Monthly checks, and the 24 hour clock that starts with a fault

Most fire safety duties are annual, and an annual duty is easy to hold in your head. Regulation 7 is monthly, which is a different kind of problem. Twelve times a year, in every high-rise residential building, somebody has to walk the building, check a defined list of equipment, and write down what they found.

It applies to any building containing two or more sets of domestic premises that is at least 18 metres above ground level or has at least seven storeys, measured to the top storey in line with Appendix D of Approved Document B. Storeys below ground do not count towards the total.

What is actually on the list

The duty covers lifts for use by firefighters, evacuation lifts, and what the regulations call essential fire-fighting equipment. That last phrase does more work than it looks like it does, because it pulls in two separate definitions.

The first comes from regulation 6(7), and covers inlets for dry-rising mains, inlets for wet-rising mains, outlets for dry-rising mains, outlets for wet-rising mains, smoke control systems and suppression systems.

The second adds anything in the common parts falling under three headings: fire detection and fire alarm systems, including any detectors linked to ancillary equipment such as smoke control systems; evacuation alert systems; and automatic door release mechanisms linked to fire alarm systems.

Read together, that is a longer list than the one most buildings are running. Rising main outlets on every landing get checked far less often than the panel in the entrance lobby. Automatic door release mechanisms, the hold-open devices that drop a cross-corridor door when the alarm sounds, are frequently nobody's specific job. They sit somewhere between the door contractor and the alarm contractor, and a door that no longer releases is not obvious to anyone walking past it.

The 24 hour clock

This is the part that changes the shape of the work.

If a check identifies a fault, the responsible person has to take steps to rectify it. Where the fault cannot be rectified within a 24 hour period beginning with the time the fault is identified, they must, as soon as reasonably practicable, report the fault to the local fire and rescue authority by electronic means. When it is fixed, they must report the rectification the same way.

Two things follow from the drafting. The clock starts when the fault is identified, not when it is reported internally, not when a contractor is instructed, and not when somebody gets round to reading the check sheet. So the time of identification is itself a piece of information you need to have written down, because it is the thing that determines whether a report was due and whether it was late.

And the duty does not end at the first report. A fault reported and then quietly fixed leaves the obligation half discharged. The fire and rescue authority is entitled to know when the building is whole again, and an open fault sitting on their system against your building is not a good look at the next engagement.

In practice the failure mode is rarely refusal. It is a check carried out on the 3rd, a sheet handed in on the 9th, and a fault that has been live for six days before anybody with the duty knows it exists.

Servicing is a separate obligation

The monthly check is a check. It is not a service, and it does not replace one.

Smoke control systems carry their own maintenance regime under BS 7346-8, which sets out planning, installation, commissioning and maintenance for smoke control components, with testing and inspection by a competent person at least annually and commonly twice a year in practice. Alarm systems, evacuation alert systems to BS 8629, sprinklers and rising mains each have their own standards and their own intervals.

Running the two together is where buildings tend to get into trouble, in both directions. Some treat the monthly walk as evidence the system is maintained, which it is not. Others treat the annual service certificate as evidence the monthly duty is discharged, which it also is not. They are separate records answering separate questions, and a regulator or an insurer will ask for both.

Making it a system rather than a habit

The reason regulation 7 slips is almost never that somebody decided not to do it. It slips because a monthly task with no fixed owner and no forcing function drifts to the fifth week, then to the seventh, and the gap only becomes visible when someone counts the records twelve months later and finds nine.

A few things make the difference.

Fix the date, not the month. A check due on the first working day is a check that happens. A check due "in August" is a check that happens on the 29th, or does not.

Name a person, not a role. Roles change hands without a handover of the recurring work attached to them.

Put the equipment list in the system rather than on the sheet. If the schedule is generated from an asset register, adding a new evacuation alert panel or a second dry riser outlet updates the check automatically. If the list lives in a Word document somebody copied from the last building, it goes stale the first time the building changes.

Record the time of identification on every fault, not just the date. The 24 hour rule is written in hours.

Make the resident-facing record a by-product. The regulation requires the record of the monthly checks to be accessible to residents. If that means somebody manually assembles a summary every quarter, it will lapse. If the record is published from the same place the check is logged, it does not.

Where this sits in SAMRISK

The equipment itself belongs in items as a real asset register, so the risers, panels, smoke control plant, door release mechanisms and lifts are a list the system holds rather than a list somebody maintains by hand. The monthly check is a recurring job in maintenance with a named owner and a due date, chained off the compliance calendar so the next one is created when the last is signed off and the interval cannot quietly stretch.

Anything found becomes a record in incidents with the time it was identified, which is the field the 24 hour clock actually runs on, and the remedial work becomes a tracked task with a completion date rather than an email. Contractor attendance and the annual service certificates sit against the same assets through contractors and permits and documents, so the check history and the servicing history read as one story. The wider picture lives in fire safety, and for buildings in scope it feeds the safety case without being retyped.

The point

Regulation 7 is not a difficult duty. It is a repetitive one, and repetitive duties fail quietly.

The buildings that get this right are not the ones with the most thorough check sheet. They are the ones where the check has a date, an owner and an equipment list the building itself keeps up to date, and where a fault found at half past two on a Tuesday is timestamped at half past two on a Tuesday.

Sources: The Fire Safety (England) Regulations 2022 (SI 2022/547), regulations 3, 6 and 7, legislation.gov.uk; BS 7346-8:2013, Components for smoke control systems, code of practice; BS 8629:2019, Code of practice for the design, installation, commissioning and maintenance of evacuation alert systems.