Change Control on Higher-Risk Building Projects

Building control approval for a higher-risk building is approval for a specific design. The moment construction starts, reality begins negotiating: a product is discontinued, a survey finds something the drawings did not know, a client changes their mind about a layout. On an ordinary project these are Tuesday. Under the higher-risk building regime they are controlled changes, and the Building (Higher-Risk Buildings Procedures) Regulations 2023 prescribe exactly how each kind must be handled before it happens.

The net is wide by design: a change to the current plans, carrying out work otherwise than in accordance with those plans, a change to the stages of the work, or a change to any of the strategies, policies and procedures in the agreed documents. In other words, if the approved application described it and you now intend to do it differently, the regime has an opinion about the order of events. The question is only which category the change falls into.

A major change is one with a significant impact on the design or the fire strategy, the kind of change that would alter or undermine the basis on which approval was granted. Moving from one structural solution to another, changes that touch means of escape, compartmentation or the external wall build-up: this territory. A major change needs its own building control approval application to the regulator, with a fee, and the change must not be carried out until that approval is granted. Determination can take up to six weeks, which puts major changes squarely on the critical path: discovering one late is how programmes lose their summer.

A notifiable change is serious enough that the regulator must be told before it is carried out, but it does not stop the clock the way a major change does: notify first, then proceed. And every controlled change, whatever its size, must be recorded, with the change, the reasoning and the assessment entering the project's change control log and its golden thread. That record is not bureaucratic decoration: at Gateway 3, the signed declarations that the building complies are only signable if the built reality and the recorded reality match.

Disciplined teams make this regime almost invisible. They classify proposed changes the day they arise, not the week the trade needs an answer. They batch design decisions early, because the cheapest change is the one made before approval. They keep the change log as they go, so completion is an assembly, not an archaeology. This is easiest when design and construction are one team, which is how MVV runs projects: the people assessing a change against the fire strategy are the people who drew it and the people building it. If your higher-risk project expects to evolve, and every real project does, build the change discipline in before the first application, not after the first surprise.