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Regulation 38 and the 'Golden Thread'

The Grenfell Tower tragedy in 2017 and the fire within the student accommodation in Bolton triggered an overdue shift in attitudes towards fire prevention, as well as new legislation and regulations. As Dame Judith Hackitt set out in her recent review of building safety after Grenfell, there is a pressing need to preserve the ‘golden thread’ of information about construction and refurbishment work.
What is Regulation 38? Regulation 38 of the building regulations requires that:

“The person carrying out the work shall give fire safety information to the responsible person not later than the date of completion of the work, or the date of occupation… whichever is earlier.”

This regulation aims to ensure that information critical to the fire safety of people in and around the building is communicated to the owner, occupier and/or end user, so that the building can be operated and managed correctly.

It should ensure that – provided the building is constructed in accordance with the design information available when most fire safety strategies are developed and drafted, i.e., RIBA Stage 3 – the fire safety strategy given to the responsible person is correct and accurately reflects the fire safety precautions in the building.

This enables the responsible person to conduct a suitable and sufficient fire risk assessment (FRA) for the building.  It will accurately record the physical fire safety precautions in place, and so enable risks to the relevant persons in the building to be understood in a way that allows them to be appropriately addressed.

Going forward higher standards will now be needed in relations to this and one of the best courses of action suggested will be to simply keep a diary of the build as you go, pictures, materials used etc. Tangible evidence for future assessments and fire strategy guides that can be called upon with ease.

One of the big talking points was fire doors, the following checklist from Fire Door Alliance provides an example of the type of information relating to each individual installed fire door, that you should include in the fire safety handover pack.

 1. The location and rating of every fire door in the building.

 2. The fire door certificate – which MUST be relevant to each installed fire door.

 3. The type of seal (intumescent / smoke seal / acoustic) fitted to the door or frame.

 4. Details of the doorframe (hardwood, softwood, MDF etc.) and how that relates to the fire door test.

 5. Details of hinges, closers and other essential building hardware (CE marked) and how that relates to the fire door test.

 6. Maintenance information for each component, including the door leaf.

 7. Frequency of inspection and maintenance, depending on expected usage of the door.

What are your thoughts on Regulation 38? Have you found a better a way track it all and keep the Golden Thread of information intact and easily accessible?