The requirement for the maintenance of a "Golden Thread" of information for higher-risk buildings (HRB, as defined below) is one of the major principles introduced by the Building Safety Act 2022 (BSA). This requirement came into force on 1 October 2023 and places a responsibility on the relevant dutyholders (identified below) to ensure that key building and fire safety information is easily accessible throughout the life cycle of a HRB.
The Golden Thread of information goes hand in hand with the Dutyholder regime and Gateway regime, which also form part of the sweeping changes laid down by the BSA.
What work does the Golden Thread apply to?
The Golden Thread of information is required in respect of:
- any HRB once it is occupied;
- any building work to create a new HRB; and
- any building work to an existing HRB.
In order to manage the evolving risks throughout the life cycle of a HRB, the maintenance of the Golden Thread of information applies during the design, construction and occupation phases of a HRB.
What is a higher-risk building?
Broadly speaking, a "higher-risk building" is defined as a building which is:
- at least 18 metres in height, or has at least seven storeys; and
- contains at least two residential units
It includes care homes and hospitals, but excludes residential institutions and hotels. The applicability of this statutory exclusion is outside the scope of this guide, but note a hotel will only be excluded from the HRB regime if the relevant building comprises entirely of a hotel that is not part of a residential building and does not contain serviced apartments.
What is the Golden Thread?
The Golden Thread of information must contain information relevant to the HRB and how it complies with the Building Regulations.
The nature of the Golden Thread of information will depend on what stage of the life cycle the HRB is at (i.e. design, construction or occupation phase) and will therefore evolve but includes (among other things) the approved drawings and plans, fire and emergency file, mandatory occurrence reporting plan, construction control plans and any other documents used to form part of a Gateway application for approval from the Building Safety Regulator (BSR).
When applying for the completion certificate for a completed HRB as part of approval for Gateway 3, a statement must be given to the BSR that a copy of the Golden Thread information has been provided to the relevant person (i.e. the principal accountable person or the accountable person for a higher-risk residential building, or the responsible person for a non-residential building or non-residential parts of the building). As part of the hard-stop presented by Gateway 3, a HRB cannot be registered and occupied until the completion certificate has been issued by the BSR – please refer to our guide regarding the Gateway regime for further details.
Who is responsible for the Golden Thread?
The client is ultimately responsible for creating and maintaining the Golden Thread of information and for ensuring that other dutyholders meet their duties, but the client can delegate its duties to such dutyholders (mainly the principal contractor and principal designer in respect of the design and construction phases). The client must share such information about the building with every designer and contractor on the project.
- During the design phase, the principal designer is responsible for capturing and keeping the design information up-to-date as part of managing the Golden Thread of information.
- During the construction design phase, the Golden Thread of information will be handed over to the principal contractor, who will then be responsible for managing the Golden Thread of information and keeping it up to date. The principal designer will need to work with the principal contractor, to ensure any changes to design work are captured in the Golden Thread of information.
- On practical completion, the client must hand over the Golden Thread of information to the relevant person (i.e. principal accountable person, accountable person or responsible person as described above).
How must the Golden Thread be stored?
The regulations implementing the BSA set out how the information must be stored and the key requirements (and supplemented by the guidance from the Government and the Construction Leadership Council) indicate that the information must:
- be kept in an electronic format and be capable of being transferred electronically to other people;
- be accurate and up to date;
- be held in a secure system;
- be made available as soon as reasonably practicable following a request from a principal designer or principal contractor; and
- provide a record-keeping system so that if the information is amended, it must be clear who made the change and when.
What happens if these requirements are not complied with?
A breach of the Golden Thread requirements can result in criminal liability. For example, when an accountable person or principal accountable person stops being responsible for a higher-risk residential building or any part of it and they do not transfer the Golden Thread of information to the new accountable person or principal accountable person, they can be prosecuted, leading to a fine and up to two years' imprisonment (or both).
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