Hi,

It's my first post here but I've been a long time reader - I wonder if somebody could clarify a matter for me.

On one of the sites I'm involved in, there are numerous nominal fire doors which are deemed semi-critical to the fire strategy of the building (I say semi because of the other measures in the building which have improved MoE and early detection and warning (e..g over L3).

These are clearly very old existing doors built way before BS 476 and 8214. They do not have any certification labels or plugs to confirm they have been tested for fire resistance in a furance. They are all 44mm thick and the majority do not have any intumescent seals or grooves to support seals. The majority of the door gaps between the vertical edges and frames are less than 4mm, most are less than 1mm (the areas where these are is deemed acceptable in the FRA as the risk of the door warping and binding on the frame in the event of a fire arguably would have little effect on life safety, as in these cases somebody would have made their escape from such a plant room way before the fire would have been able to affect the doors in such a way. Some doors also have Georgian wired glass which appears to have installed with glazy putty only and no intumescent sealant/seals between the beading and glass.

In their professional assessment (as a technical engineer and experience in FM), the doors in the majority of cases would be satisfactory as nominal FD30 (s) doors, even without the intumescent seals. On some of these intumescent seals are being retrofitted where the door gap is closer to 4mm than 2mm, especially where adjacent to critical escape routes. Certain other remedial works are being implemented where the doors should provide protection against cold smoke (i.e. retrofit of batwing seals / additional of drop down seals where the threshold gap is > 3mm and threshold strips can't be added due to flooring types, trip hazards etc).

However, I want to clarify what judgement the Responsible Person (or whoever is delegated in its stead) is able to do with respect to nominal fire doors. The FRA is being conducted in house and the individual is more than competent. If they are able to suitably determine such a door would likely perform its function as an FD30 door (assessing thickness, frame gaps, penetrations, assessment of non-compliant remedial works (i.e. against accepted good industry practice), closing devices, presence of intumescent material for ironmongery, fire-rated ironmongery etc), in the same way that a fire door inspection would do, is there a need for them to engage external services? They are not officially 3rd party certified by BM Trada or FDIS, or similar. Obviously nominal fire doors should be assessed by a competent individual who is able to assess their suitability for the intended fire compartmentation function - my question basically is what determines competence.

The previous organisational mismanagement of fire safety affairs and the building in general means there is no paperwork to support the doors were ever formally assessed to be nominal FD30 doors. There is neither any evidence of a previous FRA conducted on the site. Since acquisition of the site, there has been a lot of work to establish levels of compartmentation and risk assess and generally improve the fire safety profile of the building - does there need to be any 3rd party appraisal if they can manage this in house and have the technical knowledge? Obviously an FRA can be done in house as liability falls on the Responsible Person (organisation), the question is whether granular assessments such as fire door "compliance" can, and would stand up to scrutiny in court if anything untoward was to happen.

Sorry for the long-winded message, hopefully somebody can help and provide some clarity on the technical legalities of their approach.

Under the Regulatory Reform (Fire Safety) Order 2005 the Responsible Person must carry out a suitable and sufficient Fire Risk Assessment. They must keep relevant persons safe by managing fire safety risks and implement preventative and protective measures. Under Article 18 of the RR(FS)O the Responsible Person should engage one or more Competent Persons to assist them in their duties as necessary. The RR(FS)O describes the Competent Person as somebody that has sufficient training and experience or knowledge and other quailities to be able to properly assist in undertaking proctective and preventive measures.

Where an employee and where an owner or employer has sufficient competence they may carry out the Fire Risk Assessment to the extent that they have the necessary competence. The fire doors should be part of that fire risk assessment and the person assessing them should be able to show they have the necessary competence, but that does not necessarilly mean they must have specific qualifications relating to fire doors. https://www.legislation.gov.uk/uksi/2005/1541/article/18

Given the age of the doors, lack of certification, and no historical FRA paperwork, I’d personally commission a full independent FRA. While the Responsible Person can assess nominal doors in‑house if they have demonstrable competence , the judgement involved here — thickness, gaps, glazing, ironmongery, smoke control, and the absence of test evidence — is exactly the kind of thing that could be challenged later . An external assessor gives you a defensible baseline and removes any doubt about competence under Article 18 .

Thank you very much both, I agree with the advice to engage the services of an external FRA.

With respect to judging doors to be nominal fire doors based on thickness alone, should this be done by an FDIS or similar approved inspector or would it likely be a sufficiently defensible position for the client if the risk assessor clearly shows they have the knowledge / competence to assess fire doors (e.g. through a baseline portfolio of other sites)?

Just to be clear, I'm not referring to the impact of nominal fire doors (unknown / possibly reduced fire resistance) on the wider fire strategy and risk assessment recommendations but on judging whether a nominal fire door without any certification can be judged to e.g. provide an FD30 resistance (or recommend necessary upgrades - I assume best practice would dictate any subsequent remedial work be undertaken by a third party certified company?).

It is not possible to assess a door as a Nominal Fire Door by thickness alone.

If the Fire Risk Assessor or indeed the RP has a good knowledge of fire doors, timber doors and joinery, they may well be competent to assess timber-based fire doors and make appropriate decisions about them. Clearly, the more knowledge and experience they have - the better outcome you would expect.

When choosing fire door installers, maintenance & repairs contractors and inspectors etc you should always carry out due diligence about their credentials before engaging them. Membership of a Third Party Certification scheme could be a sign of competence but is no guarantee.

Sorry if I was unclear, I didn't mean by thickness alone. I meant in conjunction with assessing the other factors (door material, density and type - solid, tubular cored etc, frame-door gaps, intumescent material around ironmongery, fire-rated ironmongery, presence of seals etc). As far as I'm aware and happy to be corrected, the industry practice for noting a solid core timber door, assuming the other factors comply with what is expected of industry good practice (e.g. gaps 2-4mm, <10mm for a threshold fire resistant only door and <3mm for a fire and smoke resistant door) is that it should generally be a minimum of 44mm thick for an FD30 door and 54mm for an FD60. Obviously the person conducting the FRA will have to take a view on the absence of rebated/surface intumescent seals between the frame and door and subsequent effect on performance.

Thanks Neil, that has provided some clarity to me as exactly how you demonstrate competence has always seemed wishy-washy coming from a sector which is more rule-based. Some claim third party certification is an absolute must but in my field, some companies or individuals who show the badge can't unfortunately demonstrate the deep-level holistic understanding of principles and it makes it feel like gaining the certification was just a tick box exercise.

The most recent government guidance on fire door inspections comes from 8th August 2025 pertaining to Regulation 10 of the Fire Safety (England) Regulations 2022.

Fire Safety (England) Regulations 2022: fire door guidance (accessible) - GOV.UK

You can see that paragraph 6.3 says "The checks under regulation 10 should be simple and basic. You should not need to engage a specialist to carry these out"

In terms of the door standards for old doors (it sounds like your doors pre-date the CP3 standards?), I always use the LGA guidance as a basis. I know the LGA guidance was written primarily for CP3 fire doors, but I find it useful nonetheless. If the door is solid and close to 44mm then it's almost certainly capable of resisting fire for 30 mins, the old doors are often better than the modern certified ones. I would insist on either a 25mm rebate or upgrading to intumescent strips and smoke seals. The door should form a good seal with the rebate and have acceptable gaps around, A good door closer is essential (never accept the rising butt hinges). I also tend to accept doors with Georgian wired glass, which will not have been installed with intumescent seals, putty etc.