Competence, organisational capability and the Golden Thread – a Building Safety Act assurance maturity journey

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Even with the Building Safety Act 2022 having passed its second birthday, many of the requirements have not quite reached maturity.

There are two, very specific, matters that run right through the new Regulatory Regime brought in by the Building Safety Act 2022 – Competence and Accountability. And both need to be assured and evidenced by accurate and up-to-date information.

Photograph: iStock/PeopleImages

Its secondary legislation – The Higher-Risk Buildings (Management of Safety Risks etc) (England) Regulations 2023 – not only outlines the prescribed principles for managing building safety risk in the occupation phase, it also includes a requirement for an accountable person to ensure that any person responsible for or assisting with compliance with a duty in or under Part 4 of the 2022 Act has the relevant competence. That Regulation covers both individual and organisational capability requirements for the occupation phase.

Individual competence

We will consider ‘individual competence’ first, and how this feeds directly into being accountable, which includes being responsible for assessing and managing the risks posed to people in and about the building from structural safety or the spread of fire in the parts of the building they are responsible for. This requirement to manage risk will depend on analysis and use of accurate and assured building safety information held in the Golden Thread, something we will briefly touch on later in this article. 

The Regulation states that individual competence covers “the skills, knowledge, experience and behaviours (also known as ‘SKEB’) necessary to perform the functions for which they are responsible in a satisfactory manner”.

The newly published BS 8670‑1:2024 Competence frameworks for building safety: Part 1: Core criteria – Code of practice has been developed to provide a framework against which to build all building safety-related professions and trades competence frameworks. It describes competence as: “for an individual to be deemed competent means that they need to have the appropriate skills, knowledge and experience, combined with appropriate behaviours, and an understanding of the limits of their own competence, to be able to fulfil their defined role, function or activity and carry out appropriate tasks.

This is sometimes referred to by the abbreviation SKEB. Behavioural competence, when combined with existing skills, knowledge and experience, helps to engender a sense of individual responsibility and accountability as part of an effective and strong safety culture: “An assessment of skills, knowledge, experience and behaviours explores whether an individual demonstrates general competences designed to anticipate the broad demands of particular roles, functions, activities or tasks. Assessment cannot predict future circumstances and complexities or give complete assurance that an individual in the same role will always respond in the same way.”

Of special importance is the concept of ‘integrity’ about all the work they are asked to undertake, and most importantly understand, and do not exceed, their own level of competence to undertake any specific task.

Sofie Hooper is head of policy and research at the Institute of Workplace and Facilities Management (IWFM). Photograph: IWFM

This latter expectation, not to exceed their own competence, is also enshrined in the new Building Safety Act, and its associated Regulations to the extent certain dutyholders are required to refuse to undertake work for which they do not have the appropriate SKEB.

Managing competence

Of particular importance to the occupation phase is PAS 8673:2022 Built environment – Competence requirements for the management of safety in residential buildings – specification. This Publicly Available Standard is being referenced directly by the Government (and the Building Safety Regulator) as the standard that can help confirm that individuals have competence to perform their roles and be used as a benchmark to assess individuals’ competence. While compliance with that standard does not guarantee meeting all legal obligations, it goes a long way to assuring that it does!

Moving from ‘individual’ competence requirements to the ‘organisational capability’ mentioned in The Higher-Risk buildings (Management of Safety Risks etc) (England) Regulations 2023, this should “ensure that the functions for which it is responsible are performed in a satisfactory manner” – translated as essentially the management of competence throughout an organisation.

And it’s not just required in the occupation phase – in primary legislation the Building Safety Act 2022 explicitly requires it both in Part 3 (relating to the design and construction phase) and implicitly in Part 4 (relating to the management of occupied higher-risk buildings, or HRBs).

The big underpinning question is of course ‘how’ organisations will manage the competence of all those under their control, whether direct employees or those they may sub-contract in to supplement competences their direct workforce do not have. And does it have an equivalent of PAS 8673?

Whereas the expectation on organisations to manage the competence of their employees and/or contractors is not new, it may not have been widely delivered as expected. The new regulatory regime recognises this concern, and it expects organisations to actually evidence that they have a comprehensive process for managing competence across their organisation – including on any projects they may lead or be part of.

The requirements of the Act, as indeed has long been a requirement of previous health and safety legislation, dictate that anyone seeking to employ anyone else, an individual or as an organisation, should have undertaken appropriate due diligence to ensure appropriate competence for the proposed work is in place.

Photograph: iStock/Ridofranz

How this should be done has previously been addressed, to an extent, by way of compliance with ISO/BS standards such as 45001, 9001, 14001 etc. However, any requirement for evidencing this has tended to rely on appropriate recruitment practise and management of CPD and has not to date included for ‘behaviours’.

