Chris Hall of Siderise looks at the new design quality regime under the Building Sagfety Act, and the Gateway 2 approval for higher-risk buildings in particular, discussing what architects need to know on the documentation requirements
One of the most significant changes brought in by the Building Safety Act (BSA) is the new building control regime and approval ‘Gateways’ for higher risk buildings (HRBs) – in particular Gateway 2. Here, a full application is submitted to the Building Safety Regulator (BSR) outlining how compliance with the functional requirements of the Building Regulations will be met, and construction cannot begin until it is approved. For architects, this means that plans must be prepared with an appropriate amount of detail, particularly around key elements such as fire safety.
However, reports from the BSR suggest that so far applications have frequently lacked the level of detail and documentation necessary to progress through smoothly, leading to project delays. To help overcome this, there is a clear need for construction product manufacturers – especially those producing life safety-critical products – to provide support beyond the basics of accurate product information.
Fundamental information
Accurate and substantiated product information is essential for safe designs, regardless of the building type or use. Therefore, as standard practice, manufacturers must ensure architects have access to clear, accurate and up-to-date product information that is not ambiguous. Any performance claims should be backed up by testing carried out to the standards stipulated by the applicable compliance guidance or the regulations as a minimum. These results should be verified by accredited third-party certification bodies wherever possible for greater assurance. This data should also be captured within usable BIM models which have been authored to industry standards such as the NBS BIM Object Standard.
However, a common misunderstanding is that Gateway 2 is simply an assessment of the building design. The BSR states that plans need “to outline exactly how compliance with the functional requirements of the Building Regulations is going to be met – and that they do not rely on unrealistic management expectations.” This means that there needs to be detailed justifications of why certain products or approaches are being used on a specific project and how they contribute to compliance. For this to happen, contractors and specialists must not only be brought into the design process at a much earlier stage than what had become the norm, but manufacturers must be ready to share their expertise to ensure products are used correctly to support compliance and long-term safety of the building.
Application support
Manufacturers are often considered specialists, and are seeing an increasing trend of being asked to support designers in preparing key details or providing the right training and education at this crucial stage. This can include project-specific advice and guidance ranging from product selection and calculations, to arranging bespoke testing of specific elements.
For project teams, working with manufacturers earlier on in the construction process can also help to limit the risk of changes to specifications, as the products will not only be specified correctly for the application but will be cost factored too. The new building safety regime requires all projects to demonstrate a clear change management process. On higher-risk projects, this is prescribed by law. A “change to any part of the active fire safety measures or passive fire safety measures in a proposed higher-risk building referred to in the fire and emergency file” after Gateway 2 approval is classed as a ‘major change’ and would mean that project teams would need to refer back to the BSR. They then have up to six weeks to approve the change or request more justification. As well as incurring a fee, this could potentially cause significant delays to the build programme, as no work can begin on the area subject to the change until it has been approved.
Additionally, early involvement from manufacturers of safety critical products can help build up a bank of information that can be incorporated in or used to contribute to the Golden Thread. This can include everything from test data to a history of technical communications and training, which can be added to in later stages of construction, such as when product installation inspections have taken place.
Of course, for manufacturers to be a genuinely useful resource during the pre-construction phase, it is vital that the industry feels confident in their skills, knowledge, experience and behaviours. Therefore, manufacturers need to make a clear commitment to competency and upskilling. This ensures that design or product suitability advice is backed by accurate and accessible product data and has been delivered by someone competent enough to interpret the project needs and requirements, understand any potential parameters or limitations, and identify the right solutions.
Supporting safety
Gateway 2 is a real opportunity for the industry to ensure the highest levels of fire and building safety are inherent to the design from the outset. Manufacturers of life safety critical products can lend their expertise and experience to support designers in producing detailed applications that demonstrate the diligence necessary to create safe and long-lasting buildings.
Chris Hall is external affairs director at Siderise