High-Risk Buildings and the Golden Thread: Ensuring Compliance Through MEP Design

By Helen Morphew

The UK’s building safety landscape has undergone a major transformation following the introduction of the Building Safety Act 2022. At the heart of this reform is the Golden Thread of Information, a digital record designed to ensure accountability and transparency throughout a building’s lifecycle. For building services engineers working on High-Risk Buildings (HRBs), compliance with the Golden Thread is not just a regulatory requirement—it’s a fundamental shift in how buildings are designed, constructed, and maintained for long-term safety.

What Are High-Risk Buildings (HRBs)?

HRBs are defined as buildings over 18 metres (or at least seven storeys) that contain at least two residential units. Hospitals and care homes that meet these criteria are also classified as HRBs. Due to their potential fire and structural safety risks, HRBs are subject to the three Gateway process under the Building Safety Act:

  • Gateway 1 (Planning Stage) – Ensures fire and structural safety considerations are embedded at the earliest design phase. Local planning authorities must consult the Health and Safety Executive (HSE) before granting permission for HRBs.
  • Gateway 2 (Pre-Construction Stage) – Before construction begins, detailed designs must be submitted for approval by the Building Safety Regulator (BSR). Any non-compliance could result in costly project delays.
  • Gateway 3 (Completion & Handover Stage) – The final review before occupation. The BSR must confirm that the as-built project aligns with approved plans, with all necessary fire and structural safety data in place.

For building services engineers, these gateways place greater emphasis on early coordination, compliance tracking, and digital documentation. Failure to adhere to the requirements at each stage can lead to rejection, redesign, and significant delays.

The Role of the Golden Thread in MEP Design

The Golden Thread of Information ensures that accurate, up-to-date, and easily accessible data is maintained throughout a building’s lifecycle. For building services engineers, this means:

  • Design Documentation & Traceability – engineers must provide detailed, structured records of all systems, including fire safety measures, ventilation, electrical distribution, and water supply.
  • Real-Time Digital Record-Keeping – All changes to MEP designs must be documented in a structured, digital format to allow future accountability.
  • Alignment with Fire & Structural Safety – MEP designs must not compromise fire compartmentation, means of escape, or structural integrity. For example, penetrations for ductwork or cable trays must be fire-stopped correctly and recorded.
  • Collaboration with Duty Holders – The Accountable Person (AP) and Building Safety Manager (BSM) rely on accurate MEP data for ongoing maintenance and risk assessments. Without clear documentation, building safety compliance can be compromised post-occupation.

Key Compliance Challenges for Engineers

While the Golden Thread improves safety, it also presents new and existing challenges for MEP professionals:

  • Design Coordination Across Disciplines – MEP systems must align with architectural and structural elements to maintain fire safety and accessibility. Early engagement with structural engineers and fire consultants is critical.
  • Fire & Smoke Control Measures – Fire alarm systems, smoke extraction, and sprinkler systems must meet BS 9991, BS 9999, BS 5839 and Approved Document B standards. These systems must be carefully integrated and documented within the Golden Thread.
  • Material Selection & Certification – Cables, ductwork, and pipe insulation must be fire-rated and compliant with HRB regulations. Using uncertified materials can lead to Gateway rejection.
  • Change Management & Version Control – Any deviations from the approved design must be justified, risk-assessed, and recorded digitally to meet Gateway 3 requirements.
  • Testing, Commissioning & Handover – All MEP systems must be tested before handover, with documented commissioning reports that form part of the Golden Thread.

How Technology Supports Compliance

Technology plays a crucial role in helping engineers meet the rigorous documentation and compliance demands of HRBs:

  • BIM (Building Information Modelling) – Digital modelling enables real-time coordination of MEP designs, reducing errors and ensuring all systems are designed with fire safety in mind.
  • Digital Gateway Trackers – These software tools help track design approvals, flag compliance issues early, and ensure documentation is up to date for Gateway 2 and 3 submissions.
  • Smart Sensors & IoT Integration – Post-occupancy monitoring of MEP systems, such as HVAC efficiency and emergency lighting status, can enhance ongoing compliance and maintenance.
  • AI & Data Analytics – Predictive maintenance solutions can use AI to monitor MEP performance in real time, helping building managers identify potential failures before they become safety risks.

The Golden Thread is more than just a regulatory obligation—it is a framework for improving building safety, operational efficiency, and long-term compliance. For MEP engineers, embracing digital tools, robust documentation practices, and early-stage coordination is essential to meeting HRB requirements and ensuring safer buildings for occupants.

By proactively integrating the Golden Thread into MEP design, engineers can streamline compliance, improve project efficiency, and contribute to a safer built environment for the future.

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