Fire safety in blocks of flats has received intense scrutiny following the Grenfell Tower tragedy. New legislation and heightened enforcement mean landlords and building owners face significant responsibilities and potential penalties for non-compliance.
Are you confident about fire safety in your block of flats?
Check your understanding and compliance.
Why fire safety in flats is different
Blocks of flats present unique fire safety challenges:
Multiple occupancies under one roof
Complex responsibilities:
- Landlord controls common areas
- Tenants control within flats
- Shared means of escape
- Multiple households to evacuate
- Varying levels of fire awareness
Dependency on passive protection:
- Flat compartmentation must contain fire
- Flat entrance doors protect escape routes
- Common area fire resistance critical
- One person's actions affect everyone
Sleeping accommodation
Higher vulnerability:
- People asleep cannot detect fire early
- Delayed response to alarms
- May include vulnerable or elderly residents
- Nighttime evacuation more complex
- Reduced escape capability
Vertical escape routes
Additional challenges:
- Single staircase often only means of escape
- Fire or smoke in staircase cuts off escape for multiple floors
- Longer distances to safety
- More difficult for mobility-impaired persons
- Smoke rises, affecting upper floors first
Blocks of flats rely on compartmentation — keeping fire contained within the flat of origin long enough for everyone to escape. This means flat entrance doors, fire-resisting construction, and proper maintenance are absolutely critical. Failure of compartmentation can turn a single flat fire into a building-wide catastrophe.
Key legislative changes post-Grenfell
The Grenfell Tower fire in 2017 killed 72 people and exposed serious gaps in fire safety regulation and enforcement. New legislation closed these gaps:
Fire Safety Act 2021
Enacted: April 2021
Key changes:
Flat entrance doors explicitly covered:
- Previous ambiguity removed
- FSO now clearly applies to flat entrance doors
- Landlords explicitly responsible for ensuring doors provide adequate fire resistance
- Even though doors are technically within flats, landlord responsible for fire performance
External walls covered:
- FSO now explicitly includes external walls and cladding
- Attachments to external walls (balconies, etc.)
- Removes previous uncertainty about scope
Importance:
- Before FSA 2021: some argued flat entrance doors weren't covered by FSO
- Now: absolutely no doubt — landlord must ensure doors are compliant
- Failure to ensure compliant flat entrance doors is criminal offence
The Fire Safety Act 2021 changed the game for landlords. You cannot claim flat entrance doors are the tenant's responsibility. You must ensure every flat entrance door provides adequate fire resistance. This means knowing the specification of every door, inspecting them regularly, and replacing non-compliant doors.
Building Safety Act 2022
Enacted: June 2022 (phased implementation)
Key provisions:
Higher-risk buildings regime:
- Buildings over 18m or 7+ storeys with residential units
- New Building Safety Regulator
- Accountable Person responsible for building safety
- Mandatory occurrence reporting
- Resident engagement duties
Building safety cases:
- Accountable Person must prepare safety case
- Demonstrate building is safe
- Identify all fire safety risks
- Show how risks are managed
Enhanced enforcement:
- Building Safety Regulator has strong powers
- Significant penalties for non-compliance
- Residents can escalate concerns
Impact on landlords:
- Higher-risk buildings have extensive additional duties
- Lower blocks still covered by FSO and FSA 2021
- Enforcement has intensified across all residential buildings
Fire Safety (England) Regulations 2022
Requires landlords to:
- Provide fire safety information to residents
- Annual check of flat entrance doors
- Share fire risk assessment information
- Ensure residents understand evacuation strategy
Information duties:
- Instructions for what to do if fire occurs
- Information about building's fire precautions
- Importance of not propping fire doors open
- How to report fire safety concerns
Who is responsible?
The landlord / building owner
Primary responsible person under FSO:
Responsible for:
- Common areas (hallways, stairways, lobbies)
- Communal facilities
- Flat entrance doors (ensuring adequate fire resistance)
- External walls and cladding
- Fire safety equipment in common areas
- Conducting fire risk assessment
- Implementing fire safety measures
Not responsible for:
- Internal arrangements within flats (tenant's responsibility)
- But must ensure tenant actions don't compromise building safety
Landlord vs Tenant Fire Safety Responsibilities
Landlord Responsibilities
Recommended- •Fire risk assessment of building
- •Common area fire safety (alarms, lighting, extinguishers)
- •Flat entrance doors meet fire resistance standards
- •Fire doors in common areas properly maintained
- •Information and instructions to residents
- •External walls and cladding safety
- •Annual flat entrance door checks (from Jan 2023)
Tenant Responsibilities
- •Don't create fire hazards in flat
- •Keep flat entrance door closed
- •Don't modify flat entrance door
- •Maintain smoke alarms in flat (if provided)
- •Allow landlord access for fire safety checks
- •Follow fire safety instructions provided
- •Report fire safety concerns to landlord
Bottom line: Landlords have the primary legal responsibility for fire safety in blocks of flats. While tenants must cooperate and not create hazards, the landlord cannot delegate fire safety duties and will be prosecuted for failures, not the tenant.
