Water Management in Higher-Risk Buildings

‍

Water Management Compliance and Evidence in the Higher-Risk Building Regime: An Analysis of Gateways 2 and 3

The Building Safety Act 2022 (BSA) changed the rules for how Higher-Risk Buildings (HRBs) are approved and signed off in England. It created the Building Safety Regulator (BSR) as the single authority for building control, and introduced a three-stage gateway process with a hard stop/go decision at each point. The BSA was designed primarily to address fire safety and structural risk but the way the gateway process works means it now applies to every building system, including water management.

The BSR's Gateway 2 (Building Control Approval) and Gateway 3 (Completion Certificate), applicants must show they have met every relevant Building Regulation. This "all regulations hook" is the design, justification, and verification of systems covered by Approved Document G (Sanitation, Hot Water Safety, and Water Efficiency) and Approved Document H (Drainage and Waste Disposal) into a level of scrutiny they have never been subject to before.

‍

While there is no explicit statutory mandate for automated water leak detection systems within the Building Regulations, such technology has become a de facto mandatory requirement for HRBs, driven by two industries working in parallel:

1. Insurers: The Joint Code of Practice (JCOP) on the Prevention and Management of Escape of Water on Construction Sites is a condition of site insurance. It requires Active Automatic Flow Monitoring Shutoff (AAFMS) devices on HRB projects.
2. Planners and Sustainability: BREEAM sustainability assessments, commonly required by local authorities as part of planning approval, award credits for automated water monitoring and leak detection (WAT 02 and WAT 03).

Quensus sits at the intersection of both. It is not just a useful tool, it is a direct answer to JCOP and BREEAM requirements and because it generates a real-time, verifiable data record, it also provides the evidence the BSR needs at Gateway 2, Gateway 3, and for the building's lifetime Golden Thread.

‍

A. Defining the Higher-Risk Building (HRB) and BSR Scope

When a building is occupied, it qualifies as an HRB if;

●    Is at least 18 metres in height OR has at least 7 storeys; and

●    Contains at least 2 residential units.

Supported and sheltered accommodation is included whereas hospitals, care homes, and hotels are not (they fall under separate fire safety legislation). During design and construction, the definition is broader and does include hospitals and care homes at the same height threshold.

‍

B. Gateway 2: The Building Control Approval Stop Point (Design)

Gateway 2 is the "stop/go" point that occurs before any construction work can legally begin. It replaces the old deposit of plans process, and the bar is significantly higher.

‍

C. Gateway 3: The Completion Certificate Stop Point (As-Built)

Gateway 3 is the final "stop/go" point that occurs after construction is complete but before the building can be legally occupied. It is a criminal offence to occupy a new HRB that has not been registered with the BSR, and registration is not possible until a Gateway 3 Completion Certificate has been issued by the BSR.

The BSR's core function is to conduct a final audit to verify that the "as-built" building complies with the Building Regulations. The regulator will take the approved Gateway 2 design documentation and compare it directly against the Gateway 3 as-built documentation. Every difference must be recorded and justified in the Change Control Log.

‍

‍

A. The Building Regulations Compliance Statement

This document is not a checklist, it is a detailed narrative that has to explain, for every relevant element of the design, what standard is being followed and how the requirements are met with references to labelled plans and drawings.

The Construction Leadership Council (CLC), whose guidance the BSR endorses, specifies that this statement must:

1. Identify every element of the works that need to demonstrate compliance, for example "potable water supply," "scalding prevention," "foul drainage."
2. Clarify which code or standard will be used to demonstrate compliance for example BS EN 12056-2 for drainage, or CIBSE Guide G.
3. Justify how the functional requirements have been met, with a clear narrative referring to suitably labelled plans and drawings.

This represents the end of the "design by building control" culture. In the past, designers might have submitted ambiguous plans with the expectation that the building control body would "tell us what you want". The BSR has been clear that it will not engage in design discussions or consultancy; it will act solely as a regulator.

If an application is not 100% complete, justified, and evidenced, it will be rejected. Placing the entire burden of proof on the Principal Designer to define and evidence compliance upfront.

‍

B. Approved Document G (Sanitation, Hot Water Safety, and Water Efficiency): What Evidence Is Required

Each part of Approved Document G needs specific, traceable evidence in the Gateway 2 submission. A note on a drawing is not enough.

‍

C. Approved Document H (Drainage and Waste Disposal): What Evidence Is Required

The same applies to Approved Document H. Stating that drainage is "adequate" is not acceptable, the designer must name the standard being used and show the calculations that back it up.

‍

D. Role of Water Management in the Fire and Emergency File (FEF)

The Fire and Emergency File (FEF) is a required Gateway 2 document. It is where water systems and fire safety directly intersect with the BSA's primary focus on fire safety. The FEF must detail all active and passive fire safety measures. For a building services engineer, this includes all water-based fire suppression and management systems.

The Gateway 2 submission must include full details for:

‍

‍

‍

A. The Gateway 3 Application: Demonstrating As-Built Compliance

At the completion of the project, the applicant must apply for the Gateway 3 Completion Certificate.

The BSR compares what was approved at Gateway 2 against what was actually built. The Client, Principal Designer, and Principal Contractor must all sign a declaration stating that, to the best of their knowledge, the building as-built complies with all applicable requirements.

That creates a significant professional and legal liability which in turn drives the need for verifiable evidence.

