Fire doors, fire stopping and compartmentation: understanding the responsibilities of the Responsible Person, inspectors and specialist contractors

This article provides general information on how responsibility for passive fire protection is normally structured in England. It is not legal advice. Every building is different, so building owners and managers should seek advice from a qualified fire risk assessor or solicitor for their specific circumstances.

Passive Fire Protection Is a Chain, Not a Single Certificate

Passive fire protection works as a chain of responsibility rather than a single handover point.

A building manager appoints a fire door inspector, receives a report, appoints a contractor and receives a completion certificate. It's a reasonable assumption that responsibility has now moved on to the specialist. In practice, the legislation is structured a little differently.

In a block of flats, the Responsible Person generally holds legal responsibility for managing fire safety in the common parts. Depending on the building, that could be the freeholder, landlord, management company, Right to Manage company or housing association. A managing agent or specialist contractor can carry out duties on the Responsible Person's behalf, but appointing someone else does not, by itself, remove the Responsible Person's underlying duties.

Who Is the Responsible Person for Fire Doors and Fire Protection?

Under the Regulatory Reform (Fire Safety) Order 2005, as amended, responsibility generally follows control of the premises.

For residential blocks, this typically covers the common parts, the building structure, external walls and flat entrance doors, insofar as the Fire Safety Order applies. The Fire Safety Act 2021 clarified this further, confirming that the Order extends to the structure and external walls of buildings containing two or more domestic premises, including doors and windows within those external walls.

The September 2026 government guidance for residents confirms that the Responsible Person must assess relevant fire risks, put appropriate fire precautions in place, take action to control identified risks and maintain records.

The key point for anyone managing a building is this: appointing a fire door company does not mean the work of managing fire safety is finished. The Responsible Person still needs to appoint competent people, act on what those people advise them and continue managing the building afterwards.

Does a Fire Door Inspector Take On Responsibility Once They Inspect?

This is where a lot of confusion sets in, and it's worth being precise about it.

An inspector is generally responsible for the professional service they've been instructed to carry out. If a competent fire door inspector is asked to assess 300 flat entrance doors, they should carry out that inspection accurately, record what they find, flag relevant defects, explain any limitations and produce a report that fairly reflects what was seen.

What an inspector does not normally do is take over responsibility for managing the building simply because they produced a report. The Responsible Person still needs to review the findings, decide on an appropriate response and arrange the necessary remedial work or fire door installation.

Government guidance draws this distinction clearly for fire doors: the Responsible Person must have arrangements in place to act on issues found during checks, and where repair or replacement is needed, this should be carried out by a competent contractor as soon as reasonably practicable.

Not Every Fire Door Check Is the Same

A routine Regulation 10 check is not the same thing as a detailed specialist fire door inspection.

In buildings with a storey more than 11 metres above ground level, the Responsible Person must use best endeavours to carry out annual checks of flat entrance doors and quarterly checks of communal fire doors. Government guidance describes these as relatively simple visual checks that shouldn't normally need a specialist.

That's quite different from a detailed condition or compliance inspection, which is intended to establish the construction, condition, suitability, defects and remedial needs of an existing fire door assembly. Clients regularly conflate a "Regulation 10 check" with a "full fire door inspection." They serve different purposes and shouldn't be treated as interchangeable when planning fire protection services for a building.

Wondering what a proper condition survey should actually include? Read our guide by Head of Fire Door Operations, Michal Burski: Comprehensive Guide to Fire Door Inspection Reports: What Should You Actually Receive?

What Responsibility Does a Fire Stopping or Fire Door Contractor Actually Carry?

A specialist contractor does carry responsibility, generally for the work that falls within their own scope and control.

Article 5 of the Fire Safety Order is relevant here. Duties can extend beyond the Responsible Person to another party with control of the premises, but only to the extent of that control, and the Order also recognises situations where a contract or tenancy hands maintenance, repair or safety responsibility to someone else.

In practice, this means a specialist contractor can't reasonably say they carry no responsibility because the client is the Responsible Person, and equally, a client can't reasonably say they carry no responsibility because a contractor certified the works. Both positions oversimplify how the duties actually sit.

For building work in England, the Building Regulations dutyholder regime adds a further layer, placing direct duties on those carrying out the work. Since October 2023, contractors have needed to plan, manage and monitor building work so that it complies with the relevant requirements, and the people doing the work must have appropriate competence.

For a deeper look into how product testing standards are evolving across the UK, read our overview on Navigating the BS 476 to BS EN 13501 Transition: What It Means for Your Fire Protection.

Does Responsibility Transfer to the Contractor Once Remedial Works Are Complete?

Not completely, and this is probably the question most building managers actually want answered.

Completing remedial works does not generally transfer the overall statutory responsibility for fire safety away from the Responsible Person. A contractor should take responsibility for the work they've actually completed, which includes using suitable products and systems, working within tested or assessed applications, following the relevant installation requirements, keeping accurate records and providing appropriate certification.

The Responsible Person remains responsible for managing the building as a whole, maintaining the fire precautions in place, responding to future deterioration or alterations and making sure the overall fire safety arrangements stay appropriate over time.

For higher-risk residential buildings, this is even more clearly defined. Government guidance confirms that Accountable Persons and the Principal Accountable Person can employ others to carry out duties on their behalf, but cannot delegate their own legal accountability for building safety.

Why Third-Party Certification Matters for Passive Fire Protection

Third-party certification isn't a legal requirement on every fire door or fire stopping project, so it's worth being careful with how this is framed. What it does provide is one of the strongest available ways of demonstrating that a specialist contractor works under an independently assessed system of competence and quality control.

That typically includes independent assessment of the company, defined competence requirements for operatives, documented installation procedures, surveillance audits, traceable certification and inspection of completed work.

