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20 January 2023
In essence, information about a building ‘the golden thread’ needs to be kept digitally and securely, be a building’s ‘single source of truth’ be available to people who need the information to do a job at the time they need it and be presented in a way they can use it.
During the occupation phase, the information kept needs to show how those responsible for the building are assessing and managing its safety risks. The HSE guidance is subject to the publication of regulations which will provide further details about the information that needs to be held.
But owners and managers can start by reviewing the information on the building they currently have and taking all reasonable steps to find any information that isn’t readily available. Holding such information enables those responsible to assess building safety risks, take all reasonable steps to prevent building safety risks and minimise the impact should any building safety incidents occur.
Accountable person: What information is required from them?
The Building Safety Act requires a building’s ‘accountable person’ to gather certain types of information about their building, known as the ‘golden thread of information’. Examples are a completion certificate for refurbishment work and the specification or certification for key materials such as replacement cladding.
Some of this information is needed to register a building with the Building Safety Regulator, while some of it will need to be included in the building’s safety case report, to help show that all reasonable steps to manage building safety risks have been taken. Examples of the types of information needed (which may be subject to change and some of which will require access to individual flats) includes:
Basic building information
This would include: when the building was built, relevant design codes or standards and reference to a building control body completion certificate; the building’s height, type of flats, details of common parts and any underground levels; plans of the building as built and as it currently is; if the building is part of a wider development, details of any shared facilities, for example utilities, car parking or access; and an overview of the wider area such as nearby buildings and transport routes.
The building’s construction
Details likely to be needed include the primary load bearing system, the stability system and construction materials used; the compartmentation standard; means of access and escape including travel distances; and regulations in force at the time of construction or refurbishment.
This comprises information about residents relevant to managing building safety risks, including those who can’t evacuate without help and those whose first language is not English and extra facilities such as charging battery-operated mobility vehicles, as part of the building safety risk assessment.
If a building has been refurbished, information on changes to the whole building, common areas, or individual parts, need to be collected. If a building is older, it may have refurbishments that were completed to different safety standards. Some of these may have no impact or be designed to improve safety, while others may significantly change the building and its safety management.
Fire prevention and protective measures
Building owners and managers need to identify what measures are in place and how they help control the building’s safety risks. They will need to confirm that all the measures described were installed correctly, work as intended and have been properly maintained.
Considerations will include: the type and location of primary load bearing and stability systems; the type and location of secondary systems relevant to building safety risks for example, cladding support systems; the building’s Approved Document A consequence class and the measures taken based on that class; information about the building’s foundations; and findings from any previous structural surveys or inspections.
Information on ongoing structural safety and any significant challenges to maintaining structural safety will also be needed. Measures in place to monitor, manage and mitigate any structural issues should be identified. If there is no current information available, consideration should be given to a survey of the structural condition of the building.
Services and utilities
Information should be gathered about all connected services and utilities, including details such as where the supply enters the building, where and how it can be isolated, and the name and contact details of the supplier. Where the supplier’s responsibility for maintenance starts and who undertakes maintenance and repairs on their behalf should also be identified.
Plant rooms and incoming supplies should be marked on building plans, and pipe and cable routes should be identified. If individual flats are supplied with gas, pipes feeding the internal network should be identified, enabling consideration of their impact on common parts of the building or evacuation plans. Services and utilities, including ducts and pipes, will pass through fire resisting compartment barriers such as walls and floors.
Those responsible for a building should seek assurance that fire stopping has been completed to an appropriate standard from specifications, certifications and possibly surveying examples.
Maintenance and inspection
Some maintenance and inspection will be directly relevant to managing building safety risks such as maintaining fire alarms and sprinklers and inspecting fire doors. Building owners and managers will need to understand what work should be done and how often, how any issues raised will be managed, who undertakes any work and how their competence can be assured. Policies and procedures that are part of the organisation’s safety management system will be relevant when gathering information and assurance about maintenance and inspection.
For newer buildings, projects involving more than one contractor must have a health and safety file. These are given to clients once a project is completed and should be given to any subsequent owners if ownership changes. Information that may form part of the health and safety file includes:
- a brief description of the work carried out
- key structural principles, for example, bracing, sources of substantial stored energy (including pre- or post-tensioned members) and safe working loads for floors and roofs
- the nature, location and markings of significant services, including underground cables, gas supply equipment, and firefighting services
- information and as-built drawings of the building, its plant and equipment (for example fire doors or the means of safe access to and from service voids)
Where regulation 38 of the Building Regulations applies, the person carrying out the work should give fire safety information to the client no later than completion or occupation, whichever is earlier. This may include as-built information, including plans of the building to allow the client to operate, manage and maintain the fire safety provisions in the building.
Some information may not be readily accessible if the building is older, or has changed hands many times, but those responsible will need to take reasonable steps to find the required information. If gaps remain after consulting planning authority, building control or previous owners’ records, consulting with specialists, commissioning reports or undertaking surveys may be needed. Investigations should be proportionate to the importance of the missing information.
If problems are found when gathering building information such as with control measures, for example, missing fire stopping, fire doors that have been replaced with normal doors, ineffective smoke control or a broken alarm system, action should be taken. Any response should be proportionate to the risk and should demonstrate that all reasonable steps to keep people safe and meet the relevant legal duties have been taken. If any remedial work takes time, additional temporary measures should be considered.
The guidance as published is part of an iterative process, with new regulations and further guidance expected to provide more detail.
The message from the HSE, however, is that it’s not too early for those responsible for high rise residential buildings to start gathering the necessary information on building safety and remedying or mitigating any issues which are discovered in the process.
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