The Building Safety Act 2022 marks a defining moment in the UK’s approach to managing fire and structural safety in higher-risk residential buildings. Introduced in response to the Grenfell Tower tragedy and subsequent inquiries, the Act introduces a new regulatory regime that aims to prevent such disasters from happening again. The legislation places greater accountability on those involved in the lifecycle of a building, from design and construction to occupation and ongoing management.
This includes clear legal duties for dutyholders and Accountable Persons (APs), a rigorous Gateway approval process, and the mandatory use of digital record-keeping through the Golden Thread of information. Importantly, it also strengthens the voice of residents by mandating engagement strategies that keep them informed and involved in decisions affecting their safety.
At RAM Building Consultancy, we help clients navigate this complex framework with confidence. From pre-construction planning and drone-enabled diagnostics to compliance documentation, Gateway support, and digital Golden Thread management, our end-to-end service ensures clients remain on track and compliant at every step.
Understanding the Roles: Dutyholders, APs and PAPs
Who’s Who under the Act
The Building Safety Act clarifies who holds legal responsibility at each stage of a building’s development and occupation. During the design and construction phase, the primary Dutyholders include the Client, Principal Designer, and Principal Contractor. Each must ensure that building work complies with all relevant safety requirements, and that risks are identified, managed, and recorded appropriately.
Once a building is occupied, responsibility shifts to the Accountable Person (AP), typically the building owner or managing entity. Where multiple APs exist (such as in buildings with mixed ownership), one must be appointed as the Principal Accountable Person (PAP). The PAP takes overall responsibility for building safety, overseeing regulatory interactions and ensuring consistent compliance.
Their core duties include:
- Registering higher-risk buildings with the Building Safety Regulator (BSR)
- Compiling and maintaining the Safety Case Report
- Managing the digital Golden Thread of information
- Ensuring all contractors and managers are demonstrably competent
- Responding to incidents and ensuring resident engagement protocols are followed
Why Clarity of Roles Matters
Failing to define and communicate roles clearly can lead to project delays, legal non-compliance, and unmanaged safety risks. More seriously, unclear responsibilities can result in criminal penalties or regulatory enforcement if things go wrong.
That is why clear documentation, role mapping, and internal governance structures are essential. RAM Building Consultancy offers tailored competence frameworks that define who is responsible for each part of a project and support clarity through tools like drone-based building assessments, visual mapping of risk zones, and bespoke documentation audits. This clarity underpins not just legal compliance but effective handovers and smoother project delivery.
Navigating the Gateways: Planning for Occupation
Gateway 1 – Planning Gateway
Gateway 1 is designed to front-load fire safety considerations in the planning phase. Before a planning application is approved, a Fire Statement must be submitted. This document demonstrates how fire safety has been considered in the design, layout, and access arrangements for the building.
The Health and Safety Executive (HSE) now acts as a statutory consultee at this stage, reviewing fire statements to ensure they align with safe design principles. Without HSE agreement, the local authority cannot grant planning permission.
RAM supports Gateway 1 compliance by collaborating with design teams to:
- Identify key fire risks early in the concept stage
- Develop robust fire strategies embedded in architectural plans
- Prepare and submit compliant Fire Statements that meet HSE standards
This proactive approach reduces the likelihood of costly design changes further down the line.
Gateway 2 – Building Control Approval
Before any construction begins, developers must pass through Gateway 2 by submitting comprehensive documentation to the Building Safety Regulator. This gateway replaces traditional building control approval for higher-risk buildings and introduces more rigorous scrutiny.
The submission must include:
- Full design plans and technical specifications
- A Construction Control Plan outlining how risks will be managed on site
- A Competence Declaration confirming the qualifications of all dutyholders
- A Change Control Plan to track and record any design changes
- A Fire and Emergency File detailing fire safety systems and procedures
- A strategy for Mandatory Occurrence Reporting (MOR)
- A Developer Statement confirming compliance intentions
Digital formatting, naming conventions, folder structures, and secure uploading all matter here. Mistakes can delay approval significantly.
RAM offers end-to-end support at Gateway 2, including:
- Document preparation and formatting for digital portals
- Pre-submission compliance reviews
- Liaison with the Regulator to streamline validation and approval
Gateway 3 – Completion & Occupation
Before residents can occupy a new higher-risk building, Gateway 3 requires that several conditions are met:
- The full Golden Thread of information must be handed over
- A Completion Certificate must be obtained from the Regulator
- The building must be registered with the BSR
- A Building Assessment Certificate must be issued to the PAP
RAM coordinates the final handover process, ensuring that all records, inspections, and stakeholder communications are in place. Our team works closely with clients to secure approvals efficiently and to avoid costly delays during the transition from construction to occupation.
Golden Thread of Information: What, Why, How
What Is the Golden Thread?
