Building Safety Policy

1. Introduction

1.1 One Manchester (OM) is committed to achieving excellent standards in the services it provides and to ensuring our homes are safe and meet legislative and regulatory requirements.

1.2 Part 4 of the Building Safety Act 2022 (the Act), as well as the supporting legislation, sets out a new regime for the management of occupied higher-risk buildings (HRBs). A HRB is defined under the Act as a building that is at least 18 metres in height or has at least 7 storeys and contains at least 2 residential units.

1.3 The key duty holders under the Act are the Accountable Person (AP) and Principal Accountable Person (PAP) for a HRB. An Accountable Person is an individual or organisation that is legally responsible for repairing any common parts of the HRB (e.g., corridors or lobbies). There can be more than one AP for a HRB. If there is only one AP at a HRB, that person will be the PAP. Otherwise, the PAP will be the person that owns or has a legal obligation to repair the structure and exterior of the building.

1.4 As an AP and the PAP for 19 no. HRBs, OM is required to ensure its obligations under the Act are met and that our residents and those in or about our buildings are safe.

2. Policy purpose

2.1 The purpose of this Policy is to set out OM’s approach to ensuring our HRB’s are safe and meet the requirements set out in the Act and its supporting legislation.

2.2 Whilst this Policy is focussed on the management of our HRB’s, OM recognises its duties and responsibilities as a landlord in connection with the safety of all of its housing stock, premises and any other buildings that it has responsibility for. OM currently manages circa 12,000 domestic properties and several other assets including community centres and garages.

3. Policy scope

3.1 This Policy relates to all 19 no. OM managed HRB’s.

3.2 The applicable 18 no. occupied HRB’s (with storeys indicated) are:

Abbey Court (16)
Bickerdike Court (17)
Chadwick Place (7)
Cornwall Court (16)
Cundiff Court (12)
Duffield Court (13)
Fulton Court (9)
Hopton Court (9)
Hornchurch Court (13)
Hulme Court (13)
Ledburn Court (13)
Meredith Court (9)
Platt Court (14)
Royce Court (13)
St. Georges Court (16)
Thomas Court (13)
Westcott Court (13)
Worsley Court (9)

3.3 The applicable 1 no. unoccupied building is Fell View (10).

4. Roles and Responsibilities

4.1 Building safety responsibilities are assigned to key roles within the organisation, and we will ensure there are suitable and sufficient arrangements in place to manage building safety risks.

4.2 The OM Board has ultimate governance responsibility for ensuring compliance. The Board must:

• Ensure that OM has appropriate policies and procedures in respect of building safety and effective arrangements for the implementation of those policies and procedures.
• Ensure that building safety is resourced, risks managed and legal responsibilities discharged.
• Agree a suite of Key Performance Indicators (KPIs) in respect of building safety and regularly review these to ensure effective governance and assurance is maintained.
• Monitor and scrutinise OM’s building safety performance at each Board meeting and at time to time when any specific issues arise.
• Ensure arrangements are in place to promote effective resident engagement and that resident feedback is considered in safety decisions.
• Assist in promoting a positive safety culture within OM and take a keen interest in building safety matters.

4.3 The Chief Executive Officer (CEO) is responsible to the OM Board for ensuring that OM operates safely and achieves the Board’s objectives via OM’s Building Safety Strategy.

4.4 The Leadership Team is accountable for ensuring operational compliance. Their responsibilities include (but are not limited to):

• Ensuring any building safety related policies, procedures and systems are effectively implemented across the business.
• Ensuring that management decisions taken either individually or in Committee reflect the intentions of this Policy and the Linked Policies and Procedures.
• Making sure their Directors and Heads of Service are aware of their responsibilities in relation to this Policy and the Linked Policies and Procedures and in accordance with any legislative and regulatory requirements.
• Reporting compliance performance and risk to the Board and consulting with the Board in relation to building safety matters that will affect OM and those in or about its buildings.
• Ensuring suitable and sufficient resources and systems are in place in respect of building safety.
• Ensuring arrangements are in place to establish and monitor the competency of colleagues, contractors and consultants to implement the requirements of this Policy.
• Overseeing and scrutinising remediation plans.
• Assisting in promoting a positive safety culture within OM and take a keen interest in building safety matters.

