If the top storey of a block of flats is more than 11 metres above ground level, the Responsible Person must use best endeavours to check flat entrance fire doors at least every 12 months and must check fire doors in the common parts at least every 3 months.
Those Regulation 10 checks are simple routine checks. They do not replace the fire risk assessment, the duty to maintain fire precautions, or a more detailed professional fire door inspection where one is needed.
What Regulation 10 requires
The Fire Safety (England) Regulations 2022 introduced specific fire-door checking duties for multi-occupied residential buildings in England. Where the top storey is more than 11 metres above ground level, the Responsible Person must arrange:
- checks of fire doors in communal areas at least every 3 months; and
- best-endeavours checks of flat entrance fire doors at least every 12 months.
The height test is based on the top storey, not simply on an informal description such as “four storeys” or “five storeys”. If the building is close to the threshold and the height is uncertain, it is sensible to establish it from reliable records or competent measurement.
What about blocks below 11 metres?
The specific quarterly and annual Regulation 10 checking frequencies do not apply simply because a lower-rise block contains fire doors. That does not mean the doors can be ignored.
The Fire Safety Order still requires suitable fire precautions and maintenance of fire-safety measures. The fire risk assessment should consider whether the existing doors are adequate for the building and how their condition should be monitored. The appropriate inspection regime should therefore reflect the building, the doors, their use and any known concerns.
Routine checks and professional inspections are different
Government guidance makes an important distinction between the simple checks required by Regulation 10 and the wider assessment of whether a fire door is suitable for its location.
A routine check is intended to identify obvious problems that may have developed through damage, wear or interference. Typical checks include whether the door closes properly, whether the self-closing device operates, whether there is visible damage and whether obvious gaps, seals or hinges appear defective.
A professional door-by-door inspection is more detailed. Depending on the agreed scope, it can consider the condition and operation of the complete door set, including the door leaf and frame, clearances, seals, hinges, closer, glazing and relevant ironmongery. It can also provide a structured defect schedule so remedial work can be instructed and tracked.
When a more detailed inspection may be appropriate
A detailed inspection may be appropriate where the fire risk assessment identifies uncertainty or defects, where routine checks repeatedly identify problems, following significant works, after damage, or where the Responsible Person needs a reliable door-by-door record for a managed block or portfolio.
The correct response is not automatically to replace an older door simply because it lacks modern certification. Current government guidance makes clear that an existing flat entrance door may still be adequate if its fire performance is suitable for the building and the door remains in appropriate condition.
A practical approach for managing agents
- Confirm whether the top storey is above 11 metres where that is not already established.
- Put the required Regulation 10 routine checks into the building's management programme.
- Keep a clear record of checks, access attempts, defects and follow-up work.
- Make sure residents receive the required information about fire doors.
- Use the fire risk assessment to identify where a professional inspection or further investigation is needed.
- Do not leave an obvious functional defect unresolved merely because wider responsibility or funding is still being discussed.