Those wanting clear direction or instruction on the implementation of the golden thread will be disappointed by the government’s latest clarifications. Here we highlight the top six takeaways.
For example, the Department for Levelling Up, Housing & Communities (DLUHC) has refused to “define digital” or mandate “particular coding standards or exchange mechanisms”. However, there is also flexibility where the industry needs it in the golden thread. For example, the DLUHC observes that while it is preferable for the same information management system to be used by the client and the accountable persons, this “may not be possible in practical terms, specifically for large projects”.
The clarifications appear in the DLUHC responses to the construction industry’s feedback to the consultation on proposals for improving the building control regime for higher-risk buildings (HRBs) and wider changes to the building regulations that apply to all building work, which were published last week.
In particular, the DLUHC’s responses to the feedback on the golden thread total nearly 2,500 words.
BIMplus has waded through the government’s statements and below we highlight some of the key takeaways.
How the golden thread is managed, kept and maintained
Government response: “We consider that mandating particular coding standards or exchange mechanisms as a solution for the whole of industry could create an unnecessary burden. It will be for individual dutyholders to agree the digital solutions and exchange mechanisms that work for their organisations.
“The client and other dutyholders must ensure that whatever digital solution and formats that are used can be transferred throughout the building lifecycle, so that the golden thread can be handed over to the principal accountable person or the Responsible Person at building completion and that the information is useable and accessible.
“The government acknowledges the requests for additional guidance and that this guidance should clearly signpost to existing standards or best practice.
“The government also considers that it would not be appropriate for all the information in the golden thread to be publicly available. Certain information will have security or commercial sensitivities and it will also include personal data.
“Once buildings are occupied the registration and key building information will be published and residents will be provided proactively with certain information about their building, and will be able to request further information.”
Relevance, security and accountability
Government response: “The government is clear that most of the golden thread information should be kept up to date. However, some of the information may be relevant even if it does not reflect the current building. For instance, the building completion certificate would be retained and the certificate itself would not be updated.
“It is important that the golden thread of information is secure. While accessibility is essential, ensuring the golden thread is secure will mean that dutyholders will trust that sensitive information is safe and can be stored in the golden thread.
“The golden thread will support greater accountability alongside requirements on change control, which will ensure there are clear records of when a change was made, who made the change and who approved the change.
“The government will not mandate how this information is recorded and organisations can decide what is most appropriate for their needs. We expect that digital systems that automatically record changes to information and documents will play a large part in this process.”
Information handover on building completion
Government response: “The golden thread information should be handed over to the relevant person. The information should be provided in such a way to ensure none of the information is lost or corrupted. We expect parties to work cooperatively to ensure this objective is achieved.
“As part of the building completion certificate application, the client and the relevant person should co-sign a statement confirming that the client has handed over the golden thread to the relevant person, and that the relevant person has received the golden thread. This reinforces the importance of this step and will support culture change across industry.
“The government considers that it is important that there is clear accountability on each dutyholder for meeting their statutory duties. However, the client has overall responsibility for the building and the other dutyholders are answerable to the client. It is, therefore, the client who should be responsible for signing the statement and for handing over the golden thread information.”
Client’s duties in new and existing HRBs
Government response: “It is important that the client is responsible for putting in place the golden thread of information and ensuring that other dutyholders are meeting their duties with regard to the golden thread.
“The government is clear that the client is the person responsible for commissioning the building work and they have overall control over the project and, therefore, it is appropriate that they are ultimately responsible for the golden thread. Although the client can delegate tasks, they cannot delegate responsibilities.
“The principal designer and the principal contractor need to be satisfied that the client is aware of their duties, including in relation to the golden thread of information, and the client will need to ensure that those they appoint have the right competencies to take on these roles.
“The government agrees that it is preferable if the same information management system can be used by the client and the accountable persons as this will enable information to be shared quickly and easily. However, this may not be possible in practical terms, specifically for large projects. If separate information management systems are used, then the client and the accountable person would need to agree this.
“This will not be a decision that the client can solely make. As set out in paragraph 7.97, information will have to be shared between the client and the accountable persons to ensure that they can meet their duties to comply with building regulations and to manage building safety under the Building Safety Act 2022.”
Principal designer and principal contractor duties
Government response: “Both contractors and designers must be satisfied that the client is aware of their duties before they begin work, and it would be expected that, if necessary, they would make the client aware of their duties regarding the golden thread.”
Golden thread remaining relevant and proportionate
Government response: “The golden thread information must be regularly reviewed to ensure it remains relevant and proportionate. The government will not be mandating how organisations operate and is clear that there is a duty on all dutyholders to ensure the golden thread is relevant and proportionate.
“For some it may be appropriate for the person who created the information to review it. However, for some projects that might not be feasible. It is for individual dutyholders to decide how this duty should be delivered in individual projects or organisations.”
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