Building Safety Policy and Procedure (BSA2022-CDM2015)

1. Purpose

To ensure all construction activities undertaken by Pleavin Power Ltd comply with the Building Safety Act 2022 and The Construction (Design & Management) Regulations 2015, promoting a safe, transparent, and accountable built environment.

This policy and procedure has been developed to establish a robust framework ensuring that all construction activities undertaken by Pleavin Power Ltd align with the requirements of the Building Safety Act 2022, thereby prioritising the safety and well-being of building occupants and stakeholders

2. Scope

This policy applies to all projects involving the design, construction, refurbishment, or maintenance of buildings, with particular emphasis on higher-risk buildings (HRBs) as defined by the Act.
This policy and procedure applies to all employees, contractors, consultants, and stakeholders involved in the design, planning, construction, and occupation phases of projects.

3. Policy Statement

For the purposes of this policy Pleavin Power Ltd is classed as a CONTRACTOR and aims to fulfil all duties and responsibilities which are applicable to us under the Building Safety Act 2022 and the Construction (Design & Management) Regulations 2015.

Pleavin Power Ltd is committed to:

Upholding the highest standards of building safety throughout all project phases.
Ensuring compliance with all relevant provisions of the Building Safety Act 2022 and the Construction (Design & Management) Regulations 2015.
Promoting a culture of safety, transparency, and continuous improvement.
Engaging proactively with regulatory bodies, clients, and other stakeholders to foster collaborative safety management.

The following procedure provides information and describes how compliance to the BSA 2022 and CDM 2015 is to be achieved by across all stakeholders and all interested parties where the regulation applies.

4. Responsibilities

4.1 CDM Duty Holder Responsibilities

Integration of CDM with Building Safety Act Compliance

CDM roles support compliance with the Building Safety Act by ensuring that health and safety responsibilities are embedded throughout the lifecycle of a building. All duty holders support the Accountable Person in fulfilling legal obligations. The following responsibility summary provides a broad outline of expectations under CDM 2015 and BSA 2022.

4.1.1 Client

Ensure that suitable arrangements are made for managing the project, including allocation of sufficient time and resources.

Appoint a competent Principal Designer and Principal Contractor where more than one contractor is involved.

Maintain and provide relevant information to other duty holders.

Ensure that a Construction Phase Plan and Health and Safety File are prepared.
For projects that involve High Risk Building (HRB) work
- Further documents and information must be provided to the Building Safety Regulator (BSR) such as drawings and plans, a competence declaration, a construction control plan, a mandatory occurrence reporting plan (MOR)
- Clients are responsible to put into place a record of information about the building (Also known as the Golden Thread) this information describes the building and shows how it complies with the building regulations. Records must be maintained of how those responsible for building work comply with their duties and how you will manage the work.
- Ensure all necessary building information (e.g., as-built plans, Safety Case, fire strategy) has been transferred to the Principal Accountable Person (PAP) or Accountable Person (AP) for a high rise residential building or a Responsible Person for a non residential building.
- When building work is finished a completion certificate must be applied for. The Principal Accountable Person (PAP) is legally responsible for applying for the completion certificate at Gateway 3, as per Schedule 5 of the Act.

Resource: https://www.hse.gov.uk/construction/cdm/2015/index.htm

4.1.2 Principal Designer (PD)

Plan, manage and monitor the pre-construction phase.

Coordinate health and safety aspects of design work.

Ensure that other designers comply with their duties.

Assist the client in obtaining pre-construction information.

Provide information needed for the Health and Safety File.
For projects that involve High Risk Building (HRB) work
- A mandatory occurrence reporting plan (MOR) must be established and in operation during construction of a new HRB or works to a HRB (unless the work only consists of exempt work or emergency Repairs)
- You must use the record keeping system provided to ensure that all design information about the building is up to date. This may be a Common Data Environment (CDE) or other compliant digital platform.

Resource: https://www.hse.gov.uk/construction/cdm/2015/principal-designer.htm

4.1.3 Principal Contractor (PC)

Plan, manage and monitor the construction phase.

Prepare and revise the Construction Phase Plan.

Organise cooperation between contractors.

Ensure that suitable site inductions, welfare, and reporting are in place.

Liaise with the Principal Designer and share safety information.

For projects that involve High Risk Building (HRB) work
- A mandatory occurrence reporting plan (MOR) must be established and in operation during construction of a new HRB or works to a HRB ( unless the work only consists of exempt work or emergency Repairs)
- You must use the record keeping system provided to ensure that all design information about the building is up to date. This may be a Common Data Environment (CDE) or other compliant digital platform.

Resource: https://www.hse.gov.uk/construction/cdm/2015/principal-contractor.htm

4.1.4 Contractors (C)

Plan, manage, and monitor their own work to ensure safety.

Comply with directions from the Principal Contractor.

Ensure workers are trained and competent.

Provide necessary supervision and welfare.

