BUILDING SAFETY AND COMPLIANCE
With the Building Safety Act now in force, any failure to maintain an accurate, accessible, and up-to-date Golden Thread of estate-related data represents ‘serious corporate risk’, the author stresses.
David
Infrastructure Risk. This refers to the potential harm or disruption to essential services that could lead to significant loss of life, economic impact, or even national security threats. The review found that £1.2 bn of investment was needed to address backlog maintenance across the NHS estate to ensure that commitments under the NHS Constitution, specifically, providing ‘services from a clean and safe environment that is fit for purpose based on national best practice’ – were being met. Failure to address backlog maintenance also placed
Trusts at risk of breaching their obligations under the Health and Social Care Act 2008 (Regulated Activities) Regulations, and particularly Regulation 15(e), which requires service-providers to ensure that premises and equipment are properly maintained to protect service- users from harm.
Additional legal duties for the Accountable Person With the advent of the Building Safety Act, all hospital buildings over 18 metres are now classified as Higher- Risk Buildings. This places additional legal duties on the ‘Accountable Person’ to identify, manage, and document, how building safety risks are being addressed and mitigated. To meet these complex demands, Trusts must establish
robust information management systems, centred around Common Data Environments (CDEs). A CDE is a centralised digital platform that acts as a single source of truth for all building-related and operational data. Features typically include: n A Centralised Repository: housing all project information, including contracts, drawings, models, and communications.
n Single Source of Truth: reducing errors and ensuring consistency across stakeholders.
n Enhanced Collaboration: enabling secure, real-time sharing of information between parties undertaking maintenance and construction work.
n Efficiency gains: reducing project delays, duplication, and cost overruns.
CDEs support Building Information Modelling (BIM) processes, feeding into an Asset Information Model (AIM) that supports the ongoing management of the building across its lifecycle. Critically, CDEs help maintain the Golden Thread by ensuring that all decisions, changes, approvals, and risk assessments, are captured, version- controlled, and readily accessible.
CDE ownership ‘delegated’ Most NHS Trusts only use CDEs during a construction project, and ownership is delegated to one of the delivery partners (designers or contractors). On completion of the project, the underlying funding for the CDE ceases, and it is closed down, without much of the critical information being transferred to the client. Some of the lessons being implemented through the NHP, and the paradigm shift to the intelligent hospital concept, are around the use of a number of data key principles, which should be applied to all hospitals designated as HRBs. These are: n Data ownership – data must be separated from applications, owned by the Trust/NHS, and accessible free of charge to legitimate users.
n Available – must provide ‘live’ services and accurate data for the right users and the right time.
n Reliable – must meet high standards for quality and accuracy to ensure consistency and performance.
n Findable – can be easily discovered and accessed by authorised users.
n Secure – Must be secure by design (cyber and physical), and protect from unauthorised access and tampering.
A narrow window of opportunity The Building Safety Act is now in force. Regulatory obligations are legally enforceable. Failure to maintain an accurate, accessible, and up-to-date Golden Thread is no longer merely poor practice – it represents serious corporate risk.
Boards must understand that non-compliance could lead not just to regulatory censure, but potentially criminal liability for senior leaders who knowingly take, approve, or ignore, unsafe decisions. The NHS has a narrow but critical window to modernise its estate information management practices. By acting now, investing in digital capability, demanding compliance from supply chains, and embedding Golden Thread principles from the outset, Trusts can: n Protect patients, staff, and visitors. n Shield the organisation from reputational and financial harm.
n Demonstrate good governance and corporate responsibility.
n Honour the hard lessons learned from past tragedies.
Keeping the Golden Thread alive is not just a technical requirement. It is a fundamental duty of leadership.
Hemming
David Hemming CEng, FICE, FCMI, FIWFM, who heads the Estate and Major Programme area within the NHS Shared Business Services Consulting team, is a Chartered Civil Engineer, with 30 years’ experience working in the construction and property sectors worldwide. The majority of his career has been with the public sector – working in Defence, Higher Education, Central Government, and Health. He started his career
in the Army, serving with the Royal Engineers for over 20 years, and he has been the director of Estates and Facilities for a number of high-profile institutions, delivering a high number of major projects and programmes. He holds Fellowships in both the Institution of Civil Engineers and the Institute of Workplace and Facilities Management. He sits on a number of national and international committees and advisory groups, and has written a number of technical guides and standards in the facilities management field, and published papers, articles, and book chapters, on the subject of Indoor Environmental Quality, health, and wellbeing.
June 2025 Health Estate Journal 45
Nick Beer -
stock.adobe.com
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