In the realm of construction, change is a constant. But amidst the cacophony of regulations and standards, a new symphony has emerged – the Building Safety Act 2022. Intended to reform building safety, this legislation aims to improve the design, construction and management of all buildings, with additional requirements for higher-risk buildings in England – those at least 18 metres or seven storeys high and containing two or more residential units. 1

What is the Building Safety Act?

The Building Safety Act 2022 (BSA) is a pivotal piece of legislation. Enacted in response to a government commissioned Independent Review led by Dame Judith Hackitt following the tragic events of the Grenfell Tower fire, its primary goal is to enhance safety and accountability within the UK construction industry.

This groundbreaking Act doesn’t just tweak existing laws - it reshapes the entire framework laid out by The Building Act 1984 – the primary legislation that introduced Building Regulations. It also grants the authority to introduce new secondary legislation – legislation that provides the detailed rules, regulations and procedures necessary for implementing the overarching Act effectively.

The core aim of the BSA is to establish a comprehensive framework for ensuring the safety of buildings throughout their lifecycle – from initial design and construction to ongoing occupation and maintenance. However, its focus is largely on structural and fire safety, rather than other aspects of building safety. Key provisions within the BSA include the expansion of building safety regulations to cover a wider range of structures (such as mixed-use developments and structures with external cladding systems), the creation of a dedicated Building Safety Regulator to oversee compliance and enforcement and the implementation of rigorous safety standards and procedures to mitigate risks and enhance transparency.

The BSA: a Brief Timeline

Introduced to parliament in July 2021, the BSA received Royal Assent on 28th April 2022, officially taking effect on 1st April 2023. However, the new regulatory regime for higher-risk buildings came into force on 1st October 2023, albeit with some transitional arrangements for ongoing projects.

On 6th April 2024, the six-month transition period ended, ushering in the full implementation of the new regime. This included the establishment of Registered Building Control Approvers (replacing the Approved Inspector role), along with the introduction of Registered Building Inspectors. Additionally, it was the date when the new duty-holder requirements became fully operational. 2

However, concerns soon emerged regarding the ability to assess all the organisations and individuals wishing to become Registered Building Control Approvers (and Inspectors) by 6th April 2024. In response, the Health & Safety Executive (HSE) extended the competence assessment period for Registered Building Inspectors until 6th July 2024, granting them more time to demonstrate their competence. 3

Failure to complete a competency assessment and upgrade their registration class by this new deadline will restrict professionals to supervised work only. With little prospect of further extensions, the looming deadline has sparked fears of a potential building inspector crisis and the possibility that construction work could “grind to a halt” if inspectors aren’t registered in time. 4

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Source: Cohesive

Key Changes and Challenges

The introduction of the BSA has been one of the biggest cultural and regulatory shifts for decades. Construction professionals must acquaint themselves with the act's nuances to adapt effectively. With its expanded scope and the introduction of a regulatory watchdog, adherence to stringent safety protocols along with transparent communication with stakeholders becomes paramount.

Embracing the changes outlined in the Building Safety Act is crucial for professionals in construction. This includes conducting thorough risk assessments, collaborating closely with the Building Safety Regulator and maintaining transparent communication channels with clients.

In this article we explore the key implications introduced by the BSA and examine how the industry must adapt. Key topics include:

  1. Gateways: Impact on Programmes
  2. Adapting Designs: The Second Staircase Rule
  3. Misconceptions Surrounding the Principal Designer Role
  4. Contractor Risk Profile and Responsibility
  5. Implications for Consultant Appointments and Scopes of Service
  6. Will the BSA Increase Preliminaries Costs?
  7. Impact on Procurement and Design Completion
  8. Does JCT 2024 Recognise the Building Safety Act?

1. Gateways: Impact on Programmes

We must remember that the BSA affects all buildings, not just those deemed higher-risk. However, for higher-risk buildings (HRBs), a specialised regime introduces three critical ‘gateway’ procedures outlined below:

  • Planning Gateway (1): At the planning application stage
  • Gateway 2: Before building work commences
  • Gateway 3: When building work is completed

These gateways serve as stop/go decision points that must be successfully navigated before progressing to the next stage of construction. These decision points are designed to pause construction or occupation until specific safety criteria are met.

The Building Safety Regulator (BSR) – the designated authority responsible for overseeing building work for higher-risk buildings – will collaborate with local authorities and fire and rescue authorities to ensure safety considerations are met at each stage.

