Fire Risk Assessment, Fire Door Surveys and Compliance Vs Life Safety
- marchw
- Apr 29
- 11 min read
Updated: 7 days ago
In this blog we discuss the line between fire door compliance and fire life safety and the potential for issues with ethics in upselling. There are three key issues that we look at in this blog:
· Competency
· Assigning risk.
· Ethical conflicts of interest.
We look to explore these areas with you now to help you the reader avoid some of the pitfalls. We have aimed this document at Responsible Persons as defined in The Regulatory Reform (Fire Safety) Order 2005 (RRFSO).
First;y though, there is one question we note that people ask and despite what anyone may tell you, at the time of writing, there is one very clear answer.
Is it a legal reuirement to have a fire door survey?
NO.
It is not a legal requirement to have a fire door survey.
We lead this blog with our key advice and then if you wish to read on for some background and examples, please do, as it will help you understand the pitfalls we are hoping to help you to avoid.
· Get a fire risk assessment (as you must by law anyway), preferably completed by a third party accredited company ensuring the competence of the fire risk assessor.
· Don’t get a fire door survey until your fire risk assessor says you need one.
· If the recommended fire door survey is likely to be sold to you by the same company who supplied the fire risk assessment, get a second opinion first.
· If the remedials are sold to you by the same company supplying the fire door survey, avoid. It's is not a survey, its a quote survey, that you are paying for.
We are not saying fire doors don’t need to be checked. They absolutely do. Fire doors are a critical passive component of a buildings fire safety design. If the requirements of the RRFSO apply to your property Article 17 requires that you maintain your doors.
Furthermore, if you have a residential property where the RRFSO applies, then the Fire Safety (England) Regulations 2022 (FSER) are also likely to apply. Regulation 10 requires that you check all common fire doors quarterly, irrespective of height, and all flat entrance doors annually if exceeding 11m in height (measured from the ground to the highest occupied finished floor level) as stated in Building Regulations Approved Document B (ADB) Volumes 1 and 2. In addition the FSER requires you to inform residents of their responsibilities to fire doors, in Regulation 10.
As you can see there’s already quite a lot going on and a lot of requirements of duty holders. Since Grenfell, a large industry has sprung up to assist the Responsible Person with checking fire doors, primarily with Fire Door Surveys and then with the remediation of doors where they do not achieve standards set in codes of practice. And this is where the issues start.
Basic government guidance suggests the following checks (follow the links in the further reading section to get greater detail) – Checks for
damage or defects that might affect the door’s ability to resist the spread of fire or smoke
any damage to intumescent strips or smoke seals, if present
large gaps
the presence of an effective self-closing device
Competency
Fire door surveys generally apply British Standards, yet not all fire doors need to achieve current British Standard codes of practice. A door may be perfectly adequate and able to function as intended when it was installed before British Standards were established. A door survey will not consider this factor. It will apply the current standard even though you shouldn’t apply standards retrospectively. It should be noted that British Standards are not regulation.
A fire door survey of timber doors typically looks to see if fire doors comply as follows:
· Are doors labelled as a certified fire door?
· Is there damage to the door?
· Is the frame suitable and in good condition?
· Are there adequate smoke and intumescent seals?
· Glass is fire rated and beading is installed correctly.
· Gaps are between 2-4mm.
· Threshold gaps don’t exceed 3mm.
· There are 3 hinge sets, with the correct screws, complying with the relevant British Standards in force at the time of the survey
· All door furniture, ie, closers, letterplates, etc, comply with the relevant British Standards in force at the time of the survey
A good door surveyor may note:
· whether a door is the correct fire resisting rating for its location, but this is rare
· that a door labelled as a fire door is in fact not required to be a fire door, but this is rarer still
Case Study – Summer 2025. Croydon.
It is common for doors that don’t need to be fire doors to be included in fire door surveys simply because they have a fire door label on them. We worked with a customer in June 2025, where they had a door survey that resulted in a quote for £15,000 for new fire rated hinges. Worryingly, had the doors been fire doors, the fire door surveyor missed critical issues with doors. Even still, as original doors, they did not need new fire rated hinges to comply with British Standards. In the end, on review of fire engineered design, it was noted that other than a few cross-corridor doors, of which there were no issues, none of the doors included in the survey need to be fire doors due to the presence of other fire safety systems that made this possible. We advised the client in our fire risk assessment and saved them £15,000.
You would be surprised how often a brand new door will fail compliance checks by a fire door surveyor. A common issue is a new build project, having its doors checked in the last phase of Building Control checks may have all gaps measured as just right. Then the building is signed off, the heating turned on and the moist cold timber doors dry out and shrink, leaving the building owner a large number of doors that won’t ‘pass’ in a fire door survey as many doors now have excessive gaps exceeding 4mm.