‍

B. As-Built Drawings and Plans for Public Health Systems

This is not just a review of pipe routes; it is a component-level verification audit. The Gateway 2 approval was based on a specific water efficiency calculation using specific fittings. At Gateway 3, the applicant must prove those exact fittings were installed. The as-built evidence must include:

‍

C. The Change Control Log: Documenting and Justifying All Water System Deviations

The Change Control Plan submitted at Gateway 2 is the process. The Change Control Log submitted at Gateway 3 is the record of everything that actually changed (the result). Any deviation from the approved design such as re-routing a soil stack, changing a valve spec, moving a TMV must be logged, justified, and if it is a major change, pre-approved by the BSR before the work goes ahead. A contractor who finds a clash on site cannot just fix it and move on. Work stops, the change is formally submitted, and the log is updated. Failure to following this process is a criminal offence.

‍

D. Handover to the Accountable Person (AP): Water Systems in the Safety Case

Passing Gateway 3 also requires formally handing the complete Golden Thread over to the building's Accountable Person (AP). The AP (the person or entity responsible for the building in occupation) uses this to produce and manage their Safety Case Report. They have a legal duty to manage building safety risks (fire/structure) on an ongoing basis and to do that they need the as-built plumbing information to do this effectively (e.g. to know where risers are, to manage leaks that could damage fire-stopping).

‍

‍

A. Defining the Golden Thread for MEP Systems

The Golden Thread is the single source of truth for the building. It is a digital, secure record of everything needed to understand how the building was designed, built, and should be managed. It is not a one-off handover document, it is a living record that starts at the design stage and is updated throughout the building's lifecycle. For M&E and public health systems, this means adopting clear information management processes such as those set out in the UK BIM Framework, from day one of the project.

It is the mechanism that enables the BSR to hold duty holders accountable.

‍

B. Integrating Design Specifications, As-Built Data, and Commissioning Reports

For the water management and public health systems, the Golden Thread must contain the following interlinked information as a minimum:

‍

C. Lifetime Risk Management: The Golden Thread's Role in Ongoing Safety

When a leak happens, the AP uses The Golden Thread to locate the system, find the isolation valves, and assess the risk. After a repair, the Golden Thread must be updated. If a leak saturated a wall, the record must show not only that the leak was fixed, but that fire-stopping in that wall was checked and confirmed intact.

‍

‍

A. Is Water Leak Detection Mandated by the BSA or Building Regulations?

No not explicitly, for general domestic water supplies. An analysis of Approved Document G (Sanitation, hot water safety and water efficiency) and Approved Document H (Drainage and waste disposal) confirms they set functional requirements for system integrity (e.g., drainage air tightness tests 45) and water efficiency, but they do not contain any requirement to install active automated leak detection systems on the potable water supply. The drivers are found through other methods.

‍

B. The Commercial Imperative (I): Insurance and the Joint Code of Practice (JCOP)

This is the main reason leak detection ends up on HRB projects is Escape of Water, one of the most common and costly causes of loss on construction sites. Insurers pay out £1.8 million per day on domestic escape of water claims. Aviva has noted that a significant proportion of these relate to problems with the original installation.

In response, the insurance industry, via the Construction Insurance Risk Engineers Group (CIREG) and RISC Authority, has published the Joint Code of Practice (JCOP) on the Prevention and Management of Escape of Water on Construction Sites.

This JCOP is de facto mandatory which includes "mandatory obligations" and "compulsory procedures". Insurers make compliance with the JCOP a condition of site insurance. A Principal Contractor on an HRB site who ignores the JCOP is likely uninsured for water damage, a risk no client, developer, or funder will accept.

The JCOP mandates a formal "Water Management Plan" (WSMP)  and explicitly requires technology to "detect anomalous flow rates and automatically isolate pipework" (especially outside working hours). The code specifically calls for the use of Active Automatic Flow Monitoring Shutoff (AAFMS) devices and in high-risk areas, passive "puddle" sensors. This means that, from a risk and insurance perspective, a smart leak detection and shutoff system such as Quensus Leaknet Solution is mandatory on an HRB construction site.

‍

C. The Commercial Imperative (II): BREEAM WAT 02 and WAT 03

This is the second major push, often written directly into planning conditions by local authorities as part of sustainability targets. The BREEAM New Construction standard awards valuable credits for water monitoring and detection:

●    BREEAM WAT 02 (Water Monitoring): Awards one credit for a water monitoring system with pulsed meters that record consumption.

●    BREEAM WAT 03 (Water Leak Detection): Awards credits for a "permanent automated water leak detection system that alerts the building occupants to the leak". To achieve the credits, the system must cover the mains supply, and sub-metering of high-use areas(like WC blocks) or tenanted areas is encouraged.

BREEAM guidance explicitly recognises "Smart leak detection systems that are based on 'self-learning' (machine learning)" as an acceptable and compliant alternative to older, manually-programmed systems. This directly endorses the specification of AI-based systems.

To summarise the two main drivers:

‍

D. When a Water Leak Becomes a Building Safety Risk

There is a third route available to Principal Designers that is worth using. A dripping tap is not a building safety risk on its own but leave a leak undetected for long enough and it can become one. Making the argument clearly in the Gateway 2 Compliance Statement gives a solid, justifiable basis for specifying advanced leak detection as a proactive risk measure.

‍

‍

A. How the System Works: AI-Powered Monitoring and AAFMS

The Quensus system is an AI-powered, real-time water monitoring platform. Its architecture consists of:

●    Sensors and Valves: A range of flow sensors, meters, and automatic shutoff valves (solenoid, motorized, and butterfly) for different pipe sizes.

●    AI Monitoring: The "LeakNet" system uses AI to learn a building's "normal" water consumption profile and can therefore detect anomalies (leaks) with high accuracy, from pinhole leaks to major bursts.

●    Control and Alerts: It provides remote alerts via SMS/email and allows for remote monitoring and control (including water shutoff) via the "FlowReporter" app.

‍

B. Five Ways Quensus Supports HRB Compliance

‍

Water System Documentation at Gateway 2 vs Gateway 3

Compliance Drivers and How Quensus Addresses Each One

‍

‍