So how will these new gateways affect construction programmes?

At each checkpoint, thorough assessments and approvals will need to be made before progressing to the next stage. As a result, construction programmes will need to incorporate additional time and resources to accommodate these gateways effectively. Delays or issues encountered during gateway assessments have the potential to disrupt project timelines significantly, resulting in costly delays. Therefore, construction programmes will need to be meticulously planned and managed to ensure adequate time is allocated for gateway reviews and approvals.

Below, we outline some of the key requirements under each gateway, along with their implications.

Gateway 1:

At Gateway 1, a Fire Statement (amongst other deliverables) needs to be submitted evidencing that specialist fire safety advice has been considered in the design before planning is granted. Given the need for the BSR to be consulted, stakeholders should be mindful that the planning determination period could take longer and therefore additional time allowances might be considered in project planning programmes.

It’ll also be important to engage early with the local fire brigade (prior to the G1 application being submitted) to avoid delays after an application has been submitted. London Fire Brigade response times, for example, have recently been as long as 18 weeks. Finally, a general shortage of competent chartered fire engineers – which clients must appoint to sign off fire strategies and produce the required fire statements – could cause backlogs and impact programme.

Gateway 2:

The next checkpoint, Gateway 2, requires building control approval from the BSR before ‘work’ can commence on site. This ‘work’ encompasses a broad range of construction activities, such as enabling works involving permanent structures, but excludes demolition. 5

This requires submission of various plans and documents – none of which can rely on assumptions about the building use. It is expected that Stage 4 design information will generally be required (given the need for contractor input at this stage). The regulator, and a multi-disciplinary team, then has 12 weeks to approve or reject the application, so construction programmes will need to allocate sufficient time for the process.

Failure to obtain approval could significantly disrupt project timelines, leading to costly delays and potential contractual penalties. This is a crucial checkpoint in the project lifecycle so it’s essential that the documents submitted are thorough and accurate, and that any regulatory concerns or queries are addressed promptly and openly.

Between Gateways 2 and 3:

During construction, between Gateways 2 and 3, various notices, compliance statements and reports need to be submitted. Record keeping must be robust and the golden thread of information 6 (including detailed as-built records) will need to be developed and maintained prior to handing over to the building owner (or the (Principal) Accountable Person) at Gateway 3. The Principal Designer (Building Regs) is primarily responsible for managing the golden thread during the design and construction phases (in conjunction with the Principal Contractor) of a building project, coordinating, and collating all the relevant information about the design, construction, materials used and any changes or modifications made throughout the process. Updating and maintaining these records has both time and cost implications, the extent of which will, in part, depend on the size and complexity of the project. 7

During the critical phase between Gateways 2 and 3, effective change management will be paramount to maintaining the integrity and compliance of the building project. Without proper setup, this process can become onerous and unmanageable, potentially leading to significant challenges and risks.

The new change control regime introduced under the BSA establishes systematic procedures for managing and documenting changes made throughout the lifecycle of the building. Any alterations to the design, construction, or materials used are carefully assessed for their impact on safety, compliance and project objectives. ‘Major’8 and ‘notifiable’9 changes have the greatest potential to cause delays and increase contract risk. Major changes, such as changing the height of a proposed high-risk building, require the submission of a change control application form to the BSR for approval. The determination process can take up to six weeks, during which time the ‘major’ change cannot be commenced.

Notifiable changes also require the client to notify the BSR and submit certain prescribed documents. The risk here is that there is no prescribed period for the BSR to reply to the notification, nor is there a “deemed approval period”. Once the BSR has been notified of the change, the client can progress that change and continue the works. However, does this put the client at risk? If the BSR were to later disagree with the change categorisation and regard it as being a major change (which might not be until applying for a Gateway 3 completion certificate), the project could face major delay. Hence, a collaborative approach with the BSR will be crucial.

Changes made under the new change control process, particularly major ones, will naturally result in increased administration and possible delay. However, there are both practical and contractual solutions to manage these risks. It will become more important than ever to get the initial design right. Creating a complete digital model of the building in BIM from the outset will help identify any potential design clashes and ensure compliance prior to submitting the building control approval application under Gateway 2. Contractually, provisions can also be added to allow extra time for the submission of applications for major changes (depending on the source and reason for a major change being required). Flexible mechanisms for granting extensions of time while awaiting BSR approval could also be added to contracts, as well as termination rights if the BSR rejects an application.

