Building Passport has been actively engaged in attending the Building Safety Regulator's (BSR) educational video call sessions. These sessions have shed light on the new requirements set to come into effect on 1st October 2023 under The Building Safety Act. In this blog post, we aim to provide you with an overview of the key points discussed with respect to submitting information to the BSR's new portal which is currently being built to collect design and construction information for High Risk Residential Buildings (HRRBs), and the level to which you should be collecting information on your construction projects and buildings more generally.
1. Submission of design and construction information
From 1st October 2023, HRRB construction projects will be required to submit comprehensive information to the Building Safety Regulator (BSR) to prove that the building complies with the requirements of the Building Safety Act. This regulatory measure is a significant step towards ensuring enhanced building safety standards across the United Kingdom.
2. What information is required?
The Accountable Person(s) will have to submit evidential information on the building's design and construction to the BSR. However, industry will not be provided with a comprehensive list of documents or detailed guidelines on the specific contents of this submission. This leaves room for interpretation, necessitating careful consideration and cooperation among stakeholders.
3. What will the portal look like?
The new portal is currently being developed by the Health and Safety Executive & BSR. What we know at this stage is that it will be a .gov.uk website with a form (or series of forms) to fill in and a file upload facility.
4. Limited access to submitted information
An important point to note is that neither the building owner nor the Principle Accountable Person (PAP) will have direct access to the information submitted through the BSR portal. Therefore this cannot count as evidence that the Golden Thread of building information has been transferred to the building owner or PAP.
5. Transferring information to the PAP or owner
The BSR will want to have access to proof that all pertinent information regarding the design and construction of the building, effectively the start of the Golden Thread, has been effectively transferred to the PAP/owner. Furthermore this information needs to be in a readable format for anyone to understand - i.e. complex BIM/COBie files will not be appropriate. It is crucial to recognise that the information requirement vastly surpasses the scope of Regulation 38 of the Building Regulations 2010 (as amended) which is there to ensure that the responsible party for the building, upon occupation, possesses sufficient fire safety information for effective management.
6. What does that mean for information collection?
Because we are none the wiser on specifics of information being required by the BSR it is safest to assume that as much information as possible should be collected. Hence, it will be essential to maintain a comprehensive record throughout the construction process, documenting design intent, changes, and the reasoning behind those changes, together with warranties, commissioning certificates etc. This record should be contributed to from multiple sources and transferred to the PAP upon completion.
7. Collaboration and the Golden Thread
To ensure a seamless transfer of information to the PAP/owner without loss of critical details, collaboration and agreement among all stakeholders involved in the design and construction phase is paramount. This collaboration is crucial in creating and preserving a unified Golden Thread that encapsulates essential information from multiple sources. Furthermore, to smooth the transition of information to the PAP/owner, it makes sense to adopt a system which is also suitable for information management during the occupation phase of a building.
8. What do these Golden Thread systems look like?
Different methods and systems are being used to approach the Golden Thread. We lay out below the 4 options that we have seen adopted across the industry so far:
i) Using generic systems:
The most commonly seen solution is creating a customised environment through platforms such as Sharepoint or Dropbox. The fundamental issue with these is that they are not built to store information alongside a building forever. They are usually set up and owned by a particular stakeholder - whether that be the principle designer or building owner. If subscriptions are not renewed (this might be because a project has come to an end or because the building changes hands) then all of this historic information can be lost. Furthermore, every building might have a different file structure, making it near impossible for new users to navigate and find what they are looking for.
ii) Using unfit-for-purpose systems:
Another method which is adopted less-widely is using construction software to maintain a Golden Thread. Using BIM/COBie systems is almost a holy grail solution, where every nut, bolt, weld etc is recorded. Obviously going into this much detail is time consuming, and therefore extremely expensive to upkeep after the construction phase is over and the building enters the occupation phase of its life. We understand from HSE that this level of information gathering is not necessary to prove alignment with the Building Safety Act.
iii) Proprietary systems:
Larger asset owners have been known to build proprietary systems. These are great while that building is under their ownership, as specific functionality requirements will be available. However, when that building changes hands there is a huge headache when it comes to information transfer and maintaining the Golden Thread. Furthermore, using proprietary systems creates additional work for appointed professionals if they are asked (as they should be) to contribute information to the Golden Thread of that building - they need to spend time becoming familiar with the system and may not follow specific rules/guidelines that the proprietor of the system has for its employees. This also harks to the inherent desire in the property industry to own and control everything about a building. This issue leads to data siloing which in turn makes Golden Thread curation extremely difficult.
iv) Built-for-purpose systems
The other approach is to adopt a system which has been built for exactly the purpose of curating Golden Thread information. In this case information on a building is stored alongside it forever, as opposed to being held against a specific user or specific company with a subscription. The building owner has control over access to the system until a new owner takes their place. This approach ensures there are never any gaps in information and, crucially, it keeps evidence of everything that's ever happened to a building throughout its lifetime, including who's previously had access - whether they are owners or professionals working on behalf of the owner.
The Building Safety Act's new requirements, effective from 1st October 2023, mark a significant milestone in the pursuit of enhanced building safety standards. As we navigate these changes, let us remember the importance of maintaining a comprehensive record of design and construction information, while embracing collaborative efforts and utilising tools such as Building Passport software to promote transparency and competence and to streamline the transfer of critical information. Together, we can forge a safer future for our built environment.