Fire Safety (England) Regulations 2022: fire door guidance
Updated 28 February 2023
1. The Fire Safety (England) Regulations 2022
1.1. The Fire Safety (England) Regulations 2022 were placed on the statute book on 18 May 2022, and came into force on 23 January 2023. The regulations implement the majority of those recommendations made to government in the Grenfell Tower Inquiry Phase 1 report which require a change in the law.
1.2. Responsible Persons, including both building owners (for example freeholders) and other persons having control of the premises (for example managing agents) were required to comply with the regulations from 23 January 2023. Any breach of the regulations is a criminal offence if the breach places one or more relevant persons (for example residents, staff or visitors) at risk of death or serious injury in the event of fire.
2. About this guide
2.1. This short guide is intended to assist those with duties under the Fire Safety (England) Regulations to comply with regulation 10, which makes requirements about fire doors in all buildings that contain two or more domestic premises and that contain common parts, through which residents would need to evacuate in a fire.
2.2. This guide is aimed at carrying out simple checks upon a fire door, and is based on the assumption that the fire risk assessment has already assessed the suitability of the fire doors. It is about making sure that the fire doors remain suitable thereafter and match those that were taken into account in the fire risk assessment.
2.3. This means that regulation 10 applies to all blocks of flats (or parts of such blocks) that incorporate common parts, regardless of whether the block is purpose-built or is a conversion; for the purpose of this legislation, flat entrance doors are included within the meaning of common parts.
2.4. Regulation 10 makes requirements in relation to two matters, namely:
- information about flat entrance doors that the Responsible Person must give to all residents (whether tenants or leaseholders) - this requirement relates to all blocks of flats
- routine checks of fire doors that the Responsible Person must ensure are carried out - these checks are only required in blocks of flats in which the top storey is more than 11m above ground level (typically, a building of more than four storeys)
3. What the law requires
3.1. The Regulatory Reform (Fire Safety) Order 2005 (as amended) (‘the FSO’) requires that, in a block of flats, there are suitable fire precautions in place to make sure that the common parts are safe to use as a means of escape in the event of fire. The appropriate fire precautions are determined by carrying out a fire risk assessment.
3.2. As this is a legal requirement under Article 9 of the FSO, you should have already made sure that a suitable and sufficient fire risk assessment has been carried out; if there is no fire risk assessment in place, you must arrange for this to be carried out as soon as is practicably possible.
3.3. Fire-resisting doors (fire doors) are one of the most important measures to safeguard the means of escape from fire. Your fire risk assessment should already have identified the doors in question and determined whether the doors are adequate to resist the spread of fire and smoke into, or within, the common parts. You should have already taken steps to maintain doors in good order, and where it has been found that the existing door is inadequate and needs to be replaced, this must be done by a competent person.
3.4. As with all fire safety measures, fire doors need to be kept in good working order and in good repair. Wear and tear, for example, can result in defects. The objective of regulation 10 is to ensure that such defects do not materially undermine the ability of the doors adequately to prevent fire and smoke spread, whether to the extent originally designed or as verified as adequate in the most recent fire risk assessment.
4. The role of fire doors
4.1. In general, fire doors within a block of flats fall into four categories, namely:
- flat entrance doors: these are particularly important, because, in blocks of flats, most fires occur within the flats themselves, and the flat entrance door prevents the spread of fire and smoke into the common parts, thereby placing other residents at risk
- doors to stairways and lobbies (between corridors and stairways): these keep the stairways and lobbies free from fire and smoke, so that they can safely be used by residents and others who might need to leave the building during a fire, and to assist firefighters during firefighting operations
- doors that sub-divide corridors: these are to limit the spread of fire and smoke throughout, for example, a long corridor
- doors to plant rooms and cupboards (for example containing electrical distribution equipment) and to service risers (shafts which allow the vertical passage of cables, pipes)
5. Information for residents: what you need to do
5.1. Residents have an important role to play in ensuring that, if there is a fire in their flat, the flat entrance door is an effective barrier to the spread of fire and smoke into the common parts.
