Principal Accountable Persons: Have you got the key (building information)?

On 17 May 2023, the UK Government published guidance on the key building information that the principal accountable person will need to provide to the Building Safety Regulator ("BSR") when registering a high-rise residential building (those of at least 18 metres or seven storeys tall). Registration is now a legal requirement under the Building Safety Act 2022.

The principal accountable person ("PAP") must take all reasonable steps to find and provide the current information about the building's structure and fire safety. This will not usually require instructing a separate survey and will likely be found in the most recent fire risk assessment or external wall system assessment.

THE 10 Specifics

The recent guidance directs that the PAP should provide the following types of information when registering a building:

1. Fire and smoke controls

Information will be required on (i) the evacuation strategy for residential areas; (ii) the fire and smoke control equipment in residential units (including in shared areas); and (iii) the types of lift(s) installed (i.e., evacuation lift, firefighters lift, fire-fighting lift, modernised lift for fire service or firemen's lift).

2. Fire doors

Information will be required on (i) the certified fire resistance of residential front doors and any other fire doors that residents can use; (ii) the quantity of each door with a certified fire resistance for 30, 60 or 120 minutes; and (iii) any doors with an unknown fire resistance.

3. Energy supplies, storage and generation

Information will be required on the type of (i) energy storage for the building (i.e., lithium ion or hydrogen batteries); (ii) energy generated on site (i.e., air source heat pumps, solar panels or biomass boilers); and (iii) energy supply (i.e., district heating, mains electricity/gas or oil). 

4. Structure type

Information will be required on the type of building structure in terms of its constituent materials e.g. composite steel and concrete, steel frame etc.

5. Roof

Information will be required on (i) the type of roof on the building i.e. whether it is flat/pitched/mixed; (ii) the location of any insulation; and (iii) the predominant material covering the roof.

6. Staircases

Information will be required on the number of (i) internal and external staircases (including basement staircases) and (ii) internal staircases that run from ground level to the top floor.

7. External Walls

Information will be required on what materials are visible on the outside of the walls and what percentage of each is visible. If aluminium composite material (ACM) or high-pressure laminate (HPL) is present, the accountable person will be required to confirm whether it (i) meets the fire classification as set out in the British Standard or better; or (ii) has passed a large-scale fire test to the relevant British Standard.

Information will also be required on (i) the type of insulation in the outside walls (including the percentage of each type of insulation used); (ii) any external wall or roof features; and (iii) the two most prevalent materials used in each feature. For these purposes, features on the roof include communal recreation areas, telephone masts or roof lights, and on outside walls these might be balconies, communal walkways, escape routes to the roof or advertising signs. Information will also be required on any machinery in an outbuilding, on the roof or in a room on the roof.

8. Building use

Information will be required on the primary and secondary uses of the building. For these purposes, the primary use relates to the area that takes up the majority of floor space above ground level. If there are floors below ground level, the accountable person must also confirm how many there are and what they are used for.

Note that any different past primary use must also be notified.

9. Works since the original build (even if only to part of the building)

Information will be required on asbestos removal/remediation, additional balconies, change in the number of residential units, additional staircases, window alterations, rewiring, adding or removing floors, reinforcement works to large panel systems and any external wall works.

Information will also be required on any changes regarding fire systems, emergency lighting, cold water systems (in multiple units), heating or hot water systems (in multiple units) and gas supply.

10. Connections

Information will be required on any connections to other buildings; or between structures within the building (if the building is made up multiple structures).

KEY TAKEAWAY

In submitting a registration application to the BSR, it will be the responsibility of the principal accountable person to collate and provide the information outlined above. This information will likely be found in the building’s records, fire risk assessment and/or external wall system assessment. It will be crucial to ensure assessments are up to date and effective information management systems are put in place.

For further information on matters relating to the Building Safety Act please see our Building & Fire Safety Hub.