Guidance

Safety management systems for high-rise residential buildings

Published 19 September 2023

Applies to England

This guide is for accountable persons of a high-rise residential building. It will help you understand how to set up and manage a safety management system as set out in the guidance safety case for a high-rise residential buildings.

The information in this guide does not cover all circumstances or constitute legal advice. It explains how to set up and maintain an effective system to manage the risk of the spread of fire or structural failure in a high-rise residential building.

Getting started

A safety management system (SMS) is a formal management system or framework for managing safety risks.

One model for a SMS is based on the Plan, Do, Check, Act approach. This model covers:

• Plan: determine your policy and plan for implementation
• Do: assess risks and implement your plan
• Check: measure performance
• Act: review performance and act on lessons learned

Other SMS models include:

• the British standard on fire risk management systems BS 9997:2019 on bsigroup.com
• the International Organization for Standardization (ISO) Occupational Health and Safety Management System ISO 45001:2018 on iso.org

You do not have to get the SMS accredited to an external standard. Most importantly it needs to be a system that works for you.

Be proportionate

Base your SMS on a risk assessment of your building. Your SMS should be proportionate to the hazards of your building. Things that might influence you are the:

• complexity of your building, is it a mixed-use building, or is it a complex design structurally
• complexity of the measures in place to control building safety risks, consider how many safety measures you have in place, and how they integrate
• number of buildings you manage
• size of your organisation
• extent to which contractors and third parties manage or maintain the measures in place
• resident profile, for example, do any of your residents need help to evacuate or have any additional needs

If you produce any documents, they should be concise and easily understood.

Continuous improvement

An effective SMS promotes continuous improvement. This means that you regularly review and update:

• the measures you are using to manage building safety risks
• the systems, policies and procedures that ensure their effectiveness

You may already have improvement or action plans in place. Consider what you do well and identify areas for improvement.

When you document areas for improvement, you should list:

• what your organisation wants to achieve and why
• timescales
• resources
• named people to lead the improvement

Senior managers should measure progress against your improvement plan.

Plan: determine your policy and plan for implementation

Before starting work on your safety management system (SMS), consider your current building safety measures and how you manage them. Explain how you want to develop these in the future and set out the steps required to achieve this.

Leadership

An effective SMS relies on leadership from senior managers. As well as supporting the aims of the SMS, leaders influence the wider culture of an organisation. They also help to put resources in place to deliver it.

Roles and responsibilities

Everyone in an organisation has a part to play in the SMS, but some will have specific roles and responsibilities. Identify and define these as part of the SMS. You may already have set out roles and responsibilities in a health and safety policy, fire safety arrangements or in individual job descriptions.

Anyone with specific responsibilities should have the necessary competence (skills, knowledge, experience and behaviours), to perform their duties. It is important that everyone in a specific role gets the training they need. Your organisation should also ensure appropriate authority and budgets are available to support specific roles.

You may use designers or contractors for refurbishment or maintenance. Have a system in place to ensure they are competent. They should be able to provide evidence of background checks and refer to third party certification or accreditation bodies where appropriate.

Do: assess risks and implement your plan

Assessing building safety risks

Although the law defines the building safety risks as spread of fire and structural failure, their causes and consequences will vary from building to building. You can use the information from risk assessment on your parts of the building as part of the SMS.

You can read more about assessing safety risks in the building safety guides for accountable persons.

Maintenance, inspection and remediation

Parts of your building and its equipment will need maintenance and inspection. This includes servicing and inspection in line with relevant legal requirements, British Standards and the manufacturer’s instructions.

The Fire Safety Regulations on legislation.gov.uk, set out expectations for some of the measures in place to control building safety risks.

Maintenance schedules

Be aware of the maintenance and inspection requirements relating to building safety. You will need a system for scheduling, undertaking, and recording the necessary work. You need to keep evidence of completed work as part of the information you hold about your building.

Keep records of maintenance and inspection work, including any remedial works. This will help demonstrate that building safety risks are being managed on an ongoing basis.

Employing contractors

Using contractors to perform maintenance and inspection work is very common. It is vital that any contractors, either organisations or individuals, have the necessary skills, knowledge, experience, and behaviours required to perform the work. There is more than one way to do this. For example, you could have an approved contractors list, or make enquiries about skills etc before appointing a contractor. Including competence requirements in tender specifications or contracts can also help.

Give contractors all the relevant information they need to compete their work. This may include paper or electronic information and asset tag numbers, if you have these. It might also include details of the equipment involved, manuals or manufacturer’s maintenance recommendations. They may also need relevant building information, such as details about any asbestos present.

Put effective measures in place to ensure contractors’ activities are undertaken safely. This should include any potential impact their work may have on residents.