UK government research describes third-party construction product schemes as voluntary schemes that independently assess safety, quality or performance requirements. Government and HSE guidance make a broader point too: third-party assessment can help demonstrate competence, but certification alone does not remove the need to check whether a contractor is actually competent for the specific project in front of them. For passive fire protection, where hidden defects can go unnoticed for years, that distinction matters more than in most other trades.

What Should You Expect from a Specialist Passive Fire Protection Contractor?

A competent specialist should be able to establish the required fire performance of an element before starting work, rather than simply repairing whatever is visible.

That means understanding what the element is meant to achieve, reviewing the available evidence relating to the existing construction, checking whether a proposed repair is actually supported by test evidence, certification, assessment or manufacturer instructions, and being upfront about when existing construction can't reasonably be verified.

For fire doors, a good contractor should be able to explain what's being retained, what's being replaced, what evidence supports the proposed remedial work and when replacement, rather than continued repair, is the more appropriate option.

For fire stopping, they should understand the supporting construction, the type of penetration, the services running through it, the aperture size, the required fire resistance, orientation and the specific tested system being installed. A tube of fire-rated sealant on its own is not a fire stopping system.

Clients should expect clear records before, during and after any works, normally covering the scope, door or penetration identification, photographs, materials and products used, relevant system references, installation records, any limitations or variations found and completion certification.

Certification Should Show What Was Done, Not Just Say "Compliant"

This is one area where genuinely professional passive fire protection work separates itself from basic maintenance.

A completion certificate should never be treated as a document that automatically makes every existing element compliant. A good contractor will clearly distinguish between existing conditions they could verify, work they actually completed, elements that were outside their scope, areas that could not be accessed, existing components that could not be identified, and any departures that need further investigation, alongside the exact work being certified.

That level of detail protects both the Responsible Person and the contractor, and it builds the traceable information needed for future inspections and ongoing maintenance.

For qualifying building work, Regulation 38 requirements also apply. Fire safety information relating to the design, construction, services, fittings and equipment must be handed over so the Responsible Person can operate and maintain the building safely, and the strengthened post-2023 arrangements require confirmation that this handover has actually taken place.

Who Is Responsible When Defects Are Found But the Work Isn't Completed?

An inspector's responsibility is normally to identify and communicate findings accurately, within the scope they were instructed on.

If a report says a door needs replacing or a compartment breach needs remediation, the inspector does not usually become responsible for physically carrying out that work simply because they identified it. The Responsible Person then needs to weigh up the risk, set priorities and arrange the necessary action.

Where significant defects remain outstanding, they should stay part of the building's ongoing fire safety management rather than disappearing once a survey is filed away. In short: inspection identifies and records the risk, remedial work addresses the defect, and ongoing fire safety management keeps the risk under control. These are related duties, but they are not the same duty.

Higher-Risk Residential Buildings: An Additional Layer of Accountability

Buildings that are at least 18 metres high, or have at least seven storeys and contain two or more residential units, fall within the higher-risk residential building regime.

These buildings have Accountable Persons and a Principal Accountable Person, in addition to the usual Responsible Person duties under fire safety legislation. The Accountable Person or Principal Accountable Person must manage building safety risks connected to fire spread and structural failure, and must maintain the necessary building information.

As set out above, government guidance is explicit that this legal accountability cannot be delegated to a managing agent or contractor, even though those organisations may well carry out the practical work.

The Bottom Line: Responsibility Should Be Traceable

The safest approach to passive fire protection isn't to ask who you can hand responsibility to. It's to ask whether every decision, inspection and completed item of work can be traced back to a competent person, appropriate evidence and a clearly defined scope.

The Responsible Person is responsible for managing fire safety. The assessor or inspector is responsible for providing a competent and accurate assessment within their agreed scope. The designer is responsible for the design they provide. The specialist contractor is responsible for properly carrying out and documenting the work within their control. The certification body provides independent assurance within its own certification scheme. And the Responsible Person remains responsible for making sure the whole system is managed, maintained and acted upon.

That's a far more accurate picture of how passive fire protection should work in practice than the idea that one certificate transfers all responsibility from one party to another.

To explore the Golden Thread of information in detail and learn why digital traceability is defining the future of fire safety, read our recent article by Operations Manager, Jurij Stekolnikov: The Golden Thread: Why Digital Traceability is the Future of Fire Safety.

Frequently Asked Questions

If we appoint a fire door company, does that remove our responsibility?

No. Appointing a competent contractor is part of managing fire safety properly, but the Responsible Person retains overall legal responsibility for the building.

Is a Regulation 10 fire door check the same as a full fire door inspection?

No. A Regulation 10 check is a routine visual check. A full inspection is a more detailed assessment of construction, condition and remedial needs, usually carried out by a specialist.

Does a completion certificate mean everything is now compliant?

Not automatically. A good certificate should state clearly what was inspected, what was completed, what was outside scope and what still needs attention, rather than simply stating "compliant."

Do higher-risk buildings have different responsibility rules?

Yes. Buildings at least 18 metres high, or with at least seven storeys and two or more residential units, also have Accountable Persons and a Principal Accountable Person, whose legal accountability cannot be delegated.

Speak to a Specialist in Passive Fire Protection

Understanding who is responsible for what is only half the job. The other half is making sure your fire doors, fire stopping and compartmentation are actually assessed, documented and maintained by people who can evidence their competence.

Contact Crown Fire Systems today. Whether you need an urgent passive fire protection assessment, expert fire stopping remediations or compliant fire doors across London and the Home Counties, our team is ready to help you build a clear, traceable record of compliance and keep your building safe.

About the Author: Michal Burski is the Head of Fire Door Operations with over 12 years of industry experience, specialising in multi-tier delivery oversight, estimating and compliance-driven contracts for commercial passive fire safety.