When is Fire Safety content separation required?

The changes to Regulation 38 under the Fire Safety Act 2022 apply to all buildings and requires the Building Owner to witness that all Fire Safety related information is received at Handover. The Act specifically defines the requirements to assess the information of any High-Risk Buildings (HRB); this is known as The Golden Thread of information. Documentation for the Fire and Structural Safety requirements for HRB should continue to be reviewed and updated during the occupation stages, especially when maintenance works on site affects these elements of the building. This can be as simple as drilling a hole to install broadband in an apartment as it may affect fire compartmentation. An auditable record of the documentation and their updates is known as the Golden Thread and should be accessible on request. All HRB will be assessed by the Building Safety Regulator throughout the build phase and will be approved at handover prior to the building being occupied.

For buildings that fall outside the HRB threshold, the local planning department will assess the building prior to completing a Building Control Certificate. At handover of these buildings, the Regulation 38 information should be approved and documented, assisting the Client with reviewing, and confirming they are in receipt of the information.

Traditionally, Regulation 38 information is embedded throughout the Operation & Maintenance Manual which makes evidencing this information more difficult. Fire Safety Content Separation breaks out this information from other documentation to its own dedicated Fire Safety section of the handover pack, to aid the handover process. COGNICA will collate and deliver Fire Safety documentation into its own dedicated section within, or alongside, the O&M Manual

Have the requirements been agreed between the Duty Holders?

In terms of the Building Safety Act, the Client, the Principal Designer, and the Principal Contractor are known as the Duty Holders. For HRB’s the documentation that will be held in The Golden Thread should be agreed between these parties at Gateway 1, then confirmed at Gateways 2 and 3. This layout should also include who is responsible for each of the required documents during the construction phase.

For buildings that fall outside the HRB threshold, consideration should be made at a planning stage of how the Regulation 38 information will be approved at handover. This may already be stipulated in the Employers Requirements; however, it is the responsibility of the Client and the Principal Contractor to agree how this information will be received.

Where Fire Safety Content Separation is required, COGNICA will seek clarification that the content and layout of this section has been agreed between the duty holders. COGNICA will build the structure of the manual and deliverables, including the separated Fire Safety section, to meet these requirements.

Are all Duty Holders satisfied with Fire Safety content documents only being provided in the separate section?

The Golden Thread of information infers the concept of the Single Source of Truth. As documentation is expected to be revised throughout the building lifecycle then it is essential that only a single instance of the latest version of each document is held in the handover pack. Should duplication occur, there is a risk that revisions to one document risk other copies remaining as original, thereby corrupting the Golden Thread and Single Source of Truth.

COGNICA work to ensure that all stakeholders understand the principles of the requirements. If the Duty holders state they require document duplication, COGNICA will adhere to this request in the understanding that the Client has processes in place to handle changes during the Occupation phase.

For all types of buildings, on authorisation from the Principal Contractor, COGNICA will provide Fire Safety content separation as its own section alongside the O&M manual, to support Regulation 38 sign off. The Fire Safety content must be approved by an authorised party (external to COGNICA) prior to delivery during Handover.

Contact Us now to discuss how COGNICA can support you through the O&M Manual requirements laid out in Regulation 38.