CHANGES TO BUILDING REGULATIONS AND FIRE SAFETY – PART 2 A DUTY HOLDERS 31-07-2026
Date: 31 July 2026
Recorded session: Approximately 1 hour 39 minutes of transcribed discussion
Main speakers: Margaret Sackey, Gary Watts and Ivan Young, with contributions from Debbie Carlton, George Stevenson, Howard Hall and others
Executive summary
The workshop focused on translating the Building Safety Act into practical project controls. The central message was that clients and duty holders must define responsibilities early, appoint people who are competent for the specific work, maintain verifiable evidence, control change and secure complete lifecycle information. Gary Watts explained the legal and management-system duties; Ivan Young demonstrated a technology approach to competence evidence, drawing comparison, RFIs, Golden Thread records and as-built outputs. The closing discussion exposed unresolved industry gaps around competence definitions, RIBA/gateway alignment, contract responsibilities, regulator guidance and the consistent production of verified as-built information.
1. Purpose and context
- Workshop 7 continued the monthly USHA/BIM/BSA/FSA series on practical implementation of the Building Safety Act and related fire-safety duties.
- Margaret Sackey framed the session around collaboration between university fire-safety teams, built-environment professionals, clients, designers, contractors and consultants.
- The two principal contributions were Gary Watts on duty-holder and information-management obligations, and Ivan Young on using the Strand platform to evidence competence, compliance, change control and project information.
2. Duty holders, accountability and information assurance
- Gary Watts described the post-Grenfell regime as requiring stronger culture, accountability, evidence and traceability across design, construction and occupation.
- Clients were presented as active duty holders who must plan, manage and monitor work; appoint competent principal designers and principal contractors; coordinate the project team; and obtain enough evidence to support compliance declarations.
- Where a client fails to make the required appointments, the client may inherit those duties. Appointment terms, project briefs and construction control plans therefore need to be explicit and agreed in writing.
- Gary highlighted potential organisational and personal liability, including Section 161 of the Building Safety Act, where senior officers act through consent, neglect or negligence.
- Designers and contractors must cooperate, report compliance concerns and provide sufficient information about design, construction, maintenance and completed work to the client.
- Fire-safety and handover records should be complete, accurate, transferable and verifiable, supporting operation, inspection, testing and maintenance throughout the building lifecycle.
3. Refurbishment and operational fire safety
- A refurbishment case study showed that new services, penetrations and temporary ceiling removal can affect compartmentation, escape routes, smoke control and evacuation arrangements.
- The project team should assess whether proposed work constitutes a significant change, review the fire strategy, update fire-risk information and establish temporary controls during construction.
- Handover information should record changes to fire-safety measures, compartmentation, fire stopping, doors, ventilation, certification, drawings and plans.
4. Defining and demonstrating competence
- Debbie Carlton argued that competence assessment must begin with the demand side: the duties, work package, context, expected outcomes and performance requirements of the actual project.
- The discussion distinguished general personal attributes from project-specific capability. Skills, knowledge, experience and behaviours must be assessed in the context of the work to be performed.
- Participants noted that scarce competent resources may require combined teams, additional supervision or different sequencing rather than relying on a single qualification or individual.
- The client remains the ultimate duty holder and must appoint competent people, while the principal designer should help the client understand the competence required for the project.
- The group emphasised the need not only to be competent, but to retain evidence demonstrating why appointments and decisions were reasonable at the time.
5. Strand demonstration
- Ivan Young demonstrated Strand as an email-driven project information system intended to ingest, classify and track project records without requiring users to learn a separate interface.
- The demonstration compared drawing revisions, detected undeclared changes, generated RFIs, identified cost and risk impacts, and created entries for the Golden Thread.
- Strand was described as maintaining an immutable project-state record, tracking decisions and originators, and producing reports for specific packages at a defined point in time.
- Ivan said the system scores submitted evidence against competence and compliance standards, while decisions remain with named human stakeholders rather than the software.
- For Gateway 3, the system is intended to preserve the consented Gateway 2 design, track subsequent change, ingest site evidence and generate verified as-built information.
6. Gateways, RIBA stages and as-built information
- A major discussion concerned the lack of a fully coordinated relationship between Building Safety Regulator gateways and the RIBA Plan of Work.
- Participants agreed that Gateway 3 requires reliable as-built information, yet contractual expectations and standard project stages do not always make responsibility for producing it sufficiently explicit.
- Howard Hall described the gateway regime and RIBA stages as separate processes that have been mapped together without complete coordination of definitions, outputs and contractual responsibilities.
- The group highlighted recurring gaps between shell-and-core, fit-out and client works, where parties make assumptions without receiving verified as-built records and later commission measured surveys to reconstruct missing information.
- There was concern about regulatory ambiguity, inconsistent contract forms and limited regulator capacity, alongside support for developing practical examples and industry guidance.
7. Agreed and proposed follow-up actions
- Bring Anthony Taylor back for a future workshop to explain the Construction Leadership Council guidance on handover information requirements.
- Continue work on clear definitions and expectations for as-built drawings, O&M information and lifecycle handover records.
- Clarify project-specific competence requirements before assessing individuals or organisations, including client competence and capability.
- Make appointment terms and construction control plans explicit about information, evidence, declarations, change control and handover responsibilities.
- Ensure refurbishment projects review temporary and permanent impacts on compartmentation, evacuation, fire strategy and building information.
- Publish the workshop recording, notes and slides when available, and use attendee feedback to shape future sessions.
- Hold the next workshop at the end of September and share learning from the series with the USHA board and conference.
8. Open questions
- How should client competence be continuously determined, assessed and verified?
- What evidence is sufficient to demonstrate competence for a particular role, building type and work package?
- How should legacy experience be assessed where formal qualifications did not historically exist?
- Who contractually owns the production, verification and approval of as-built information?
- How should gateway deliverables align with RIBA stages, JCT/NEC contracts and different phases of fit-out?
- How can technology support assurance without creating over-reliance on automated outputs?
Source note: This document summarises the supplied meeting transcript. Legislative and product claims are attributed to the discussion and have not been independently verified.