The Search for Certainty
At Tetra, we see ourselves as having a core role within our sector: to be useful. One of the ways we live that is by creating practical, clear content for people responsible for managing properties safely and confidently. Our latest webinar, Building Assessment Certificates & The Importance of Structural Safety, was designed in that same spirit.
Even before we began, over fifty people were already waiting in the lobby — and as we went live, hundreds more joined. The high turnout told its own story: this is an area filled with uncertainty, pressure, and change.
Few issues in property management feel as technical yet as personal as building safety. The regime that followed Grenfell continues to evolve — often faster than the systems, competence frameworks, and budgets designed to sustain it. In this session, Dr Shaun Lundy and Jason Thelwell set out where we are now, what’s changing, and what dutyholders must do to keep pace.
Shaun is Tetra’s Chief Strategy Officer, as well as IOSH Vice-President and Chair of the IOSH Construction Committee. With deep industry connections, he is often among the first to interpret and share insights on new legislation, regulator performance, and evolving competence standards.
Jason, our Fire Engineering Director, brings a complementary perspective. Having served as Chief Fire Officer and Chief Executive in the Fire and Rescue Service for more than eight years, he brings lived experience of how things can go wrong — and how robust fire strategies, smart design, and competent management can ensure they don’t.
The Post-Grenfell Picture
Shaun began by grounding the conversation in the wider landscape. “The police investigation, Operation Northleigh, continues to pursue offences including corporate manslaughter, gross negligence manslaughter, fraud, and health and safety violations,” he explained.
At present, 58 individuals and 19 companies remain under investigation, with the Metropolitan Police and Crown Prosecution Service expected to submit files in 2026 and make charging decisions by the end of that year. “It’s taken an awful long time to get there,” Shaun noted, “so we won’t see prosecutions until well into 2027 and beyond.”
At the same time, there are growing questions about the performance of the Building Safety Regulator (BSR). Established under the Health and Safety Executive, it was intended to provide oversight and coherence across fire, structural, and general safety. “Its performance has been called into question,” Shaun said. “Delays, excessive costs, and poor communication have all been raised through a House of Lords inquiry.”
In response, the regulator has now been moved under the Ministry of Housing, Communities and Local Government (MHCLG), with Andy Roe, former Commissioner of London Fire Brigade, appointed as Chair and Charlie Pugsley, former Deputy Commissioner, as CEO. Early signs of improvement are visible. “Andy’s role,” Shaun explained, “is to streamline the process — to make it proportionate — to make sure we get safe homes, without everyone getting stuck in the glue.”
That blend of proportionality and rigour became the thread running through the rest of the session.
The Golden Thread: Still More Knot Than Fabric
If there was one concept that encapsulated both the challenge and the opportunity, it was the Golden Thread.
“The Golden Thread must be secure, accurate, digital, and accessible,” Shaun reminded attendees. “It enables risk-based decision-making across a building’s life cycle.” Yet in practice, he said, “what we see is a very broken Golden Thread.”
Tetra’s Building Safety Team frequently conducts gap analyses before developing or updating Safety Case Reports. Missing fire strategies, outdated drawings, and incomplete maintenance histories are common. Jason’s fire engineering team often steps in to rebuild key documents like fire strategies and compartmentation records — ensuring that the information dutyholders submit is actually usable.
“The Golden Thread is not conceptual,” Shaun said. “It’s operational.” And the legal requirement is clear: every higher-risk building must already have a Safety Case and Safety Case Report in place. “If you haven’t got one in place now,” he warned, “you are technically legally non-compliant.”
Building Assessment Certificates: The 74 Percent Problem
From here, Shaun turned to the latest data — and it drew plenty of reactions in the webinar chat.
As of July 2025, 1,454 Building Assessment Certificate (BAC) submissions had been made. Only 170 were assessed. Of those, 74 percent were refused.
“The average review takes 123 hours,” he said, “with fees ranging from £8,000 to £20,000. And that’s before you fix what went wrong.”
The problem isn’t paperwork; it’s proof. “It’s not the writing,” Shaun explained. “It’s the demonstration of management that’s the problem.” Too many dutyholders can’t show that the actions identified in their surveys — fire doors, compartmentation, façade remediation — are actually being completed.
The regulator’s guidance on report length provides a useful benchmark: around 30–40 pages, with appendices for supporting evidence. “A 2½-page report is not going to do it,” Shaun said, “but you don’t need War and Peace either.”
A refusal does not necessarily mean a building is unsafe, he added — but it does mean the regulator was unconvinced that it’s being safely managed. “They’re looking for evidence of proactive management, not perfection.”
Structural Safety: The Regulator’s New Priority
The Building Safety Act is about both fire and structure, and this is where the regime is shifting most visibly.
“Many dutyholders have assumed a fire risk assessment alone was sufficient,” Shaun said. “It isn’t.”
He drew a sharp distinction between Condition Surveys — which assess deterioration, typically by building surveyors — and Structural Risk Assessments (SRAs), which evaluate the likelihood of structural failure and must be undertaken by Chartered Structural Engineers.
