Without Tier 2 input, your BSR submission may already be in trouble

The Building Safety Regulator isn't there to help you complete your design. It's there to check it.

When Gateway 2 first arrived, delays were inevitable. Everyone was learning, there were industry issues outside anyone's control, and there was a lot of uncertainty around what the regulator actually expected. 

That's changed now. Yet too many schemes are still trying to progress with design intent that isn't deep enough, package interfaces that haven't been resolved, or specialist input that hasn't been considered until it's too late.

Buildability comes first

In our view, buildability is key. What's the point of submitting a design that can't actually be delivered?

If a design depends on idealised tolerances or untested assumptions, it isn't ready. All you're doing is creating future change controls, more approvals, more delays, and more risk. 

Buildability is what connects design intent to a real, auditable outcome. That’s why it’s imperative to involve specialists early to challenge design assumptions before they can become on-site problems.

Competence isn't transferable

One of the biggest misconceptions is that competence can be transferred across teams. It can’t.

Architects, designers, main contractors, and specialist subcontractors all bring different knowledge and experience. A designer can't automatically understand how a package will be installed. Equally, an installer can't replace the role of a designer. 

The chain of competence only works when every part of it is present – and that's where a Tier 2 specialist can add real value. Without them, BSR submissions can lack the depth and ownership the regulator is looking for. 

Gateway-ready means thinking beyond Gateway 2

Gateway-ready has become a popular phrase, but it isn't defined anywhere in legislation. It isn't about producing more information, or less information. It's about producing the right information about the right things.

One phrase we've found particularly useful is "begin with Gateway 3 in mind." Design the package knowing what evidence will be required at the end of the project, not just what information needs to be submitted at the beginning.

That approach creates a package with ownership, logic, and a clear route toward delivery, rather than simply a drawing set that's theoretically compliant.

The commercial risks are growing

The tendency in the past was to push design decisions and resolution of risk further right of the programme. 

That can't happen anymore. The Building Safety Regulator has changed that, and that's a good thing. Risk is now being addressed where it should be. But if contractors don't make the right commercial decisions early enough, the consequences become expensive for everyone involved.

Late design and risk resolution can lead to rework, delays, additional regulatory approvals, insurance complications, and disputes over responsibility. 

Professional indemnity insurance is another area that's becoming increasingly important. Without specialist input, it's difficult to see how PI cover is always going to be honoured if designers stray into areas outside their competence. That's not just a technical issue. It's a commercial and legal one.

Why this matters now

The industry is adapting. What still hasn't fully dawned on everyone is the need to draw on the competence of specialist Tier 2 contractors.

At LockMetal, we don't start by accepting the information we've been given. We start by questioning it. We work to understand the design intent, the parameters of the structure and the materials, and how different materials and systems interact with one another. 

Just as importantly, we understand the commercial realities too: budgets, programmes and what contractors actually need from a package.

In the end, the regulator expects to see advice, design decisions and design input from competent people – and competence comes from people with the skills, knowledge, experience and behaviours needed to understand the whole package, not just one part of it. That's the value specialist Tier 2 contractors bring to every project, and why involving them early makes all the difference.