Building Safety: Implementing the Golden Thread of Information | Webinar Q&As

One of the key issues that building owners and managers need to get to grips with is how to implement and manage the golden thread. Are you prepared? Our latest webinar provides valuable insight into the 10 golden thread principles and a clear understanding of what you need to consider to meet your golden thread requirements. Watch on-demand here.  

We received some great questions during the live webinar, answered by our experts below. 

 1. Are PDFs of handwritten documents regarded as digital? 

The definition of digital in relation to the golden thread is that your documents are stored electronically and can be transferred electronically, so if your PDF is stored in that way, then we would say yes, it is fine to do this. Although, it all depends on what the PDF document contains, what its purpose is, and then how it’s going to be used. The key challenge is to make sure that you store your documents in a logical way and ensure that each document is linked to the asset that it needs to refer to, then ultimately you will be able to access it quickly and share it accordingly.  

You need to ensure that you keep your information up to date as that is the whole point of the golden thread. If a PDF will allow you to keep your information up to date, and in good time, and can be stored as a digital format that you can access and report on, then it will work.  

 2. Is a resident engagement strategy required per high rise building, or can one document be used to cover them all?  

You will need one per building. However, you could operate within an overarching framework that sets out your headline approach to your residents’ engagement strategies.  

You need to do one for each building because there could be different resident and/or risk characteristics for each. You will need to work out what you need to engage with residents on, how they can receive information from you, and how they are going to be able to feed information back to you. This will likely look different for different types of buildings, so think about this across your whole portfolio.  

3. Is there a golden thread checklist for fire safety works of what needs to be included in each pre-construction, design, operational and aftercare? 

This is what we are essentially waiting for in the secondary legislation and specific guidance. The government’s recent consultations provide a good indication of what that this might include. 

The key principles of the golden thread apply here – making sure the right information goes to the right people at the right time.  

You should review the fire strategy for the building because that is going to give you a clear indication of whether you have any gaps and what you need to address.  

4. What do you think the biggest challenges are with all this from what you’ve seen so far working with other organisations? 

The first challenge is ensuring that organisations really understand what they need to know and include in the golden thread. Bigger organisations have access to more resources, with more time and more financial help to get to grips with everything. It is therefore important for smaller organisations to be clear on what they need to hold as they work through this process themselves. 

Once organisations have an idea of what they need to include, it’s then about trying to scope all of that information and approach it in logical way. Ask yourself, what is the information that we need to hold? Where does that exist across our whole organisation? Don’t just think of this in terms of information relating to the building itself, as it is also about who lives in the building, what risks might be created, as well as the other ancillary information you might need to hold. 

Being able to approach the above in a logical way and thinking of it as a project opposed to something that can be looked at every now and then is the right way forward. 

We have had discussions with organisations who knew they had gaps around how they currently manage data, and they’ve seen this as a springboard to look at a business transformation approach to how they use and manage data in the right way across the organisation. In that case, it’s then also about thinking of wider organisational transformation as well as how different teams and services work together. Data is essentially a can opener; it helps you understand other things that require work. 

Once you get a sense of all the information you need to hold, you then need to think about turning it into something useful. Ask yourself, how do we actually use this information?  

In addition, we’ve seen that lots of buildings that are over 40 years old lack information, so you need to ask yourself, what surveys do we need to commission that is going to provide this information? What is going to give us everything we need? Clients are looking at whole building surveys to give them all that information retrospectively.  

Another challenge that links with the golden thread is the wider safety management system (a requirement under the Act to ensure building safety risks are managed) and all the elements that fit together to make up that system, from your governance and assurance framework, processes and procedures, individual policies and training and competence. We’ve seen clients struggle with taking a holistic approach, so it is important that you look wider than just your individual buildings.  

These challenges may need you to look at your organisational approach. We’ve seen with other areas of property compliance that the organisational approach is sometimes lacking overall oversight, leadership, and a real understanding of governance that then supports people at the ground level who are trying to put everything into place.  

5. Is there a case for not overcomplicating this at the moment, is just starting the process going to be ok for now, knowing that we have a ton to do going forward to make it ‘perfect’? It is something we have tried to get clients comfortable on, because a lot are panicking! What soothing advice do you have? 

Take things bit by bit and approach this in bitesize chunks so it doesn’t become overwhelming. It is really important to have a plan in place and appreciate that you’re not going to be able to resolve this overnight. Take time, take a step back, and plan it properly.  

We recommend coming up with a project plan that sets out exactly what you need to do and then put in place something that is realistic. If there are any obvious quick wins in there that allow you to pull information together quickly, then take that opportunity, but if you are at a point where you need to do something that is more fundamental, then take your time opposed to rushing anything.  

The Building Safety Regulator (BSR) accepts that organisations are not going to be perfect from day one, we must be realistic. We are still waiting for the secondary regulations and there is still a lot of work for the BSR to do to prepare for the new regime. The key thing is to get a plan in place, get moving on it, and work towards it. Even if you are in a comfortable position, you still need to keep reviewing things as you move forward because this is something that will need continually refining and updating as you identify new ways of holding new information that is relevant to your risks.  

