Don't argue with the referree'! Creating better Safety Case Reports

We always tell our children before a sporting fixture, 'don't argue with the referee'…. There's no point, they're always right, right??!!!! But what does this have to do with your Safety Case Report submission to the Building Safety Regulator (BSR)….

At RiskFlag our aim is to equip clients with the tools to efficiently understand their risk and develop safety cases at scale. But it's also so important for us to share learning and experiences, particularly with the confusion around High-risk Building (HRB) safety cases and the feedback organisations are receiving on HRB Safety Case Report (SCR) submissions. 

This short article summarises some generic feedback on SCR from the BSR, with the hope that it will improve your submission.... Remember, the BSR is the 'referee'!

Top tips when creating your HRB Safety Case Report (SCR) Submissions

1. This may sound simple, but make sure that you convince the BSR in your SCR that you know your building; when it was built, how many floors and layout etc. But most importantly make sure that this data is consistent through the whole report. Inconsistencies in the SCR should be caught and addressed at the peer and independent review stage within your organisation, prior to sign off by the PAP, or PAP representative (if organisation).
2. You must know your residents and explain what processes / systems you have in place to document resident needs and how this is reviewed. This could be captured in the Safety Management System (SMS) and summarised in the SMS chapter of the SCR.
3. In the Planning for Emergencies chapter of your SCR explain the processes in place to ensure that all key stakeholders know how to isolate services in the event of an emergency, this includes the suppliers. You could run a training day for suppliers (gas, electric and water) at the buildings that you consider higher risk, this would be used as evidence with the safety case.
4. If you lack information about the building (you may have only just taken it on, for example) you must demonstrate that you have taken all reasonable steps to find the information. If you still cannot find the information, the you must explain the associated risk and how can this risk be mitigated. This could be captured in your Managing Risks chapter of the SCR.
5. Competency…. Competency…. Competency….! This is the second most common clarification that we have seen raised by the BSR, after clarifications around the SMS. Why are the people involved in the development and management of the safety case competent and why are all contractors working on the building or conducting surveys competent? This must be explained in the SCR and managed in the safety case. Competency isn’t just about having the person or organisation having the correct qualifications, but also about having suitable and recent experience. In aviation we use the acronym SQEP – Suitably Qualified and Experienced Person.
6. Key Performance Indicators (KPI), in the context of safety, must be defined. An example of a KPI is how quickly resident reports are triaged by your organisation, to assess if they are safety related and need escalation to the PAP. Furthermore, how are safety issues raised to the senior leadership? A summary of this could be provided in the SMS chapter of the SCR.
7. If the building has been subject to a major change (addition of adjoining buildings, for example) or has been a change of use or resident demographic then the process for review of strategies and polices should be defined and summarised in the SCR.
8. If there has been any major change to the building then any potential implications to the buildings structure must be considered, evidenced in the safety case and summarised in the SCR. The impact on vertical and horizontal loads with the addition of secondary structures, for example. This is where it is essential to get structural expertise input to the safety case.

The above list is not exhaustive, just key points that RiskFlag has been made aware of over the past few weeks. 

Key points

One final point is about organisations receiving different feedback on SCR for sister buildings, when the two sets of feedback should be fairly similar. This must be very frustrating. We must remember that the BSR is learning too and standardisation within the BSR will come, we must be patient. 

In order to help the BSR to standardise, organisations must document the inconsistencies in feedback from the BSR, particularly around sister building feedback. You could even register it as a complaint to the BSR, however, it’s so important to be constructive in your complaint. You’re unlikely to get a response, but the BSR will gather a data base of evidence, which will help them improve.

I did say one final point, but this is actually now my final point! We often get asked, how much evidence should I upload with the SCR submission? You should only upload evidence that is essential to your safety argument, this is not all the evidence that supports your safety case. We are aware of organisations that have been asked to upload all the evidence that supports the safety case, this is incorrect and the BSR is aware of this inconsistency. 

So please, let's not 'argue with the referee' but ensure that we continually develop and learn to make our High-risk Buildings (HRB) safer.