The package of reforms brought in through the Building Safety Act (the Act) and accompanying secondary legislation, introduces a new framework to deliver the recommendations of Dame Judith Hackitt.
The consultation responses set out the government’s policy position for the golden thread requirements for occupied higher-risk buildings.
The following provides further details on the information and documentation that will make up the content of a building’s golden thread of information for occupied higher-risk buildings.
The new regime requires buildings to be considered as a holistic system and golden thread content regulations should be considered in conjunction with the wider reforms which deliver on the government’s commitment to ensuring that residents are, and feel, safe in their homes.
Ensuring the golden thread content exists is an essential requirement of the new regime. The information must be stored in electronic format and be readily available to support the day-to-day management and operation of the building. The golden thread information will contain the evidence needed to demonstrate an understand of a building, and the associated building safety risks and the arrangements for the mitigation and management of those building safety risks. For occupation, the golden thread information is required to substantiate the content of a safety case report and will be used to demonstrate building safety risks are being assessed, mitigated and managed on an ongoing basis.
Meeting existing duties will contribute to the golden thread content, for example the handover of information requirements set out in Regulation 38 of the 2010 Building Regulations require sufficient information relating to fire safety to enable them to manage the building effectively to be shared. Also, the Fire Safety Order requires fire risk assessments to be undertaken and a record maintained of the fire safety arrangements in place.
Further, the Fire Safety (England) Regulations 2022, which came into force in January this year, require dutyholders responsible for a high-rise residential building (therefore including all higher-risk buildings) to share specified information with their local fire and rescue service, provide a secure information box for fire fighters complete with floor and block plans as well as details of firefighting equipment, install wayfinding signage and undertake monthly checks of key firefighting equipment. All this information will be relevant golden thread content.
The government will soon lay the Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2023. These regulations will specify the information and documents that must be kept as the golden thread information for an occupied higher-risk building. Accountable persons will be responsible for collating and keeping this information and ensuring it is up to date.
Maintaining and managing the information and documents that make up the content of the golden thread are a vital component of the responsibilities placed on accountable persons.
To deliver a whole building approach, it will be necessary for the golden thread to include plans and designs of the building which reflect its current state and, where possible, plans which show the building when it was first built. A single set of plans may be sufficient, however, in some cases multiple plans will be required in order for the whole building to be covered. If a building was developed according to a specified design code, this information would also prove valuable as part of the golden thread content.
In addition to plans and building design, details of the construction materials used, for example on walls, floors and doors, and their fire resistance and performance need to be known and understood. This fire management information is already needed to fulfil the risk assessment required for external walls of all higher-risk buildings.
Accountable persons must assess the building safety risks which relate to their buildings, they should understand the scenarios and pathways that might lead to a fire spreading or a structural failure. The details of these assessments must be recorded. As such, the golden thread information should contain all relevant documents which evaluate fire and structural risks as well as any that provide assurances that further assessments of either are not required. Documentation already created as a result of meeting duties set out in the Fire Safety Order will be included within this.
Identified building safety risks must be mitigated and managed and the details of the measures that are in place within a building to deliver this should form part of a building’s golden thread information. Fire safety management measures, namely equipment, devices, or materials that prevent or reduce the outbreak, severity and spread of fire and smoke in the building and facilitate evacuation of the building should be recorded along with where they are located. Structural safety measures, namely anything that has been put in place for the purpose of preventing or reducing the severity of any structural failure in the higher-risk building should be recorded.
As well as detailing all equipment to be used by the emergency services, and how the equipment is operated, the emergency arrangements for a building should include details of the evacuation strategy as well as any evacuation procedures. These details will also need to be shared, along with other information, to residents in the building.
Safety equipment and devices require testing and maintenance, often to manufacturers requirements, to ensure functionality is preserved. Therefore, records should be kept in the golden thread of any schedules of repair and maintenance as well as the outcomes of inspections and testing of equipment. Such information will evidence that accountable persons are taking all reasonable steps to manage building safety risks on an ongoing basis.
Accountable persons must demonstrate they are assessing and effectively managing building safety risks on an ongoing basis through a safety case report. The report’s accuracy and effectiveness in making this demonstration is reliant on the documentation and information held in the golden thread. The required content of the safety case report is set out in regulations.
New higher-risk buildings that have been developed under the Building Safety Regulator and passed through the new gateway requirements, will benefit from having detailed records of the building work that has taken place and features of the building. The information and documentation required in order for a completion certificate application to be successful for new higher-risk buildings will deliver much of the golden thread content outlined above. As such, this must be handed over to accountable persons for their records and in turn it will support accountable persons demonstrate compliance with their responsibilities.
Further information and documentation required for inclusion as part of the golden thread information is set out in full in the Regulations.