Managing agents
If landlord employs managing agent:
Agent responsibilities:
- Carry out fire safety duties on landlord's behalf
- Arrange fire risk assessments
- Implement fire safety measures
- Maintain equipment and systems
- Communicate with residents
Landlord remains responsible:
- Cannot delegate legal responsibility
- Remains responsible person under FSO
- Must ensure agent is competent
- Must monitor agent's performance
Leaseholders and resident management companies
Long leaseholders:
- Often responsible for building management
- Take on responsible person duties
- Must comply with FSO and FSA 2021
- Same obligations as landlords
Resident Management Companies:
- Company owned by leaseholders
- Acts as responsible person
- Full FSO compliance required
- Directors should ensure competent management
Flat entrance door requirements
Flat entrance doors are now an explicit priority for fire safety compliance:
Specification requirements
Minimum standard:
- FD30 (30-minute fire resistance)
- FD30s (with smoke seals) strongly preferred/required in many cases
- Self-closing device essential
- Intumescent strips and smoke seals properly fitted
- Certification evidence available
Higher-risk buildings may require:
- FD60 (60-minute fire resistance)
- Enhanced specifications
- Your fire risk assessment will specify
FD30s (with smoke seals) is now the expected standard for flat entrance doors. While FD30 without smoke seals may be technically acceptable in some older buildings, best practice and increased enforcement make FD30s the safer choice. Smoke kills faster than fire — smoke seals save lives.
Annual inspection requirement
Fire Safety (England) Regulations 2022 require:
- Annual check of every flat entrance door
- Started January 2023
- Landlord must arrange inspection
- Must keep records
What to check:
- Door closes and latches properly
- Self-closing device functioning
- No visible damage
- Seals intact
- Gaps within tolerance
- Certification present (if possible to check without entering flat)
Access issues:
- Must be done with tenant cooperation or during void periods
- Communicate importance to tenants
- Consider access clauses in tenancy agreements
- May need to schedule appointments
Remediation obligations
If inspection identifies defects:
- Landlord must arrange repairs or replacement
- Even though door is technically within flat
- Cannot expect tenant to pay (landlord's legal duty)
- Should prioritize most serious defects
Common remedial actions:
- Replace worn or missing self-closers
- Replace or repair damaged seals
- Adjust gaps if excessive
- Replace non-compliant doors entirely
Budget implications:
- Replacement FD30s doors: £250-450 each plus installation
- Multiply by number of flats
- Significant capital expense for large blocks
- But legal requirement and life-critical
Housing association fined £75,000 for non-compliant flat entrance doors
Following Grenfell, fire officers conducted comprehensive inspections of social housing blocks. A housing association managing 8 tower blocks (380 flats) was found to have serious flat entrance door deficiencies.
- ✗No records of flat entrance door specifications
- ✗Many doors replaced by tenants over years without landlord knowledge or approval
- ✗Of doors assessed, 35% were standard timber doors, not fire doors
- ✗Where fire doors existed, 60% had non-functioning or missing self-closers
- ✗Gaps exceeded 3mm on over 40% of doors
- ✗No systematic inspection regime existed
- ✗Housing association couldn't demonstrate compliance despite repeated fire officer requests
Enforcement Notices issued for all 8 blocks. The housing association was prosecuted under FSO and fined £75,000 plus costs. Required to survey all 380 doors (cost £25,000), replace 132 doors completely (£85,000), and repair/adjust remaining doors (£48,000). Total cost exceeded £230,000 plus the fine.
Post-Fire Safety Act 2021, ignorance is not a defense. Landlords must know the specification of every flat entrance door, have evidence of compliance, and maintain systematic inspection regimes. The cost of proactive compliance (perhaps £60,000 over 5 years) would have been far less than reactive enforcement. More importantly, non-compliant doors put hundreds of residents at risk.