Uncovering issues that need attention

Maintenance and inspection will often identify things that require further attention. Addressing these matters will ensure your equipment and control measures continue to work effectively.

When you receive reports, certificates or other maintenance documents, review these to see if any action is required. Put processes in place to consider, complete, and track any identified actions to completion.

If any actions cannot be completed as recommended, record the reasons why. Consider whether you can put any temporary or alternative measures in place.

If you find a control measure is not working as it should (for example because of breakdown reports or resident concerns), consider what additional measures you can take until repair or replacement can be completed.

Manage change

Effective change management is essential to ensure you are managing building safety. Changes that may impact building safety risks normally fall into one of 4 categories, changes:

• to the building
• to the number of residents, or their needs
• to existing management systems, including organisational changes such as the which organisations run the building or the individuals in particular roles
• made by others that may affect building safety

Have systems in place to identify the impact:

• of changes on building safety risks, systems should include the impact at design, implementation and completion stages
• while the change is being made, this could include any temporary changes to risk management or control measures needed, for example, because of building work

Things to consider when managing change include:

• what changes may have an impact on building safety risks, which include changes to any part of the building that impacts your part of the building or external changes
• like-for-like changes that may not have an impact once completed, but may involve temporary modifications while the change is made, for example, changes in fire escape routes due to scaffolding on part of the building
• the roles and responsibilities for assessing, authorising, and managing changes
• how you will identify the permanent or temporary impact of any changes and any changes needed in the measures to control building safety risks
• how you will manage the change process, including liaison with other interested parties
• the need for any relevant approvals such as planning permission or building control approval
• how to review changes after completion to understand if they were completed as planned
• how to review changes to pick up if any control measures were disturbed and need reinstating, and if maintenance schedules need to be updated

Planning for emergencies

Serious building safety incidents can happen and it is important to be prepared. There are general principles for dealing with emergencies, but the arrangements you make should be specific to your building.

Many high-rise residential buildings are designed to support a ‘stay put’ approach. This means only residents directly affected by a fire are evacuated. Other buildings operate a simultaneous evacuation strategy. This means everyone leaves the building during a fire. Sometimes this type of evacuation strategy is used as a temporary measure while fire safety issues are put right.

You can read more about managing safety risks in the building safety guides for accountable persons.

If an alarm system is fitted, a maintenance regime should be in place. Other factors that may influence emergency arrangements include:

• resident evacuation plans (where relevant)
• premises information boxes
• the views and needs of the local fire and rescue service

If circumstances change, review the emergency arrangements to make sure they are still fit for purpose. Examples of changes include:

• changes to the building itself
• changes in access to emergency equipment such as hydrants or firefighting rising mains

Whatever arrangements you have in place, you should make residents aware of what they should do in the event of an emergency. This includes what they should do if they are in a common area such as a corridor or community room when a fire breaks out.

You can read information about preparing a resident engagement strategy.

Check: measure performance

Monitoring and auditing

Monitoring the performance of your SMS gives you confidence that the measures in place are managing building safety risks effectively. It can also give an early indication of any matters requiring attention, or if anything could be done better in the future.

Active monitoring

Provides information in advance of a problem or an issue. Examples include:

• checking maintenance tasks are completed on time
• ensuring fire door inspections are carried out

These are sometimes referred to as leading indicators because they are reviewed before an unwanted event has happened.

Reactive monitoring

Provides information on what has already happened. Examples include:

• incident investigations
• equipment breakdowns

These are sometimes referred to as lagging indicators because they are reviewed after an unwanted event has happened. Information and concerns raised by residents or contractors can also indicate how building safety is being managed.

An effective system for monitoring performance will use both active and reactive monitoring.

Managing multiple buildings

If you manage more than one building, it is important to consider the individual performance of each one separately. You cannot manage safety risks effectively as an average of a portfolio of properties.

Decide what is acceptable in terms of performance. This will depend on what is being measured and its importance for safety. Whatever measures you use, you will need a process in place to investigate any dips in performance. This ensures safety is not compromised.

You should regularly update senior managers on the performance of measures being monitored.

You may also have a schedule of audits which contribute to monitoring your SMS. A system should be in place to review and implement findings (non-conformances) from audits.

Act: review performance and act on lessons learned

Review your safety management system

You should review your SMS to ensure the measures in place remain effective. Triggers for a review include:

• an incident or problems that have been identified, including dips in monitored performance, feedback or complaints from residents
• changes in the building, its residents, or the accountable persons or principal accountable person
• changes in legislation, guidance and standards, you will need systems in place to ensure you keep up to date with developments
• a scheduled review

The review process should involve the leadership team and senior managers. This ensures that they are aware of the resources needed and any recommendations for improvement.