Following the UK Building Safety Act

The new Building Safety Act 2022 that came into force in October 2023 – is the most significant change in building legislation in a generation, changing the way buildings are designed, built and managed. This is a fundamental shift for those involved in the supply chains and those providing products and services offering Passive Fire Protection of structural steel.

This new act includes building managers, asset owners, contractors, specifiers, and designers, each of whom must understand their roles and responsibilities.

The major element of the change is what is known as the Golden Thread. The Golden Thread is a digital record of all aspects of the fire protection installed, including application records, theoretical product thickness, data sheets and anything relevant to the steel's fire protection provision.

By following the requirements set out in the Golden Thread, those involved can be assured that they are creating a safe, efficient building.

Why you should engage early in the Golden Thread process

Engaging with multiple stakeholders - including designers, fabricators and applicators - early and consistently throughout the process is vital to delivering a successful, safe and cost-efficient solution. Working together, we share knowledge and help our clients to reach their goals; after all, we are all now part of this renewed responsibility. 

We want to help our customers capture relevant data on the use of our intumescent coatings so that they can provide digital information on safety and quality to their customers. This information also provides a sound basis for future decision making.

The Golden Thread runs through what are known as three Gateways of the process. All three gateways are essential from the outset to completion and occupation so that end users can be assured of compliance, quality and safety and have confidence in the products used to provide fire and life safety – in particular ‘safety critical’ components.

To protect structural steel with intumescent coatings, the engineering community and the supply chain must understand more detail of specific gateways than others. 

Golden Thread: The Three Gateways offer clear guidance

Gateway 1 – covering the planning stage, has been in force since August 1, 2021, and sets out the framework for the second and third stages. Applicants need to demonstrate that fire safety matters have been incorporated into the planning stage for all buildings. 

If a fire statement is required to be submitted with a planning application, it will be an issue for consideration for the Local Planning Authority (LPA) when reaching its decision on the application. Contractors should note that if the LPA considers the statement inadequate, it can refuse the application.

Gateway 2 – submitting building control approval to the Regulator to enable construction to start. This should include written declarations covering the competency of the main contractor, and designer, a description of works and plans and a planning statement from Gateway 1. 

Gateway 3 – providing information to ensure the building is safe for occupation. Submitting a completion certificate application and providing updated plans is required.

Under the terms of the act, the term competence is a core requirement.  As part of this part of the act, the Building Safety Regulator (BSR) has introduced an Industry Competency Committee whose role will be to monitor and improve industry competence. This is fulfilled by regularly publishing guidance and advice available to the industry.

The registration must be made by the organisation or person who owns or has responsibility for the building, to be known as the Principal Accountable Person, including contractors, building managers, building owners and housing associations.

In addition to registering the building, the Principal Accountable Person must have assessed all building safety risks and taken all reasonable steps to control them, give the safety case report to the BSR on request and apply for a building assessment certificate when relevant. This means working with specialists where relevant to help the process along.

Understanding your role under the Building Safety Act

We at Sherwin-Williams welcome this new guidance. Now, we must use it. We are all responsible, and have our parts to play in this new process. Finding your way around your own part in it will help everyone involved stay safe and secure.

Structural engineers, designers and specifiers will be more concerned with the requirements under gateways one and parts of two. Applicators will need to understand parts of Gateway Two and Gateway Three, while fabricators will need to understand the broader picture across all three gateways.

If you are the Principal Accountable Person, you have to show that the building was compliant with applicable building regulations during its construction and provide evidence of meeting the requirements of the new building control route throughout the building’s design and construction and refurbishment. 

A Principal Accountable Person who fails to register an occupied higher-risk building without a ‘reasonable excuse’ will be liable to either a fine or imprisonment for a term not exceeding two years.

It is the responsibility of each Principal Accountable Person to provide the right information to the supply chain - including those bidding for the intumescent fire protection package - who in turn are responsible for all information being passed onto us is accurate.

Remember, whoever you are in the supply chain developing these buildings, you have a part to play.