Episode 190:

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I am your host Maria Skoutari and this week we will be talking about the Change Control Log relating to making changes to Higher Risk Buildings.Todays’ episode meets PC3 of the Part 3 Criteria.

And make sure to stay until the end for an example scenario.

This topic is central to compliance under the Building Safety Act 2022 and the regulations that came into force in 2023 and 2024. Many architects describe this as where their professional duty of care meets legal accountability.

Before we jump into the change process, let’s very briefly clarify what a higher risk building is in case you haven’t listened to previous episodes.

Under the Building Safety Act, a higher risk building is typically one that is:

• At least 18 metres in height, or
• Seven or more storeys, and
• Contains two or more residential units.

This definition also applies to hospitals and care homes during design and construction, though they fall outside certain in-occupation aspects of the Act.

So once a building falls into this category, it must follow the new approval process managed by the Building Safety Regulator (BSR). This three-stage approval process — known as the Gateways — ensures that there is regulatory oversight before construction starts, during construction, and prior to occupation.

You might recognise these stages as:

• Gateway 1 – Planning stage
• Gateway 2 – Building control approval
• Gateway 3 – Completion and occupation

Today’s focus sits squarely between Gateways 2 and 3 — the period of change during construction, when projects are most likely to evolve, and the need for transparency becomes crucial.

We covered this a few episode ago, but at the heart of the Building Safety Act is the concept of the golden thread which is living information about the building that must always be accurate, accessible, and secure throughout its life.

Now when changes occur during design or construction, they have the potential to compromise that golden thread, and this is where the change control plan and change control log comes into play.

So, what’s its purpose:

The goal of the change control log is to create a traceable record of decisions, to ensure that every change is assessed for safety impact before it’s implemented. Historically, undocumented changes, whether in materials, layout, or construction methods, have been some of the root causes of unsafe buildings.

Under the new regime, any change to the agreed documents (which are the documents and information submitted to the building safety regulator for building control approval) is considered a controlled change. Meaning, the change must be assessed, recorded, and, where required, notify or seek further approval for these changes.

So let’s look at the types of changes to be recorded, known as controlled changes and their process of submission to the Building Safety Regulator:

Controlled changes fall into three categories: recordable, notifiable, and major. Understanding these definitions is vital to consultants managing their professional and legal responsibilities.

Starting with the Recordable Changes:

These are the simplest. A recordable change is one that doesn’t materially affect building safety or compliance with the Building Regulations. For example, changing a product to another of the same or higher specification, such as swapping one fire-rated plasterboard brand for another with identical fire resistance rating, would count as a recordable change. Even though the Building Safety Regulator doesn’t need to be notified, it’s crucial that the change is recorded in the change control log, along with details of the decision, who approved it, and any supporting documentation.

The other category relates to Notifiable Changes:

This is the middle category, meaning it includes changes that might affect compliance with Building Regulations. Applicants in this occasion are required to inform the Building Safety Regulator before starting work linked to the change.

Notifiable changes include alterations to:

• The construction control plan
• The change control plan itself
• The layout or dimensions within a residential unit
• Openings for services like pipes, ducts, or cables
• Fixings or support systems for walls
• Fire safety documents, such as the fire compliance statement or fire and emergency file
• The partial completion strategy or staged work statement

The Building Safety Regulator must be notified of these changes before works proceed. Once the change is submitted work can commence, in the meantime, the Building Safety Regulator may request further information about the change but the applicant does not have to stop work while they rescind back to the request. If the change is not notified and works do not stop until it is, applicants could received an order to stop the relevant work or may even be required to resubmit the application for major change approval.

And the final and most crucial category, Major Changes:

Major changes are the most serious and constitute of changes that undermine the basis on which the building control approval was granted.

These could include:

• Increasing the building height or adding storeys
• Changing structural systems
• Altering the core fire strategy
• Removing key safety features

For major changes, the process resembles a new Gateway 2 submission. Before carrying out any major change building work relating to the proposed change must stop and a formal new approval must be obtained before carrying out the work.

In addition to the changes, the Building Safety Regulator must also be informed if the client, principal designer or principal contractor change as well as relating to changes in contact details associated with the application, including the email address used to access the online application.

