Building Safety: The full regime approach

Last Updated: 15th March 2024

Whilst there is a lot of focus within the sector around completing building safety cases and safety case reports for your higher-risk buildings, these are just a few elements of the regime, so it’s crucial that you take a step back to focus on the building safety regime as a whole. With the full implementation of the Building Safety Act 2022 (the Act) from October 1st 2023, there’s a lot to think about when it comes to building safety. To help you tackle your obligations without feeling overwhelmed, we have broken down the building safety regime to highlight some of the key requirements that might have slipped your mind but are necessary in keeping your buildings and residents safe.  

If you need a quick recap on the key takeaways and most recent updates from the Building Safety Act, read our blog ‘The Building Safety Act 2022: Everything you need to know in 5 minutes’ here.

Considering other parts of the building safety regime (such as the golden thread, mandatory occurrence reporting system, and resident engagement strategies) will allow you to gain a holistic view of your building safety approach which will, in turn, help you understand the steps you need to take to stay compliant.  

Below are four key duties that principal accountable persons and accountable persons must have in place alongside safety cases and safety case reports.  

The Golden Thread  

The government defines the golden thread of information as “both the information that allows you to understand a building and the steps needed to keep both the building and people safe, now and in the future.” 

All relevant information about a higher-risk building should be stored within the digital golden thread. This information must be a trusted and accurate representation of your building so that it can be maintained and managed reliably. The golden thread will ensure that you have all the relevant building safety documents and that everyone who needs to see them can access them with ease.  

Your golden thread of information should include how you identify, manage, and mitigate building safety risks to prevent or reduce the risk of structural collapse or fire spreading.  

Your golden thread must be: 

• Kept digitally and securely. 
• Representative of your building’s single source of truth. 
• Readily available to people who need the information to undertake building safety related activities and tasks. 
• Presented in a way that is easy to read and use. 

To find out how to store your information digitally in the golden thread to efficiently record the life cycle of your buildings, watch out on-demand webinar, ‘Building Safety: Implementing the Golden Thread of Information’. 

Mandatory Occurrence Reporting System 

Mandatory occurrence reporting is required to help improve the communication and reporting of safety occurrences between the principal accountable person and the Building Safety Regulator (BSR). It is also required to identify, capture, record, and store safety occurrences to learn from them and prevent them happening again. 

A safety occurrence is an incident or situation related to the structural integrity or spread of fire in a higher-risk building, and without the situation being remedied would likely result in a significant number of deaths, or serious injury to a significant number of people. You should consider incidents that could arise as your building ages, as well as ways that you could reduce these risks, who will be responsible for reporting them to the Building Safety Regulator and how they will we recorded and investigated.  

On 31st January 2024, the government published an update on operating mandatory occurrence reporting system. This includes updates on:

• The process for notifying the BSR of any safety occurrences that have happened.
• The duties of the Responsible and Accountable Persons.
•  Scenarios to help you think about what a safety occurrence might be. 

Safety Management System  

A Safety Management System (SMS) for high-rise residential buildings is a formal management system or framework for managing safety risks. The benefits of implementing an SMS include an increased safety culture, better risk management, and increased productivity, as well as providing assurance that you have the infrastructure in place to comply with building and fire safety legislation.  

Government guidance recommends using a recognised model to develop your SMS, such as the Health and Safety Executive’s Plan, Do, Check, Act approach, or the British Standard BS 9997 on fire risk management systems and the International Organization for Standardization (ISO) Occupational Health and Safety Management System.  

The Plan, Do, Check, Act model is an easy-to-understand, 4-step guide to managing your SMS. It covers:  

• Plan: determining your policy and plan for implementation. Consider how you plan to develop building safety measures. 
• Do: assess risks and implement your plan. Identify and analyse any risks and decide how you would deal with potential changes to these risks. 
• Check: measure performance. Monitor the performance of your SMS and building safety approach regularly. 
• Act: review performance and act on lessons learned. Review your SMS to ensure the measures in place are still effective and implement improvements if they no longer are.  

Whichever model you choose should capture the above principles in some way.  

Resident Engagement Strategy  

Resident communication and engagement are crucial elements in an effective building safety approach. Having clear and robust residents’ engagement strategy in place for each higher-risk building will ensure residents’ voices are heard by allowing them to have a say in building safety decisions. If you do not have a strategy currently, it’s important that you produce one as soon as possible. You must submit a copy of the resident engagement strategy as part of your application for a building assessment certificate, which the Building Safety Regulator will instruct you to do at some point from April 2024. 

Your strategy must cover:  

• The information about building safety decisions that you will provide residents with. 
• What building safety questions you will ask residents about. 
• How you will collect and use residents’ opinions, including collection methods. 
• How you will measure and review resident participation.  

After developing your strategy, you must distribute it to residents and monitor it, ensuring that you review it at least every two years or after any significant building changes.   

It is important to note that you will need a separate complaints procedure that residents can use to raise any safety concerns. You can mention your complaints procedure in the resident engagement strategy, but your strategy should not address how you plan to handle resident complaints. 

To gain assurance that your building safety approach is robust and compliant, and your residents and buildings are safe, you must look at the building safety regime as a whole. Consider each element mentioned above as well as dedicating time to develop your safety cases and reports.