5.2. Regulation 10 requires that residents are given information that:
fire doors should be kept shut when not in use;
- residents or their guests should not tamper with self-closing devices;
- residents should report any fault or damage immediately to the Responsible Person.
5.3. The above information must be provided by the Responsible Person to any new resident as soon as reasonably practicable after the resident moves into their flat. The Responsible Person must also remind all residents about this information at periods not exceeding 12 months starting from when the regulations come into force.
5.4. Where a resident wants to alter or change their front door, this should be done with the knowledge and agreement of the Responsible Person to ensure that it does not negatively impact upon the overarching fire risk assessment for the premises.
6. Routine checking of fire doors: what you need to do
6.1. Regulation 10 requires that, if the top storey of the building is above 11m in height (typically, a building of more than four storeys) the Responsible Person must:
- use best endeavours to check all flat entrance fire doors at least every 12 months; and
- carry out checks of any fire doors in communal areas at least every 3 months.
6.2. The government is committed to ensuring that undue burdens are not created for freeholders and, through service charges, for leaseholders. Accordingly, for the purpose of the fire door checks required by the Fire Safety (England) Regulations, it can be assumed that the Responsible Person has evidence that the design, specification and installation of the door is adequate for its location or is taking separate measures to deal with any inadequacies in inherent fire performance; identification of issues in relation to the type of door and its intended resistance to fire and smoke is a matter for your fire risk assessment.
6.3. The checks under regulation 10 should be simple and basic. You should not need to engage a specialist to carry these out. With appropriate instruction, caretakers, managing agents, housing officers and maintenance personnel should be able to do them (for example in the course of other routine checks and visits to the building) as the checks are only visual and do not involve, for example, use of tools.
6.4. The Responsible Person will need to ensure that the necessary arrangements are in place to address any issues identified. The extent to which the individual appointed to carry out the checks will also be able to address the issues or complete any repairs will be determined by their skills, knowledge and experience of fire doors. Where inspections identify the need for repair or replacement of any fire door (for example communal or flat entrance door), this work must be undertaken by a competent contractor as soon as reasonably practicable.
Flat entrance doors
6.5. To check flat entrance doors, you will need access to each flat, so that the door can be checked on both sides. Arrangements should be made with residents in advance to carry out these checks. You could consider offering a range of times, so that residents can be present. Other than in very small blocks of flats, it is unlikely that all doors can be checked on a single occasion.
6.6. Regulation 10 requires that, over every 12 month period, you keep a record of the steps taken to check flat entrance doors. In any cases when access to a flat was not granted, this must also be detailed. Ultimately, you might need to consider legal action if a resident persistently refuses to cooperate with these checks. It may be useful to pre-plan the checks that need to be undertaken. For example, this could take the form of a checklist, on which you can record the outcome of each check. A sample checklist is included as an appendix to this guide. You could also use electronic means to plan and record checks.
6.7. Each time you carry out fire door checks, you should check that:
a. The resident has not replaced a fire-resisting flat entrance door with a new, non-fire-resisting door; this may be obvious if the door is of a different design from all other doors in the building but may not be where flat entrance doors are all of a different design. Where any doubt exists, the resident will need to confirm that the new door is fire-resisting, has been installed by a competent person, and they will be required to provide the technical information relating to the door to the Responsible Person. Modern fire doors should display a visible fire resistance rating (see photo 2).
b. Letterboxes are firmly closed and not jammed open. Where a letterbox has been fitted to a door that did not previously have one, the resident will need to confirm that the new letterbox is suitable for use in fire-resisting doors and has been fitted by a specialist contractor.
c. There is no damage to, or defects in, the door, frame or the securing wall that might affect the ability to resist the spread of fire or smoke (for example a split in the wood of a timber fire door, damage to any glazing in the door, warping of the door that affects its fit in its frame, a hole where a lock has been removed). Doors should also be checked for any alterations that may affect their fire resisting qualities.
