Fire Door Inspection Requirements (Reg 17)
Under the Regulatory Reform (Fire Safety) Order 2005 (RRO 2005), the Responsible Person for a non-domestic premises has a legal duty to ensure the safety of employees and relevant persons in the event of a fire. A critical component of this duty is the maintenance and management of fire doors. Specifically, Regulation 17 requires that equipment provided in respect of the premises is subject to a suitable system of maintenance and is maintained in an efficient state, in efficient working order and in good repair.
For business owners, this means that simply installing fire doors is not enough. You must actively ensure they remain fit for purpose throughout their lifecycle. This article outlines the practical requirements for inspecting fire doors under UK law and best practice.
Understanding the Scope of Regulation 17
Regulation 17 of the RRO 2005 does not specify a strict frequency for inspections, such as "every six months," because the required frequency depends on the usage and risk level of the building. However, the duty is absolute: the Responsible Person must ensure that fire doors are capable of performing their intended function.
This means that if a fire door is propped open, damaged, or has compromised seals, it is considered non-compliant. The "efficient state" refers to the door's ability to resist the spread of fire and smoke for its designated fire rating (e.g., FD30 or FD60). Failure to maintain these doors can lead to enforcement notices, fines, or, in the worst-case scenario, prosecution in the event of a fire.
The Role of PAS 79 and Best Practice
While the law sets the general requirement, industry standards provide the practical roadmap for compliance. PAS 79, the specification for fire risk assessment, and guidance from the British Woodworking Federation (BWF) suggest that a competent person should inspect fire doors regularly.
For high-usage or high-risk buildings (such as care homes, schools, or hospitals), it is widely recommended that inspections take place every 3 to 6 months. For lower-risk commercial environments, an annual inspection may suffice, provided a robust system of weekly checks by staff is in place. These inspections should look beyond the surface level to ensure the door's assembly is complete and correct.
Key Inspection Points for Fire Doors
To ensure compliance with the RRO 2005, an inspection must verify that the door set—including the door leaf, frame, hardware, and seals—is in good condition. When assessing your fire doors, the following elements should be checked:
- Intumescent Seals and Smoke Seals: Check that the strips around the door frame or leaf are intact, continuous, and securely fixed. They must not be painted over or damaged.
- Gaps: Ensure the gap between the door leaf and the frame is consistently within the recommended tolerance (typically 3mm to 4mm), and the gap under the door should not exceed 8mm (to prevent smoke passage).
- Hinges and Ironmongery: All hinges should be firmly fixed with screws that are not missing or loose. The door closer must be operational, ensuring the door closes firmly onto the latch from any open position without assistance.
- Glazing and Apertures: If the door has a vision panel, the glass must be securely beaded and intact. Any holes for locks or letter plates must be fitted with appropriate intumescent protection.
- Signage: All fire doors must display a mandatory sign reading "Fire Door Keep Locked" or "Fire Door Keep Shut," positioned clearly on the face of the door.
Who Can Carry Out Inspections?
The RRO 2005 requires that maintenance be performed by a competent person. Competency is defined by the Health and Safety Executive (HSE) as having the necessary skills, knowledge, and experience to carry out the task safely and effectively.
While daily or weekly visual checks can be performed by trained staff members (such as checking a door isn't wedged open), a more detailed technical inspection should ideally be conducted by a specialist. This is particularly important for complex door assemblies or where significant repairs are needed. A generic maintenance team may lack the specific knowledge of fire door construction standards required to identify subtle defects.
Common Failures and Remedial Actions
One of the most common failures identified during fire risk assessments is the intentional disabling of fire doors. This includes using fire extinguishers or wedges to hold doors open, which compromises the compartmentation of the building. Under the RRO, this is a breach of duty.
Another frequent issue is wear and tear on hardware. Loose hinges can cause the door to drop, creating a gap that exceeds safe limits. If a closer is failing to shut the door effectively, the mechanism must be repaired or replaced immediately. It is vital to use like-for-like replacement parts that are fire-rated to the same standard as the door; standard door hardware cannot be used on a fire door.
Documenting Your Inspections
Under Regulation 17, you must keep records of your maintenance activities. This acts as evidence of your compliance should the Fire and Rescue Service conduct an audit. Records should include the date of the inspection, the name of the inspector, the specific doors checked, and details of any defects found and rectified.
If a defect is identified that cannot be repaired immediately, interim measures must be put in place. This could include ensuring the door is kept shut and locked until repairs are completed, or evacuating the immediate area if the risk is significant.
Ensuring Compliance with Expert Support
Meeting the requirements of Regulation 17 can be complex, particularly for businesses with multiple premises or older buildings. If you are unsure whether your fire doors meet the necessary standards, it is prudent to seek professional advice.
HawkSwift Ltd provides comprehensive fire risk assessments conducted by NEBOSH-qualified assessors. Our team can review your current fire safety arrangements, including the condition of your fire doors, and provide a clear, actionable report within 48 hours. With fire risk assessments starting from £199 + VAT, we make compliance straightforward and affordable for UK business owners. To ensure your premises are safe and legally compliant, book a fire risk assessment today.