What Owners of Non-Higher-Risk Buildings Need to Know

Building safety reforms still affect owners of non-higher-risk buildings. This guide covers client duties, CDM roles and leaseholder protections. It also reviews the Building Safety Regulator’s strategic plans, checks key points against legislation, and flags what remains unverified.

Section 2(1) of the Health and Safety at Work etc. Act 1974 just says employers must provide a safe system of work SSoW. It doesn't say "if you run a chemical plant" or "if your work is inherently hazardous." That's exactly why the seven cases span such different kinds of organisation: a paper sack manufacturer, a heavy steel producer, a grocery wholesaler's logistics operation, a plastics converter, a small conveyor-systems manufacturer, and a residential renovation firm. None of these are the high-hazard petrochemical operators HSG250 was originally written for, yet HSE prosecuted every one of them on the same basic finding: no safe system of work, or an inadequate one, for a task that turned out to be more dangerous than anyone had formally worked through.

The fine range tells the same story from a different angle. £16,000 for a small engineering firm and £1.5 million for Tata Steel are not the same enforcement action in miniature and in large; they're the same legal failure, scaled to the harm caused and the means of the organisation. HSE doesn't have a lower bar for smaller or less obviously hazardous employers, it just tends to find the failures later, often only after something has already gone wrong, because lower-hazard-looking environments get less scrutiny until an incident forces the issue.

That's the thread connecting this list back to the documents for the office tenancy. An office looks nothing like a steelworks or a sugar beet processing line, but the moment you introduce a contractor doing electrical work, roof access, or hot work during a fit-out, you've created exactly the kind of non-routine, elevated-risk task that section 2(1) was written for, and that every one of these prosecutions turned on. The building type changes the specific hazards; it doesn't change whether the duty applies. That's really the point HSG250 itself makes when it says a permit-to-work system should flex to the level of risk rather than being reserved for one type of site: the underlying obligation to have a safe system of work is universal, and only its formality (a verbal instruction, a written procedure, a full permit) should vary with the risk in front of you.

New Item Added: Martyn's Law

The Terrorism (Protection of Premises) Act 2025 (“Martyn's Law”) was not previously on the

checklist and has been added under Building & Fire Safety. It received Royal Assent on 3 April 2025

and creates new security and preparedness duties for premises with public access — a standard tier

for capacity of 200–799 and an enhanced tier for 800+, regulated by the Security Industry Authority

(SIA). Commencement is expected around Spring 2027 (roughly 24 months after Royal Assent).

Whether this property falls into scope depends on its public-access capacity, which is a property-

specific judgement for the user to make.