Gateway 3:

The final Gateway – Gateway 3 (also known as the pre-occupation stage) – introduces further implications for the programme.

After submitting an application to the BSR (which requires compliance declarations being made by the dutyholders) there is another statutory determination period of 12 weeks. However, before submission, all the prescribed documents need to be prepared (including the fire & emergency file), reflecting the as-built building. Each construction phase dutyholder must declare that the building satisfies all the functional requirements of the Building Regs. The BSR then undertakes inspections, assessing whether the building work complies with the regulations before issuing a completion certificate.

Once again, preparing the comprehensive documentation, as well as the regulatory review process itself takes time. There is also the potential for remediation and rectification works to address any non-compliance with building safety regulations. These works can impact the construction programme by adding additional tasks, costs and time to the project schedule.

Gateway 3 is also the stage when the Principal Contractor hands over the golden thread of information to the building owner. The process of gathering all the relevant information, organising/categorising it and then verifying its accuracy and completeness, will have both time and cost implications. Larger and more complex projects may require more time to gather and document the necessary information, while smaller projects may be completed more quickly. Similarly, the cost of compiling and handing over the golden thread can also vary depending on the resources and effort required. Any delays or inefficiencies in the process could extend project durations or necessitate additional resources to address the issues.

Once Gateway 3 approval has been granted, the client can register the building for occupation (with the building being registered as a HRB on the BSR register) and will receive a Building Assurance Certificate which should be displayed publicly in the completed/occupied building.

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2. Adapting Designs: The Second Staircase Rule

Another pivotal change introduced by the BSA is the requirement for a second staircase in all new high-rise residential buildings above 18m. This mandate aims to enhance fire safety and evacuation procedures. For designers, this is a fundamental shift in approach, necessitating meticulous planning and integration of additional elements into designs. The challenge lies in balancing safety requirements with aesthetic considerations and practicality, requiring a delicate dance of creativity and compliance.

The rule requires a reimagining of building layouts and spatial configurations. Designers must integrate this additional element into their plans, considering factors such as access and egress points, circulation flow, and spatial efficiency. Each design decision must be weighed against its impact on safety protocols, ensuring that the second staircase seamlessly integrates into the building's overall architectural vision.

However, the rule extends beyond structural and architectural considerations, permeating into broader aspects of building design. It prompts a re-evaluation of building materials, construction methods and occupancy capacities, requiring designers to adopt a holistic approach to building design. Collaborative engagement with structural engineers, fire safety specialists and regulatory authorities will be essential to navigate the intricacies of compliance.

Moreover, the rule requires a reassessment of emergency evacuation procedures and protocols. Designers must devise comprehensive evacuation plans that account for the presence of multiple staircases, addressing factors such as evacuation routes, signage and accessibility for individuals with disabilities. Simulations and mock evacuations may be necessary to provide insights into the efficacy of these plans, allowing designers to refine and optimise their approach to emergency preparedness.

Although the Government has given developers a 30-month transitional period to comply with the second staircase requirements (expiring in September 2026)10, the new requirement represents a paradigm shift in residential building design – one that will require a multifaceted approach. Designers will need to navigate a complex interplay of safety imperatives, aesthetic considerations and functional requirements, harnessing their creativity and expertise to create buildings that prioritise both safety and architectural excellence in equal measure.

Although the Government has given developers a 30-month transitional period to comply with the second staircase requirements, the new requirement represents a paradigm shift in residential building design – one that will require a multifaceted approach.

3. Misconceptions Surrounding the Principal Designer Role

An area of confusion that has surfaced since the implementation of the BSA pertains to the role of the Principal Designer under the Act. Despite efforts to clarify responsibilities, misconceptions persist, leading to ambiguity and potential gaps in accountability.

The confusion appears to lie in differentiating the responsibilities of a Principal Designer under the new Building Regulations from those under the Construction (Design and Management) Regulations (CDM). The role shares a title but is governed by two different pieces of legislation and thus have different responsibilities.

For any project subject to Building Regulations, there is now a requirement to appoint two Principal Designers – one under Building Regulations and another under CDM Regulations.11

Their respective responsibilities are as follows:

  • Principal Designer (BR) – must plan, manage and monitor the design work during the design phase of a building. They ensure that the design complies with the Building Regulations.
  • Principal Designer (CDM) – must plan, manage and monitor the pre-construction phase of a project and to co-ordinate matters relating to health and safety.

