Adam Sanders explains why block managers should use consultants to help with safety cases, but that the key to success is the effective implementation of in-house management systems.
In January I wrote an article discouraging hysteria about safety case reports, and promoting a more effective strategy for building safety in blocks of flats.
My argument is that building safety legislation (the Building Safety Act and 31 pieces of associated secondary legislation) focuses on ensuring we know how buildings work and who’s responsible for each aspect. The regulator wants safety case reports to prove that knowledge and management systems exist. The report is an output, not the starting point.
Building safety isn’t compliance. What’s developed instead is a consultants’ charter, often beginning with a gap analysis. We’re not talking about a McKinsey Consulting 7-S job; we’re talking about Fred cobbling together a spreadsheet of every British Standard and assessment type he can think of, then working out what the building lacks.
Safety cases (and fire risk assessments) are about assessing risks and implementing proportionate measures. Lazy or ill-informed assessors might suggest compliance with all standards without explaining why.
Where to start? The BSA calls for a risk assessment, and the Regulator's guidance recommends it be scenario-based. This involves listing potential fire and safety scenarios, some generic (e.g. a kitchen fire) and some building-specific (e.g. a car fire under an overhang).
So what’s a safety case about? In case you skimmed the rant above, let’s reiterate that a safety case isn’t a report or a document. The BSA defines it as 'effective planning, organisation, control, monitoring, and review.' The safety case is the management system that implements and measures safety controls and reacts when things don’t work as planned.
At the core of that system should be a Claim – Argument – Evidence (CAE) model. Starting with risk scenarios, claims are made about why those risks shouldn’t occur. Each claim needs arguments and evidence to prove it.
“A consultant-led safety case can result in templated documents, leaving the PAP vulnerable to prosecution if they aren’t implemented and followed to the letter.”
Arguments and evidence can often be reused across claims. But if evidence fails (e.g. a fire alarm goes into fault), the CAE model should allow for easy identification and re-evaluation of claims. If this leads to the need for interim measures, a mandatory occurrence report to the Regulator may also need to be filed.
Can’t we just outsource this? Consultants can help articulate the hazard identification and risk assessment process, along with the CAE model, but be cautious about handing over full control. A consultant-led safety case can result in templated documents, leaving the PAP vulnerable to prosecution if they aren’t implemented and followed to the letter. With a 94% success rate, the HSE prosecutes not necessarily for unsafe actions but for not adhering to policies and method statements.
From a practical perspective, an HRB’s safety case should align with the block manager’s policies. It’s impossible to implement unique systems for each block at scale.
What should management software look like? If you’re highly organised and only manage a few HRBs, spreadsheets might work (though not recommended). Software that manages building assets and links activities to claims will simplify the process. Avoid software marketed as a “golden thread” solution. What’s needed is workflow, information managed in a way that’s analytical and reportable, and an audit trail.
Obviously, I would say this because I work for a software company, and RiskBase makes the best safety management tools. We also run in-person seminars and webinars on the Building Safety Act and Safety Cases for block managers.
Email me adam.sanders@riskbase.uk or drop me a message on LinkedIn and I’d be happy to give some friendly advice on the bigger picture or get you onto one of our seminars.
Adam Sanders, Technical Director at RiskBase