Fire risk assessment requirements
Legal obligation
FSO requires:
- Suitable and sufficient fire risk assessment
- Covers all common areas
- Includes flat entrance doors
- Updated regularly
- Implemented recommendations
Who can conduct:
- Competent person
- Landlord if competent
- Usually specialist fire risk assessor
- Must have knowledge of residential buildings
What assessment must cover
For blocks of flats:
Building construction and layout:
- Means of escape (usually single staircase)
- Fire resistance of structure
- Compartmentation effectiveness
- Vertical and horizontal fire spread risks
Fire safety measures:
- Fire detection and alarm systems
- Emergency lighting
- Fire-fighting equipment
- Fire signage
Flat entrance doors:
- Specification and fire resistance
- Condition and maintenance
- Self-closing devices
- Gap tolerances
External walls:
- Cladding type and fire performance
- Attachments (balconies, etc.)
- Post-Grenfell, this is critical
Vulnerable occupants:
- Elderly or disabled residents
- Evacuation capability
- Personal Emergency Evacuation Plans (PEEPs) if needed
Management and information:
- Staff training (if communal staff)
- Information provided to residents
- Maintenance regimes
Assessment frequency
Review fire risk assessment:
- At least annually
- After significant changes (refurbishment, cladding work, resident demographics)
- After near-misses or incidents
- When new legislation enacted
- If defects identified
Fire detection and alarm systems
Common area alarms
Typical requirement:
- Fire alarm system in common areas
- Minimum: manual call points at exits
- Often: automatic detection in hallways, stairwells
- Sounders audible throughout common areas
- BS 5839 compliant system
Testing:
- Weekly alarm test (different call point each week)
- Six-monthly service by competent technician
- Keep records
Alarms within flats
Tenant responsibility (usually):
- Smoke alarms within individual flats
- Often provided by landlord but tenant maintains
- Should be on every level and in circulation areas
Landlord obligations:
- Ensure smoke alarms fitted initially
- Check functioning at tenancy start and changes
- May need to check during void periods
Interconnection:
- Newer buildings may have flats linked to common alarm
- Allows earlier warning of flat fires
- Coordination with evacuation strategy
Emergency lighting requirements
Common area emergency lighting
Legal requirement:
- All escape routes must have emergency lighting
- Stairways, corridors, lobbies
- All exit doors
- 3-hour duration for residential buildings
Testing:
- Monthly function test
- Annual duration test
- Records essential
Within flats
Not usually required:
- Emergency lighting within individual flats not legally required
- Residents expected to use torches if needed
- Common area emergency lighting ensures escape route protection
Evacuation strategies
Simultaneous evacuation
Traditional approach (low-rise blocks):
- Everyone evacuates simultaneously on alarm
- Direct to assembly point
- Simple and clear
When suitable:
- Low-rise buildings (typically 3-4 storeys or less)
- Simple layout
- Good compartmentation
- Able-bodied occupants
Stay put policy
Traditional approach for purpose-built flats:
- If fire in another flat, stay in your own flat
- Only evacuate if fire in your flat or told to by fire service
- Relies on compartmentation containing fire
- Common staircase kept clear for fire service
When suitable:
- Purpose-built blocks with good compartmentation
- Properly maintained flat entrance doors
- Fire-resisting construction
- Single staircase that would become congested
Post-Grenfell concerns:
- Stay put requires excellent compartmentation
- Flat entrance doors must be compliant
- Cladding must not allow external fire spread
- Many reviewing stay put policies
Stay put policies are under scrutiny. Grenfell showed stay put can fail catastrophically if compartmentation fails. Many landlords are reviewing evacuation strategies. Your fire risk assessment should explicitly state your evacuation strategy and justify why it's appropriate for your building. Don't assume stay put is still suitable.
