The Regulatory Reform Order 2005
The Regulatory Reform Order or Fire Safety Order was introduced in 2005, it was in essence to simplify, rationalise and consolidate the previous legislation. It shifted responsibility away from the Fire service, and to the "Responsible Person" for that building. The "Responsible Person" has a legal duty to oversee Fire Safety for their building, and making sure that building complies with current regulations.
Fire Door Inspections form a key component to a Fire Risk Assessment, and must be kept up to date.
Article 17 of the (RRO) states "requires a suitable maintenance regime to ensure relevant equipment is kept in an efficient state". This includes Fire Doors and Escape Doors.
Article 18 "requires the responsible person to appoint one or more competent persons to assist in undertaking the preventative and protective measures".The Fire Safety (England) Regulations 2022 will make it a legal requirement from 23 January 2023 for responsible persons for all multi-occupied residential buildings in England with storeys over 11 metres in height to:
undertake quarterly checks of all fire doors[footnote 1] (including self-closing devices) in the common parts
undertake – on a best endeavour basis – annual checks of all flat entrance doors (including self-closing devices) that lead onto a building’s common parts.
The regulations will also require responsible persons to provide to residents of all multi-occupied residential buildings with two or more sets of domestic premises (that have common parts) information on the importance of fire doors to a building’s fire safety.
The Grenfell Tower Inquiry in the Phase 1 report noted that “Fire doors play an essential role in preventing or inhibiting the spread of smoke and toxic gases and in preserving the effective compartmentation of buildings.”
The Inquiry noted that the fire doors in Grenfell Tower did not, through damage and/or disrepair, act in the way that they should so that they prevent smoke and gases from spreading.
The Inquiry recommended (Recommendations 33.29 (a) and (b)) that the owner and manager of every residential building containing separate dwellings carry out an urgent inspection of all fire doors to ensure compliance with current legislative standards and that regular (no less than every three months) checks be carried out to ensure all fire doors are fitted with an effective self-closing device which is in working order.
In addition, the Inquiry recommended (Recommendation 33.30) that all those who have responsibility for the condition of the entrance doors to individual flats in high-rise residential buildings (with unsafe cladding) be required by law to ensure these doors comply with current standards[footnote 2].
Prior to the Fire Safety Act 2021, flat entrance doors in multi-occupied residential buildings may not have been routinely considered as part of the fire risk assessment process. The Fire Safety Act 2021 has removed the legal ambiguity and confirms that flat entrance doors are in scope of the Fire Safety Order.
The regulations will require responsible persons to undertake best endeavour annual checks of flat entrance doors and quarterly checks of communal doors in multi occupied residential buildings above 11m.
Information on the importance of fire doors to a building’s fire safety will help to deepen residents’ understanding of their role in keeping their building safe and encourage them to allow responsible persons access to check their flat entrance doors.