BUILDING SAFETY AND COMPLIANCE Further underlining this, in response to the 2022 Murray
Review on Capital Allocation methodology, NHS England increased the targeted proportion of capital expenditure to be spent on backlog maintenance from 6 to 13%. This was formalised within NHS England’s Operational Capital Guidance 2022–2025, reinforcing that capital spend must be prioritised towards ensuring building safety and regulatory compliance. The current data provided through the ERIC process indicates that many Trusts are not addressing their Critical Infrastructure Risks, and the numbers keep growing. Thus, compliance with the Building Safety Act, maintaining an accurate Golden Thread, and investing in estate condition, are not discretionary activities; rather they are matters of patient safety, legal obligation, and executive accountability.
Although hospitals are not residential buildings in the traditional sense, they fall squarely within the scope of BSA22 because they house highly vulnerable occupants.
that compliance obligations under BSA22 start early – from the commencement of RIBA Stage 2 (Concept Design). Going through the BSR will extend the timelines for Building Control approval. Delays in action, lack of preparation, or unfamiliarity with the legal framework, could lead to serious consequences, not only in terms of regulatory breaches, but, far more importantly, in terms of future patient safety and public trust.
An enduring set of duties Another misconception is that a hospital higher than 18 metres is no longer deemed to be at ‘high risk’ once it is in occupation. This is not true. It will always remain a Higher Risk Building, and this places an enduring set of duties on an NHS Trust in terms of ‘maintaining the Golden Thread’ – this being a complete, accurate, and accessible digital record of information about a building, from its design and construction, to its ongoing maintenance and use. This comprehensive record ensures that those responsible for building safety have the necessary information to manage risks, comply with regulations, and demonstrate that the building is being safely managed. This could have significant consequences for how Trusts address safety- related backlog maintenance. Although NHS hospitals are exempt from direct control
With the advent of the Building Safety Act, all hospital buildings over 18 metres high are now classified as Higher-Risk Buildings.
by the Building Safety Regulator, they are answerable to the Care Quality Commission (CQC) for compliance with premises and equipment standards. In particular, CQC inspections against Regulation 15 will be informed by how well building safety risks are being managed and documented.
The Golden Thread: more than a filing system The ‘Golden Thread’ is not just a document archive, or a digital library of building plans. As outlined by Dame Judith Hackitt in her post-Grenfell review, and reinforced by guidance from the Construction Leadership Council (CLC), the Golden Thread represents a fundamental cultural shift in how buildings are designed, constructed, and maintained. At its core, the golden thread ensures that those responsible – clients, designers, contractors, and accountable persons, can demonstrate compliance with building regulations, understand structural and fire risks, and proactively manage them throughout a building’s life. The Golden Thread must be accurate, easily understandable, up-to-date, and accessible to those who need it. Executive decision-making must also be captured
within the Golden Thread. For example, when a Trust CEO or CFO makes a decision about the level of investment allocated to address building safety risks, that decision, and the rationale behind it, must be formally recorded. Transparency in these decisions is critical. In the context of Grenfell, the Golden Thread would have demonstrated who proposed the change of cladding, who approved it, and their understanding (or lack thereof) of the associated risks. From real-world NHS experience, it is rarely engineers
or project teams who make final calls on financial envelopes, costs, and ‘value engineering’ choices; it is typically SROs, CEOs, or Boards. They must have a clear understanding of their role, and their personal and corporate accountability, in decisions affecting building safety. The importance of this cannot be overstated. To put
the broader risk into perspective: back in 2012, the Department of Health initiated a review of Critical
Building safety is no longer a technical issue – it is a boardroom responsibility. Trust leaders must act now to protect lives, reputations, and their own accountability, under the law
44 Health Estate Journal June 2025
Paul -
stock.adobe.com
Carmina -
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