The Principal Designer (CDM) focuses specifically on health and safety compliance under the CDM Regulations, whereas the Principal Designer (BR) ensures compliance with the broader set of Building Regulations governing the design and construction of buildings. Clients need to understand the role of each Principal Designer when making appointments but should note that these roles can be carried out by the same person or company (providing they have the requisite skills, knowledge, experience and competence).

The Principal Designer (CDM) role typically resides with the project’s architect, which means we can expect architectural firms to extend their services to include the new role of Principal Designer (BR). However, to take on this responsibility, architects will need to enhance their expertise by deepening their understanding of all Building Regulations. Alternatively, opting for a contractor 12 or an independent professional (sub-contracted by the architect) might prove more effective. Such an expert could effectively scrutinise and question the architect’s designs, ensuring they align with Building Regulation requirements. The HSE specifically notes that the Principal Designer (BR) should be part of the design team, assuming an influence over design decisions.

With a surge in demand for Principal Designers (BR) due to the BSA, concerns have arisen about the market's capacity to meet this demand. All projects needing a new Building Regulations application must now have a Principal Designer (BR), posing challenges in terms of expertise and resource. Stakeholders will need to invest in training and development initiatives to expand the pool of qualified PDs and ensure adequate capacity to support project delivery.

4. Contractor Risk Profile and Responsibility

The BSA heralds a paradigm shift in contractor risk profiles. While contractors have always borne a degree of risk on their projects – particularly given the industry’s fondness of design and build contracts – the BSA now places a greater emphasis on accountability and ownership throughout the project lifecycle.

In addition to traditional risks such as delays and cost overruns, contractors now face heightened scrutiny regarding the safety and compliance aspects of their work. This enriched scope of responsibility underscores the need for contractors to adopt robust quality assurance and compliance strategies that encompass not only the technical aspects of construction but also compliance with regulatory requirements and adherence to safety protocols.

Furthermore, under the BSA, contractors are expected to take ownership of project outcomes, including the long-term safety and integrity of the buildings they construct. This places a greater onus on contractors to ensure their work meets not only the immediate project requirements but also the long-term sustainability and safety standards mandated by the legislation. In practical terms, this may involve implementing additional quality control measures (enhanced assessment of their supply chain), conducting regular inspections and maintenance, and providing ongoing support to building owners and occupants to ensure continued compliance with safety regulations. These additional requirements will undoubtedly entail additional costs for clients.

Another key element of the risk equation is insurance, and how the BSA will affect policy terms and related premiums for Contractor’s All Risks (CAR) and professional indemnity insurance. The BSA introduces greater regulatory oversight and stakeholder scrutiny, placing contractors under heightened risk exposure to claims from clients, building occupants and regulatory authorities. As a result, insurance providers may adjust policy terms and premiums to reflect the increased risk profile of contractors operating under the new regulatory framework. Additional coverage may also be required to meet the evolving safety and compliance standards mandated by the legislation. With claims and premiums anticipated to rise under the BSA, contractors may need to budget for higher insurance expenses and clients for rising preliminaries costs.

Other examples of how the BSA will affect contractors’ risk profiles include expanded liability for defects, deficiencies and non-compliance with building safety standards. Contractors may be held financially responsible for rectifying these issues, potentially leading to costly remediation efforts and legal disputes (particularly given the introduction of Remediation and Remediation Contribution Orders), as well as more stringent requirements under the Defective Premises Act 1972. Contractors will also have a heightened focus on risk management practices and maintaining comprehensive documentation throughout the project lifecycle. This includes conducting thorough risk assessments, implementing robust quality control measures and documenting all aspects of construction activities to demonstrate compliance with regulatory requirements.

Overall, the BSA will compel contractors to adopt a more proactive approach to risk management, regulatory compliance and collaboration to mitigate potential liabilities and ensure the successful delivery of safe and compliant construction projects. Project teams must ensure that there is absolute clarity in preliminary documents as to who is responsible for which elements of BSA compliance, particularly in relation to the higher-risk building regime.

5. Implications for Consultant Appointments and Scopes of Service

The legislation's impact extends to all parties in a project team. Consultants must also adapt their offerings to align with the evolving regulatory framework with new safety and building standards, while also mitigating liability. This shift requires consultants to review and potentially revise their contractual agreements to clearly define responsibilities and expectations, minimising the risk of conflicts and disputes throughout the project lifecycle.