Progressive horizontal evacuation
Alternative approach:
- Move to another compartment on same floor first
- Then downwards if necessary
- Used in care homes and some complex buildings
When suitable:
- Large floor plates with good compartmentation
- Mobility-impaired residents
- Phased evacuation needed
Communicating evacuation strategy
Residents must know:
- What the evacuation strategy is
- What to do if they discover fire
- What to do if alarm sounds
- When to leave, when to stay put
Communication methods:
- Fire action notices in common areas
- Information leaflet to all residents
- Induction for new residents
- Periodic reminders
Ongoing responsibilities
Regular inspections and testing
Weekly:
- Fire alarm test
- Visual check of common areas (fire doors not propped, escape routes clear)
Monthly:
- Emergency lighting function test
- More detailed inspection of common areas
Six-monthly:
- Fire alarm system service
- Fire door inspections (common areas)
Annually:
- Fire risk assessment review
- Flat entrance door checks
- Emergency lighting duration test
- Deep clean and inspection of common areas
Maintenance and repairs
Prompt attention to:
- Fire door defects
- Alarm system faults
- Emergency lighting failures
- Damage to fire-resisting construction
- Blocked escape routes or fire equipment access
Budget for:
- Regular servicing contracts
- Replacement of life-expired components
- Unexpected repairs
- Periodic upgrades
Record keeping
Essential records:
- Fire risk assessment (current version and reviews)
- Fire alarm test records (weekly tests, service reports)
- Emergency lighting test records
- Flat entrance door inspection records
- Fire drill records (if conducted)
- Staff training records (if employed staff)
- Incident records (fires, false alarms, near-misses)
Retention:
- Minimum 5 years for test records
- Fire risk assessments should be kept indefinitely with review history
- Good records demonstrate due diligence
Information and communication with residents
Regular communication:
- Fire safety reminders (don't prop fire doors, keep escape routes clear)
- Importance of flat entrance doors
- What to do if fire occurs
- Any changes to procedures or building works
Fire Safety (England) Regulations 2022 require:
- Information about building's fire precautions
- Evacuation strategy explained
- Who to contact about fire safety concerns
- Annual reminders recommended
External walls and cladding
Post-Grenfell scrutiny
The issue:
- Grenfell Tower had ACM (Aluminum Composite Material) cladding with combustible core
- Fire spread rapidly up external wall
- Led to catastrophic loss of life
- Thousands of buildings identified with similar cladding
Government response:
- Ban on combustible cladding on high-rise residential
- Building Safety Fund to remediate dangerous cladding
- Enhanced assessment and testing requirements
- Criminal prosecution for some cases
Landlord obligations
Must identify:
- Type of external wall construction
- Cladding type and fire performance
- Attachments to external walls
- Fire risk from external wall system
Assessment:
- Specialist assessment required for buildings over 18m
- EWS1 form (External Wall System) process
- May need intrusive testing
- Affects property values and mortgageability
Remediation:
- If dangerous cladding identified, must be removed/replaced
- Building Safety Fund may cover costs (apply early)
- Leaseholders should not be forced to pay
- Interim measures while awaiting remediation (waking watch, enhanced alarms)
Cladding issues are complex and specialist. If your building is over 18m or has any form of external cladding, engage a specialist fire engineer to assess. Don't assume your building is safe — get it checked. If dangerous cladding is found, apply for Building Safety Fund support immediately and implement interim measures.
Higher-risk buildings (over 18m)
Building Safety Act 2022 regime
If your building is over 18m or 7+ storeys:
Accountable Person:
- Must register building with Building Safety Regulator
- Prepare safety case demonstrating building is safe
- Ongoing safety management duties
- Mandatory occurrence reporting
- Resident engagement
Additional requirements:
- Building safety manager
- Golden thread (information management)
- Safety case reviews
- Enhanced inspections
Residents' voice:
- Must engage with residents
- Consider resident concerns
- Resident panels in larger buildings
Enforcement:
- Building Safety Regulator has significant powers
- Compliance notices
- Substantial fines
- Building closure in extreme cases
Lower buildings still covered by FSO
Buildings under 18m:
- Not caught by BSA 2022 higher-risk regime
- Still fully covered by FSO and FSA 2021
- Same flat entrance door duties
- Fire risk assessment required
- Fire and Rescue Authority enforcement continues
Costs and budgeting
Typical fire safety costs for blocks of flats
Initial assessments:
- Fire risk assessment (small block): £500-£1,500
- Fire risk assessment (large block): £1,500-£5,000+
- Flat entrance door survey: £50-150 per flat
- External wall assessment: £5,000-£25,000+
Equipment and installation:
- Fire alarm system (small block): £3,000-£8,000
- Fire alarm system (large block): £8,000-£30,000+
- Emergency lighting (per floor): £1,500-£4,000
- Flat entrance door replacement: £250-450 per door plus installation
Annual ongoing costs:
- Fire alarm servicing: £400-£1,500/year
- Emergency lighting servicing: £200-£800/year
- Fire risk assessment review: £300-£1,000/year
- Flat entrance door inspections: £50-100/door
- Fire door maintenance: £200-£1,000/year
Service charges:
- Must recover costs through service charges
- Need to consult leaseholders on major works
- Fire safety compliance not optional
- Leaseholders may challenge costs
Budget proactively for fire safety. Regular maintenance and inspections are far cheaper than reactive remediation after enforcement action. Include fire safety as a line item in annual budgets. Expect £50-150 per flat per year for routine maintenance, plus capital expenses for equipment replacement and upgrades.
