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BUILDING SAFETY ACT - OUR APPROACH
BSA Dutyholder Obligations | Gateway 2 and 3 | The Golden Thread | Competence Management | MOR
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The Building Safety Act 2022 represents the most significant change to construction regulation in a generation. For developers, investors and consultants working on residential and mixed-use schemes, it has restructured the obligations, timelines and competence requirements that govern how buildings are designed, built and handed over. Understanding those requirements, and selecting a contractor who has embedded them into their delivery process, is now a fundamental part of project planning.
Shore Construction acts as principal contractor on both higher-risk buildings and on the wider range of projects to which the Building Safety Act applies. Our approach is process-led: the Act's requirements are integrated into how we manage preconstruction, procurement, site delivery and handover, rather than treated as a compliance layer added after the fact.
Higher-Risk Buildings
Under the Building Safety Act, a higher-risk building (HRB) is defined as a residential building of 18 metres or seven storeys or more in England, containing at least two residential units. This threshold brings with it a substantially more demanding regulatory regime, administered by the Building Safety Regulator (BSR).
The Gateway regime structures the development process into defined stages, each requiring formal regulatory approval before work can proceed. For principal contractors, Gateway 2 and Gateway 3 are the critical points.
Gateway 2 is the before-construction stage. Before any work begins on site, the principal contractor must demonstrate to the BSR that the proposed design meets the functional requirements of the building regulations and that the construction approach is sound. The submission requires detailed information on construction methodology, structural approach, fire strategy, and the competence of the delivery team. Shore prepares Gateway 2 submissions in close collaboration with the principal designer and client team during preconstruction. This is not a document exercise; it is a genuine test of delivery readiness, and we treat it as such.
Gateway 3 is the completion stage. Before a higher-risk building can be occupied, the principal contractor must submit a completion certificate application to the BSR, accompanied by evidence that the building as constructed conforms to the approved plans. This requires rigorous as-built documentation, sign-off on all safety-critical elements, and confirmation that the Golden Thread information is complete and fit for handover. Shore manages Gateway 3 preparation as a continuous process throughout construction, not a retrospective exercise at practical completion.
The Golden Thread
The Golden Thread is the digital record of information about a higher-risk building, created during design and construction and passed to the accountable person at completion for use throughout the building's operational life.
As principal contractor, Shore is responsible for managing the Golden Thread through the construction phase. In practice, this means maintaining a complete, accurate and auditable record of every decision that affects the design or safety of the building: design changes, material substitutions, structural amendments, fire-stopping installations, and any deviation from the approved Gateway 2 submission.
We structure Golden Thread management through our Common Data Environment from the outset of the construction phase. Each trade contractor is required to provide documented evidence of safety-critical installations as work proceeds, not retrospectively. This approach means that the Golden Thread is a live record of the building as it is being built, rather than a compilation exercise at the end of the project.
For clients and their asset management teams, a well-maintained Golden Thread reduces the burden of the Building Safety Case at occupation and provides a reliable foundation for the building's ongoing safety management obligations under the Act.
Mandatory Occurrence Reporting
Under the Building Safety Act, principal contractors on higher-risk building projects are required to report certain safety occurrences to the BSR as they arise. Mandatory occurrence reporting (MOR) is not optional and cannot be deferred; it applies to occurrences that create a significant risk to life in or about the building.
Shore's approach to MOR begins with clear internal protocols for identifying, escalating and documenting reportable occurrences. Our site management teams are trained on what constitutes a reportable occurrence under the regulations, and our SHEQ function provides oversight across all HRB projects. Where a reportable occurrence is identified, we manage the BSR notification process and keep the client fully informed throughout.
MOR is not only a regulatory obligation; it is a signal of a well-managed site. A principal contractor with robust MOR protocols in place demonstrates the kind of safety governance that the Building Safety Act was designed to require.
The Building Safety Act Beyond Higher-Risk Buildings
The Building Safety Act does not apply only to higher-risk buildings. The Act introduced new and expanded dutyholder roles that apply to all projects subject to building regulations in England. These roles carry statutory obligations under both the Act and the CDM Regulations 2015, including requirements to plan, manage and monitor work so that it complies with the building regulations and is carried out safely.
Shore fulfils its principal contractor dutyholder obligations on all applicable projects, not only those that meet the HRB threshold. This includes maintaining a Construction Phase Plan that reflects current building regulations requirements, managing the competence of our supply chain, and ensuring that building control applications and notices are submitted and managed correctly throughout the project lifecycle.
For clients developing schemes below the HRB threshold, our approach provides confidence that regulatory compliance is being managed proactively and that the project is being delivered in a way that will withstand scrutiny at building control sign-off and beyond.
Competence
The Building Safety Act places explicit emphasis on competence: the obligation on all dutyholders to ensure that those carrying out building work have the appropriate skills, knowledge, experience and behaviours to do so safely and in compliance with the building regulations.
As principal contractor, Shore takes this obligation seriously at every level of the supply chain. We assess the competence of trade contractors against the specific requirements of each project, with enhanced scrutiny applied to packages involving safety-critical elements. On higher-risk building projects, this assessment goes beyond the standard accreditation check; we require evidence of directly relevant project experience and technical capability on a package-by-package basis.
Our own site management team maintains the qualifications, training and continuing professional development appropriate to the projects we deliver. We do not sub-contract our principal contractor responsibilities.
DEMONSTRATING COMPLIANCE
Working with Shore on BSA-Compliant Delivery
The Building Safety Act has changed the nature of the principal contractor role. It is no longer sufficient to manage a construction site safely and deliver a building that broadly meets its specification. Developers and investors need a principal contractor who understands the regulatory framework, can demonstrate compliance to the BSR, manages the Golden Thread rigorously.
Delivering buildings that can be occupied, managed and maintained safely for the long term.