Under the BSA, consultants face expanded responsibilities. These could include additional requirements related to building safety, fire protection and compliance with new regulations. As a result, consultants may need to adjust their scopes of service. Also, with a greater emphasis on accountability, consultants will be held more accountable for ensuring their designs, plans and recommendations comply with building safety regulations. This could influence the way consultants approach their work and interact with clients and other stakeholders.

Practical implications include the need for consultants to conduct thorough assessments of their existing service offerings to pinpoint areas that may require updates or enhancements to meet the new regulatory requirements. For instance, architects and engineers may need to incorporate additional safety measures into their designs. Similarly, project managers may need to implement new protocols for overseeing construction activities to ensure compliance with building regulations (eg compliance statements and agreeing on a change control procedure for HRB projects with contractors).

As mentioned earlier, the potential for programme delays because of the higher-risk building regime (gateways 1 - 3) needs to be considered relative to consultant fees. Clarity in consultant fee proposals and subsequent appointments is required to ensure clients can obtain as much fee fixity as possible given the current unknown efficiency of the gateway 2 & 3 processes.

Finally, consultants must stay informed about regulatory updates and industry best practices to provide value-added services to their clients. G&T is seeking to do this by attending industry training sessions (including those presided by the HSE), participating in professional development activities and actively engaging with regulatory authorities (eg building control officers and fire safety inspectors) to remain abreast of the latest developments in building safety standards and regulations. By proactively adapting to the changing regulatory landscape and providing comprehensive and compliant services, G&T will continue to deliver world class services to its clients while mitigating potential risks and liabilities associated with the BSA.

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6. Will the BSA Increase Preliminaries Costs?

The BSA introduces new requirements and responsibilities related to building safety and compliance. This is likely to have an impact on preliminaries – the cost of site-specific overheads on a project. 13 Under this legislation, various parties involved in the construction process may incur additional costs associated with fulfilling their obligations. Here's a breakdown of potential impacts and responsibilities regarding preliminaries costs:

Contractors: Contractors may have to increase preliminaries costs as they take on greater responsibility for ensuring compliance with building safety regulations. This could include expenses related to implementing new safety measures, conducting additional inspections and tests and maintaining comprehensive documentation to demonstrate compliance.

Consultants: Consultants may also incur additional preliminaries costs as they adapt their scopes of service to meet the requirements of the BSA. This could involve investing in training and professional development to stay informed about regulatory updates and industry best practices.

Clients/Developers: Clients and developers may bear some of the preliminaries costs associated with ensuring compliance with the BSA. This could include expenses related to hiring consultants with expertise in building safety, conducting pre-construction assessments and risk assessments and obtaining necessary approvals and permits from regulatory authorities.

Insurance Providers: Insurance providers may adjust premiums for CAR and professional indemnity insurance to reflect the increased risk exposure and liability associated with the BSA. Contractors and consultants may need to budget for higher insurance costs to protect against potential liabilities and claims arising from construction projects.

Overall, the impact of the BSA on preliminaries costs will vary depending on the specific requirements and responsibilities of each party involved in the construction process. The net effect, however, will almost certainly be inflationary.

7. Impact on Procurement and Design Completion

The legislation's impact on procurement and design cannot be overstated. The requirement for designs to be completed and building regulations submitted prior to commencing construction adds complexity to procurement processes. The definition of "completed" designs poses a challenge, potentially extending project timelines and increasing costs. The requirement for completed designs places additional pressure on design teams to deliver comprehensive and accurate documentation within tighter timeframes. This may necessitate additional resources, such as hiring specialised consultants or investing in advanced design software, to ensure designs meet the rigorous standards set out in the BSA.

Given the level of design information required for Gateway 2 (RIBA Stage 4 design) applications under the higher-risk building regime, project teams are grappling with ways to maintain competitive commercial practices in the contractor market (given the need to embed Principal Contractors within project teams prior to the submission of the Gateway 2 application). This is to ensure the design is buildable and aligns with the project’s delivery method (eg in phases or not). Consequently, the industry needs to reconsider the timing of procuring HRB projects due to the necessity of earlier contractor involvement. This shift may result in procuring contractors with less cost fixity, increasing client risk, as client-contractor design collaboration occurs earlier in the design process. Although early collaboration is beneficial, it may come at a commercial cost.

To tackle these challenges, stakeholders should embrace proactive and innovative strategies in procurement and project management. This may involve adopting agile procurement methodologies that allow for flexibility and adaptability in response to evolving design requirements. Additionally, leveraging digital technologies like Building Information Modelling (BIM) can streamline design, foster collaboration among project teams, and enhance the accuracy and completeness of design documentation.

