Important Guidance on the Golden Thread

The Construction Leadership Council (the CLC) has published new Guidance: Delivering the Golden Thread: Guidance for duty holders and accountable persons.

This is an in-depth and technical guide to delivering the golden thread, for all parties involved with the design, construction and management of higher-risk buildings in England.

The Guidance can be found here and a summary is found here.

What is the golden thread?

The “golden thread of information” is a key concept in the building safety regime in England. It is about the recording and management of building and fire safety information, related to higher-risk buildings. It was a flagship recommendation in the 2018 Independent Review of Building Regulations and Fire Safety  led by Dame Judith Hackitt, to ensure a robust golden thread of key information is gathered and passed across to future building owners, thereby underpinning more effective safety management throughout the building life cycle. This was against a backdrop the Hackitt Review described as “the ineffective operation of the current rules around the creation, maintenance and handover of building and fire safety information”.

The golden thread was then enshrined in legislation, putting significant obligations on parties involved in the design, construction / refurbishment and occupation of higher-risk buildings, to gather, produce, share and update certain information. However, those obligations are spread among:

• the Building Safety Act 2022 (which in turn amends the Building Act 1984 and provides for the Building Regulations to make golden thread provisions), at sections 33, 88 and 90;
• the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023, setting out the golden thread principles and obligations during the design and construction phase at Part 4;
• the Higher-Risk Buildings (Management of Safety Risks etc) (England) Regulations 2023 at Part 2 and the Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024, covering the golden thread in the occupation phase; and
• various other 2023 Building Regulations for higher-risk buildings, which interface with the Regulations above in respect of the golden thread.

So far, so much regulation. Despite some existing guidance from the UK Government and the Building Safety Regulator, questions have arisen as to exactly what is required for meeting the golden thread obligations and in what level of detail.

The Construction Leadership Council Guidance

The new Guidance from the CLC seeks to address those questions. The foreword, by Dame Hackitt, says that it “sets out in much more detail what the golden thread is and how it may be developed during design, through construction, handover and completion of the building and into occupation. It seeks to set out the clear purpose of the golden thread, which is first and foremost intended to rebuild and then retain trust in the safety of our higher-risk building stock”. The Guidance goes on to:

• Set out the legal basis for the golden thread at section 2. This covers “the fundamentals”; an outline of the regulatory regime (including the relevant primary and secondary legislation); duties related to managing and storing the golden thread; and highlighting existing guidance.
• Consider the golden thread for the design, construction and building work on higher-risk buildings, at section 3. This summarises the information and documents that duty holders need to obtain and update; including what is required for the building control approval application at gateway two / due to changes during construction work / for the completion certificate application at gateway three; and running through the position from design to handover and completion.
• Consider the golden thread for occupied higher-risk buildings at section 4. This outlines the information an accountable person must keep about an occupied higher-risk building, to comply with their duties and demonstrate the safe management of their building; the role of accountable persons; the prescribed information and documents to be kept; how to use this to deliver the requirements of the safety case report; and organisational information management to support the golden thread for organisations that manage multiple higher-risk buildings.
• Finally, it contains Annexes A to E, including a glossary and an outline of the legislative requirements for duty holders and accountable persons.

Altogether, the Guidance is a comprehensive look at the golden thread, with granular levels of detail. This will help to bridge the gap between the legal requirements and on the ground implementation. The Guidance also acknowledges that as the new building safety regulatory regime is at an early stage, understanding and experience on the golden thread will evolve. It notes that the Guidance is a “work in progress” which will be revised if necessary, including potential development of case studies and practical examples.

Whilst the Guidance is not a statutory document, the CLC itself is a very well-established body, which works in partnership with government and organisations across the industry. Building Safety is identified as one of its four strategic priorities. This Guidance has been produced by an industry working group (with acknowledgements given to the Building Advisory Committee Golden Thread Working Group; the Department for Business and Trade; the Ministry of Housing, Communities and Local Government; HSE and others) and is endorsed by Dame Hackitt. It is also very timely, following the renewed focus on building safety in the wake of the Grenfell Inquiry’s (final) Phase 2 Report being published on 4 September 2024.

In short, this Guidance will be welcomed as essential reading for anyone involved with the golden thread and the wider building safety regime.

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