The Safety Schemes in Procurement (SSiP) members have also long used their pre-qualification questionnaires as a light-touch route to consider the organisations’ competence management. The SSiP Forum is just about to release a revised ‘common assessment standard’ that looks more deeply into the matter; however this remains at a pre-qualification level and should not be acceptable as the deep-dive due diligence exercise necessary before engaging individuals or organisations for a specific, perhaps complex, project.

To fill this gap The Building Safety Alliance , of which IWFM is a founding member, has recently published BSAS 01:2024 Organisational Capability Management System Standard – Management of Competence. This standard has been designed to provide guidance to organisations on how to make a judgement that they are employing an organisation which is appropriate for the project/job they require being undertaken, and the processes that need to be in place to enable the outcomes. Importantly, like PAS 8673, it can also be used to evidence their organisational capability to the Regulator and other interested parties. This standard was launched at the Building Regulators’ Conference on 21 May 2024.

While it was originally initiated to assist those operating in the ‘occupied residential sector’, it is essentially agnostic to the work the organisation undertakes and can therefore be used in the design and construction phase as well to manage and evidence organisational capability.

Supported by the British Standards Institute, those using the free standard will recognise the Plan-Do-Check-Act methodology used across existing ISO/BS standards so it can be used complementarily. In addition, its design, by way of identifying ‘Core Principles’, means SME or micro-businesses can manage it successfully.

Golden Thread

Nevertheless, you can have all the competent people in the world on hand, but if they are being asked to make decisions on ‘duff’ information they will not get very far, which brings us to the next element – the assurance of information and the recording and maintenance of it in what is now known as a Golden Thread.

As we know, there are ‘prescribed formats’ for ‘prescribed information’ which will constitute a Golden Thread, and that information should be accurate, current and available to the right people at the right time.

We should also recognise that the Golden Thread relating to the design and construction phase is different to the Golden Thread information that constitutes the ‘Safety Case’ during the management in occupation.

During the design and construction phase, the Golden Thread is there to provide evidence and an audit trail of assurance/quality control that the building works comply with what is known as the ‘relevant requirements’ – essentially compliance with Building Regulations. The Building Safety Alliance has designed a quality assurance process that could be used throughout the lifecycle of a building, including for a design and construction process, recording each element of design and construction, showing that checks and balances have been applied.

When these records exist, they provide the evidence of compliance with both competence expectations and the ‘relevant requirements’ (i.e. Building Regulations). This provides the essential assurance to those responsible for managing the building long-term over its lifecycle, that their decisions regarding risk management, planned and preventative maintenance etc, are based on good, accurate and current information.

As the Principal/Accountable Person’s duties include management of structural risk, they need such detailed information to inform the long-term testing, inspection and maintenance of the fabric and structure of the building throughout its lifecycle.

Digital record

All those involved in the design and/or build of any works that fall under the building regulations, (therefore almost all work) should consider the benefit of maintaining such a system, a digital record.

While not a legal requirement for works unrelated to HRBs, with the significant increased focus on competence and its application, and the significant extension of liability (potentially up to 30 years) insurers, let alone the owners of the building to which the work has been done, should really wish to know that the information is available, and remains available.

During management, much (but not all) of that information will be used to manage building safety risks, (defined as the risk of spread of fire and structural safety). The remainder of the information is still required to be maintained, managed and to remain available – however, much will be historic records, and these will not be needed on a daily basis during the occupied phase until such time as proposed future works require reference to them. At this point in time, any changes will need to be updated in the records, and any information necessary for the management of the building will also need to be updated where appropriate.

As noted above, the Golden Thread, or Safety Case, in occupation is focused on the management of building safety risks (spread of fire/structural safety), and The Higher-Risk Buildings (Keeping and Provision of Information etc. (England) Regulations 2023 provide all the needed detail about what information should be kept, who should keep it and who the information should be shared with, also covering some limitations to the duties.

The Building Safety Alliance has translated this information into a list of assured information and documentation that is needed, alongside a series of processes that assist, and gives guidance to those providing information to the Golden Thread, and to those who have to use and maintain it. The Alliance will be publishing this guidance in several tranches over the next several months – so keep an eye on the Alliance’s website and the wealth of information and resources on the IWFM website.

The IWFM’s training courses empower professionals to achieve compliance, identify potential hazards, implement preventative measures and develop robust emergency response protocols. Our commitment to continuous learning and professional development ensures that professionals remain at the forefront of safety best practices, fostering secure and thriving built environments for all.

We recommend professionals primarily consider our courses Building Safety Act: Methodologies for Evidencing Organisation Capability and Building Safety Act: what FMs need to know and do, while many of our other courses touch on building safety issues.

Sofie Hooper is head of policy and research at the Institute of Workplace and Facilities Management (IWFM) and Anthony Taylor is managing director of Resolve Risk Ltd and interim chair of the Building Safety Alliance Ltd.

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