“You can’t assume a building that’s been through building control is structurally sound,” he said. “We’re discovering that some simply aren’t.”
Tetra’s approach is phased:
- Phase 1 — an initial appraisal of risk;
- Phase 2 — an intrusive investigation if concerns arise or records are incomplete.
Jason added the practitioner’s perspective: “We’ve seen 1960s blocks where the structure’s safe for another five years, but after that decanting and demolition are the only realistic options.”
Many BAC rejections, Shaun explained, have been down to insufficient evidence of structural safety. The regulator now expects a stand-alone SRA to be referenced in every Safety Case Report.
Gateways: The Bottleneck at Gateway 2
Shaun then turned to the Gateway process, particularly Gateway 2 — now the principal choke point.
“Up to 45 percent of submissions fail validation,” he said. “The usual reasons are missing structural or fire detail, corridor design issues, and incomplete smoke-system information.”
Average processing time is 16–18 weeks. “That’s painfully slow if you’re waiting to remove a waking watch or install a fire alarm system,” Shaun observed.
Gateway 3 — completion — will bring its own test: a requirement to demonstrate a fully up-to-date Golden Thread before any project handover. Build UK’s recent guidance was recommended as essential reading for those preparing Gateway submissions.
Competence: From Slogans to Systems
The second half of the session focused on competence — an area Shaun has helped to shape nationally.
“I’ve had the privilege of being appointed as the Technical Author for the Industry Competence Committee’s Task & Finish Group,” he explained. “We’ve published fifteen draft principles for consultation, with a British Standard to follow in the next two years.”
The Intelligent Customer principle, he said, means “clients must assure themselves that those they employ are competent — and be able to prove it.” Competence now means skills, knowledge, experience, and behaviours, not just qualifications.
Jason brought that to life: “Ask for evidence of internal audits. Ask what their QA sign-off process is. Ask how they mentor staff and whether there’s a culture that allows challenge.”
Shaun emphasised that Tetra’s draft guidance on Managing Competence is deliberately scalable. “Whether you’re a five-person consultancy or a thousand-person organisation, the process should fit. The consultation’s live now — and feedback’s welcome.”
What the Regulator Really Looks For
In response to an audience question — what should we prioritise before submitting a BAC? — Shaun’s answer was direct:
“It’s not a passive process. You don’t upload a report and wait for a certificate. The regulator will always challenge.”
Be prepared to provide:
- the latest Fire Risk Assessment,
- Compartmentation Survey,
- Fire Strategy,
- Structural Risk Assessment,
and be ready to explain your management system and competence assurance processes.
“They’ll ask how you checked the people who wrote your surveys were competent,” Shaun warned. “They’ll ask to see your Plan–Do–Check–Act cycle. If you can’t show that, it doesn’t look good.”
Jason added: “Make sure your fire strategy, compartmentation survey, and engineered solutions dovetail. When they don’t, it’s immediately obvious.”
External wall assessments were another recurring reason for failure. “If you’ve had a FRAEW or EWS report done but not acted on it, that’s an easy rejection,” Shaun noted. “Get peer review where needed — validity matters.”
Heritage Buildings and Practical Mitigation
Not every building fits the rulebook. Asked about listed and heritage stock, Jason explained that “many operate on simultaneous evacuation strategies supported by advanced detection systems.” In some cases, clients have even fire-tested historic doors to evidence performance.
Shaun’s advice was pragmatic: “Sometimes you need a bespoke fire-engineered solution. That’s where expertise really earns its keep.”
The Road Ahead
Will the qualifying height fall from 18 metres to 11? Shaun’s answer: “It’s not a question of if — just when.”
Wales has already extended its regime to all heights with proportional measures. In England, he expects a similar broadening once the >18 m stock is processed — “probably a four-to-five-year horizon.”
The implication is clear: more buildings will fall within scope, and more owners will face the same structural and competence requirements now applied to high-rise blocks.
What Dutyholders Should Do Now
Shaun’s closing message was one of urgency but also opportunity:
“Don’t delay. Make your plans. Get on with it. The regulator is becoming less tolerant of excuses — and there’s a limited pool of competent people to do this work.”
In practical terms:
- Commission a Structural Risk Assessment by Chartered Structural Engineers. Tetra is able to offer you this service.
- Update your Fire Strategy to reflect the as-built reality.
- Maintain the Golden Thread — digital, indexed, and current.
- Track and evidence actions through a Plan–Do–Check–Act framework.
- Evidence competence for internal and external teams.
- Peer-review your external-wall documentation.
- Keep your Safety Case Report concise and active — about 30–40 pages of claim, argument, and evidence.
Now It’s Your Turn to Get Involved
We were asked more questions than we could cover during the live webinar — which is why we’re hosting a Building Safety Drop-In Session, where you can put your questions directly to Dr Shaun Lundy and Jason Thelwell, and hear the answers live.
Join us on 9 December for this interactive follow-up session and send your questions in advance. Register here.
If you missed the original webinar, or want to revisit specific sections, you can watch the full session on demand here.
For further information, contact info@tetraconsulting.co.uk or visit tetraconsulting.co.uk.