Insights

Fire door compliance under the Fire Safety (England) Regulations 2022

The Fire Safety (England) Regulations 2022 placed specific, time-bound fire door duties on responsible persons for multi-occupied residential buildings; this article explains what those duties are and what compliance looks like in practice.

Insight — fire door compliance under the fire safety (england) regulations 2022

Fire doors are the physical means by which the compartmentation strategy is maintained at every opening through a fire-resisting wall or floor — and the element of that strategy most directly affected by daily use, wear, and human behaviour.

Until January 2023, the specific inspection requirements for fire doors in multi-occupied residential buildings were broadly defined by general fire risk assessment obligations rather than by explicit regulation. The Fire Safety (England) Regulations 2022 (SI 2022/547) changed that. They introduced specific, prescriptive inspection duties for responsible persons, and the standard of compliance they set is higher than many buildings currently meet.

What the 2022 Regulations require

The Regulations apply to multi-occupied residential buildings with storeys above 11 metres. For buildings above that threshold, the responsible person must ensure that a quarterly check is carried out on all fire doors in communal areas — not flat-entrance doors — to check that they are in working order and in good repair.

For the same buildings — those with storeys above 11 metres — the responsible person must also check all flat-entrance doors leading onto the common parts at least once every twelve months, which in practice means arranging access with individual flat occupiers. This is a best-endeavours duty rather than an absolute one: the responsible person must be able to show reasonable attempts to gain access to each flat, not guarantee that every door is inspected every year.

The Regulations also require that residents of all multi-occupied residential buildings subject to the Regulatory Reform (Fire Safety) Order 2005 are provided with information about fire doors — specifically about the importance of ensuring that fire doors are kept shut when not in use and about the general effect of fire doors. This information obligation applies to all such buildings, not just those above 11 metres.

What a quarterly check should cover

The quarterly check applies to fire doors in communal areas, not flat-entrance doors, which are checked annually (see below). It is not a detailed technical inspection — it is a condition and functionality check that any reasonably trained person can carry out. For each fire door, the check should confirm that: the door closes fully and latches properly without being forced; the self-closing device is present, functional, and not been disabled; intumescent strips and cold-smoke seals are present and undamaged; there is no excessive gap between the door leaf and the frame or the floor; and the door and its hardware are generally in good condition without visible damage.

Any door that fails a quarterly check should be recorded and reported, and a decision made about remedial action. A fire door that cannot be closed and latched, or whose self-closer has been disabled, is not performing its fire safety function and should not be left in that state.

The annual flat-entrance door inspection

The annual check of flat-entrance doors is a more thorough assessment than the quarterly communal-door check, and access must be arranged with the occupier of each flat. Government guidance on the Regulations sets out what a good check should look for; Apex's practice is to assess the full door set against that guidance rather than carry out a cursory visual check.

The annual inspection should assess the full condition of the door set, including: the condition and integrity of the door leaf and frame; the operation and condition of the self-closing device; the presence and condition of intumescent strips and cold-smoke seals on all sides; any glass panels and whether they are fire-rated; the condition of door hinges; and whether the door has been altered in any way that might affect its fire performance.

In practice, the annual inspection cycle presents a significant access coordination challenge in large blocks. Planning the cycle well in advance, writing to residents with adequate notice, and having a clear process for following up missed visits are all necessary to achieve compliance at scale.

Common fire door defects and what they mean

The most consistently found defects in fire door surveys of older residential buildings are: disabled or defective self-closing devices; gaps between the door leaf and frame or floor that exceed acceptable tolerances (typically 3mm at sides and top, 8mm at the floor in the absence of a threshold); missing, displaced, or damaged intumescent strips and cold-smoke seals; and glass panels that are not fire-rated or that have been replaced with non-fire-rated glass after the original installation.

Each of these defects has a different consequence. A door with a disabled self-closer will not close in a fire — meaning it provides no barrier between the escape route and the fire or smoke. A door with excessive gaps will allow smoke to pass even if it closes. A door with damaged intumescent strips will expand less effectively in a fire and allow flames to pass. Understanding the consequence of each defect helps in prioritising remedial action.

Beyond compliance: keeping fire doors effective

Regulatory compliance sets the minimum standard. The practical objective is keeping fire doors effective as fire-safety measures, which requires a somewhat broader approach than ticking the inspection boxes.

Resident behaviour is the element that statutory inspection most frequently cannot address. A self-closing fire door that has been wedged open — because it is heavy, noisy, or inconvenient — is not performing its function, regardless of whether it passed its last quarterly check. Communicating with residents about why fire doors matter, and being responsive when residents report doors that are difficult to use, is a material part of keeping fire safety working in practice.

Apex's fire door survey service covers both the regulatory inspection requirements and more detailed technical assessment of fire door condition and performance. We can support responsible persons in setting up compliant inspection programmes and in specifying remediation for doors that are not fit for purpose.

Common questions

Do the 2022 Regulations apply to the main entrance door of a building as well as flat doors?

The Regulations apply to fire doors in communal areas and flat-entrance doors. The main entrance to a building from the street is not always a fire door in the regulatory sense — whether it is depends on the building's design and fire strategy. Any door that is specified as a fire door in the building's fire risk assessment is subject to the inspection requirements.

Who can carry out the quarterly fire door checks?

The Regulations do not specify a formal qualification requirement for the person carrying out quarterly checks. They should however be sufficiently trained to recognise the common defects described above and to understand what constitutes a pass or fail. Many responsible persons use their building management staff for quarterly checks and specialist fire door surveyors for the more detailed annual inspections.

Related service

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