Building Safety Act 2022 & Cladding Works: RAMS and Method Statement Obligations for Contractors

Table of Contents

• Building Safety Act 2022: What Changed
• Higher-Risk Buildings and Enhanced Obligations
• The Golden Thread and Documentation Requirements
• RAMS Obligations Under the New Regime
• The Principal Designer's Role in Cladding RAMS
• What Your Cladding RAMS Must Include
• Frequently Asked Questions
• Next Steps

Building Safety Act 2022: What Changed

The Building Safety Act 2022 is the most significant reform of UK building safety legislation since the Building Act 1984. Enacted in direct response to the Grenfell Tower fire and Dame Judith Hackitt's Independent Review of Building Regulations and Fire Safety, it fundamentally changes the obligations of everyone involved in the design, construction, and management of buildings — including specialist subcontractors carrying out facade and cladding works.

For contractors, the most important changes are:

• A new statutory regime for higher-risk buildings (HRBs) — buildings over 18 metres or 7 storeys used for residential purposes — that requires gateway approvals before, during, and after construction.
• A requirement to maintain a Golden Thread of building information throughout the construction process and throughout the building's life.
• Enhanced duties on the Principal Designer to coordinate and review safety documentation from all dutyholders.
• New obligations on the Accountable Person — the entity responsible for managing safety in occupied HRBs.

While CDM 2015 continues to apply to all construction work, the Building Safety Act adds a further layer of obligation for HRBs that contractors must understand before writing their RAMS.

Browse all trade RAMS templates on the RAMS AI trade hub — covering 22 specialist construction trades.

Higher-Risk Buildings and Enhanced Obligations

Under the Building Safety Act, an HRB is defined as a building that is at least 18 metres or 7 storeys in height and contains at least 2 residential units. The enhanced regime does not currently apply to commercial or office buildings of any height, though this scope may be extended in future.

For cladding contractors working on HRBs, the key practical implications are:

• Gateway 2 approval — Before work can begin on an HRB, the client must obtain Building Regulations approval from the Building Safety Regulator (BSR). This includes the full design package for the external wall system. Your cladding RAMS and method statement may be reviewed as part of this process.
• Change control — Any change to a design feature relevant to building safety on an HRB must be notified to the BSR. If you propose to deviate from the approved facade design — for example, using a different fixing system or insulation product — this may require a formal change control process.
• Gateway 3 completion — Before an HRB can be occupied, the client must complete a compliance declaration and hand over the Golden Thread documentation to the Accountable Person. Your RAMS, inspection records, and material certificates form part of this handover.

The Golden Thread and Documentation Requirements

The Golden Thread concept requires that information about the design, construction, and safety of an HRB is created, managed, and maintained throughout the building's life. For facade contractors, this means:

• Material certificates — UKCA/CE fire test certificates, technical data sheets, and COSHH information for every facade product must be kept and handed over.
• Inspection records — Hold-point inspections during installation — particularly for fire barriers, cavity closers, and fixing arrangements — must be formally recorded.
• As-built records — Any deviation from the approved facade design must be recorded and, where necessary, notified to the Principal Designer and the BSR.
• RAMS and method statements — These documents form part of the construction phase record. They should be version-controlled and any revisions clearly tracked.

Contractors who treat RAMS as transient documents that are discarded after the job are not meeting their Golden Thread obligations on HRBs. Documents must be stored in a format that can be retrieved and reviewed years or decades later.

RAMS Obligations Under the New Regime

On HRBs, your RAMS must go beyond the standard CDM 2015 requirements. In practice, this means:

• Design information integration — Your RAMS should reference the Gateway 2 approved facade design and confirm that your installation method is consistent with it. If you are working from a different specification, you should not proceed until the discrepancy is resolved through the change control process.
• Fire compliance documentation — Your method statement should include specific sections on fire barrier installation, with hold points requiring inspection sign-off before the next phase of work proceeds. Material specification should be confirmed at these hold points.
• Competency evidence — The Building Safety Act places greater emphasis on the competency of all dutyholders. Your RAMS should identify the qualifications and experience of key personnel including your supervisor and any specialist operatives.
• Interface management — On complex HRBs, multiple contractors contribute to the external wall system. Your RAMS should identify interfaces with other contractors — particularly structural frame contractors, insulation installers, and fire barrier specialists — and confirm coordination arrangements.

The Principal Designer's Role in Cladding RAMS

Under the Building Safety Act, the Principal Designer has enhanced obligations on HRBs. They must coordinate safety across all dutyholders, review competency, and ensure that safety information is maintained. In practice, this means your cladding RAMS may be reviewed by the Principal Designer's team before you are allowed to start work.

To make this review as smooth as possible, your RAMS should:

• Clearly reference the approved facade design specification
• Confirm compliance with Approved Document B requirements for the building height
• Include fire barrier installation sequences with hold points
• Provide material certificate references
• Demonstrate that operatives hold appropriate qualifications

For more on cladding and facade RAMS requirements, see our guide on Commercial Cladding & Facade RAMS in 2026.

What Your Cladding RAMS Must Include

For HRB cladding projects, a compliant RAMS should cover:

• Reference to Gateway 2 approved facade specification
• Confirmation of material fire classifications (Class A2-s1,d0 minimum for >11m residential)
• Fire barrier installation method and hold-point inspection schedule
• Material certificate references for all facade products
• Facade access method with full risk controls
• COSHH references for hazardous substances
• Competency requirements and evidence for key personnel
• Interface management plan for other facade subcontractors
• Golden Thread documentation requirements: what to record, in what format, and how to hand over
• Change control procedure: what to do if the design changes during installation

The Commercial Cladding & Facades RAMS generator on RAMS AI produces a CDM 2015 and Building Safety Act aligned document that covers all of these requirements.

Frequently Asked Questions

Q: Does the Building Safety Act apply to all cladding projects?
A: The enhanced HRB regime applies specifically to buildings over 18 metres or 7 storeys containing at least 2 residential units. For other buildings, CDM 2015 applies as normal. However, Building Regulations fire compliance requirements — particularly Approved Document B — apply to all buildings and have been significantly tightened since 2018.

Q: What happens if we change a facade product during installation?
A: On HRBs, any change to a safety-relevant aspect of the design must be processed through the building's change control system and may need to be notified to the Building Safety Regulator. Your RAMS should be updated to reflect the change and re-submitted to the Principal Designer for review.

Q: Do we need to keep our RAMS after the job is finished?
A: Yes. On HRBs, the Golden Thread requires that construction documentation is maintained throughout the building's life. Principal contractors typically hold RAMS records for a minimum of 15 years. As a subcontractor, you should confirm the Principal Contractor's document retention requirements before the project ends.

Next Steps

If you are preparing RAMS for a cladding project on a higher-risk building, the Commercial Cladding & Facades RAMS generator on RAMS AI provides a structured starting point aligned with both CDM 2015 and Building Safety Act requirements.