The Health and Safety Executive (HSE), who are the home of the BSR, provide great advice which is a useful starting point for the key things to expect and ultimately help to help you develop your plan for moving forward.  

Storing building information - golden thread - Building safety - HSE 

6. How long should golden thread data be held? For months, years or lifetime of the building?  

Store the data for as long as you need it to be able to manage the building and evidence that the building is safe, and your control framework has been and is operating effectively.  

This is an opportunity to look at your organisation’s policy around data and information retention. Think about the records which will have a legally defined timeframe for how long you keep them for. For example, landlord’s safety gas records must be kept for at least two years, and there will be other records that will need to be held for different periods of time.  

At the same time, don’t keep information just for the sake of it – you need to ensure that your golden thread of information contains the key data that shows what’s going on in your building at that point in time, and also that you have managed it to keep it safe. There are many issues that can come about from storing data forever, so don’t just default to keeping everything.  

7. Registrations with the BSR are due between April and October, but do the safety case reports need to be ready by then as well?  

The information you need to register your building is the key building information from the regulations which are coming into force on 6th April. In terms of your safety case, the BSR published advice in a recent press release that explains you should have your regime in place from October 2023, so make sure that you are working towards that October date. However, you don’t have to provide your safety cases as part of the registration. The BSR will approach you once you’ve registered your buildings and, in a phased approach, will require you to apply for your Building Assessment Certificate. As part of the application for the certificate, you will need to have your safety case reports prepared. 

Safety case reports are not required between April and October for the purposes of registration, but you should be working towards having all of the regime in place by October regardless. You should work to have your safety cases ready as soon as possible.  

8. I see individual residents' disabilities requirements don’t align with the overall fire strategies designed for buildings as a whole. i.e., mobility issues through cross corridor fire doors etc. Where does the building owner’s responsibilities sit for individual requirements?  

This will come down to the balance between the risks that you understand, the risks that can be created, and then someone’s rights to continue to live in their home. You need to at least demonstrate that you have understood the relevant risks and that you’re working with the resident to address what support they might need, and then taking steps to provide that support in an appropriate way. Ensure that you have things in place to be able to manage that risk in the event of a major incident, for instance, a potential fire risk. As an organisation, you may also want to review what policies are in place around things like independent living, adaptations, and so on. Some organisations have supportive policies in place to help people and secure alternative accommodation if that’s in their best interests.  

You have diversity and equality obligations, as well as obligations under the Building Safety Act 2022. One of the key principles around this is ‘reasonably practicable’. What do you understand the risk to be? And what are the things that are reasonably practicable to do to be able to manage and mitigate that risk?  

9. Maybe slightly outside of the scope, but what are the rules around Personal Emergency Evacuation Plans (PEEPs) in high rise properties and how this contributes to the Golden Thread? 

For those that followed the government’s approach to PEEPs, this was a major issue as part of the Grenfell Tower public inquiries, phase one and phase two. There was a recommendation from phase one that organisations should have to carry out PEEPs in general needs accommodation and share that information with the Fire and Rescue Service. There was then pushback on that from organisations and the Fire and Rescue Service, as well as the government, around the practical challenges and issues with this. This is an issue that has not gone away, the government have published two lots of consultations; one around how they could implement PEEPs and one around emergency evacuation information sharing (EEIS+). We are currently awaiting the outcome of the latter consultation – you might wish to have a look at the government’s proposals to give you an indication of the potential. 

https://www.gov.uk/government/consultations/emergency-evacuation-information-sharing 

One of the key things to consider is your understanding of risk, what would you tell an inquiry if something went wrong to justify your position on something? Think about what is reasonable, but also what you can manage as an organisation and take the appropriate steps. 

You need to ensure that residents can get in touch with you if they have any concerns, then be able to support them. Ask your residents if there’s anything that they think you could be doing to support them, as this might inform your resident engagement policy as well.   

10. Just to clarify, is a Building Safety Case required on buildings in scope regardless of whether they have had major refurbishment works? 

Yes. 

11. Is the building freeholder/owner always defined as the Principle Accountable Person (PAP) and that it's always the PAP who needs to register the high-rise residential building? 

Where there is more than one Accountable Person, it is the PAP that needs to register the building. This is the person or organisation who has control of the building. You will find information on the HSE website that explains this further and will guide you through the process. The key building information regulations also give further information on how to determine what parts of a building an Accountable Person is responsible for.  

https://www.legislation.gov.uk/ukdsi/2023/9780348243963 (from Section 26) 

https://www.hse.gov.uk/building-safety/roles.htm 

Resources mentioned: 

As mentioned, click here to watch our previous webinar on ‘data into intelligence’ on-demand. The webinar will provide you with insight into how you take a wealth of data and do something with it.