility. To find out about more about this read our blog “BSA Fire Statement Submission”.

This blog is based on information from our RIBA accredited CPD about the Building Safety Act. You can register for this as an online webinar or on-site presentation below.

BSA CPD webinar