4.5 The Building Safety Steering Group (BSSG) is responsible for strategic direction and leadership in relation to building safety. The membership of the BSSG is as follows:

• Chief Experience Officer (Chair)
• Head of Health, Safety & Compliance (Vice Chair)
• Senior Building Safety Manager (Member)
• Fire Safety Manager (Member)
• Head of Assets & Sustainability (Member)
• Head of Neighbourhoods (Member)
• Head of Repairs (Member)
• Head of Communications, Marketing & Brand (Member)
• Head of Customer Experience (Member)
• Risk and Assurance Manager (Member)
• Executive Support (Minute Taker)

4.6 In line with its Terms of Reference, the BSSG is responsible for actions including (but not limited to):

• Assisting with the identification and management of building safety related challenges and risks that could affect the ability of the Building Safety Team to
deliver their remit.
• Promoting collaboration, engagement and awareness of building safety across all OM stakeholders including colleagues and residents.
• Identifying, sharing and monitoring factors outside of OM / the BSSG’s control that may impact upon building safety.
• Agreeing if any risks associated with building safety need to be added to the OM corporate risk register.
• Providing reports to the Asset Management Group.
• Providing updates and recommendations to the Leadership Team for them to review / approve where necessary under its Terms of Reference. For example, if there is a proposed increase in risk on the OM corporate risk register for building safety.

4.7 The Head of Health, Safety and Compliance is responsible for the overall implementation of this Policy and ensuring the Building Safety Team (and other relevant colleagues across OM) are delivering against their building safety objectives. Their responsibilities include (but are not limited to):

• Supporting OM to ensure compliance with the Act and all other associated and relevant legislation and regulatory requirements.
• Leading collaboration across OM to deliver the requirements of this Policy and the Linked Policies and Procedures.
• Monitoring performance against the KPIs agreed for building safety.
• Providing reports to the Leadership Team and Board on building safety.

4.8 The Senior Building Safety Manager will lead and develop the Building Safety Team to ensure the effective implementation of all building safety activities. Their responsibilities will include (but are not limited to):

• Developing suitable and sufficient building safety policies, procedures and systems.
• Developing and implementing key safety systems to support risk management approaches and collation of ‘Golden Thread’ information.
• Ensuring the effective implementation of OM’s Mandatory Occurrence Reporting System.
• Ensuring building safety related complaints are handled in line with OM’s Complaints Policy.
• Engaging and establishing effective working arrangements with internal and external stakeholders (including the Building Safety Regulator) to ensure compliance with fire and building safety legislation and regulatory requirements.
• Providing updates on building safety to the BSSG and the Head of Health, Safety and Compliance.
• Developing suitable information material (e.g. OM website, leaflets, letters) to provide fire safety and building safety advice to residents.

4.9 Building Safety Managers are responsible for the ‘day to day’ management of all HRB’s with a focus on the operational delivery of building safety compliance. Their responsibilities include (but are not limited to):

• Ensuring that for each HRB, building safety risks are assessed and managed in compliance with the Act.
• Maintaining an up to date Building Safety Case for each HRB.
• Ensuring that for each HRB, building safety risks in relation to refurbishments, upgrades, planned works etc. are assessed and managed.
• Auditing surveys / reports and feeding information into relevant Building Safety Case Reports.
• Ensuring HRB’s are compliant with all inspections, checks and assessments and any required follow-on works are completed as appropriate.
• Ensuring that remedial works to buildings are co-ordinated and delivered appropriately in line with OM’s legal and regulatory obligations.

4.10 Building Safety Officers are responsible for supporting the ‘day to day’ management of all HRB’s with a focus on compliance inspections and resident engagement. Their responsibilities will include (but are not limited to): 

• Ensuring assets – e.g. fire doors, sprinkler systems, fire alarm / evacuation alert systems, emergency lighting, Premises Information Boxes etc. – are inspected in line with OM’s Asset Inspection (Fire Safety) Procedure.
• Raising repairs for non-compliant assets and tracking / monitoring those repairs to close out, ensuring all required repairs are being appropriately completed and evidenced.
• In conjunction with the annual Flat Entrance Fire Door Check, undertake home safety visits to record key information and provide verbal fire safety and building safety advice to residents.
• Ensuring Person Centred Fire Risk Assessments and Residential Personal Emergency Evacuation Plans are completed for relevant residents in line with OM’s Person Centred Fire Risk Assessment (PCFRA) and Residential Personal Emergency Evacuation Plan (RPEEP) Procedure (name TBC).

4.11 The Building Safety Coordinator will ensure the effective coordination of key building safety activities:

• Acting as key point of contact for residents on building safety matters, triaging emails to the Building Safety Managers.
• Supporting the Building Safety Managers with Building Assessment Certificate applications.
• Extracting remedial works from surveys / assessments / reports, allocating building safety actions, and tracking / monitoring these to close out.
• Ensuring all documentation for each HRB is properly maintained, retained and available.

