18 metres or 7 storeys: the line that names you

When a fire safety breach surfaces in a hospital or care home, the inspector does not ask the facilities manager to explain. The Building Safety Regulator, the fire and rescue authority or the insurer asks the accountable person to produce the evidence. In England, that responsibility rests with a named individual, and the name on the breach is the director's.

The same obligation looks different in Singapore, where the Fire Safety Act and the SCDF place duties on the building owner and the fire safety manager. If your portfolio spans both markets, the gap between the two is where your exposure lives.

The stakes: who holds the duty and what happens when it is missed

In England, the Building Safety Act 2022 created the Building Safety Regulator (BSR) as the building control authority for higher-risk buildings. A higher-risk building is at least 18 metres in height or has at least 7 storeys, and contains at least 2 residential units. Hospitals and care homes are included in the higher-risk regime under Part 3, which covers design, construction and building work to existing higher-risk buildings. Under Part 4, which covers in-occupation duties, hospitals and care homes are excluded.

That distinction matters because it determines which regulator is looking at your building, and at which stage. For new residential buildings over 11 metres, the sprinkler question sits inside the broader fire safety framework, and the evidence trail starts at Gateway 2, where work can only start after BSR building control approval.

How the UK treats sprinklers in new residential buildings over 11m

England's approach to sprinklers in new residential buildings over 11m is built on the Building Safety Act 2022 and the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023. The BSR expects applicants to demonstrate compliance clearly, rather than just declaring it, by providing evidence that covers every part of the building regulations. Multi-Disciplinary Teams (MDTs) led by BSR bring together building inspectors, structural engineers and fire safety professionals. They review completion certificate applications with the 'as built' information before issuing the completion certificate.

For a facilities manager in a hospital or care home, this means the sprinkler system is not a standalone item. It is part of a structured inspection schedule that MDTs guide, and it is checked throughout the project lifecycle. The evidence you hold needs to show the system was designed, installed and commissioned to the approved specification, and that any change was recorded, notifiable or major under the three levels of controlled change.

Regulation 26 states that a notifiable change includes any change to the construction control plan, except for amendments to the schedule of appointments within it. Regulation 29 requires notification to the Regulator if a new Dutyholder is appointed, and includes submitting an updated competence declaration. If your team has changed since the sprinkler system was signed off, that is a recordable event, and the paperwork needs to reflect it.

The government has also accepted the Grenfell Tower Inquiry's findings and is taking forward all its recommendations. The first recommendation is to create a single construction regulator, which the Single construction regulator prospectus sets out. For now, the BSR remains the authority, and the Building control FAQ explainer confirms that developers can no longer choose their building control body for higher-risk buildings.

How Singapore treats the same obligation

Singapore does not use the 11-metre threshold in the same way. The Fire Safety Act and the SCDF's fire safety requirements place duties on the building owner and the appointed fire safety manager. For hospitals and care homes, the fire safety manager is responsible for maintaining the fire safety systems, including any sprinkler installation, and for keeping the records that the SCDF inspects.

The practical difference is who holds the liability. In England, the accountable person is a named individual under the Building Safety Act 2022. In Singapore, the building owner and the fire safety manager carry the duty, and the SCDF enforces through inspections and notices. Both markets require evidence, but the UK regime is more prescriptive about the gateway process and the competence of dutyholders.

For a portfolio spanning both, the standardisation question is not about the sprinkler specification. It is about the evidence trail. Can you produce, for every building, the design approval, the installation certificate, the commissioning record and the latest inspection report, in a format that satisfies both the BSR and the SCDF?

What a dual-market portfolio should standardise

The first thing to standardise is the register of dutyholders. In England, the schedule of appointments covers the Principal Contractor and Principal Designer, and any change to that schedule is a notifiable change under Regulation 26. In Singapore, the fire safety manager's appointment is a separate record. If your team moves between markets, the register needs to show who is accountable in each jurisdiction, and when that changed.

The second is the change control log. The Building (Higher-Risk Buildings Procedures) (England) Regulations 2023 set out three levels of controlled change: recordable, notifiable and major. A change to the sprinkler system, even a like-for-like replacement, may fall into one of those categories. In Singapore, the SCDF expects notification of changes that affect fire safety systems. A single log that captures both thresholds is easier to maintain than two separate systems.

The third is the inspection schedule. MDTs in England guide the structure of a building inspection schedule, and they review completion certificate applications with the 'as built' information. In Singapore, the SCDF sets its own inspection regime. If your facilities team is running both, the schedule should show which inspections are due, which have been completed, and where the evidence is stored.

The Definition of higher-risk buildings: initial review confirms that the Building Safety Act 2022 gives the Regulator a duty to recommend changes to the definition of a higher-risk building for either Part 3 or 4. That means the scope of the regime can shift, and your register needs to be able to absorb that change without a rebuild.

Your 60-second self-check

• Could you produce the current sprinkler commissioning certificate and the latest inspection report for every hospital and care home in your portfolio, today?
• Does your dutyholder register show the current Principal Contractor, Principal Designer and fire safety manager for each building, with the date of their appointment?
• Is your change control log up to date for any sprinkler modification, replacement or repair since the building was handed over?

If you want to know where your portfolio stands, send the free 5-minute Director's Risk Check to the person who keeps your records. It comes back to you as a board-ready briefing, with the control score and the portfolio's breach exposure against official sources. You do not need to chase the paperwork yourself.

Herman's verdict

The sprinkler certificate is not the point. The point is whether you can produce it, with the commissioning record and the change log, on the day the inspector asks. If that takes a week, you have already answered the question.

— Herman