The government will not set a time limit on how responsible people must share golden thread information with the building safety regulator (BSR) and others, despite responses to a query asking for a precise time frame.
In a July 2022 consultation, the Department for Leveling, Housing and Communities (DLUHC) said that the golden thread information for the highest risk buildings (see box below) must be shared “in a timely manner” with the BSR, the responsible person(s) and the client.
A response to the consultation was published this month, with some calling for a definition of the term “timely manner”. One respondent suggested creating “a clear enforcement process and sanctions against […] responsible persons who refuse, or do not, to share information”.
The inquiry included a question about handing over information from one responsible person to another. Nine out of 51 respondents said a time limit should be set to facilitate enforcement.
But the DLUHC’s response said it would only stipulate that the information be shared “as soon as reasonably possible”.
He added: “We believe that enabling the right people to have the right information at the right time is essential to support the management of building security risks and the safety of residents. While we understand the requests of a precise time limit for sharing information and documents, we believe that requiring time limits in legislation will be too inflexible.”
The department also said it does not believe it is “necessary to mandate the frequency with which golden thread information is reviewed[ed] and updated”. However, some data and documents will need to be kept up-to-date at all times.
Under the Building Safety Act (BSA) 2022, the responsible person is the organization or person who owns or has a legal duty to repair a building. The responsible person is the company or person who has a legal duty to ensure fire safety under the Fire Safety Order 2005.
DLUHC plans that when a responsible person changes, such as through the sale of a building, it is required to release the golden thread information to the new responsible person.
It will also be a requirement to share some of the information with the residents of the buildings.
The Golden Thread concept comes from Dame Judith Hackitt’s review of building safety following the Grenfell Tower tragedy in 2017. She identified the need to collect, store and maintain critical information on higher risk residential buildings during the life cycle of the building.
The BSA came into force without this provision, but it is expected to be introduced in the coming weeks through the High Risk Buildings (Preservation and Provision of Information, etc.) (England) Regulations 2023.
The Golden Thread: What Should You Include?
The information and documents to be stored on the golden thread will include:
- The application and certificate of completion or partial completion (for those buildings that have gone through the new building control process for higher risk buildings).
- Copy of any certificate issued for work carried out under a competent persons plan.
- Fire safety information and documents that the client of the program work (carried out under a competent person scheme) must provide to the responsible person.
- Registration information.
- Key building information.
- Building Assessment Certificate Application and Certificate (and any notice given by the Regulator where an application for a Building Assessment Certificate is refused).
- Information and documents related to fire safety management.
- Information and documents relating to the evacuation of the highest risk building.
- Information and documents to be provided to the fire and rescue service in accordance with regulations 4, 5, 6 of the Fire Safety England Regulations 2022.
- Information and documents related to structural safety and structural risks.
- Building security risk assessments and documents and information related to building security risk management, including the security case report.
- Information related to building design (ie design codes, standards and design intent applied to construction).
- Construction plans.
- Information and documents related to the mandatory notification of incidents.
- Information and documents that will be proactively provided to residents.
- Information and documents about relevant complaints.
- Copies of any infringement notices.
