The Building Safety Act 2022: a new regime for higher-risk residential buildings.

The BSA introduced two new roles for occupied HRBs. An Accountable Person (AP) is anyone who holds a legal estate in possession in any part of the common parts, or who has a relevant repairing obligation in relation to any part of the common parts. A building can have multiple APs.

Where there are multiple APs, one of them is the Principal Accountable Person (PAP). The PAP is the AP that holds the legal estate in possession of the structure and exterior of the building, or has the relevant repairing obligation for those parts. The PAP is the AP that the Building Safety Regulator interacts with as the lead duty-holder for the building. Most HRBs have a single AP, who is therefore also the PAP. Buildings with mixed ownership or complex tenure can have several APs and a single PAP.

The PAP carries specific duties: registering the building with the Building Safety Regulator, applying for a Building Assessment Certificate, preparing and maintaining the safety case report, complying with information and resident engagement duties, and responding to BSR direction. APs that are not the PAP carry duties in relation to their own scope of the building.

Every occupied HRB must have a safety case. The safety case is a structured argument, supported by evidence, that the PAP has identified the building safety risks, has put in place reasonable measures to manage them, and continues to monitor and review those measures. The PAP captures this in a safety case report, which is the document the BSR requests when it issues a Building Assessment Certificate.

The fire risk assessment is one component of the safety case. It is not the safety case in itself. The safety case sits at a higher level: it answers the question "is this building, with its current management arrangements, an acceptable level of risk to its residents?" The FRA answers a narrower technical question: "what fire risks exist in the common parts and what reasonable measures should the Responsible Person take?" The two documents inform each other, and the same evidence often appears in both, but they are distinct.

In practice this means the FRA on an HRB has to be of a quality that holds up under safety case scrutiny. Vague findings, weak evidence, inconsistent risk ratings or unclear action plans that might survive a routine FSO inspection will not survive a safety case review.

The BSA introduced specific duties on the PAP to engage with residents on building safety. The PAP must prepare and maintain a residents' engagement strategy, must provide residents with prescribed information about the building and its safety, and must operate a complaints system that allows residents to raise building safety concerns and have them addressed within a defined timeframe.

For FRA practice, this matters in two ways. The FRA itself is one of the documents the PAP can be asked to share with residents under the prescribed information duty. And the resident engagement process can surface fire safety concerns (storage in escape routes, propped-open fire doors, faulty equipment, vulnerable residents) that feed into the next FRA review.

FRA Flow is built for housing FRA programmes, including programmes that include HRBs. The data model supports the higher evidence and audit-trail expectations an HRB FRA carries: every observation linked to its location and evidence, every finding linked to its supporting data, every reviewer signature timestamped and content-hashed. The reviewer queue is designed for the competent reviewer discipline an HRB programme assumes by default rather than as an aspiration.

For PAPs running multi-building HRB portfolios, FRA Flow keeps the operational programme view: which buildings are due, which assessments are in review, which findings are open, which buildings have had a recent significant change. The FRA itself sits inside the broader safety case process, but the FRA software does the heavy lifting on the FRA-shaped part of the work.