TWO THINGS, ONE NAME

What is a building safety case?

Most people use "safety case" and "safety case report" to mean the same thing. They are not the same thing, and the difference decides whether you are actually compliant or just holding a document.

One is the work. The other is the write-up. You cannot buy your way to the first by commissioning the second.

Look through Part 4 of the Building Safety Act and you will find "safety case report" in section 85. You will not find a definition of "safety case" anywhere. The phrase comes from the safety-critical industries the regime borrowed from: nuclear, offshore oil and gas, rail.

In those industries a safety case means the whole argument that a thing is safe. The evidence, the assessments, the controls, the management arrangements, and the reasoning that ties them together. The report is simply the document that presents that argument to a regulator.

The Act builds the same structure without using the label. Section 83 requires every accountable person to assess the building safety risks for the part of the building they are responsible for. Section 84 requires them to take all reasonable steps to stop those risks materialising, and to have formal arrangements for planning, organising, controlling, monitoring and reviewing that work.

That is your safety case. It is continuous, it is distributed across every accountable person, and it exists whether or not anybody has written anything down.

Section 85 then requires one person, the principal accountable person, to prepare a safety case report. That report contains the section 83 assessments and brief descriptions of the section 84 steps.

So the report is downstream. It reports on the case. If the assessments have not been done and the arrangements do not exist, there is nothing to report, and no amount of document-writing fixes that.

The Act never actually says "safety case"

WHERE THE TERM COMES FROM

One is the work. The other is the write-up.

THE DISTINCTION THAT MATTERS

The work

The safety case

Building Safety Act 2022, sections 83 and 84

What it is

The assessments of your building safety risks, the steps taken to control them, and the arrangements that keep that going: planning, organising, controlling, monitoring, reviewing.

Who owns it

Every accountable person, each for the part of the building they are responsible for.

Scope

Split across the building. Each AP covers their own part.

Timing

Continuous. Reassess at regular intervals, whenever you suspect the assessment is out of date, and whenever the Regulator directs it.

It exists

Whether or not anybody has written anything down. Doing nothing does not mean you have no safety case. It means you have a bad one.

The write-up

The safety case report

Building Safety Act 2022, section 85

What it is

One document containing the section 83 assessments and brief descriptions of the section 84 steps. The Act's word is "brief".

Who owns it

The principal accountable person alone. Not shared. If you are the PAP, this one is yours.

Scope

The whole building, pulled together from what every AP has done.

Timing

Prepared as soon as reasonably practicable after the building is occupied or after you became PAP, whichever is later. Then revised as assessments and steps change.

It exists

Only if somebody writes it. And it can only describe work that has actually happened.

Which is why the report cannot be the first thing you commission. A consultant can write you a beautiful section 85 report. They cannot write your section 83 assessments into existence, and they cannot invent the section 84 arrangements your accountable persons are supposed to be running. Buy the document first and you have paid for a description of work nobody has done.

What the Regulator expects to find in the report

NINE AREAS, FOUR QUESTIONS

Government guidance sets out nine content areas. They answer four questions in order, and the order is the useful part: you cannot describe how you are managing a risk until you have described the building it lives in.

Question one

What is this building, and who is responsible for it?

Basic building information

Name, address, registration number, build date, height, storeys, floorplans, unit types, common areas, resident profile, other uses, surrounding area, services and utilities.

People responsible

The principal accountable person, the owner, every other accountable person, the Responsible Person under fire safety law, managing agents, and how information is shared between them.

Question two

What is it made of, and what condition is it in?

Construction methods and materials

Structural elements, materials, load-bearing and stability systems, cladding, foundations, ground conditions.

Structural condition

History of problems, current maintenance arrangements, and the surveys and inspections you hold with their findings.

Building work and refurbishment

Any work affecting the safety risks. For large panel system buildings, the remediation history.

Question three

What is protecting people in it?

Fire safety measures

Standards applied, external walls, structural protection, balconies, compartmentation, fire doors, smoke control, escape routes, stairs, detection and alarm, sprinklers.

Emergency plan

The evacuation strategy, how you communicate it to residents, and the facilities provided for the fire and rescue service.

Question four

How do you know it is working, and how do you keep it working?

Building safety risk assessments

A summary of the assessments made by each accountable person, the methodology used, the findings, and how the risks are being managed.

Safety management systems

Roles, maintenance and inspection procedures, how changes are controlled, and how performance is monitored.

Read question four again. That is the section 83 and 84 work turning up in the report. Everything above it is context. If you can answer questions one to three but not four, you have a building description, not a safety case report. That is the most common thing we see.

Four things a safety case does not mean

WHERE PEOPLE TRIP UP

The myth

"We need to get a safety case report written."

The reality

You need the assessments and the arrangements first. The report describes them. Commissioning the document before the work is buying a description of something that does not exist yet, and it is the most expensive way to discover your accountable persons have not done their section 83 assessments.

The myth

"It is a submission we make when the Regulator asks."

The reality

Section 85 requires you to prepare it and keep it revised. That is the duty, and it bites as soon as reasonably practicable after occupation or after you became principal accountable person. Handing it over is a separate event. If the Regulator asks and you start writing, you were already late.

The myth

"The safety case is the freeholder's problem."

The reality

Section 83 puts the assessment duty on every accountable person, for the part of the building each is responsible for. Only the report is the principal accountable person's alone. And in a building run under Right to Manage, the freeholder may not be an accountable person at all.

The myth

"There must be a required length and format."

The reality

There is not, and we are not going to pretend there is. Government guidance sets out the nine content areas and says nothing about length, proportionality, or who is qualified to write it. What the Act does say is that the report contains "brief descriptions" of the steps taken. Brief is the Act's word, not ours.

Go deeper

KEEP READING

Not sure whether you have a safety case or just a document?

Send us what you hold and we will tell you what is actually there, what is missing, and what your accountable persons still need to do. We have no works arm and we do not sell safety case reports, so we have no reason to tell you that you need one.