Building Safety Act · Mandatory · Construction
Change Control Log
A log recording all changes to the design, specification, or construction of a higher-risk building.
Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. BSA 2022 / BSR Guidance remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.
| Legal basis | Building Safety Act 2022 + BSR Guidance |
| Status | Mandatory — all changes to Gateway 2 approved design must be recorded, assessed, and (if notifiable) approved by BSR |
| Project phase | Construction |
| Notifiable changes | BSR has 8 weeks to respond to a notifiable change application |
| Change categories | Category 1 (minor) / Category 2 (significant) / Category 3 (notifiable) |
1. Change Control — Preventing Uncontrolled Deviations from the Approved Design
One of the direct lessons from the Grenfell Tower fire was that changes to the building's design — including the external cladding system — were made without adequate assessment of their safety implications. The BSA's change control regime is designed to prevent this: every change to the Gateway 2 approved design of an HRB must be assessed, categorised, and (if significant) approved by the BSR before it is implemented. The Change Control Log is the documented evidence that this process was followed.
In practice, construction always involves changes from the design — materials become unavailable, site conditions are different from those assumed, and design coordination issues arise. The change control process does not prevent these changes; it ensures they are properly assessed before implementation and that their impact on building safety is understood. A well-functioning change control process is a mark of a mature BSA-compliant construction programme, not a bureaucratic burden.
Proceeding with a notifiable change before BSR approval is a breach of the BSA — do not implement notifiable changes without confirmation
If a change is assessed as Category 3 (notifiable) under the change control plan, work on the affected element must not proceed until the BSR has given approval. The 8-week assessment period applies. Programme pressure does not justify proceeding with notifiable changes before approval is obtained. An unapproved notifiable change may jeopardise the Gateway 3 completion certificate — as the building will not conform to the Gateway 2 approved design without BSR approval for the change.
2. Change Control Log — Content
The following table sets out the required content of the change control log for an HRB construction project.
| Field | Description |
|---|---|
| Change ID | Unique sequential reference. |
| Date identified | When the change was first identified. |
| Change originator | Who identified or proposed the change. Organisation. |
| Element affected | Specific element of the building. Drawing reference. |
| Description of change | Clear description of what is proposed to change and why (e.g. specified material no longer available). |
| Impact assessment | Does the change affect: Building Regulations compliance? Fire safety? Structural safety? External wall system? Means of escape? |
| Category | Category 1 (minor) / 2 (significant) / 3 (notifiable). |
| PD/engineer assessment | Principal Designer's assessment and sign-off. For structural changes: structural engineer assessment. |
| BSR notification | Category 3: date BSR notified; BSR reference; date BSR approval received. |
| Approval to proceed | Date and authorisation to implement the change. |
| Implementation date | Date the change was implemented. |
| Golden thread updated | Which golden thread documents were updated. Dates. |
| GW3 impact | Does this change require updating the GW3 submission? Y/N |
3. Common Mistakes
No formal change control process for HRB construction
An HRB site that manages changes informally — verbal instruction, email from the architect, site manager decision — does not have a change control process. Every change, however minor, must go through the change control process to be assessed and categorised.
Failing to update the golden thread when changes are approved
A change that is approved and implemented but not reflected in the golden thread means the golden thread no longer accurately describes the building. The change must trigger updates to all affected golden thread documents — drawings, specifications, safety records.
Site instruction to change an external wall detail without change control
Changes to the external wall system (cladding, insulation, cavity barriers) are almost certainly Category 3 notifiable changes. A site instruction from an architect or contractor to substitute a product in the external wall system without going through change control is a BSA breach.
Treating all changes as "minor" to avoid the BSR notification process
Systematically categorising changes as Category 1 to avoid the BSR notification process is a regulatory avoidance that could result in enforcement action. Change categorisation must be made honestly by a competent person against the criteria in the change control plan.
Not including the change control plan in the Gateway 2 application
The change control plan is a required component of the Gateway 2 application. A project that proceeds to construction without a clear change control plan lacks the framework to manage construction changes in a BSA-compliant way.
4. Frequently Asked Questions
How does the change control process relate to the construction contract?▾
BSA change control is separate from but runs alongside the contractual variation process. A variation instructed by the employer under the building contract must also be assessed through the change control process if it affects the Gateway 2 approved design of an HRB. In practice, the PC must refuse to implement a contractual variation that is a notifiable change until BSR approval is obtained — even if the employer is applying contractual pressure to proceed.
What triggers a mandatory occurrence report vs a change control notification?▾
Mandatory occurrence reporting (MOR): reports of occurrences that have caused or could cause death or serious injury from structural failure or spread of fire. These are reactive reports of incidents/risks. Change control notifications: proactive submissions to BSR before implementing proposed changes to the approved design. Both may arise from the same situation — for example, a near-miss structural incident might trigger an MOR and also require a change control notification for the proposed remedial design change.
Can a change be implemented provisionally while awaiting BSR approval?▾
No — for notifiable changes (Category 3), work on the affected element must not proceed until BSR approval is received. This is a hard stop. If programme pressure is severe, the contractor should consider whether the change is genuinely notifiable, and seek urgent guidance if uncertain. However, proceeding on the assumption that BSR will approve is not acceptable.
What if the design team and contractor disagree on change categorisation?▾
The Principal Designer has responsibility for monitoring design compliance during construction. Where there is disagreement about change categorisation, the PD’s assessment should prevail. If there is genuine uncertainty about whether a change is notifiable, the safest approach is to notify the BSR rather than risk proceeding with an unapproved notifiable change.
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