Information relating to a notifiable or major change, this needs to be provided to the Building Safety Regulator and should be done using the online service to manage a building control application. For each change, a brief description of the change should be included and why its considered to be a notifiable or major change. Things to include should consist of: 

• why the change is being made, for example, due to a change of design approach or availability of materials
• all the advice sought, even if it disagrees with the proposal
• who gave the advice, their occupation and contact details
• which agreed documents the change affects

Alongside the description, the applicant should upload copies of any updated agreed documents which are affected by the change. As well as a compliance explanation, this must explain how the building will comply with all relevant building regulations after the change is made. To change the client, principal designer or principal contractor, the compliance declaration from the outgoing client, principal designer or principal contractor must be uploaded. The Building Safety Regulator will then send an email confirmation to the client, principal designer and principal contractor when they receive a change notification or major change application.

If an applicant wishes to make multiple changes, if they:

• Relate to notifiable changes that are related to each other, these can be submitted in one change notification
• If they relate to major changes that are related to each other, they can be submitted in one major change application
• For major changes and notifiable changes that are related to each other, they can be submitted in one major change application

If changes are not related to each other, they must be submitted separately. If unrelated changes are include in a single change notification or application and the Building Safety Regulator rejects one of the changes, then all changes will be rejected. If a change affects more than one building control approval application, then the change must be submitted for each building control approval application.

For staged building applications, separate change notifications or applications for each stage must be submitted and all affected agreed documents for each of the stages must be updated.

Typically, the Building Safety Regulator will take up to 6 weeks to assess a major change application.

In terms of outcomes, the Building Safety Regulator can either approve the change meaning works can commence or approved with requirements, meaning building work can start as planned on the other parts of the major change application but not on the parts which relate to the requirements until the Building Safety Regulator is satisfied the requirements has been met. There is of course the potential of a major change application being rejected if it is determined it does not comply with building regulations.

Now, let’s look at the change control plan itself:

This is a mandatory document in the Gateway 2 submission and sets out exactly how changes will be assessed and managed throughout construction.

It must include items like:

• Policies and procedures for identifying changes
• How changes will be categorised (recordable, notifiable, or major)
• Who will make the assessment
• How communication flows between stakeholders
• How decisions are recorded in the change control log

The best way to think of it is as an operating manual. During project delivery, every team member should know where to find it and how to follow it. The plan should be specific from detailing timeframes for notifications, to who confirms compliance impacts, and what records are retained. Projects that treat this as an administrative afterthought often find themselves non-compliant later, especially when documentation is requested by the Building Safety Regulator at completion.

The change control log also acts as an audit trail. It lists each controlled change, its type, assessment outcome, date, and approvals.

A well-managed log should include items like:

• The unique reference for the change
• A short description of what changed and why
• Safety and compliance assessment details
• Evidence attachments — such as revised drawings
• Sign-off from relevant dutyholders
• Whether Building Safety Regulator notification was required and the date of submission

It’s key for the log to also align with the golden thread strategy as it can form part of the final safety case document at Gateway 3.

Similarly to the golden thread, it is encouraged that digital record platforms are used for logging and tracking controlled changes. As such systems offer secure and version-controlled systems, enable easy accessibility by relevant dutyholders, can be integrated into the golden thread information model and easily exportable for review by the Building Safety Regulator. 

By digitising the change control log, real-time visibility can be maintained and ensures future building managers or owners can easily access accurate records.

Now, lets look at who contributes to the Change Control Log:

Under the Building Safety Act, several key dutyholders share responsibility for the change control process:

• The Client – Must ensure the change control plan exists and is implemented.
• The Principal Designer – Assesses changes from a design compliance perspective and ensures they don’t jeopardise safety or Building Regulation compliance.
• The Principal Contractor – Which oversees practical implementation, ensures that work on site matches approved changes, and halts unapproved change-related work.
• The Contractors and Subcontractors – Must report any proposed variations and provide technical details for assessment.

Failure of a dutyholder to act correctly can result in criminal liability under the Building Safety Act — this underscores why robust record-keeping is non-negotiable.

Let’s look at an Example when a change is introduced mid-way through the project and the steps that should be taken:

Imagine the project is halfway through construction and it consists of a 25-storey residential tower, and a subcontractor proposes switching the insulation material due to supply issues.

What steps should be taken following this proposal:

• Firstly, the principal contractor should identify the change request.
• The principal designer then assesses the implications – particularly whether the new material affects fire performance.
• The change is then classified based on risk: if fire classification differs, it likely becomes a notifiable change.
• The client must then ensure notification is submitted to the Building Safety Regulator before installation proceeds.
• And then the process is concluded whereby the change, assessment, and correspondence are uploaded to the change control log.