Case Study – Spring 2022.
We worked with a client, who had a new build and was having a pre-occupation Fire Risk Assessment. We noted that the vast majority of timber door assemblies had excessive gaps exceeding 4mm, often finding them to be between 6-8mm. The building had not been occupied yet and had only been signed off (Practical Completion) by Building Control i6 weeks previously. On this occasion the pendulum swung the other way as we knew this client would end up with Fire Risk Assessments recommending fire door surveys in the future and once past the defects period, it would be hard to seek compensation or support from the development. In other words our client had a latent issue, that eventually they would end up potentially footing the bill for. In this rare instance we recommended that the client liaise with the developer to agree to, and pay for, a fire door survey and for any recommended remediation package.
Assigning Risk
In our experience the most common finding in a fire door survey is excessive gaps. The fire door survey, if it provides a risk rating, will often state the finding of excessive gaps as ‘high risk’. Even if it doesn’t produce a timescale for high-risk findings, what does that tell you? In our experience, most clients take that to mean high-risk so treat as relatively urgent.
And now we’re really starting to see huge costs to landlords and owners, often, unnecessarily having to be accelerated.
Case Study – Spring 2025. Central London.
We worked with a client who had a 12 storey office block. They had a door survey which cost £20,000. They had a long list of remedials. Mostly ‘high risk’ excessive gaps. The quote (by the same company undertaking the fire door survey) for remedials was £350,000.
When we looked at it we considered factors that a fire door surveyor won’t. We risk assessed considering a holistic view of the building and how it was managed. These included but were not limited to a consideration of:
· How well managed the property was by an experienced asset management company
· Tenant occupier fire risk assessments up to date
· Clear evidence of maintenance for all systems, including life safety systems
· Excellent control on fuel loads
· Trained fire wardens in place
· Clear evacuation plans in place
· Fire drill times not exceeding 9 minutes in the last 5 years
· Smoke control in all means of escape
· A fully sprinklered building resulting in a building risk profile of A1.
· Provision of fire extinguishers
· Dry riser system installed and multiple firefighting lifts present.
· A Grade A Category L1 fire alarm system.
· 4 protected staircases accessed from each floor level.
· Very high standards of fire stopping.
· Evidence of adequate compartmentation, horizontal and vertical
· Offices between 2000-3000 square metres. Fire tends to travel in areas greater than 300 square metres and flash over / a fully involved fire is decreasingly likely as the room size increases and therefore less likely the door will have heat directly against it.
· Low combustible materials in the facade
We wanted to know how a fire door with a 6mm gap was ‘high risk’ given all the other factors controlling fire risk present. A competent fire risk assessor may be able to justify that gaps exceeding guidance are not an urgent fix. We suggested the client look to prioritise the resulting door survey findings and look at what is critical, eg, doors on to protected staircases and firefighting shafts, remediating them first. We suggested that a 3-5 year cycle for the remediation programme should be reasonable in achieving the requirements of Article 17 of the RRFSO. We recommended generally ignoring the risk rating of the fire door survey and potentially consider an alternative provider for the ongoing remediation package.
If we had been assessing a 5 storey converted town house with issues with compartmentation, etc, then we would be looking much closer at the doors and the risk of fire spread. All properties are different and the key to determining risk is - risk assessment
Fire door surveyors in our view are well meaning, hard-working and conscientious. However, in our view, many surveyors are unlikely to be competent in fire risk assessment and have only trained in assessing doors to the current British Standards. If the companies they work for start moving away from rated and RAG rated approaches and systems that are potentially misleading (5mm gap, high risk – fail) to a fact based system (gap 5mm, exceeds recommended guidance – and nothing further), leaving g risk assessment to fire risk assessors, the better for clients things will be.
Unhelpfully, you can even buy gap testing tools that declare ‘pass’ or ‘fail’ on the door gap testers. The producers of these tools claim that it doesn’t fail the whole door. We have argued that that in our experience, this is not the common view amongst fire door surveyors. As you see with this exchange our Director on Linked-in had when he’d questioned the wisdom of placing qualitive phrases on the measuring tool.
Note, there’s no question on where the door might be. It is a black and white approach where the door doesn’t get ‘signed’ off if the gap is too big without remediation or replacement. In the view of the surveyor, if in doubt, recommend remediation – make sure you’re covered. This is not case for all surveyors, but liability for advice given in the industry is a big concern in the context of if a fire spreads, so it’s not a rare approach, let’s put it that way. The fact that advice provided that may place an unreasonable burden on the consumer particularly to control risks that are negligible, is still bad advice, doesn't seem to be considered as much.
