AnthonyB

How far back do you want to go? At least 26 years, I'd need to do out my 1988 & 1980 copies of BS5839-1 to check earlier

I use the old school plastic rectangles that have a mirror to check for top edge labels and seals - I'm not doing the PPM of the doors, just an indicative check for FRA purposes, so it doesn't need to be calibrated to the nearest micrometre. However if carrying out a full formal inspection of a door set I'd expect the examiner to use something more accurate & calibrated

Many of the fatalities at Grenfell were due to their flats doors not closing, allowing the central stair & landings (remote from and not directly affected by the cladding) to be rapidly filled with heat, smoke & toxic gases from the flats being consumed by fire. This why working self closers are the most important issue in flat front doors (& why in some blocks older standard doors are acceptable as long as the closers are suitable). Common sense goes out of the window in a fire and if none of the 239 people in the Tower remembered to shut their door behind them when escaping you can bet no one in your block will. The common sense attitude only works until it doesn't - with a fire being a reason for it not working. RP is being lazy and the flats probably need Air Conditioning instead.

Flat internal doorways (other than toilet/bathroom) have to be fire doors (FD30 and in the old days FD20 when such doors existed) even as single private dwellings, they just do not need self closers. P50 extinguishers are not maintenance free, that's sales talk - they require annual maintenance, but rather than using an extinguisher service company the owner of the equipment can complete it themselves - https://www.britannia-fire.co.uk/wp-content/uploads/2025/05/How-to-maintain-the-P50-.pdf

You need to elevate this to a First Tier Tribunal as it sounds excessive and not justifiable. Your FRA and F Door Inspection seem to side with you as does the official Government Guidance. If this isn't enough to overturn the s20 replacement you may need a report detailing what compliant repairs in line with the FRA are viable, but this cost is dwarfed by the amount you will all have to pay. Leaseholders can and do win Fire Safety FTTs, I have been involved in these before, it's worth a try. The agent will benefit from a full replacement through the s20 management fee process so they are bound to prefer it- after all its not their money!

If it's provided in a premises to which the FSO applies the law clearly states in Article 17 it must be subject to a system of maintenance. If it doesn't apply because its now a private dwelling again it doesn't but from a liability point of view it might be wise to dump it other than the fire blanket

In theory as long as you return it to the original condition as single dwellings with the fire doors as originally required (especially the front doors if to internal common parts) and have the correct minimum type and grade of automatic fire detection for the part of the UK your flat is in then, as they are outside the FSO and only under the Housing Act and subsidiary legislation (such the various UK countries' rental smoke alarm regulations) as you are not making it worse than the original Building Regs approval

I'd agree with the above - are you being asked for one by someone (e..g insurers?)

Because they don't understand the law. There is no such thing in law as a pre-occupancy FRA, this matter is controlled by Building Regulations separate fire safety requirements. However it is true that Building Regulations only cover a small part of the fire safety regime required for an occupied building and if the Responsible Person does not have the knowledge or competency as to the management of a building (training, maintenance, policy & procedures etc) and the aspects not covered by Building Regulations (signage, extinguishers, etc) then they need guidance and steering. From this the lucrative pre-occupancy FRA is born. You can't do a proper FRA on an empty building & it becomes worthless the moment the first people, furniture & equipment are moved in, so you need to quickly do it again. General consultancy & a pre-occupation checklist achieves the same thing (& would cost less) but instead an FRA is being requested as a quasi 'certificate of occupancy' which it isn't intended to be.

That's poor - whilst it's not legally mandated (other than in Scotland) it's accepted that it is appropriate as one of the findings of the inquiry into the Rosepark Care Home fire in 2011 where 14 people died was that the lack of ARC monitoring and reliance on staff raising the alarm in part contributed to the deaths and that ARC monitoring should be provided. Any decent FRA would as a minimum suggest that such monitoring be fitted even if not a high priority rating in the report. To not even mention it is unwise and shows a lack of consideration of sector specific technical progress.

Absolutely unreasonable and not anywhere in guidance - if this were true every terrace of houses in the country would have to have a fire door as it's front door

For fire safety they are only required where doors on escape routes sub-divide corridors, or where any doors are hung to swing both ways, others will have been likely fitted under Approved Document M for general accessibility.

If it's a stay put block it wouldn't have the communal call points and smoke alarms (in fact Building Regs & Fire Safety guidance says it absolutely should not) and would have smoke control (or at least openable windows to the stairs). Where is it? If it is in Wales the sprinklers are mandatory regardless of the evac strategy, if England they could be compensation for a departure from the normal guidance which may be pertinent to your problem. I can see how the assessor got mixed up - your current set up, using standard benchmarks, is incorrect for both stay put & full evacuate. The build is modern enough for it to be a legal requirement for the fire strategy & fire safety information relating to the design to be handed over on completion to the freeholder/owner/RMC who has a legal duty to maintain that information and pass it over if they sell the premises - this would answer the questions about the design. If the flat detection is linked to the common detection then you are set up correctly for an evac policy as it is with no changes. Fire doors do not need closers other than to the flat entrance doors where no relaxation exists in any build guidance. If the electrical board is made with a non combustible housing (metal) then it can be argued no further enclosure is necessary (opinion is sometimes divided on this). The Emergency Lighting has to be tested and the test switches make this easier - it's a sign of a poor build that they are not there as they are pretty standard and should have been there from new! Building Regs sign off is no guarantee of full compliance with the Regulations, nor of the fire safety legislation that takes force on completion - plenty of modern builds have been found to be defective despite this, sometimes with total loss fires or fatalities as a result. Building Control have no liability and it rests instead with the developer. If your FRA did not attempt to access at least a proportion of flats to examine the front door fully (both sides, top & closing) and see if the common alarm extends inside it is not compliant with current Government guidance for a suitable & sufficient FRA (as part of this, if readily accessible the roof void should also have been accessed) so you haven't had what you paid for. Housing is far more specialist than many assessors assume and this is an example of a site where a careful eye is needed! I can't give you a more definitive answer without seeing the site, remote advice can only go so far!

The correct guidance for supported living is on here: https://nfcc.org.uk/our-services/building-safety/protection-building-safety/specialised-housing/

I suggest you take the Government Guidance as evidence and take the matter to a First Tier Tribunal for review as an excessive and unjustifiable requirement, also you need to get a copy of the block Fire Risk Assessment which, if competent, should detail the grade of fire doors required and if notional doors (those to the standard at the time of installation) are acceptable, which unless there is something really left field with your block it should. Too many 'zero to hero' poorly trained door assessors are out there chasing volume inspection work or remedial/replacement work with minimal knowledge and can't handle anything more complex than a brand new door to brand new standards. I've advised countless leaseholders on this and given evidence for FTT's as this is not an isolated issue!