4.12 All OM colleagues must support the organisation in achieving compliance with its building safety obligations, including by:

• Reporting immediately any concerns they may have relating to this Policy or the Linked Policies and Procedures.
• Reporting immediately any hazards they see which may constitute a fire safety or building safety risk.
• Cooperating with other OM colleagues to enable compliance with this Policy, the Linked Policies and Procedures and the legal and regulatory duties OM holds.
• Completing all mandatory training related to building safety.

4.13 Sections 95 to 97 of the Act place a number of obligations on residents of HRB’s. Under the Act, OM’s residents should: 

• Not act in a way that creates a significant risk of a building safety risk materialising.
• Not interfere with anything that is in, or forms part of, the common parts of their building and is intended to improve the safety of people in or about the building in relation to building safety.
• Comply with a request made by OM for information reasonably required to fulfil its duties under the Act in respect of assessing and managing building safety risks.
• Comply with any contravention notices issued by OM.

4.14 OM’s Residents should also:

• Where required, provide access to their property for surveys, assessments,inspections, checks and fire and building safety related works.
• Ensure any complaints, concerns or issues related to building safety are raised inaccordance with OM’s High Rise Building Safety Resident Engagement Strategy.

5. Key policy areas

5.1 In its role as an AP and the PAP for each of the 19 no. HRBs, OM is legally responsible for each HRB’s compliance with the Act. This will require amongst other actions:

• Registering all HRB’s with the Building Safety Regulator.
• Ensuring an application is made for a Building Assessment Certificate for each HRBwhere the Building Safety Regulator requires this and in line with any directionreceived from the Building Safety Regulator.
• Maintaining the Building Safety Cases.
• Ensuring building safety risks are identified, assessed, managed and mitigated.
• Developing and implementing a Resident Engagement Strategy.
• Developing and implementing a Mandatory Occurrence Reporting system.

5.2 The practical steps OM will take to meet its obligations under the Act are set out in the Linked Policies and Procedures (section 7), along with the supporting documentation and systems. The following principles will, however, underpin our overall approach to achieving and maintaining compliance.

• Organisational Engagement and Communication – OM is committed to ensuringthat building safety compliance is not a one-time exercise but is an ongoing processthat adapts to regulatory changes, lessons learned and feedback. This includes:
o Ensuring all teams across OM are working collaboratively to appropriately capture and incorporate any new building safety risks / related changes into
Building Safety Cases and any other relevant documentation (e.g. procedures).
o Operating a Mandatory Occurrence Reporting system in line with the Act to allow for any person to report fire and structural risks and safety occurrences.
o Reflecting on feedback and where appropriate making changes to our practices and approach, no matter who or where that feedback is from e.g. residents, the Building Safety Regulator, audit findings or an incident investigation. This will ensure both a dynamic and responsive approach.
o Collaborating with key teams across OM to ensure that proposed building safety related activities can be delivered in a compliant but also operationally
achievable manner.

• Resident Engagement and Transparency – OM aim to create a culture where residents feel empowered and informed on Building Safety. Our Building Safety engagement approach will be underpinned by these principles:
o Transparency – OM commits to clear and open two-way communication with residents about safety through multiple channels.
o Inclusivity – All residents of all tenures are involved and invited to participate with no restrictions on duration or eligibility.
o Accessibility – all information is available in a variety of formats and languages. Residents who may have additional needs are proactively identified and
supported.
o Responsiveness – OM sets out clear ways for residents to raise concerns, request information and share feedback with a commitment to receiving
responses in a timely manner.
o Proportionality – Engagement activities are tailored to the specific needs of buildings and their residents and where there is limited feedback, review the
effectiveness of methods of engagement and communication.

• Culture of Continuous Improvement – OM will promote that building safety is an ongoing responsibility for all colleagues across the business and all those engaged by OM to provide services e.g. contractors and consultants. This Policy will be actively embedded across all areas of OM. We will do this by taking actions including (but not limited to) the following:
o Awareness and Training– identifying all colleagues involved with building safety activities and ensure they are aware of their role and responsibility in maintaining compliance with the Act.
o Competency – colleagues to receive appropriate training in relation to their duties. Colleagues with delegated responsibility for fire and building safety will
complete specific and relevant training to ensure they have the necessary competency to undertake required duties. All training undertaken by colleagues
will be formally recorded and refreshed as appropriate.
o Audits – internal and external audits to provide assurance on the operation and effectiveness of control measures.
o Change control – ensure that changes that may impact on building safety risks (e.g. refurbishments, system upgrades, new safety concerns) are coordinated, controlled and shared with the wider organisation.
o Promote – ensuring everyone involved in building safety (e.g. colleagues, contractors, consultants) will be encouraged to provide feedback (positive and
negative) and raise any concerns they may have about building safety.

