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Leeds: a city of converted and new towers

Leeds built its high-rise quarter from two sources: brand-new residential towers and converted mills and offices. Each raises different compliance questions.

The SAMRISK Team 5 min read

Leeds built its high-rise quarter in two distinct ways, and from above you can almost tell them apart. There are the purpose-built residential towers, recent and regular, clustered around the city centre and the waterfront. And there are the conversions: former mills, warehouses and offices given new life as homes, keeping their old shells while gaining new uses. Both contribute to the skyline, and both carry the same modern duties, but they arrive at those duties from opposite directions. The new tower was designed for the regime. The conversion had the regime applied to it afterwards.

Two routes to the same obligations

A higher-risk building in England, according to gov.uk under the Building Safety Act 2022, is at least 18 metres tall or at least seven storeys, whichever comes first, containing at least two residential units. A converted mill that now holds flats and reaches that height is as much a higher-risk building as a tower built from scratch. The Accountable Person duties, according to RICS, including registration, a safety case and a safety case report for the Building Safety Regulator, attach to the use and the height, not to the building's original purpose. A warehouse that became homes is, for these purposes, a residential high-rise.

The difference is in the evidence. A new tower was designed and documented for residential use under modern rules. A conversion was designed for something else entirely, and then adapted. Its compartmentation, its escape strategy, its external walls and its services may have been excellent for a working mill and quite wrong for a block of flats, and the conversion works are where the safety case is won or lost.

What conversions make harder

Converted buildings raise a set of questions that new-build largely answers at the design stage:

  • Compartmentation through old structures, where original openings, voids and service routes can undermine the fire strategy unless they were properly addressed.
  • External walls and any new cladding or insulation added during conversion, which the Fire Safety Act 2021 confirms the fire risk assessment must cover.
  • Escape routes threaded through a layout never designed for residential occupation.
  • Records of the conversion works themselves, which become the building's foundational safety documents.
  • Services and lifts retrofitted into structures that did not originally have them, with passenger lifts then subject under LOLER to a thorough examination every six months.

The recurring theme is that a conversion's safety depends heavily on works done at a single point in time, and the quality of the record of those works. If the conversion was documented well, the building inherits a strong starting position. If it was not, the manager is left reconstructing what was done inside the walls, which is slow and uncertain.

The record is the dividing line

For new towers, the golden thread under the Building Safety Act 2022, described by the Institution of Civil Engineers as an accurate, up-to-date digital record carried through occupation, usually started life as a genuine digital record. For older conversions, the original building predates that idea entirely, and even the conversion works may have been recorded patchily. The job for a converted building is often the same one faced by any older stock: capture what is actually there now, hold it once, and keep it current. We have set out that approach in the golden thread for buildings that were never digital.

This is where holding plans inside the compliance record, rather than in a drawer, matters most. A conversion's altered layout, its new compartment lines and its retrofitted services need to be drawn, marked and kept current, because they differ from both the original building and any standard assumption about how a residential tower is built. The plan is the only reliable way to show how this particular building actually works.

Common duties across a mixed skyline

Whatever their origin, the residential towers of Leeds share the same recurring obligations once they cross the high-rise threshold. The Fire Safety (England) Regulations 2022, in force 23 January 2023, require monthly checks of firefighters' lifts and key firefighting equipment, a secure information box holding floor plans, a single-page orientation plan and contact details, and floor and building plans shared electronically with the fire and rescue service. The fire risk assessment under the Regulatory Reform (Fire Safety) Order 2005 has to be kept current. None of this changes because a building used to be a mill.

For a managing agent or compliance team with a mix of new and converted stock, the practical answer is to describe every building the same way regardless of its history, so the team can see the whole portfolio at once. A converted building with an unusual layout still needs a current fire risk assessment, a maintenance calendar and an asset register, exactly like its purpose-built neighbour. SAMRISK holds each building as its own connected record, with a free site shell underneath, so old and new sit together in one place. You can see how that works on the buildings page.

Heritage on the outside, modern duties within

The pleasure of Leeds is partly the way it kept its industrial bones while becoming a residential city. That heritage is worth protecting, but it does not soften the duties that fall on the homes now inside those shells. A converted mill is a higher-risk building if it meets the test, with the same Accountable Person obligations as the tower next door, and its safety rests disproportionately on the quality of the conversion and the record of it.

If you manage converted stock in Leeds, treat the conversion works as the building's founding documents and keep the altered layout drawn and current. The old shell is the charm. The modern duties are the job, and they do not read the building's history before they apply.