The legislation's impact on procurement and design cannot be overstated.

8. Does JCT 2024 Recognise the Building Safety Act?

Finally, a quick note on how JCT 2024 incorporates changes to comply with the BSA. The recently released JCT Design and Build 2024 contract marks the first major update to the standard form since 2016. Many have been keenly waiting to see how the JCT would deal with the BSA, but it appears that provisions are limited.

The new 2024 contract recognises some of the requirements of the BSA, such as the new dutyholder obligations. For example, a new Article 7 has been included, which requires parties to identify who the Principal Designer and Principal Contractor will be for the purposes of the amended Building Regulations. It also requires the Employer to provide the Contractor with “building information”14 and for the Employer and Contractor to comply with their obligations under Part 2A of the Building Regulations 2010. However, there is no new drafting in the 2024 form to tackle the complexities of the new regime for Higher Risk Buildings, obligations relating to the new Gateways, Mandatory Occurrence Reporting and the Golden Thread of information requirements.

The JCT produced a separate note covering their approach to BSA compliance, acknowledging they have made no special provisions regarding these complexities. These will need to be introduced by way of a bespoke schedule of amendments, with particular attention given to who falls responsible in the event delays are caused by the gateway regime and BSR.

Adapting to the Regulatory Changes

In conclusion, the Building Safety Act 2022 represents a seismic shift in the construction industry, reshaping practices and priorities across the board. From adapting designs to clarifying responsibilities and reimagining procurement processes, stakeholders must navigate a complex regulatory landscape with agility and foresight. By embracing collaboration, innovation and a commitment to excellence, the industry can rise to the challenge and usher in a new era of safety and sustainability, which perhaps is long overdue.

With a wealth of experience and industry expertise, Gardiner & Theobald stands ready to support stakeholders in navigating these changes, offering expert guidance, strategic advice, and innovative solutions to help clients navigate the complexities of the new regulatory environment and achieve their project objectives effectively and efficiently.


1 Note: this applies to hospitals and care homes during design and construction phases only (not in occupation). Back

2 Note: ongoing higher-risk projects can continue to benefit from the transitional arrangements after 6th April 2024 providing certain criteria were met prior to the 6th April 2024 deadline. Back

3 Provided that professionals have registered by 6 April 2024 and certain other (Temporary Class 1 Registration) criteria have been fulfilled. Back

4 Back

5 In the UK, obtaining building control approval for demolition typically falls under the regulatory framework outlined in the Building Act 1984 and associated regulations, such as the Building Regulations 2010. Back

6 The new "golden thread" of information under the Building Safety Act refers to a comprehensive and transparent record of building information that must be created, maintained, and updated throughout the entire lifecycle of a building. This information includes details about the design, construction, and ongoing maintenance of the building, as well as any changes or modifications made over time. The golden thread aims to improve building safety and accountability by ensuring that crucial information is readily accessible to all relevant parties, including building owners, regulators, and emergency responders. Back

7 Additional costs may arise from the need for specialised software or tools to organise and manage building information effectively. Furthermore, the Principal Designer (Building Regs) may need to allocate resources for training and professional development to stay updated on regulatory requirements and best practices related to the golden thread. Any delays or inefficiencies in managing the golden thread could result in increased project costs due to potential disputes, rework, or regulatory non-compliance. Back

8 A major change is one that would undermine the basis by which building control approval was granted. If the controlled change is a major change, the client must make a change control application to the BSR. A major change must not be commenced until the change control application is granted. An application is expected to be determined in 6 weeks (or a longer period as agreed in writing). Back

9 A notifiable change is one that potentially has an impact on compliance. If the change is notifiable, the client must notify the notify the BSR in writing of the change and submit certain prescribed documents. Back

10 This period starts from the date the new Approved Document B was published (March 2024), so the transitional period expires on 30th September 2026. Back

11 though this may be the same person/company if they have the necessary experience and skillset. Back

12 At the point of Principal Contractor (PC) appointment, the PC could fulfil the role of Principal Designer (subject to competence). Back

13 Preliminaries are the costs that are directly related to the running of the project that are not accounted for under labour or material. Whilst they do not form a part of any of the packages of works required by the contract, are required by the method and circumstances of the works. Back

14 (under regulation 11A this is information relevant to the design or construction and about how compliance with the Building Regulations 2010 is achieved). Back