We also flagged an additional issue that the tool was stated as a fire door gap tester but was set to ‘pass’ 2mm, 3mm and 4mm doors and ‘fail’ 5mm and 6mm doors. As we’ve discussed this is not necessarily or automatically correct for reasons already stated.
Furthermore, not all doors are wood. Metal fire doors are common and their tolerance differ. We asked the manufacturer of the gap tester tool:
1. Where on the product does it say 'for use with timber doors only'? (Answer: it didn’t)
2. What is the recommended tolerable gap on a metal door? (Answer: 3mm only – 4mm would be a ‘fail’ working on the industry basis, yet the tool would mean it would pass)
3. What is the recommended tolerable gap on a metal door fitted with an astragal? (Answer up to 6mm, yet the tool would state it as a ‘fail’).
We never got a clear response. Responses came back referring to test evidence of doors from manufacturers and that test data supports the claim. Test data and measurements do not, in the context of fire doors at least, determine risk, fire risk assessors do. Moreover a perfectly good door assembly being assessed may be 40 years old and there is no data available.
We recommend you avoid tools/door gap testers that add qualifying words or statements if undertaking door checks yourself.
Ethical conflicts of interest
Our biggest issue and concern facing the sector now is the risk of products being driven by commercial interests not safety. In other words, your fire risk assessment stating you need a fire door survey. You may weel do, but we also know some companies have thresholds set for risk assessors. For example, if the risk assessor finds a range of 3 differing faults with 3 different doors, eg, door A has missing hinge screw, door B has 5mm gap between leaf and frame, door C has a damaged smoke seal, then the assessor needs to recommend a door survey. It doesn’t matter if there are 10 doors or 1000 doors, the threshold is met.
Challenge the requirement for a door survey or get a second opinion. Safety consultancies are commercially driven of course, they wouldn’t exist if they weren’t, but some lean more towards making money for investors and shareholders than others.
Let’s look at why there is a risk by looking at the potential costs (for you) and profits (for them):
It might cost the client somewhere in the region of (estimate considers timber doors based on anecdotal information):
· £350 for remedy of the gap on a single leaf door, retaining the existing door leaf
· £800-£1000 possibly for a single leaf replacement
Increase the figures significantly for double doors assemblies.
Now imagine your asset has 800 doors. You are needing a door survey (Let’s say £20 + VAT per door) and in the view of the fire door surveyor, whose company will supply the remediation (so this a quote you’re paying for) 75% of doors need remediation of ‘high risk’ door gaps. Let’s split it and say 80% will need remediation at £350 and 20% will need replacement at £800.
· Door survey = £19,200
· Remediation – replace = £115,200
· Remediation – adjust = £33,600
Total – £168,000
We don’t know about you, but our eyes are watering. We think we are splitting it too far as well and think it is likely more like 60/40. That takes you past the £250,000 mark - a quarter of a million pounds.
Don’t forget indirect costs such as time and salaried hours of those planning and arranging, impact on business operations during works, complaints and dissatisfaction from tenants, and so on.
Also don’t forget the £2000 you spent on the FRA. If the company completing the FRA is affiliated with the door surveying company, there is a possibility they may get a percentage of the survey fee or have an arrangement of some type of benefit-in-kind. If they undertake the door survey, they get all of the profit. Tempting wouldn’t you say?
We don’t know what the margin is on those figures but the fire door surveyor is reviewing anything between 12-20 doors an hours, more in some cases. The first hour probably pays their day rate and the rest is profit to the company.
So, you can see that fire door surveys and their remediation are potentially very lucrative and you can see why we say there is a potential conflict of interest when upselling.
We make a promise to our clients:
Health, Safety & Fire Consulting will not offer services or products we have recommended you need. We will not have links to anyone that does supply your service or product and will not receive any financial reward or benefit in kind from making our recommendations. We act and are completely impartial and independent. That’s our ethical guarantee.
For qualified and accredited fire risk assessment and fire safety advice that’s ethical and impartial:
Contact Health, Safety and Fire Consulting Ltd – 01276 930243 – www.healthsafetyfireconsulting.com
Further Reading:
The Regulatory Reform (Fire Safety) Order 2005
The Fire Safety (England) Regulations 2022 https://www.legislation.gov.uk/uksi/2022/547/regulation/10/made
Building Regulations Approved Document B Volumes 1 and 2
Fire Safety (England) Regulations 2022: fire door guidance
Disclaimer
This blog is not intended as training. You will not be competent to give fire safety advice, undertake a fire risk assessment or carry out a fire door survey by reading it. For assistance contact Health, Safety & Fire Consulting Ltd for support and advice.
We do not suggest that all companies nor any specific company acts unethically or with bias towards commercial enterprise. We point to the risk of how some companies may operate and why that might be.
© Health, Safety & Fire Consulting Ltd – April 2026.
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