• Risk Management and Compliance Monitoring – OM will ensure that it has suitable and sufficient systems and procedures in place to effectively manage risk and monitor compliance.
o Risk Management – for each HRB, identify and risk assess building safety risks (fire, structural and operational), provide mitigation and control measures and where appropriate recommend further actions to be taken. OM will assess whether interim mitigation measures are required whilst those further actions are outstanding.
o Compliance – for each HRB, ensure all compliance activities are being undertaken with non-compliant actions being assigned, tracked / monitored and
closed out.
o Reporting – provide assurance and oversight to the BSSG, Leadership Team and Board that building safety risks and any non-compliance are being appropriatelymanaged.
o KPIs – implement appropriate KPIs for Building Safety related activities and ensure OM’s performance against these is regularly monitored by the BBSG and reported to the Leadership Team and Board.
o Escalation of concern – OM will ensure it has a clear escalation process in place which allows for building safety related concerns to be addressed in a pragmatic and compliant manner that is appropriate to the circumstances and associated level of risk (whether that be risks to residents, colleagues and / or OM as an organisation).

• Assessments, surveys, inspections and servicing – OM will have systems and procedures in place to ensure that any necessary assessments, surveys,
inspections and servicing at our HRB’s are completed at appropriate intervals and where relevant in line, with OM’s statutory obligations. OM will have clear and robust processes for where any necessary assessments, surveys, inspections and / or servicing cannot be completed in line with expectations (which may include where appropriate and necessary, the implementation of interim mitigation measures).

• “Golden Thread” of information – OM will ensure there is a digital ‘single source of truth’ for each HRB to ensure the management of building safety throughout its lifecycle and that OM can meet its obligations under the Act in respect of the keeping and provision of information (including to residents).
o Accuracy and Ease of Use – all information will be validated, up-to-date and reliable.
o Security and Compliance – information must be secure with any sensitive information protected.
o Accountability – responsibilities for updating information to be clearly set out to foster a proactive safety culture.
o Longevity and Digital Format – all information will be stored in a structured digital format to last the lifetime of the HRB.
o Transparency – all requests for building safety related information and documentation will be promptly referred to the appropriate team or colleague within OM and handled in accordance with OM’s obligations under the Act and by reason of its status as a registered provider of social housing.

• Building Safety Case Reports and Assurance – OM will develop and maintain an up to date Building Safety Case and Building Safety Case Report for each HRB. In order to do this, OM will take actions including (but not limited to) the following:
o Proactively undertake, where reasonably required, further surveys, assessments and investigations. This may include, but is not limited to, Visual Structural Assessments, Fire Risk Appraisals of External Walls (FRAEW’s), Retrospective Fire Strategies, Type 4 Fire Risk Assessments and Compartmentation Surveys.
o Develop and implement KPIs to provide ‘real time’ assurance and oversight.
o Conduct External Audits as required to monitor compliance and provide assurance.

• Repair and Maintenance Activity – OM will seek to mitigate the risk of repair and maintenance activity in relation to building safety. In order to do this, OM will take actions including (but not limited to) the following:
o Ensure all internal colleagues and external third-party contractors conducting repairs and maintenance activity have an awareness of building safety and the obligations with which OM must comply.
o Require internal colleagues and external third-party contractors to provide evidence of their competence, experience and qualifications in relation to the
works they are carrying out.
o Implement a Permit to Work Scheme for all HRB’s to ensure specified maintenance, remedial and alterations works are undertaken without
compromising building safety.
o Where approval from the Building Safety Regulator is required, ensure this is sought and received before repairs and maintenance activity commences
(except in the case of works classed under relevant legislation, as emergency works where alternative procedures are in place).
o Ensure all parties follow digital record-keeping requirements.
o Undertake audits to ensure compliance where works have taken place.

• Planned and Major Works – OM will ensure the requirements of the Act are being met through the design and construction phases of works to its occupied HRB’s. OM will take actions including (but not limited to) the following:
o Ensure that all those appointed by OM to design, manage and / or conduct works have suitable and sufficient competence, experience and qualifications to conduct the work for which they are appointed.
o Where approval from the Building Safety Regulator is required, ensure this is sought and received before the works commence (except in the case of works classed under relevant legislation, as emergency works where alternative procedures are in place).
o Implement a change control plan for managing and documenting modifications and recording in a change control log.
o Ensure all parties follow digital record-keeping requirements in respect of the works.

