They will also have to produce a "safety case", a type of permissioning regime used in industries such as nuclear, petrochemical and railways, to show that they are taking actions to reduce a building's safety risks. The government highlights that management system principles may provide a reasonable basis for these. This is where another new element will come in: the introduction of a "gateway system". This will be a series of points that must be satisfactorily passed, taking a safety-case approach, before the next phase of a development can proceed.
- Before planning permission is granted -- requiring the applicant to submit a "fire statement" with their planning application and the relevant planning authority to consult with the fire and rescue authority.
- Before construction starts -- requiring dutyholders to demonstrate how they comply with building regulations by providing full plans and supporting documentation.
- Before occupation begins -- requiring dutyholders to hand over building safety information and secure registration and the building safety certificate, providing assurance of risk management, before occupation is allowed.
Importantly, occupation is where the concept of a new "golden thread of information" will feature prominently. Those who have designed and constructed a building will need to ensure all information around safety is passed on to the client, to form the basis of the "safety case" in occupation. Information handover is a critical feature that IOSH has highlighted.
Safety must be an integral consideration throughout the design and construction phases, as well as the occupation
Effective action
The question is, do these proposed changes go far enough? One key point to make is that the proposals go further than some of the Hackitt recommendations, such as suggesting a new statutory objective for all those involved in the process to promote building safety, as a cornerstone of a new culture.
And although Dame Judith Hackitt focused on new buildings above 30 m (or ten storeys) in height, the changes being consulted on apply to new buildings 18 m or above (or six storeys). This is quite a significant difference and will mean many more multi-occupancy buildings would be covered by the new system.
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