Brighton’s seafront blocks and their duties

Brighton's seafront is one of the most legible bits of coast in England from the air. The Regency crescents and squares step back from the promenade in pale terraces, the piers reach out into the Channel, and between and behind them sit the taller blocks, residential towers, converted hotels and mixed-use buildings, that have filled in the gaps over the past sixty years. It is a handsome skyline and a complicated one to manage, because the same stretch of coast holds Georgian listed terraces and modern high-rise residential within a few hundred metres of each other, and the duties that attach to each are very different.

The buildings that cross the line

The Building Safety Act 2022 draws a clear threshold. A higher-risk building in England is one that is at least 18 metres tall or at least seven storeys, whichever comes first, and contains at least two residential units (gov.uk, under the Building Safety Act 2022). Hotels, care homes and secure accommodation are excluded from that occupation-phase definition.

Brighton's exclusion list is interesting in its own right. The seafront has a long history of hotels, and several have been converted to residential use or replaced by residential towers. The status of a building can therefore turn on its current use rather than its appearance, and a manager who assumes a tall block is out of scope because it once was a hotel may be wrong. The honest first step on any seafront block is to establish, plainly, whether it meets the threshold as it is used today.

For the blocks that do cross the line, the regime is well defined. The building must be registered with the Building Safety Regulator. An Accountable Person must be identified, and where several organisations share responsibility, a Principal Accountable Person carries the registration duty. That dutyholder must hold a safety case and produce a safety case report for the regulator (RICS).

What the Accountable Person is signing up to

It is worth being concrete about what these duties mean week to week, because the language of the Act can make them sound more abstract than they are.

• Registration. The building is on the regulator's register, with the dutyholders named. This is not a one-off form; the register has to reflect reality as the building and its management change.
• The safety case. A reasoned account of the building's fire and structural risks and how they are managed, supported by evidence. It is a living document, not a binder produced once and shelved.
• The safety case report. The summary the Building Safety Regulator can ask for, drawing on that underlying case.
• The golden thread. An accurate, up-to-date digital record of building information, held through the building's life (ICE). For an older converted block, assembling this from scattered paper is often the hardest part.

The seafront makes some of this harder. Salt air, exposure and the age of the converted stock all mean that the structural and external-wall picture is rarely simple, and the evidence behind a safety case has to reflect that honestly rather than assert that all is well.

The external wall question on the coast

The Fire Safety Act 2021 clarified that a building's fire risk assessment must cover the structure, the external walls, including cladding and balconies, and flat entrance doors (gov.uk). On the seafront, external walls do a lot of work: they take weather most inland buildings never see, and balconies facing the Channel are both a selling point and a part of the external wall system that has to be understood.

For high-rise residential buildings specifically, the Fire Safety (England) Regulations 2022, in force 23 January 2023, require responsible persons to share external wall system information and floor and building plans electronically with the local fire and rescue service, to keep hard-copy plans and a single-page orientation plan in a secure information box, and to carry out monthly checks of firefighters' lifts and key firefighting equipment (NFCC; gov.uk). On a dense seafront with constrained vehicle access, a clear orientation plan is not a formality; it is what helps appliances reach the right entrance from a promenade rather than the wrong street behind it.

Holding the duties together

The common failure on a mixed seafront is fragmentation. The fire risk assessment lives with one consultant, the structural reports with another, the plans in a drawer, the monthly checks in a logbook nobody cross-references against the safety case. Each part may be sound, but the whole is only as strong as a manager's ability to assemble it on demand.

The buildings that manage this well treat the safety case as the spine and hang the supporting evidence off it: the risk assessments, the plans the fire service expects, and the monthly check log the regulations require, all against the same building. SAMRISK is built around that single-record approach, which matters most when a building is old, exposed and complicated, as so much of Brighton's seafront is.

For the wider duty set behind all of this, our piece on what an Accountable Person actually signs up to walks through the role in plain terms, and our note on keeping a safety case alive between reviews covers how to stop the case going stale once it is built.

The seafront does not change the duties. It just makes the case for keeping them in one honest, current place rather harder to ignore. A converted hotel that became flats, an exposed balcony that forms part of the external wall, a salt-worn structure that needs its evidence kept current: each is a reason the building's record has to be assembled and trusted, not scattered. The blocks that age well along this coast will be the ones whose managers treated the safety case as a living account of a demanding building rather than a document produced once and forgotten.