d. The condition of the fire-resisting glass and glazing system in the door panels, and any associated side or over panels forming part of the doorset, retains their ability to resist the spread of fire and smoke.
e. There are no obvious defects in the hinges (for example missing or loose screws), or any other element of the ironmongery (for example ventilation grilles).
f. Intumescent strips (which expand when exposed to fire and seal gaps around the door) and smoke seals (which look similar to draught seals), if present, are undamaged, make contact with the door edge or frame, and have not been painted over during decoration activities. (If they were not originally present, this may be acceptable, subject to the findings of the fire risk assessment.) These strips and seals may be fitted to either the door or the frame, and they are normally combined (see photo 3).
g. The gap between the door and the frame is not too large. The industry standard is that the gap size should never be more than 4mm, except at the bottom of the door, where the gap should be as small as practicable, while ensuring that the door is unlikely to snag on the floor even if the door drops slightly on the hinges. Simple “gap tester” cards are available for this purpose.
h. There is an effective self-closing device on fire doors of flat entrances and fire doors within common parts (see photos 4,5). This is very important. A fire door that does not close fully into its frame will not adequately hold back fire and smoke. You should check that the door will close fully into its frame when opened to any angle and allowed to close under the action of the self-closing device. A simple way to check this is to:
- firstly, open the door fully, then let it go
- then open the door to around 15 degrees and let it go
In both cases, the door should fully close into the frame, overcoming the resistance of any latch or friction with the floor.
Typical examples of fire doors signage (signage may differ in style, content and format from the examples shown)
Typical examples of self-closing devices (subject to capability to close the door from any angle of opening). Whatever device is fitted, it must meet the requirements of the check and close appropriately.
Doors to stairways and lobbies and doors within corridors
6.8. These doors are subject to greater wear and tear, and to greater potential for damage, than flat entrance doors, so they must be examined more regularly. While the Fire Safety (England) Regulations require that they are checked every three months, it is a simple matter for them to be monitored on an ongoing basis when any other checks in the common parts are carried out or the building is visited.
6.9. Checking these doors is similar to checking flat entrance doors, so you should check for:
- damage or defects that might affect the door’s ability to resist the spread of fire or smoke (see 6.7a-e)
- any damage to intumescent strips or smoke seals, if present (see 6.7f)
- large gaps (see 6.7g)
- the presence of an effective self-closing device (see 6.7h)
6.10. In some premises, corridor and lobby doors might be held open on magnetic door hold-open devices (see photo 6). For this to be the case, there would be a need for smoke detectors, activation of which would cause the door to close. Care should be taken when checking the self-closing device on these doors. Use the test button, where provided, to close the door, rather than pulling the door from its magnet.
6.11. Although unusual, where a double door is installed, that requires one leaf to close before the other, a door selector may be fitted to ensure that the doors swing closed in the correct order. Where such a selector is fitted, this should be checked to ensure that it is operating correctly.
Doors to plant rooms, service cupboards and risers
6.12. These doors should also be checked at least every three months. Again, the checks are similar to those described for other doors. In particular, you should check for:
- damage or defects that might affect the door’s ability to resist the spread of fire or smoke (see 6.7 a-e)
- any damage to air transfer grilles that may be present in the door (see 6.7e)
- any damage to intumescent strips or smoke seals, if present (see 6.7f)
- large gaps (see 6.7g)
6.13. In the case of these doors, they may be either self-closing or kept locked shut. If the doors are self-closing, they should be checked as described in 6.7h).
6.14. Caution should be exercised to ensure that entry into any of these areas can be carried out safely by those involved, taking into account any findings of the relevant health and safety risk assessment.
Fire doors checks are vital in making sure your block of flats is safe for residents. The checks are not a substitute for periodic assessment of fire doors by fire safety specialists (for example on a sampling basis during fire risk assessments).
However, the simple fire door checks described in this guide will enable you to discover, and put right, most of the rudimentary defects that prevent a fire door from doing its job.