MHCLG issues update on Government’s fire door guidance

The guidance has been revised in light of Government concerns regarding a misunderstanding of the scope and intent of the Fire Safety (England) Regulations 2022, which has resulted in burdens on leaseholders (who’ve been advised to replace flat entrance doors that were not manufactured, and certificated, in accordance with current standards for new fire-resisting doors).

For the avoidance of doubt, the Government has clearly stated that the purpose of the Fire Safety (England) Regulations 2022 is not to ensure that existing flat entrance doors satisfy the current standards for flat entrance doors in new blocks of flats, as imposed under the Building Regulations.

Rather, the purpose of the Fire Safety (England) Regulations 2022 is to implement the recommendations of the Public Inquiry into the Grenfell Tower fire which, quite correctly, emphasised the importance that flat entrance doors must be effectively self-closing.

Changes in legislation

Changes in legislation – particularly so the Regulatory Reform (Fire Safety) Order 2005 (as amended) – following the Grenfell Tower fire have not resulted in any material changes to the fire performance required of flat entrance doors in existing blocks of flats. As has been the case since the Fire Safety Order first came into force, the requirement is that the fire performance of the door is adequate to address the risk posed to residents from fire.

In the majority of circumstances, it’s expected that a door satisfying the standards for a fire-resisting flat entrance door at the time the block was built, or when the door was manufactured, will continue to provide adequate protection for means of escape in common parts of the block, provided the door is undamaged and that gaps between the door and the frame are not too large.

The absence of intumescent strips and smoke seals, and the absence of any form of certification for a fire door, does not imply that the door is unfit for purpose.

In this connection, it’s important to understand the difference between a fire risk assessment carried out in pursuance of compliance with the Regulatory Reform (Fire Safety) Order, in which the fire resistance of the doors will be considered, and the very simple (but important) checks required under the Fire Safety (England) Regulations 2022.

Revised wording

The revised wording can be found in Section 2.4, which relates to the responsibilities of the ‘Responsible Person’ under Regulation 10 of the Fire Safety (England) Regulations 2022, Section 6.7 (focused on elements to be considered when carrying out fire door inspection and checks) and also the summary box at the end of the guidance.

The update to the checklist relating to a given fire door’s intumescent strips and seals states: “The door may be acceptable, on the basis of fire risk, even if intumescent strips and smoke seals are not present (because the door was manufactured in accordance with earlier standards). The purpose of this check is to ensure only that, if these components are present, they are undamaged.”

*Read Fire Safety (England) Regulations 2022: Fire Door Guidance online