Higher Risk Buildings: A New Era of Engineering Responsibility

From Grenfell to the Building Safety Act 2022 – how the UK’s regulatory landscape has transformed, and why MEP engineering expertise is at the heart of safe, compliant Higher Risk Buildings.

The construction industry has undergone one of its most significant regulatory transformations in a generation. At the centre of this change sits a category of buildings that demands the very highest standard of engineering competence: Higher Risk Buildings, or HRBs. For building services engineers, this shift is not simply a matter of compliance – it represents a fundamental rethinking of how we design, document and deliver the mechanical, electrical and public health systems that keep people safe.

At We Design For, we have embraced this new landscape as an opportunity to demonstrate the full depth of our MEP capability. This article explores the history of HRB regulation in the UK, what defines an HRB today, and how our approach to building services engineering equips our clients and projects for success under the new regime.

The History Behind HRBs: From Grenfell to the Building Safety Act

The story of HRB regulation in the United Kingdom cannot be told without beginning on the night of 14 June 2017, when a fire broke out at Grenfell Tower in West London. Seventy-two lives were lost, and the tragedy exposed systemic failings in the design, construction and management of high-rise residential buildings – failings that had been allowed to accumulate over decades.

In response, the UK Government commissioned an independent review led by Dame Judith Hackitt. Her final report, ‘Building a Safer Future’, was published in May 2018 and made 53 wide-ranging recommendations. Central among these was a call to raise the competence of everyone involved in the lifecycle of high-risk buildings — from architects and engineers through to building managers and contractors. For the first time, engineers were explicitly identified as a key profession requiring enhanced standards in this context.

Following the Hackitt Review, the Competence Steering Group (CSG) was formed in August 2018, with the Engineering Council leading a dedicated working group for engineers. In 2019, the CSG published its interim report, ‘Raising the Bar’, setting out 67 further recommendations, including the creation of a national standard to define what competence looks like for those working on HRBs.

The legislative response came in the form of the Building Safety Act, which received Royal Assent on 28 April 2022. This landmark legislation introduced the most significant reform to building safety regulation in the UK for many years, establishing a new regulatory framework and creating the Building Safety Regulator (BSR) – an arm’s length body of the Ministry of Housing, Communities and Local Government – to oversee it.

The new regime came into full effect in October 2023, and from that point, the BSR became the sole building control body for all new HRBs and refurbishment projects on existing ones. Compliance is no longer optional, and the consequences of failing to meet the requirements are serious — including the power to halt construction projects entirely.

What is a Higher Risk Building?

Under the Building Safety Act, an HRB in England is defined as a building that:

Is at least 18 metres tall, or has at least seven storeys; and
Contains at least two residential units, or is a care home or hospital.

These buildings are subject to the most stringent requirements under the Act precisely because the potential for loss of life in the event of fire or structural failure is at its greatest. Hospitals, care homes and residential tower blocks all fall within the definition, making the scope of the HRB regime far-reaching and directly relevant to much of the work undertaken by building services engineers across the UK.

In 2025, the Institution of Civil Engineers (ICE) and the Institution of Structural Engineers (IStructE) launched the Higher Risk Buildings Register – a formal register for engineers who have demonstrated the skills, knowledge, experience and behaviours legally required to work on HRBs. This professional recognition underscores that working on HRBs is not simply a matter of applying existing practice – it demands a demonstrably higher standard of competence.

The Gateway Process and the Golden Thread

One of the most transformative elements of the new regime is the three-Gateway approval process, through which every HRB project must pass. For MEP engineers and the wider design team, understanding and navigating these gateways is now an essential part of project delivery.

Gateway 1 — Planning Stage

Fire and structural safety considerations must be embedded at the earliest stage of design, forming part of the planning application. For building services engineers, this means that fire strategy, smoke control concepts and the spatial requirements for safety-critical systems must be addressed from the outset – not retrofitted at a later stage.

Gateway 2 – Design Approval

Before any work can begin on site, the full design must be submitted to the BSR for approval. This submission must include a Building Regulations Compliance Statement, a fire and emergency file, and a construction control plan. Crucially, it must also be accompanied by a competence declaration confirming that the principal designer, principal contractor and all key appointments have the necessary competence to undertake their roles.

Gateway 3 – Completion and Handover

Before the building can be occupied, the full Golden Thread of information must be formally handed over to the BSR and the Accountable Person. This includes commissioned test results, as-built records, operation and maintenance information, and evidence that the building as delivered meets the approved design.

