Understanding the Change Control Log under the Building Safety Act 📄

What Is a Higher-Risk Building?

Before we expand on the change control process, let’s outline the definition of a Higher-Risk Building (HRB) under the Building Safety Act.

A building typically falls into this category if it is:

• At least 18 metres high, or Seven or more storeys, and

• Contains two or more residential units.

The same applies to hospitals and care homes during design and construction, although these are excluded from certain in-occupation aspects of the Act.

Once a building is classed as higher risk, it must go through the Building Safety Regulator’s (BSR) three-stage Gateway process, which ensures regulatory oversight:

1. Gateway 1 – Planning Stage

2. Gateway 2 – Building Control Approval

3. Gateway 3 – Completion and Occupation

Our focus today sits between Gateways 2 and 3 — the critical construction phase where projects evolve and change control becomes essential.

The Golden Thread and Change Control

At the heart of the Building Safety Act is the Golden Thread, the living, digital record of information that must remain accurate, accessible, and secure throughout a building’s lifecycle.

When changes occur during design or construction, they can disrupt that golden thread. This is where the Change Control Plan and Change Control Log come into play.

The Purpose of the Change Control Log

The Change Control Log is designed to maintain a traceable record of decisions and ensure every change is assessed for safety impact before implementation.Historically, undocumented changes, whether in materials, layout, or construction methods, have been key contributors to unsafe buildings. The new regime ensures that can’t happen again.

Under the Building Safety Act, any change to the agreed documents submitted to the Building Safety Regulator is classed as a controlled change. These must be assessed, recorded, and where necessary, notified or reapproved before proceeding.

Types of Controlled Changes

Controlled changes fall into three main categories and understanding them is vital:

1. Recordable Changes

These are minor changes that don’t materially affect building safety or compliance.Example: Substituting one fire-rated plasterboard brand for another with an identical specification.

Even though the BSR doesn’t need to be notified, these changes must still be logged with details of the decision, approver, and supporting documentation.

2. Notifiable Changes

These are moderate changes that might affect Building Regulations compliance.Applicants must inform the BSR before starting work associated with the change.

Common notifiable changes include alterations to:

• The construction control plan

• The change control plan itself

• Layouts or dimensions within a residential unit

• Openings for services (pipes, ducts, cables)

• Fire safety documents

• Partial completion or staged work statements

Work can proceed once the change is submitted, but the BSR may request more information. Failing to notify could lead to stop work orders or a requirement to reapply for approval.

3. Major Changes

These are significant alterations that undermine the original building control approval.Examples include:

• Increasing building height or adding storeys

• Changing the structural system

• Altering the core fire strategy

• Removing key safety features

Major changes effectively trigger a new Gateway 2 process, meaning work must stop until a formal new approval is granted.

Submitting Changes to the Building Safety Regulator

All notifiable and major changes must be submitted via the BSR’s online system, including:

• A description of the change and why it’s required

• Details of professional advice sought (with contacts)

• Affected agreed documents

• Updated versions of those documents

• A compliance explanation showing continued Building Regulations compliance

If the client, principal designer, or principal contractor changes, their compliance declarations must also be uploaded.

The BSR typically takes up to six weeks to assess major change applications.

The Change Control Plan

This is a mandatory document in every Gateway 2 submission. It defines how changes will be managed and must include:

• Policies for identifying and categorising changes

• Roles and responsibilities

• Communication protocols

• Decision-making and record-keeping methods

Think of it as an operating manual for managing change. Every project team member should know where to find it — and how to follow it.

What the Change Control Log Should Contain

A well-managed Change Control Log should include:

• A unique reference for each change

• A summary of what changed and why

• Assessment of safety and compliance implications

• Supporting evidence (e.g., revised drawings)

• Approvals and submission dates to the BSR

Digital systems are strongly encouraged, as they offer version control, secure access, and integration with the golden thread information model.

Dutyholders and Their Responsibilities

Under the Building Safety Act, responsibility is shared between key dutyholders:

• The Client: Ensures the Change Control Plan exists and is applied

• The Principal Designer: Reviews design changes for safety and compliance

• The Principal Contractor: Oversees implementation and halts unapproved work

• Contractors/Subcontractors: Report proposed variations and provide technical details

Failure to comply can lead to criminal liability making proper documentation non-negotiable.

In Summary

Once Gateway 2 approval is received:

• Any alteration to approved documents becomes a controlled change.

• Each change must be recorded, notified, or re-approved depending on its impact.

• Poor change management can invalidate approvals, delay occupation, or trigger enforcement action.

Categories of change:

• Recordable: Minor, no safety impact

• Notifiable: May affect compliance, must notify BSR

• Major: Significant, requires new approval before work continues

All changes must include a compliance explanation and be reflected in updated agreed documents. The client, principal designer, and principal contractor share responsibility and proper change management is essential for both legal compliance and professional integrity.