Resource: https://www.hse.gov.uk/construction/cdm/2015/contractors.htm

4.1.5 Designers (D)

– Eliminate or control foreseeable risks through design.
– Provide adequate information about potential risks.
– Cooperate with other duty holders to ensure a safe project outcome.
Resource: https://www.hse.gov.uk/construction/cdm/2015/designers.htm

4.2 Principal Accountable Person (PAP) / Accountable Person (AP) / Responsible Persons (Higher-Risk Buildings)

4.2.1 Principal Accountable Person (PAP)

A PAP is usually an organisation like a housing association, local authority or company appointed for High Risk Building Projects. In limited circumstances, an individual can be the PAP. For example, if they are the owner of the building or named on the leasehold as responsible for maintenance of common parts.

4.2.2 Accountable Person (AP)

An AP is an organisation or individual who owns or has a legal obligation to repair any common parts of a High Risk Building. An AP can be a freeholder or estate owner, landlord, management company, resident management company, right to manage company or commonhold association PAP’s, AP’s must:

Keep information about the building and manage the record keeping (The Golden Thread) Information System which includes the Health and Safety File, the Building Safety Case Report, residents engagement strategy and MOR Plan.
Under the Building Safety Act 2022, the Principal Accountable Person (PAP) is legally responsible for applying for the completion certificate at Gateway 3.

4.2.3 How APs work with Responsible Persons (Fire Safety)

The Responsible Person (RP) is the individual or entity in control of non-domestic premises and has a legal duty to ensure fire safety under the Regulatory Reform (Fire Safety) Order 2005. In some buildings an AP or PAP will also be the Responsible Person. Where this is not the case, building safety information must be shared across these roles and any information shared must meet data protection requirements.

4.3 Single Point Of Contact (SPOC)

4.2.3 Someone from the organisation must be the Single Point Of Contact.

The SPOC can be the PAP or AP if they are an individual with appropriate authority. If the PAP is an organisation, then an individual from within the organisation or an authorised third party may act as the SPOC.

This person must:

Discuss building safety issues with the regulator and have authority relating to the safety of the building.

5. Procedure: Steps to be taken at each project to ensure compliance with the Building Safety Act 2022

Project Initiation & HRB Assessment – Responsibility: Client

The Client shall

Determine whether the project qualifies as a Higher-Risk Building (also refer to the Higher-Risk Buildings (Descriptions and Supplementary Provisions) Regulations 2023 for further details and exemptions)
HRB Determination Statement to be completed.
- A high-rise residential building has at least:
  - 7 storeys or is at least 18 metres high
  - 2 residential units
- The building must be registered with the Building Safety Regulator (BSR) before people live there. These buildings are known as higher-risk buildings under the Building Safety Act 2022
- Each HRB must have one clearly identifiable AP, known as the PAP.
Appoint competent Principal Designer and Principal Contractor.
Provide relevant pre-construction information.

Where a building is identified as a HRB (Higher-Risk Buildings) the Gateway Process in Table 1 is to be implemented and initiation of roles and key responsibilities in Table 2. In all cases the process in Table 3 is initiated under CDM Regulations.

Table 1: Overview of Gateway Process (Higher-Risk Buildings)

Gateway	Trigger Point	Purpose	Supporting Documents
1	Before Planning Permission	Ensure early design safety and risk consideration	Fire Statement, Risk Register
2	Before Construction Starts	Confirm detailed safety compliance	Safety Case, Construction Control Plan, Design Info, Fire and Emergency File and Change Control Strategy
3	Before Occupation	Submit final Safety Case to BSR, receive Completion Certificate, and obtain approval prior to first occupation as required by regulations	As-Built Plans, Completion Certificate, Safety File

Table 2: Summary of Roles & Key Responsibilities (HRB Projects)

Role	Gateway 1 – Planning Stage	Gateway 2 – Pre-Construction	🔨 During Construction	Gateway 3 – Completion & Occupation
Client	Submit Fire Statement, define project scope, appoint PD and PC	Submit full design, safety case, and notify BSR	Monitor contractor and designer compliance, maintain communication with BSR	Register building with BSR, ensure handover of Golden Thread and Safety Case to PAP
Principal Designer	Lead safe design coordination, provide risk registers	Coordinate design handoff and validate safety design	Monitor design changes, advise on design risk mitigations, update Safety File	Finalise Golden Thread, support BSR engagement, close out design risks
Principal Contractor	May advise design if appointed early	Submit Construction Control Plan and strategies	Implement control measures, coordinate contractors, manage safety inspections	Verify as-built conditions, compile documentation, support handover
Designers	Eliminate foreseeable risks via early design	Finalise compliant detailed designs	Respond to design queries, ensure design changes are risk assessed, and communicated	Contribute to final drawing package and digital Golden Thread
Contractors	Offer buildability feedback (if involved early)	Review and plan work as per risk control requirements (RAMS)	Deliver work safely, follow Construction Phase Plan, participate in toolbox talks, site coordination meetings, and inspections	Assist in defects resolution, verify installations, contribute to “as-built” records
Principal Accountable Person	Not directly involved	Not directly involved	Monitor overall safety readiness for future occupation; begin preparations for registration and safety case documentation	Responsible for registering the building, submitting the Safety Case Report, and ensuring readiness for occupation During Occupation Implement and maintain the safety case; maintain Golden Thread; engage with residents; report safety incidents
Accountable Person	Not involved	Not involved	Coordinate with PAP and Principal Contractor; support safety documentation collection for areas under their responsibility	Collaborate with PAP; provide information and input on areas under their control During Occupation Manage safety for specific areas; conduct assessments; support resident engagement and safety case maintenance
Responsible Person	Carry out fire risk assessments and contribute to safety planning (if non-domestic spaces exist)	Ensure fire safety systems are designed in compliance with fire regulations	Oversee installation of fire safety systems; ensure fire doors, alarms, extinguishers, and signage meet standards	Ensure fire safety measures are commissioned, certified, and in place During Occupation Maintain fire alarms, emergency routes, and records; conduct fire drills and training