Running through all three gateways is the concept of the Golden Thread – a continuously maintained, digitally accessible record of all fire safety and structural safety information related to the building throughout its entire lifecycle. Far from being a mere administrative exercise, the Golden Thread creates legal accountability for every dutyholder and ensures that the building’s safety story can be told accurately at any point.

For MEP engineers, the Golden Thread is not simply a documentation requirement — it is a fundamental shift in how building services information is created, maintained and shared. Any change to an approved MEP design must be risk-assessed, justified and digitally recorded. Testing and commissioning data forms part of the permanent record. And the information handed over at Gateway 3 will form the basis of the building’s operational safety management for its entire life.

MEP Engineering in HRBs: The Technical Challenges

The mechanical, electrical and public health systems within a Higher Risk Building are among the most safety-critical elements of the entire structure. They must be designed to the highest standards, rigorously coordinated with other disciplines, and comprehensively documented from concept through to handover. The principal technical challenges for MEP engineers on HRB projects include:

Fire and smoke control: Fire alarm systems, smoke extraction and suppression systems must comply with BS 9991, BS 9999, BS 5839 and Approved Document B. These systems require careful spatial and operational coordination with the architectural and structural design, and every element must be fully documented within the Golden Thread.
Multi-disciplinary coordination: MEP systems must be integrated seamlessly with the architectural layout and structural frame. Early engagement with structural engineers, fire consultants and the principal designer is essential to ensure that service routes, plant rooms and riser shafts do not compromise fire compartmentation or structural integrity.
Material certification: Cables, ductwork, pipework and insulation must all be fire-rated and fully certified to the relevant standards. The use of uncertified materials can result in Gateway rejection and significant programme delay.
Change management: Any deviation from the BSR-approved design must be captured, assessed for its impact on safety, and formally approved before implementation. Robust design change management is therefore an operational necessity, not an optional process.
Commissioning and testing: All MEP systems must be fully commissioned and tested prior to handover, with detailed records forming part of the Gateway 3 submission and the ongoing Golden Thread.

We Design For: MEP Capability for Higher Risk Buildings

At We Design For, our multi-disciplinary expertise positions us at the forefront of HRB project delivery. Our building services engineering team brings together deep technical knowledge, a commitment to integrated design, and the process discipline that the new regulatory environment demands.

Our MEP capability on HRB projects encompasses the full spectrum of building services, including mechanical systems design (HVAC, ventilation, smoke control and suppression), electrical systems (LV distribution, emergency lighting, fire detection and alarm), and public health engineering (water services, drainage and sanitation). Critically, we design these systems as a coordinated whole — not as isolated packages – ensuring that fire safety performance is embedded into every technical decision.

Our integrated approach to Building Information Modelling (BIM) enables real-time coordination of MEP designs across disciplines, helping to identify and resolve spatial and safety conflicts at the earliest possible stage. We support our clients through every gateway submission, ensuring that documentation is structured, traceable and fully compliant with Golden Thread requirements from the outset.

Beyond the technical design, we understand that successful HRB delivery depends on the quality of relationships within the project team. We work closely with principal designers, principal contractors, fire engineers and structural engineers from the earliest stages – because in an HRB, collaboration is not a courtesy, it is a compliance requirement.

Our environmental and sustainability credentials further enhance our value on HRB schemes. The Building Safety Regulator has explicitly recognised that factors such as climate change and building performance must be integrated into regulatory decision-making. We Design For’s established capability in environmental engineering and sustainability means we can address these considerations holistically alongside safety compliance.

We are committed to ensuring that every member of our team working on HRB projects meets the competence standards required under the Building Safety Act, including alignment with the UK-SPEC HRB standard developed by the Engineering Council. Our culture of continuous professional development and rigorous quality management means our clients can be confident that their project is in capable, accountable hands.

Conclusion

The Higher Risk Buildings regime represents a step-change in the demands placed on building services engineers… and rightly so. In buildings where the consequences of failure are most severe, there can be no compromise on the quality of engineering, the rigour of documentation or the competence of those delivering the work.

For We Design For, the new landscape is both a responsibility and an opportunity. Our traditional services… delivered personably, simply and brilliantly… are now allied to a deep understanding of the HRB framework and a proven capability to navigate it. We look forward to working with clients, contractors and design teams for whom safety, quality and accountability are non-negotiable.