Navigating the gateway process

Adam Eaton, Director at Trigon Fire Safety, and Jayne Hall, Associate at Hunters, have produced a School of Specification module on navigating the Gateway process. Here, they explore architects’ responsibilities, Gateway 2 submissions, change control and demonstrating compliance at Gateway 3.

What has fundamentally changed for architects under the new building safety regime?
The biggest change is that building safety has to be demonstrated through the design process, rather than being something that can be checked at the end. From a fire engineering perspective, this means moving away from a situation where the fire strategy sits somewhat separately from the architectural design. The two need to develop together. Architects need to be able to demonstrate how key design decisions support compliance, and to maintain a clear evidence trail as the design develops. This is about accountability, but also about better coordination: the architectural, structural, fire and building services strategies need to work together as one system, with greater oversight from the architect.

What does the duty holder regime mean for architects, particularly when acting as principal designer?
The principal designer role brings a much greater emphasis on coordination and oversight. It is not simply about producing the architectural information, it is about planning, managing and monitoring design work so that the building complies with the Building Regulations, and ensuring that designers communicate and coordinate effectively. For architects, one important implication is knowing when specialist input is needed and ensuring that it is properly incorporated into the design. Fire safety is a good example. A fire engineer can provide the technical analysis, but the principal designer needs to ensure that the resulting requirements are understood, coordinated with other disciplines, and reflected in the architectural design.

A good Gateway 2 submission tells a coherent story”

What does a successful Gateway 2 submission look like, and where are project teams most likely to run into problems?
A good Gateway 2 submission tells a coherent story. The drawings, specifications, fire strategy and other supporting information should describe the same building and demonstrate how the Building Regulations requirements will be met. Gateway 2 is not intended to be a tick-box exercise or a collection of disconnected reports. A number of Gateway 2 submissions are still being rejected due to insufficient or uncoordinated information.

How should architects approach design changes once a project has passed Gateway 2?
The key is to treat change as something that needs to be actively managed, not absorbed or hidden during the construction process. Once Gateway 2 has been approved, the agreed documents form the baseline against which changes are assessed. Changes need to be evaluated and recorded, with notifiable and major changes dealt with through the appropriate process. Any changes are likely to result in delays, so contingency should be built into the programme. Fire safety is particularly sensitive to seemingly minor changes. Altering a wall build-up, changing a product, or introducing a new service penetration can have consequences for the fire strategy. Architects therefore need a clear route for identifying and assessing the implications of change before it reaches site.

What needs to be demonstrated at Gateway 3 before a higher-risk building can move into occupation?
Gateway 3 is about demonstrating that the building that has been constructed complies with the Building Regulations and the design that was approved at Gateway 2. The focus therefore shifts from design intent to evidence of the completed building, including the required completion information and the record of controlled changes. For architects, this reinforces the importance of maintaining good information throughout the project. From a fire perspective, the final building needs to reflect the fire strategy that was designed and approved, including any properly addressed changes.