Fire door checks, and the doors nobody has looked at

A fire door is the only piece of fire protection in a residential block that a resident touches several times a day. It is also the only one they can defeat with a doorstop.

Regulation 10 of the Fire Safety (England) Regulations 2022 has been in force since 23 January 2023. Three and a half years on, we have the first national measurement of whether the duty it created is actually being discharged, and the answer is uncomfortable.

What regulation 10 asks for

In any multi-occupied residential building in England where the top storey is more than 11 metres above ground level, the responsible person must carry out quarterly checks of all fire doors in the common parts, including their self-closing devices. They must also use best endeavours to check every flat entrance door that opens onto a common part at least once a year, again including the self-closer.

Two details are worth pinning down, because both get lost.

The height threshold is 11 metres, not 18. A great many four and five storey blocks that sit well outside the higher-risk regime are squarely inside this one, and they are the buildings least likely to have a fire door regime at all.

And there is a third limb that applies to every multi-occupied residential building with two or more sets of domestic premises and common parts, at any height. The responsible person has to give residents information about why fire doors matter. No height test, no exemption for the small converted terrace.

Regulation 10 is an England-only provision. The Regulatory Reform (Fire Safety) Order 2005 applies in England and Wales, but this regulation does not extend to Wales.

The first national picture

In March 2026 the Sentry Fire Safety Group published A Burning Issue: The Reality of Fire Door Safety in Social Housing, built from freedom of information responses returned by 88% of England's local authorities. It is the first national snapshot since the inspection duties came in.

Since January 2023, 89% of communal fire doors had been inspected at least once. Only 46% of flat entrance doors had.

Of the doors that were inspected, 63% of flat entrance doors and 67% of communal doors did not meet the FD30 threshold.

Then 63% of the non-compliant doors were still awaiting repair or replacement, and 51% of the responding authorities had no formal remediation plan.

Read those four numbers in sequence and the shape of the problem is clear. It is not one failure, it is four in a row: doors not checked, doors that fail when checked, failures not fixed, and no plan to fix them.

The flat entrance door figure is the one to sit with. Fewer than half have been looked at in three and a half years, and the flat entrance door is the door that separates the fire from the escape route.

Why so many fail

None of this is new. The Fire Door Inspection Scheme reported on more than 100,000 inspections carried out by its approved inspectors in 2021 and found 75% of doors failing to meet the required standard. Its 2019 data put the figure at 76%, so the picture had not moved.

The reasons FDIS recorded are almost entirely mundane. Excessive gaps between door and frame accounted for 77% of failures. Care and maintenance issues accounted for 54%. Smoke sealing problems 37%. Around 31% of the doors had been installed incorrectly in the first place.

That distribution matters, because it tells you what kind of problem this is. A door failing on a 5mm gap or a painted-over intumescent strip is not a procurement problem or a funding problem. It is a maintenance problem, and maintenance problems respond to being written down.

The most common real-world causes are the ordinary life of a building. A self-closer adjusted because a resident complained it slammed. A door leaf sanded down after it stuck one wet winter. Six coats of paint over the smoke seal. A new lock fitted by a contractor with an uncertified escutcheon. A doorstop that has been there so long nobody sees it.

The access problem, honestly

The flat entrance door number is low for a reason people do not always say out loud. Getting into 200 flats once a year is genuinely hard. Residents work, residents are elderly, residents do not answer the door to a stranger with a clipboard.

The regulation anticipates this. The flat entrance door duty is a best endeavours duty, not an absolute one. But best endeavours is a standard you have to be able to evidence, and that means the record of the attempts is the compliance artefact, not just the record of the completed checks.

Three letters, two arranged appointments and a note of the date each was sent is best endeavours. A spreadsheet with a blank cell is not, and at an inquest the difference between the two is the whole case.

What a working regime looks like

The buildings that get this right tend to share four things.

The doors are on an asset register rather than a list. Every communal door and every flat entrance door exists as a numbered thing with a location, a type, a certification reference and its own history. A door you cannot name is a door you cannot prove you checked.

The quarterly check is generated, not remembered. It has a date, a named person and a defined scope, and the next one is created when the last is signed off, so the interval cannot quietly stretch from three months to five.

Failures become work, immediately. A recorded defect that does not automatically create a job with an owner and a due date is a defect that will still be open at the next inspection. That is precisely how 63% of non-compliant doors end up waiting.

Attempted access is logged like a check. Every letter, call and no-answer visit is dated against the door, so the best endeavours position is written as it happens rather than reconstructed later.

Where this sits in SAMRISK

Doors belong in items as real assets, one record per door, with certification details, hardware and photographs attached rather than living in a survey PDF from 2023. The quarterly communal check and the annual flat entrance check are recurring jobs in maintenance, chained through the compliance calendar so the next occurrence is created on sign-off.

Anything found becomes a defect in incidents and a remedial task with an owner and a date, so the gap between finding a failure and fixing it is visible while it is still small. Attempted visits and resident correspondence sit against the same door record, which is what turns best endeavours from an assertion into evidence. Contractor attendance and certification live in contractors and permits and documents, the wider position in fire safety and risk assessments, and for buildings in scope it feeds the safety case without anybody retyping it.

The point

Regulation 10 has been law for three and a half years and it is not a demanding duty. Four checks a year on the communal doors, one attempt a year on each flat entrance door, and a record of what you found.

The national data says most of the sector is not doing it, and that where it is done, two doors in three fail. Neither of those is a technology problem. But the reason the checks lapse is almost always the same: a recurring duty with no fixed owner, no forcing function and no register of the things it applies to.

Give the doors names, give the check a date and a person, and turn every failure into a job the moment it is written down. The rest follows.

Sources: The Fire Safety (England) Regulations 2022 (SI 2022/547), regulation 10, legislation.gov.uk; Home Office, Fire Safety (England) Regulations 2022: fire door guidance; Sentry Fire Safety Group, A Burning Issue: The Reality of Fire Door Safety in Social Housing, 12 March 2026; Fire Door Inspection Scheme inspection data, 2021 and 2019.