Table 3: Summary of Roles & Key Responsibilities (Non-HRB Projects)

Role	Pre-Construction	🔨 During Construction	Post-Construction / Handover
Client	– Appoint competent duty holders (PD, PC if needed) – Provide pre-construction information – Ensure suitable management arrangements	– Ensure CDM duties are being met by PD/PC – Provide resources and cooperation	– Receive Health and Safety File – Ensure building is safely handed over and occupied
Principal Designer	– Coordinate safety during design – Eliminate risks where possible – Collate pre-construction information	– Respond to design queries – Coordinate design changes safely – Maintain and update H&S File	– Finalise H&S File – Transfer to client
Principal Contractor	– Develop Construction Phase Plan – Coordinate pre-start planning with designers and contractors	– Implement Construction Phase Plan – Manage health & safety – Induct and coordinate all contractors	– Complete site handover – Assist with compiling fire safety and H&S file information for handover to Principal Designer/Client
Designers	– Identify, eliminate, and reduce foreseeable risks – Provide information on residual risks	– Clarify design queries and safe execution – Incorporate on-site changes	– Support in final drawing preparation for H&S File
Contractors	– Participate in planning and method statements – Review site-specific risks	– Work safely following RAMS and toolbox talks – Cooperate with PC and others -Report safety incidents and concerns to the Principal Contractor	– Support testing/commissioning – Contribute to as-built records and snagging – Hand over completion information for contribution to the H&S file
Responsible Person	Ensure fire safety systems are designed in compliance with fire regulations	Oversee installation of fire safety systems; ensure fire doors, alarms, extinguishers, and signage meet standards	Ensure fire safety measures are commissioned, certified, and in place During Occupation Maintain fire alarms, emergency routes, and records; conduct fire drills and training.

Definitions & References

- Building Safety Act 2022: which became law in April 2022 was commissioned after the Grenfell Tower tragedy in 2017. It introduces wide scale reforms to support building safety across the industry through design, construction, and management of residential blocks classed as higher risk buildings.
- Higher-Risk Building (HRB): A building that is at least 18 meters in height or has at least 7 storeys and contains at least two residential units.

The Golden Thread: Is a digital record of information about a higher risk building maintained throughout the building’s lifecycle to support safety management. It must be digital, accurate, up-to-date, secure, and accessible throughout the lifecycle of the building.

- Accountable Person (AP) Principal Accountable Person (PAP): The individual or entity responsible for ensuring the safety of an HRB during its occupation phase.
- Building Safety Regulator (BSR): The regulatory body established to oversee the safety and performance of buildings, particularly HRBs.
- Building Safety case (BSC): The body of evidence to demonstrate that fire and structural risks within a higher risk building are being identified, escalated, and resolved, or managed and monitored adequately on an ongoing basis.
- Mandatory Occurrence Reporting plan (MOR) – A system to report building safety incidents and risks that have caused, or if not remedied are likely to cause: the death of a significant number of people or serious injury to a significant number of people. This is done by submitting a mandatory occurrence: as soon as you can and within 10 days of the safety occurrence being identified.
- Building safety incidents and risks – involve at least one of the following: structural failure of the building or the spread of fire or smoke in the building. For design work, a building safety risk is an aspect of the design related to structural integrity or fire risk, which if built could cause death or serious injury to a significant number of people.

BSI Flex 8670 and relevant PAS standards (e.g., PAS 8671 for PD, PAS 8672 for PC) Publically available standards specifiying competence of duty holders.

Additional References

– Building Safety Act 2022: https://www.legislation.gov.uk/ukpga/2022/30/contents

– CDM 2015 Guide: https://www.hse.gov.uk/construction/cdm/2015/index.htm

– Guidance for Duty Holders: https://www.citb.co.uk/standards-and-delivering-training/training-standards/construction-design-and-management-regulations-2015-cdm/

6. Summary Processes for Duty holders – Download to View