Fire door checks under regulation 10: the record no template holds
The Fire Safety (England) Regulations 2022 require quarterly communal fire door checks and annual flat entrance door checks in buildings above 11 metres. Regulation 10 also requires a record of the steps taken to gain access where a resident did not let you in, which is the part generic checklists miss.
By Hovermarks team
Quick answer. In buildings above 11 metres in height, regulation 10 of the Fire Safety (England) Regulations 2022 requires the responsible person to check fire doors in communal areas at least every 3 months, and fire doors at the entrances to individual flats at least every 12 months. Both checks must include ensuring the self-closing devices work. Regulation 10 also requires a record of the steps taken to comply, including where access to a flat was not granted during any 12-month period, the steps taken to try to gain access. A door you could not get into is a record you still have to keep.
Most fire door guidance stops at what to look at on the door. The regulation asks for something else as well, and it is the part that decides whether a block manager can evidence compliance for the flats that never answered the door.
Who it applies to, and the 11-metre line
Regulation 10 bites in buildings above 11 metres in height containing two or more sets of domestic premises. That threshold matters and is worth stating every time, because the duties below are not the general position for every block in the country. Below 11 metres the regulation 10 duties do not apply in the same way, and telling a duty holder otherwise gives them a false picture of an obligation they do not have. Other fire safety duties, under the Fire Safety Order and elsewhere, continue to apply regardless of height.
The two cycles
- Communal-area fire doors: at least every 3 months. The doors on corridors, stairwells, plant rooms, bin stores, anything in the shared parts.
- Flat entrance doors: at least every 12 months. The doors between the individual dwellings and the communal escape route.
Both checks must include ensuring the self-closing devices for the doors are working, which the regulation states expressly rather than leaving to practice. A door that closes when you push it but does not close itself has failed the check the regulation names.
The access-attempt record, which is the actual differentiator
Regulation 10 requires the responsible person to keep a record of the steps taken to comply with the flat entrance door duty, including in any case where access to the domestic premises was not granted during any 12-month period, the steps taken to try to gain access.
Read that carefully, because it changes what a fire door register is for. It means:
- "No access" is a recordable outcome, not a skipped inspection. The check did not happen, and that fact plus the attempts around it is what goes in the record.
- Each attempt is evidence. The letter, the card through the door, the arranged appointment nobody kept, the second visit at a different time of day: dated, described, and attributable.
- A register that only holds the doors you got into cannot evidence best endeavours for the ones you did not. It shows 84 of 120 doors checked and is silent on the 36 that matter most to the question being asked.
This is where generic fire door checklist templates fail. They are built around the door, so an unvisited door produces nothing at all. The regulation asks for a record of steps taken, which is a record about the responsible person's conduct as much as about the door.
The practical shape: every flat entrance door is an asset in the register whether or not it has ever been opened, each carrying its own history of outcomes, and a "no access" outcome is a first-class record with a reason, a date, a person, and the next attempt planned.
What the check itself covers
The commonly used five-point check, in the order most people work through it:
- Certification. A label or plug, usually on the top or hinge edge, showing the door is a certificated fire door.
- Gaps. Around 3mm at the head and along both sides. Under the door, commonly up to 8mm, or around 3mm where a cold smoke seal or drop seal is fitted. Consistent gaps matter as much as the measurement: a tapering gap suggests the door or frame has moved.
- Seals. Intumescent strips and any smoke seals present, intact, continuous, and not painted over or damaged.
- Hinges. Three or more, firmly fixed, with no missing screws.
- Closing. Open the door to about 90 degrees, let go, and it should close fully onto the latch without sticking or bouncing back.
Any of these failing is a defect on the door, and the defect needs the same treatment as any other: recorded, owned, dated for remedy.
Where Hovermarks fits
Hovermarks runs the fire door register as a QR-tagged asset per door: the communal doors on their 3-month cycle and the flat entrance doors on their 12-month cycle, each carrying its own check history, photo evidence, and defect record. "No access" is a recordable outcome rather than a gap, so the attempts to gain entry sit in the same record as the checks that happened, which is what regulation 10 asks the responsible person to be able to produce.
What it does not do: it produces the record, it does not discharge the duty. The record-keeping obligation, the decision about what steps are reasonable to gain access, and the judgement of whether a door passes remain the responsible person's. The fire safety solution shows the workflow, and the fire door inspection register template covers the fields.