Grasp the thread

The final sections of Part 4 of the Building Safety Act have come into force, covering the golden thread and safety case requirements. Dr Hywel Davies explains the implications for building managers and accountable persons

The Building Safety Act 2022 (Commencement No 6) Regulations 2024 came into force on 16 January. These bring fully into effect many sections of Part 4 of the Building Safety Act 2022, including: requirements for building assessment certificates; identifying and managing risks and preparing safety case reports; and maintaining information, the ‘golden thread’. They also require information to be shared with residents and regulators. So, what must an accountable person (AP) do?

The objective of Part 4 is for every higher-risk building (HRB) to be managed competently, with a proper risk identification, assessment and management process formally established. It requires that the information needed to manage the building safely and to demonstrate safe management is brought together in a robust digital record of the building, and that this is maintained. 

The Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 introduce the regulatory framework for the golden thread. The act requires the golden thread to be stored digitally throughout the life-cycle of the building, so that the information is accessible and can be quickly updated and handed over when assets change owner. This will drive a shift to treating building information as ‘belonging’ to the building itself, and not to the owners. Golden thread information must be:

  • Kept digitally and securely 
  • A ‘single source of truth’
  • Available, in a readily usable form, to people who need it to do a job, including emergency services
  • Proportionate (taking into account the stage the building is at in its life)
  • Explicit about how building safety risks are being assessed and managed.

The golden thread information will support the safety case and safety case report, required to support the AP’s application for a building assessment certificate. This is the legally required means to gain regulatory approval to occupy a residential HRB. This requires the AP to identify building safety risks – fire and structural – and to explain how these are being eliminated, mitigated and managed. 

This will drive a shift to treating building information as ‘belonging’ to the building itself, and not to the owner

Section 85 of the act requires that the ‘Principle Accountable Person’ (PAP) for an occupied HRB prepares a ‘safety case report’ containing: ‘(a) any assessment of the building safety risks made under section 83 by an Accountable Person for the building; and (b) a brief description of any steps taken under section 84 by an Accountable Person for the building’.

Building safety case reports should be a clear summary of the information that the Building Safety Regulator needs to see to determine whether the building is safe to occupy, and to demonstrate that the golden thread is in place and properly managed and maintained.

Each safety case report must include at least the following information:

  • Details of all APs and responsible persons for the building
  • A description of the location, shared facilities (if any), and nearby buildings and transport routes
  • Details of how the PAP and other APs have assessed building safety risks, the findings of those assessments, and any follow-up actions or recommendations
  • An explanation of the safety management system, including emergency management and evacuation procedures
  • How identified building safety risks are being managed and mitigated to ensure resident safety and keep the whole building safe
  • References to other key documents and supporting building safety information that the regulator may reasonably need 

The PAP must maintain and revise the safety case report ‘as necessary or appropriate’ and notify the regulator of all updates (with a copy, if requested).

These regulations mark the conclusion of the process of implementing and introducing the new building safety regime for HRBs in occupation. Triggered by the Grenfell Tower tragedy, they are intended to improve standards in HRBs and to re-establish trust in the sector following the revelations that emerged at the inquiry. Now to deliver across 14,000 HRBs. The real work starts here.

  1. Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 –