BUILDING SAFETY AND COMPLIANCE
Maintaining the Golden Thread is ‘fundamental’
David Hemming, a highly experienced Chartered Civil Engineer who heads the Estate and Major Programme area within the NHS Shared Business Services Consulting team, argues that the so-called ‘Golden Thread’ – a complete digital record of information about a building, from its design and construction, to its ongoing maintenance and use – ‘represents a fundamental cultural shift in how buildings are designed, constructed, and maintained’. He warns that failure to maintain an accurate, accessible, and up-to-date Golden Thread ‘is no longer merely poor practice – it represents serious corporate risk’.
The Building Safety Act 2022 marks a seismic shift in accountability, born from Grenfell’s tragedy, demanding full lifecycle transparency for Higher-Risk Buildings – including hospitals. For the NHS, this isn’t just an estates issue – it’s a legal, moral, and patient safety imperative. The ‘golden thread’ of accurate, accessible building data must be maintained from concept through occupation. Senior leaders can no longer afford to overlook their personal and corporate responsibility for safe, compliant infrastructure. The Building Safety Act 2022 (BSA22) was born from
tragedy – an attempt to ensure that the systemic failures exposed by the Grenfell Tower fire in 2017 are never repeated. Central to this new regime is the concept of the ‘golden thread’ of information: a continuous, structured, and digital record that captures key decisions, changes, safety-critical features, and compliance evidence across the lifecycle of a Higher-Risk Building (HRB).
A critical challenge and an urgent call for action For the NHS, responsible for managing some of the most complex, sensitive facilities in the UK, the arrival of the BSA22 presents both a critical challenge and an urgent call to action. Now, more than ever, healthcare organisations must place robust data management and safety compliance at the heart of both their maintenance and building programmes – not as an afterthought, but as a foundation of quality patient care, governance, and risk assurance. While this may appear to be a specialist estates issue, it is critical that greater awareness of this requirement reaches its target audience – namely, the accountable officers and Board members responsible for organisational risk, safety, and compliance. While a director of Estates may develop the forward maintenance register and capital delivery plan, they typically lack executive authority when it comes to budget-setting, and are required to deliver within a fixed budget. More and more this budget is failing to provide the necessary funds to address the risks faced by an ageing estate. The intention behind the Building Safety Act is precisely to hold senior accountable persons, i.e. those making investment decisions, approving designs, or delaying safety works, accountable for their decisions, actions, and possible inactions. There is a commonly held belief that the BSA22 only relates to High Rise Residential Buildings. The Act itself indicates that HRBs need to have two or more residential units, as well as meeting a minimum height threshold to be deemed ‘at higher risk’. This belief was perpetuated
by a piece of secondary legislation, which indicated that hospitals were excluded from being described as an HRB. This is – sadly – a product of complex legislation not being clearly set out. The exclusion only refers to the hospital not coming under the powers of the Building Safety Regulator when in occupation. In the same piece of legislation, it clearly identifies
hospitals (and care homes) as HRB. Referring to the explanatory notes for the legislation clears up the issue. It states that although hospitals are not residential buildings in the traditional sense, they fall squarely within the scope of BSA22 because they house highly vulnerable occupants, including patients who may not be able to evacuate unaided during an emergency.
Exceeding the qualifying height criteria Across the NHS, many hospital buildings readily exceed the qualifying height criteria of 18 metres set out in the Act, thus qualifying them as HRBs. Yet there remains a widespread lack of awareness from Estates departments across the NHS of their duties and obligations. New-build hospitals, or those being significantly refurbished that fit the category of an HRB, will need to go through the Building Safety Regulator (BSR) to gain Building Control approval. This ensures that a greater focus is placed on checking that due consideration has been given to fire safety by competent individuals. Within the New Hospital Programme (NHP), most
schemes, and especially those in Wave 1, are expected to exceed 18 metres in height. Many are, however, unaware
June 2025 Health Estate Journal 43
The author says: “Now, more than ever, healthcare organisations must place robust data management and safety compliance at the heart of both their maintenance and building programmes.”
Imran’s Photography -
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