What golden thread regulations mean for workplace and facilities management   

News

In late October, government laid the (draft) Higher-Risk Buildings (Keeping and Provision of Information etc) (England) Regulations 2023 in Parliament. They will become law, only once they have been debated and approved by both Houses of Parliament and will enter into force once we have received the commencement regulations. The regulations set out the golden thread information that the people responsible for an occupied higher-risk building (the accountable persons) need to keep, and what information they need to provide to others (including residents) of the building. The regulations also set out the limited exemptions to sharing the information based on security, commercial confidentiality and data protection sensitivities. Schedule 1 of the Regulations outlines what information and documentation are part of the golden thread.  

Its purpose is to improve every aspect of how critical data is utilised in building management. The golden thread of information will contain the evidence and information needed to identify and manage building safety risks. The golden thread information will enable accountable persons to demonstrate they understand the building and the steps required to keep it safe.  This is important for FMs as they are likely to be responsible to maintain the golden thread so the accountable person can demonstrate they meet their duties.  

Without information about a building, including risk assessments and details of safety features and arrangements, accountable persons cannot be confident they are meeting their obligations under the Building Safety Act 2022, or demonstrate this to others.   

This is the final set of regulations currently planned for the higher-risk building regime. The Higher-Risk Buildings (Management of Safety Risks etc) (England) Regulations 2023 which have been published previously, also contain several regulations to the golden thread, focused on the standards prescribed for how to keep the golden thread information and documents and what needs to be included in the safety case report.  

The golden thread regulation may prove to be highly effective in reassuring building owners and occupants alike, driving up standards in the sector and improving building safety. However, it remains reliant on relevant parties creating and maintaining accurate and relevant information, with robust systems and processes in place which is an ongoing journey for workplace and FM firms nationwide.  

The Department for Levelling Up, Housing and Communities (DLUHC) has recently also published two further sets of guidance on the following:  

• criteria for determining whether an existing building is a higher-risk building during building work, which is relevant for FMs to explore.  
• criteria for determining whether a new building that is being designed and constructed is a "higher-risk building."   

Both sets of guidance relate to the legal criteria for determining whether a building is considered a higher-risk building and aim to help potential dutyholders and accountable persons identify whether they are responsible for a building in scope of the higher-risk regime. They can be found on the page linked here.  

Based on feedback from stakeholders, DLUHC have also made some updates to the already published in occupation guidance. Key changes include:  

• Minor adjustments in language to make the guidance clearer, particularly regarding how to count storeys and how to consider lightwell areas.  
• Clarification has been made that other methods or guidance cannot be used when assessing whether your occupied building is a higher-risk building.  
• Diagrams 9 and 12 have been updated.   

IWFM is committed to providing our members with the tools to help deliver against the Building Safety Act 2022 duties, for that purpose:  

• We are collaborating in the Building Safety Alliance to create a master list of documents and other information sources currently used by industry, which can be used to identify the key data which needs to be specified for the Golden Thread Information Requirements.  

• We have recently published a guidance note which helps organisations to go on their digital maturity journey, in collaboration with Planon. This will be helpful for organisations trying to manage their data, information and operational management in a more digitally efficient manner.  
• We provide several courses which cover building safety and related topics, such as compliance and sustainability.   

As of 1^st October 2023, further clauses from the Building Safety Act 2022 for the occupation phase have come into force. This large-scale tool driving reform was drawn from Dame Judith Hackitt’s 2018 review of fire safety and building regulations, commissioned as a response to the Grenfell Tower fire in 2017, in which 72 people died. The Act seeks to address the management of higher-risk buildings, and improve safety and accountability in England’s construction projects, from initial plans to day-to-day occupation and even demolition.   

A major part of the Act is the creation of golden thread regulation, which is intended for ‘key information (to be) passed across (the building lifecycle - design, construction and occupation) to future building owners or those falling under the accountable person duties to underpin more effective safety management throughout the building life cycle’.