When work is being carried out on a building, how often is there little or no information available? Who holds information about a new building – the owner, the builder or the architect? Is it in the operation and maintenance manual, or in a full package of original design information?
Do you have this information, for example, for your own home or your office ? Are all the fire safety provisions, hydrant location, emergency access, fire strategy, internal fire doors, compartmentation and original plans detailed in one place? Probably not. There is no culture or practice of having this vital information in a safe, consistent spot for occupiers and future owners.
Improving information management
In her report on the Grenfell Tower fire, Building a Safer Future, Dame Judith Hackitt highlighted this as a failure of the system, and concluded that it results in a lack of accountability.
Anyone who has followed some of the evidence from the inquiry into the fire will appreciate that there are a bewildering array of sources and confused roles and responsibilities, while the system for managing information is poor if not completely lacking.
Dame Judith proposed to redress this with a golden thread of information, so called because it should be – as one dictionary defines it – 'an idea or feature that is present in all parts of something, holds it together and gives it value'. Creating a golden thread on fire safety will involve collating relevant information, making someone responsible for keeping it up to date in one location, and fostering a culture to support this process.
Statutory advisory body the Building Regulations Advisory Committee (BRAC), which brings together a cross-section of industry representatives to support officials in developing policy, established a working group dedicated to defining the golden thread. This group recently published a report setting out the principles that will inform ongoing work in developing secondary legislation and guidance.
Information and accountability
The BRAC working group has been looking at two key concepts that have emerged from the Grenfell inquiry evidence: information and accountability.
Building control currently strives to approve plans, check designs and obtain information on new and existing buildings, but these records are for the profession's own use. A package of information is then also held by the owners or architects. Some might remain with the contractor, while some is simply not collated or obtained by any party.
Over a few years much of this information may be lost, and could in any case go out of date. Far too many times, building control surveyors and designers have to look at a building and make decisions without access to any historic information.
- show that it complied with applicable Building Regulations during its construction
- prove that it meets the requirements of the new building control route – which is the golden thread/regime being introduced by the Building Safety Bill – throughout the design and construction or refurbishment of a building
- identify, understand, manage and mitigate safety risks to prevent or reduce the severity of the consequences of fire spread or structural collapse throughout the building's life cycle.
On the new approval route, the building control service provider for in-scope properties will be the building safety regulator (BSR) based at the HSE. This route will provide a far more robust system for monitoring the essential information and responsibilities.
'The BRAC working group has been looking at two key concepts that have emerged from the Grenfell inquiry evidence: information and accountability'
Golden thread principles
The golden thread will be reviewed and managed so that the information retained at all times achieves these purposes. The thread should include information and documents themselves, as well as detailing the information management processes or steps used to support building safety.
- ensuring that information is accurate and trusted
- supporting residents in feeling safe at home
- changing the culture around creating, storing and using information on building safety
- offering a single source of truth, highlighting important issues and elements of design
- keeping information secure, complying with the General Data Protection Regulation and ensuring privacy where required
- recording changes
- making individuals responsible
- ensuring the information and system are accessible, informative, understandable and easy to navigate
- formatting the information so it is durable and transferrable
- being relevant, proportionate, and robust.
The government will specify digital standards that provide guidance on how these principles can be met. It will also require that dutyholders and accountable persons create and maintain a golden thread throughout a building's life cycle under this new, more stringent regime.
The golden thread will be effective at three stages, or gateways, during the building process.
1. Early in the design stage
While seeking planning permission, the design team and other stakeholders will generate the relevant information.
2. Ahead of construction
Additional information and approvals will be collated at this stage, including confirmation of the project's compliance with the Building Regulations.
3. Before occupation
All verifications and approvals, information and data will be collated and stored for the owner, residents, visitors and other stakeholders. This will happen prior to completion or sign-off and subsequent occupation, to ensure that the information is complete and available to all.
Information should be handled in accordance with the ten outlined principles through the design, construction, occupation, refurbishment and ongoing management of the building.
Wider changes in the legal process and the building control system, mandating step-by-step approvals and increased penalties, will promote this new culture of improving building safety. This has been specifically defined to include buildings' fire and structural safety, and the safety of all those in or in the vicinity, including emergency responders.
Many people will need to access the golden thread to update and share information throughout a building's life cycle, including but not limited to building managers, architects and contractors. The golden thread will also need to be shared with other relevant stakeholders including residents and emergency responders; the designated accountable person will be responsible for ensuring this.
The BRAC working group report is developing the principles of the golden thread as an ambitious but comprehensive live document that everyone will be able to use. Practising building control officers will find it a revelation to obtain knowledge about existing buildings, as well as understanding previous designs and changes.
Ongoing work
BRAC is working with the Department for Levelling Up, Housing and Communities on setting formats and guidance for the information, but we can all appreciate that this will be a significant, long-term task. The BSR due to be created by the passage of the Building Safety Bill into law in 2022 will audit any issues that come to light and take necessary enforcement action.
To ensure this happens, the process will apply not just when the building is new or being altered, but require that all existing in-scope buildings are registered by the BSR. The new category of higher-risk buildings defined in the bill will mean all occupied residential buildings more than 18m – or seven storeys or higher – will have to be listed and have a golden thread in place.
Over the next five years, the whole register will be audited by the BSR. This will no doubt raise issues, complications and challenges when it comes to existing buildings – not least in obtaining information on the older ones – but this is an essential stepping stone to improving safety. It is important to note that for all in-scope buildings, the only route to obtain building control approval will be through the BSR.
With the introduction of the Town and Country Planning (Development Management Procedure and Section 62A Applications) (England) (Amendment) Order 2021 on 1 August, designers are now required to consult with the BSR on fire safety matters at stage one of the golden thread as part of the formal consultation process when obtaining permission. The anticipated passage of the Building Safety Bill next year will empower the BSR and result in wholesale changes to the process of building control, as well as implementing gateways two and three on the golden thread.
It is important to note that although the golden thread applies only to selected high-rise residential buildings at present, this could change. Perhaps other buildings such as sports stadia, schools, hospitals, care homes, shopping centres or even – in the long term – all flats will be brought in scope.
As things stand, the bill will effectively create a two-tier process: the BSR-assessed in-scope buildings, and other buildings that will continue on the existing local authority or approved inspector process. Yet it is hard to justify not creating a golden thread for all, not just the in-scope buildings, when it could improve safety – it will certainly make building control approval easier. This report is another step forward, but there will be many more steps ahead.
Andrew Thomas MRICS is a principal building control officer at Fylde Borough Council and member of the RICS Fire Safety Working Group
Contact Andrew: Email
Related competencies include: Data management, Fire safety, Legal/regulatory compliance