Adam Sanders, Technical Director at RiskBase talks about what property managers responsible for HRBs should focus on when supporting their PAPs.
New Year's resolutions are now long forgotten, and reverting to old habits is as easy as giving up on Dry January – but the Building Safety Act has no intention of letting anyone go ‘back to old ways. Those that try, will double-down on effort, spend a fortune and achieve very little.
Most of us are aware that a Safety Case Report (SCR) is mandatory for buildings over 18 metres or more than seven storeys. The Building Safety Regulator (BSR) is set to start demanding them from the 1st April.
I’m approached every week by people frantically trying to outsource the last-minute creation of SCRs ready for ‘the deadline’. If you’re one of them, please stop now. Take a deep breath, and read on to find out why you shouldn’t panic.
It's worth starting by referring back to the legislation. Section 83 requires the Principal Accountable Person (PAP) to assess the building for safety risks, while Section 84 requires those risks to be adequately managed. The product of these two sections is a management system colloquially referred to as a Safety Case.
Don’t confuse the Golden Thread, the Safety Case and the Safety Case Report (SCR) - they’re quite different:
- The Golden Thread is all the information about a building’s fabric and its residents, including things like risk assessments, servicing and inspections.
- The Safety Case is a live management system (or systems) that demonstrate all reasonable steps are being taken to manage risk, and that those steps are effective.
- The Safety Case Report (SCR) is a documented output of the Safety Case. It’s a snapshot of the building information and status of its management system.
Some people are scrambling to produce SCRs because of the 1st April ‘deadline’. Yet, that date is not set in the legislation, and Section 85 only requires the SCR to be produced “as soon as reasonably practicable.”
To be clear: if the Safety Case isn’t substantially complete, it’s not ‘practicable’ to produce the SCR. Attempting to do so is a waste of time and it won’t make the PAP any more compliant.
Instead, focus on assessing and manging the building safety risks. Failure to comply with Sections 83 and 84 will constitute a far greater offence than failing to produce the SCR.
For the avoidance of doubt, anyone attempting to build reliable Safety Cases using a slew of Word documents and Excel spreadsheets is likely to find themselves profoundly underprepared. To be effective, a Safety Case management system should be dynamic and cover more than just tick box compliance.
Finally: the SCR doesn't need to declare the building as perfect; it’s about persuading the regulator that the regulations and their intent is being met, gaps are identified, and there’s a plan to manage them.
For some practical advice and guidance, join our webinar on Building Safety where we’ll go into a bit more detail on what a Safety Case and an SCR could look like as well as cover off some of the regulatory angles. While it may not be as much fun as the News on the Block birthday bash, it might help you sleep better at night.
Adam Sanders, Technical Director, RiskBase
Register here for your free space on the RiskBase Webinar on Building Safety taking place on 28 March 2024.