6. Legislation

6.1 The key legislation relevant to this Policy includes, but is not limited to, the following:

• (England) Regulations 2023 – https://www.legislation.gov.uk/uksi/2023/315/contents
• The Higher-Risk Buildings (Key Building Information etc.) (England) Regulations 2023 – https://www.legislation.gov.uk/ukdsi/2023/9780348243963/contents
• The Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 - https://www.legislation.gov.uk/uksi/2024/41/contents/made
• The Regulatory Reform (Fire Safety) Order 2005 – https://www.legislation.gov.uk/uksi/2005/1541/contents
• Fire Safety (England) Regulations 2022 – https://www.legislation.gov.uk/uksi/2022/547/contents
• Fire Safety Act 2021 – https://www.legislation.gov.uk/ukpga/2021/24/contents
• Construction (Design Management) Regulation 2015 – https://www.legislation.gov.uk/uksi/2015/51/contents
• Health and Safety at Work Act 1974 – https://www.legislation.gov.uk/ukpga/1974/37/contents
• Housing Act 2004 – https://www.legislation.gov.uk/ukpga/2004/34/contents
• Building Act 1984 - https://www.legislation.gov.uk/ukpga/1984/55/contents
• The Building Regulations 2010 – https://www.legislation.gov.uk/uksi/2010/2214/contents

7. Linked polices and procedures

7.1 The following current OM policies and procedures are applicable to this Policy:

• Building Safety Strategy
• Fire Safety Policy
• Fire Safety and Evacuation Procedure
• Health and Safety Policy
• Tenancy Experience Visit (TEV) Procedure
• High-Rise Building Safety Resident Engagement Strategy

7.2 In line with our commitment to continuous improvement, OM is currently consolidating its approach to several key areas of building safety. The procedures listed below will be developed to support this Policy and OM’s continued compliance with its building safety obligations:

• Resident Engagement Strategy booklets (HRB specific)
• Management of Communal Areas Procedure
• Mandatory Occurrence Reporting (Building Safety) Procedure
• Asset Inspection (Fire Safety) Procedure
• Safety Management System (Building Safety)
• Change Management (Building Safety) Procedure
• Golden Thread Management (Building Safety) Procedure
• Control of Contractors (Building Safety) Procedure
• Building Inspection (Building Safety) Procedure
• Building Assessment Certificate Application Procedure
• Person Centred Fire Risk Assessment (PCFRA) and Residential Personal Emergency Evacuation Plan (RPEEP) Procedure (name TBC)

8. Equality, Diversity and Inclusion statement

8.1 One Manchester promotes a diverse and inclusive environment for our residents and colleagues to thrive. We are committed to enhancing a culture that respects individuals, appreciates difference and allows everyone regardless of background to reach their full potential.

8.2 We accept our responsibility to comply with equalities legislation and regulatory requirements and aim to do more. We believe, everyone requires access to the same opportunities. Through our behaviours, we aim to challenge and remove systemic barriers to equal opportunities and reduce the likelihood of all forms of discrimination, harassment, and victimisation within our organisation and our communities.

8.3 We are committed to providing excellent customer services, which are fair, equitable and inclusive. As such, we will endeavour to understand and make any reasonable adjustments required for residents in line with One Manchester’s Reasonable Adjustment Statement and Reasonable Adjustment Policy and the Equality Act 2010.

9. Equality Impact Assessment

9.1 An Equality Impact Assessment (EIA) has been completed and assessed.

10. Mandatory Regulatory Breach escalation

10.1 All colleagues must consider whether any issue, incident, failure, or concern identified through this policy may indicate actual or potential noncompliance with the Regulator of Social Housing (RSH) Standards. Where there is any suspicion, reasonable doubt, or potential regulatory impact — including risks to customer safety, home condition, legal compliance, governance, or systemic service failure — the matter must be reported through the central Regulatory Breach & Escalation Process using the online reporting form on The Hive. The reporting threshold is intentionally low; if unsure, colleagues
should escalate for assessment by the Governance Team.

11. Monitoring and review

11. The Head of Health, Safety and Compliance and the Building Safety Team will monitor performance against this Policy and report to the BSSG quarterly. 

11.2 Complaints and resident feedback are also used as an additional means of monitoring and improving the quality of the service.

11.3 This Policy will be reviewed every two years by the Board. The Building Safety Team will also conduct a documented Annual Review. Any required changes (for example, due to legislation or regulation changed) will be referred to the Board for approval.

12. Contact Person

12.1 The Head of Health, Safety and Compliance has responsibility for the effective delivery of this policy.