Enforcement and penalties
Fire and Rescue Authority enforcement
Inspection frequency:
- Post-Grenfell, residential blocks are priority for inspection
- Expect inspections, especially for blocks over 4 storeys
- Unannounced visits possible
Common issues found:
- Non-compliant flat entrance doors
- No flat entrance door inspection regime
- Inadequate fire risk assessment
- Poor maintenance of common area fire safety equipment
- Residents propping fire doors open
- Obstructed escape routes
Enforcement escalation:
- Informal advice and letters
- Alterations Notice
- Enforcement Notice (with legal timescales)
- Prohibition Notice (immediate closure if serious risk)
- Prosecution
Penalties
Fire Safety Order breaches:
- Unlimited fines on conviction
- Imprisonment up to 2 years for serious breaches
- Personal liability for landlords, directors, managing agents
Recent examples:
- £75,000 fine for housing association (flat entrance doors)
- £120,000 fine for landlord (multiple breaches in block of flats)
- £45,000 fine for managing agent (failure to implement fire risk assessment)
Building Safety Act breaches (higher-risk buildings):
- Substantial civil penalties
- Criminal sanctions for serious breaches
- Building closure powers
Frequently asked questions
Yes, explicitly since the Fire Safety Act 2021. Landlords must ensure all flat entrance doors provide adequate fire resistance (minimum FD30, FD30s preferred). This includes ensuring self-closing devices work, seals are intact, and gaps are within tolerance. Annual checks are required from January 2023. This duty cannot be delegated to tenants.
Stay put is an evacuation strategy where residents remain in their flats unless fire is in their flat or they're told to evacuate by fire service. It relies on good compartmentation containing fire to the flat of origin. Post-Grenfell, stay put policies are under scrutiny. They're only safe if compartmentation is excellent, flat entrance doors are compliant, and external walls won't allow fire spread. Your fire risk assessment should explicitly justify your evacuation strategy.
Yes. The Fire Safety (England) Regulations 2022 require annual checks of flat entrance doors starting January 2023. You must check door closes properly, self-closer works, no visible damage, seals intact, and gaps reasonable. Keep records. This is in addition to ensuring doors meet FD30/FD30s specification.
The landlord. Fire safety is the landlord's legal duty. While costs can ultimately be recovered through service charges (subject to lease terms and consultation requirements), the landlord must arrange and initially fund replacements. You cannot expect tenants to pay directly for fire safety compliance.
If tenants replaced doors without permission, the landlord is still responsible for ensuring the replacement doors meet fire safety standards. You may have grounds to require tenant to reinstate compliant door or recover costs, but you cannot leave a non-compliant door in place. Your priority must be life safety and legal compliance.
At least annually, or more frequently if significant changes occur (major refurbishment, cladding works, change in resident demographics), after near-misses or incidents, or when new legislation is enacted. Post-Grenfell, fire risk assessments for blocks of flats are under particular scrutiny. Use a competent assessor with experience in residential buildings.
The Building Safety Act 2022 applies to higher-risk residential buildings (over 18m or 7+ storeys). It creates an Accountable Person role, requires registration with Building Safety Regulator, and mandates safety cases. If your building is under 18m, BSA doesn't apply, but you're still fully covered by Fire Safety Order and Fire Safety Act 2021.
Fire Safety Order breaches carry unlimited fines and up to 2 years imprisonment. Recent fines for landlords of blocks include £75,000 for non-compliant flat entrance doors, £120,000 for multiple breaches. In addition to fines, fire authorities can issue Prohibition Notices immediately closing buildings, and you face civil liability if non-compliance contributes to injury or death. Post-Grenfell, enforcement is a priority.
Next steps
Understand specific fire door requirements:
Review your fire risk assessment duties:
What is a fire risk assessment? →
Understand the legal framework:
Managing a block of flats and concerned about fire safety compliance? A specialist fire risk assessor with experience in residential buildings can assess your building, check flat entrance door compliance, advise on post-Grenfell requirements, and help you develop a compliance action plan.
Related articles:
- Fire door requirements
- Fire doors explained
- What is a fire risk assessment?
- Fire Safety Order explained
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