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Paper 3PC1PC2PC3Hard
Principal Designer obligations: Building Safety Act gateway 2
90 min4 questionsRegulations & Standards
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Scenario
You are appointed as architect and Principal Designer under both CDM 2015 and the Building Safety Act 2022 on a 13-storey residential building in East London. The building is for a registered housing association client. The project has reached the end of RIBA Stage 3 and you are preparing the Gateway 2 application to the Building Safety Regulator (BSR).
During Stage 3 design development, the fire engineer produced a fire strategy report that relies on a BS 9999:2017 Category D evacuation strategy (simultaneous evacuation with a 30-minute hold time). You are aware that following the Grenfell Tower Inquiry Phase 2 Report (published October 2024), the HSE's Building Safety Regulator has signalled that it will scrutinise simultaneous evacuation strategies in new residential high-rise buildings very carefully and may require a stay-put or phased evacuation strategy instead.
The fire engineer's report has not yet been peer reviewed. The client wants to submit the Gateway 2 application within 12 weeks to protect their funding deadline. The client's solicitors have also raised a question: can the architect act as Principal Designer under both CDM 2015 and the BSA 2022 simultaneously, or do the roles conflict?
Primary Sources Referenced
- Building Safety Act 2022
- Building (Higher-Risk Buildings Procedures) Regulations 2023
- CDM Regulations 2015
- Building Regulations 2010 (Approved Document B)
- ARB Architects Code 2025