The Golden Thread is a digital, structured, and up-to-date record of safety-critical building information. It spans the full building lifecycle and includes everything from material specifications and structural systems to fire safety features, maintenance history, and changes made over time.
The objective is to create a transparent and accessible record that can be used by those responsible for managing the building, including future APs, facilities managers, contractors, and the Regulator, to ensure that risks are continuously understood and controlled.
Regulatory Foundations
The legal basis for the Golden Thread comes from Section 88 of the Building Safety Act and is enforced through various secondary regulations:
- The Higher-Risk Buildings (Key Building Information) Regulations 2023
- The Management of Safety Risks Regulations 2023
- The Keeping and Provision of Information Regulations 2024
These define exactly what must be stored, who must manage it, and how it must be made available.
Operational Requirements
To be compliant, the Golden Thread must be:
- Digital and securely stored
- Transferable between parties
- Intelligible and accessible to all intended users
- Updated regularly to reflect any changes
Initially maintained by the client and dutyholders during construction, it becomes the responsibility of the PAP once the building is occupied.
RAM sets up bespoke digital Common Data Environments (CDEs), integrates drone and thermal imagery, automates record-keeping, and supports change control. This approach gives clients a real-time, reliable foundation for compliance, maintenance, and risk management.
Safety Case Report & Resident Engagement
Safety Case Report
The Safety Case Report is a central requirement for occupied higher-risk buildings. It must demonstrate that the PAP understands the building’s fire and structural risks and has effective controls in place.
The report should include:
- Identified hazards and risk assessments
- Measures in place to prevent or mitigate those risks
- Evidence sourced from the Golden Thread
- Operational plans and emergency procedures
RAM helps compile and validate the Safety Case by:
- Auditing the building and sourcing evidence
- Structuring the report in line with Regulator expectations
- Reviewing for coherence with the Golden Thread
- Preparing supporting documentation and plans
This ensures that the Safety Case is not only compliant but also credible and robust under regulatory scrutiny.
Resident Engagement Strategy
In a major shift towards transparency, the Act requires that residents are kept informed and engaged about safety in their buildings.
The PAP must maintain a formal Resident Engagement Strategy that outlines:
- How residents are informed about safety features
- How changes and incidents are communicated
- How residents can raise concerns or provide feedback
RAM supports this requirement by:
- Designing communication plans and resident-friendly briefings
- Creating accessible information packs tailored to different demographics
- Managing contact logs and tracking feedback trends
- Ensuring all engagement is documented and ready for regulatory review
Compliance Checklists, Templates & Competence
Practical Tools
A range of industry checklists and templates are available to help dutyholders comply with the Act. These include formats for:
- MOR systems and incident logs
- Drone-led envelope inspections
- Safety Case evidence logs
- Competence recording and contractor vetting
RAM customises these tools based on each client’s needs and building profile. Our digital-first approach helps streamline workflows, reduce duplication, and maintain consistent documentation across the lifecycle of the building.
Competence Framework & Timelines
Competence is a core principle of the Act. Everyone involved, from architects to fire assessors, must be able to prove that they are qualified, experienced, and capable.
Compliance with the BICoF (Building Industry Competence Framework) is essential, as is timely action. Key deadlines include:
- Gateway submissions
- Building registrations
- The end of transitional arrangements in April 2024
RAM offers structured governance frameworks to:
- Vet supply chain competence
- Audit internal skills and qualifications
- Track progress against timelines and regulatory stages
This ensures that no element of the project falls behind or fails to meet legal standards.
How RAM Building Consultancy Can Help
RAM provides a holistic service for clients navigating the Building Safety Act. Our team brings technical expertise, regulatory insight, and practical tools to help you stay compliant without adding unnecessary complexity.
We support you through every stage:
- Diagnostic Surveys: From thermal imaging to structural assessments, identifying risk early.
- Gateway Compliance: Preparing documentation, submitting to BSR, managing communications.
- Digital Golden Thread: Implementing CDE systems, capturing building data, ensuring security and accessibility.
- Safety Case & Engagement: Drafting coherent, evidence-backed reports and building trust with residents.
- Competence & Governance: Frameworks for compliance, audits, supply chain checks, and milestone tracking.
Our RICS-qualified team combines nationwide reach with local service, and our public-sector framework access ensures we can work efficiently with housing associations, councils, and private developers alike.
Conclusion
The Building Safety Act represents a paradigm shift in how the UK approaches the safety and accountability of higher-risk buildings. From the planning phase through to long-term occupation, the emphasis is on transparency, competence, and robust record-keeping.
Failure to comply could result in delays, reputational damage, or even criminal penalties. But with the right guidance, these risks can be effectively managed.
RAM Building Consultancy helps clients face these challenges with confidence. Our practical, informed, and action-oriented approach ensures you stay compliant while keeping projects moving forward.
Ready to take control of your building safety obligations? Contact us today to discuss your needs, access useful resources, or schedule a compliance audit.
