Building Safety in the UK: Safety Must Be Woven Into Every Stage

26th September 2025

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The Grenfell Tower tragedy forced the UK to confront an uncomfortable truth: building safety was too often treated as a phase-based obligation, with responsibilities diluted across design, construction, and occupation. The result was devastating gaps in accountability.

The Building Safety Regulator (BSR) was created to address these systemic failings, adding stronger oversight of high-risk buildings and clearer accountability for long-term safety. But the Construction (Design and Management) Regulations 2015 (CDM) remain in force, ensuring health and safety during the design and construction process.

The real challenge is not whether CDM or BSR is “enough.” It’s that safety cannot be ring-fenced into one or the other. Safety must be holistic — woven into each stage, embedded in every decision, and shared by everyone involved.

Why Building Safety Must Go Beyond Compliance

CDM places duties on clients, Principal Designers, and contractors to reduce risk during construction. The BSR places duties on accountable persons and duty holders to ensure buildings remain safe once occupied.

But in practice, risk does not stop at handover. Design decisions affect performance in occupation; construction quality affects resident safety years later. Likewise, occupation reveals whether design and construction truly worked as intended.

Treating these responsibilities as separate is a false distinction. Safety is a continuum — and that continuum is only as strong as its weakest link.

CDM vs BSR: Two Frameworks, One Safety Challenge

This is not about assigning blame to one role over another. It is about recognising that:

• Designers must consider not only buildability but long-term safety in use.
• Contractors must deliver to specification and ensure construction quality that endures beyond completion.
• Developers and Owners must invest in maintenance and remediation, not delay until crises force action.
• Residents and Occupiers must engage with safety measures and report risks responsibly.

Everyone plays a part. This can complicate legal accountability when damages are sought — but the reality is clear: safety belongs to everyone, at every stage.

The Cost of Fragmentation in Building Safety

When responsibilities are split too rigidly:

• Dutyholders pass the baton, believing safety “belongs” to the next phase.
• Legal disputes drag on over who is liable, while risks remain unaddressed.
• Safety becomes a compliance exercise rather than a lived culture.

This is the essence of piecemeal regulation — and why Grenfell became a symbol of systemic failure.

RIBA, CDM, and BSR Gateways: Where Frameworks Collide

Fragmentation is made worse by the fact that the UK now operates three major frameworks in parallel:

• RIBA Plan of Work Stages (0–7) — design and delivery milestones familiar across the industry.
• BSR Gateways (1–3) — statutory stop/go approval points for higher-risk buildings.
• CDM Phases (pre-construction and construction) — health and safety duties across design and delivery.

Each has its own start and end markers. But they do not mirror one another. RIBA Stage 3 can straddle Gateway 1 and Gateway 2; CDM’s pre-construction phase runs continuously, while Gateway 2 introduces a hard legal stop; Gateway 3 coincides with RIBA Stage 6 but does not extend into Stage 7 (In Use).

This lack of alignment introduces real risks:

• Confusion in Accountability — one dutyholder may “complete” their RIBA stage while still falling short of BSR submission requirements.
• Gaps in Oversight — information such as fire strategies or golden thread records can slip between frameworks if updates are not synchronised.
• Reinforced Fragmentation — teams treat frameworks in isolation, passing the baton from one process to another rather than maintaining shared responsibility.

The danger is that instead of strengthening accountability, parallel frameworks create new fault lines.

Closing the Gaps: Towards Unified Oversight

The solution lies not in scrapping CDM or diminishing the BSR, but in aligning them into a coherent whole. That means:

• Unified Dutyholder Expectations – designers, contractors, and accountable persons connected through a single safety framework.
• Lifecycle Accountability – safety responsibilities continuing seamlessly from concept design through long-term occupation.
• Cultural Change – moving from compliance-driven behaviour to a mindset where safety is central to every decision.

The Role of Industry Leaders in Driving Cultural Change

For organisations working in this environment, the safest course is to act as if the alignment already exists:

• Embed safety into design decisions that anticipate occupation risks.
• Integrate CDM duties with BSR expectations.
• Create transparent accountability chains where safety responsibilities are documented, understood, and monitored across the lifecycle.

This requires more than regulatory awareness. It demands expert advice, proactive leadership, and a willingness to invest in systems that prioritise people over short-term cost savings.

Safety Is a Shared, Unbroken Responsibility

The UK is entering a new era of building safety. CDM remains vital. The BSR adds necessary long-term oversight. RIBA stages remain the industry’s shared design roadmap. But the true cultural shift comes from recognising that safety is not a staged duty. It is a shared, unbroken responsibility, carried by everyone involved in the life of a building.

For designers, contractors, owners, and occupiers, that means embedding safety into every choice, every plan, and every action. For those navigating this complex regulatory landscape, the guidance of trusted advisors can make the difference — ensuring that compliance is not just achieved, but that genuine safety is delivered, from first sketch to final occupation.