This process ensures transparency and preserves the chain of accountability.

The change control plan works alongside several other key documents required at Gateway 2, including:

• The Construction control plan, which explains how the project will be executed safely and in compliance.
• The Fire and emergency file, outlining fire safety provisions and must be updated whenever changes affect them.
• The Building Regulations compliance statement, confirming how the design meets each regulation.
• And the Competence declaration forms demonstrating that dutyholders have fulfilled their roles.

Updates to any of these documents that impact compliance automatically trigger a controlled change.

Now, what happens in cases where Partial Completions and Staged Works are proposed, how are those recorded:

Some Higher Risk Building projects are approved to be constructed in stages. If a staged work statement has been submitted, any modification to these stages can trigger a notifiable change. Similarly, changing a partial completion strategy, for example, handing over certain floors earlier, also requires formal notification to the Building Safety Regulator. These changes affect how safety is managed at handover, therefore, maintaining clear documentation is vital for both regulatory and resident assurance purposes.

Failure to manage change properly could invalidate approvals, delay completion certification, and ultimately prevent the building from being lawfully occupied. In such instances, the Building Safety Regulator has the authority to issue stop notices, require remediation, or pursue prosecution where controlled changes are not appropriately notified or recorded. Moreover, at Gateway 3, when applying for your completion certificate, you’ll need to provide the change control log and evidence that all changes were properly authorised. The Regulator’s review includes examining how well the change control plan was followed not just whether the building physically complies.

Once past the final step, however, as construction nears completion, the final submission to the Building Safety Regulator at Gateway 3 should include:

• An updated fire and emergency file
• Compliance declaration
• Mandatory occurrence reports
• The complete change control log

This evidence package must demonstrate that every change from approval to completion was controlled, assessed, recorded, and approved. Once the Building Safety Regulator reviews these and is satisfied, a completion certificate is issued legally permitting occupation. Without it, a higher-risk building cannot be registered for use.

Before we close out todays episode, some common pitfalls Dutyholders and Consulants tend to misunderstand when compiling the change control log include:

• Treating recordable changes as too trivial to log.
• Failing to cross-check whether a substitution affects fire performance.
• Making layout changes within individual units without notifying the Building Safety Regulator.
• Forgetting to update linked documents such as fire files or construction control statements.
• Poor coordination between design and site teams leading to unrecorded installation differences.

Each of these issues can unravel compliance at Gateway 3, so awareness and training are vital.

At its heart, the new change control regime isn’t only about forms and logs — it’s about culture. The Grenfell Tower Inquiry revealed systemic weaknesses where design intent was lost between architect’s drawings and site implementation. The new process expects all project participants to view change control as part of ethical architectural practice, not bureaucratic burden.

Transparent reporting of change protects the public but it also protects professionals. A properly documented change shows diligence, rational decision-making, and compliance with statutory duties.

To sum up what I discussed today:

• Once a project receives Building Safety Regulator approval at Gateway 2, all alterations to the approved plans, procedures, or documents are classified as controlled changes. This includes any variation from approved drawings, construction methods, materials, or stages of work. Each change must be either recorded, notified, or re-approved, depending on its potential impact on compliance with Building Regulations. Failure to manage and document these changes accurately can invalidate building control approval and trigger regulatory enforcement action.
• Changes are categorised according to their impact on building safety: Recordable Changes: relating to Minor modifications that do not affect compliance (e.g., equivalent product substitutions). Notifiable Changes: Which relate to alterations that might affect compliance (e.g., internal layouts, pipe openings, or updates to fire documentation) — these must be reported to the BSR before work proceeds. Major Changes: Which are significant amendments (e.g., height increases, structural redesigns, fire strategy shifts) — these require a formal change control application and prior approval from the BSR before any related work can continue. Each type of change must be logged in the change control log, and all relevant “agreed documents” must be updated to reflect the modification.
• All controlled changes must include a compliance explanation, confirming that the building continues to meet all applicable Building Regulations following the change. For major or notifiable changes, supporting evidence is submitted through the Building Safety Regulator’s online system, and the Regulator may request further information during its six-week assessment window.
• The responsibility for assessing, recording, and notifying changes lies collectively with the client, principal designer, and principal contractor. Neglecting these duties can result in enforcement notices, project delays, or even criminal liability. Proper change management is therefore essential not only for safety and legal compliance but also for protecting professional accountability and maintaining Gateway 3 certification eligibility.