Who Is Responsible for Fire Door Inspections? The Responsible Person Explained

When regulation 10 of the Fire Safety (England) Regulations 2022 says fire doors must be inspected quarterly and annually, it places that duty on the "Responsible Person." It doesn't say who that is by name. For managing agents, this creates a practical question: is it the freeholder, the managing agent, the RMC, or the building manager? And who actually carries out the inspections?

The answer depends on your management structure — and getting it wrong doesn't remove the duty. It just means nobody is doing it.

What the Law Says

The concept of the Responsible Person comes from the Regulatory Reform (Fire Safety) Order 2005 (the Fire Safety Order), which regulation 10 builds on. Under Article 3 of the Fire Safety Order, the Responsible Person is:

• The employer, if the workplace is to any extent under their control
• For any other premises, the person who has control of the premises in connection with carrying on a trade, business, or undertaking
• For any premises not covered above, the owner

For residential buildings with common parts, this typically means whoever has control of the common areas — the parts of the building where the fire safety duties apply.

Who Is the Responsible Person in Practice?

In the residential property management chain, several parties might be the Responsible Person. Here's how it works in the most common management structures:

Freeholder-managed buildings

The freeholder is the Responsible Person. They own the building, control the common parts, and hold the fire safety duties. If the freeholder manages the building directly (no managing agent appointed), regulation 10 fire door duties fall squarely on them.

Managing agent appointed by the freeholder

The managing agent is typically acting as the Responsible Person for the common parts, either explicitly through the management agreement or implicitly through taking on day-to-day control of fire safety in the building. Most management agreements include fire safety compliance within the managing agent's scope of services.

Critical point: the managing agent doesn't automatically become the Responsible Person just by being appointed. The management agreement needs to include fire safety duties — or the managing agent needs to have assumed control of fire safety in practice. If your management agreement is silent on fire safety, clarify it in writing. An ambiguous arrangement where neither party thinks they're responsible is the worst possible outcome.

Right to Manage (RTM) company

The RTM company is the Responsible Person once the right to manage has been acquired. The Commonhold and Leasehold Reform Act 2002 transfers management functions to the RTM company, including responsibility for common parts fire safety.

If the RTM company appoints a managing agent, the same considerations apply as above — the managing agent acts on behalf of the RTM company, but the underlying legal duty sits with the RTM company.

Resident Management Company (RMC)

The RMC is typically the Responsible Person if the lease structure gives the RMC control of the common parts and building management. Many blocks are structured this way — the freeholder owns the freehold, but the RMC (owned by the leaseholders) manages the building.

If the RMC appoints a managing agent, the agent acts for the RMC. The RMC retains the legal responsibility.

Can the Responsible Person Delegate Inspections?

Yes — and in practice, they almost always do. The government guidance on regulation 10 explicitly says the quarterly checks "should be simple and basic" and that "caretakers, managing agents, housing officers and maintenance personnel should be able to do them as the checks are only visual."

The Responsible Person doesn't need to personally inspect every fire door. They need to ensure inspections happen, are done competently, and are properly recorded.

Who can carry out the inspections:

• Caretakers and building managers — the most common approach for quarterly communal inspections. They're on-site, familiar with the building, and can inspect as part of their regular duties. They need appropriate instruction on what to check and how to record findings.
• Managing agent staff — portfolio managers or surveyors conducting inspections during site visits. Practical for small portfolios, less practical at scale.
• Fire door inspection contractors — specialists who inspect and report. More thorough, but more expensive. Often used for the initial baseline inspection or annual cycles.
• General fire safety contractors — some fire risk assessment companies offer fire door inspections as an add-on service.

What delegation requires:

1. Competence — the person inspecting needs to know what they're looking for. The government guidance says "appropriate instruction" is sufficient for non-specialists. This means training on the visual checks (seals, gaps, hinges, closer operation, signage, glazing) and what constitutes a pass or fail.

2. A consistent method — the inspector needs a defined checklist to follow. Without one, inspections become subjective and inconsistent.

3. Recording and reporting — the inspector needs to record findings per door and report defects to whoever manages remediation. The record is the compliance evidence.

4. Accountability — the Responsible Person remains accountable even when someone else does the physical inspection. If the caretaker misses a defect that causes harm, the question will be: did the Responsible Person ensure the caretaker was competent, was using the right method, and was properly supervised?

Generate a standardised checklist for your inspectors →

The Responsible Person's Ongoing Duties

Beyond arranging inspections, the Responsible Person's fire door duties under regulation 10 include:

Providing information to residents:

• Tell residents that fire doors should be kept shut when not in use
• Tell residents not to tamper with self-closing devices
• Tell residents to report damage to fire doors
• Provide this information to all residents at least annually, and to new residents when they move in

Maintaining fire doors: Article 17 of the Fire Safety Order requires a "suitable system of maintenance." This goes beyond just inspecting — the Responsible Person needs a system for ongoing upkeep, not just reactive repairs. Regulators check for a documented maintenance approach, not just inspection records.

Remediation: When inspections find defects, the Responsible Person must ensure they're prioritised and fixed. A quarterly inspection that identifies critical defects, with no action taken before the next quarterly inspection, is a compliance failure — even if the inspections themselves are being done on time.

Record keeping: The regulations don't prescribe a specific record format, but the Responsible Person needs to demonstrate that inspections happened and defects were addressed. Records need to be retrievable — a regulator or insurer asking to see your fire door inspection records shouldn't have to wait while you search through emails and shared drives.

For the full breakdown of what regulators check, see our compliance and enforcement guide.

Multiple Responsible Persons in One Building

In some buildings, there's more than one Responsible Person. The Fire Safety Order anticipates this — Article 22 requires multiple Responsible Persons in the same building to cooperate and coordinate their fire safety measures.

Common scenarios:

Mixed-use buildings — a residential block with commercial units on the ground floor. The managing agent may be Responsible Person for the residential common parts, while the commercial tenant (or their landlord) is Responsible Person for the commercial areas. Fire doors between the two areas need coordinated inspection.

Shared access routes — where an escape route passes through areas controlled by different parties, both Responsible Persons have duties in relation to fire doors along that route.

Sub-contracted management — a managing agent who sub-contracts building management to a site management company. Both may have Responsible Person duties depending on the contractual arrangement and practical control.

The practical advice: document who is responsible for which fire doors. A door that falls between two parties' responsibilities is a door that nobody inspects.

Common Mistakes

Assuming the freeholder handles it — many managing agents assume fire door compliance is the freeholder's problem. If the management agreement gives the managing agent control of common parts fire safety (most do), the duty is on the managing agent.

No written delegation — asking the caretaker to "keep an eye on the fire doors" without providing a checklist, training, or defined inspection schedule. This doesn't constitute a compliant inspection regime, and it leaves the caretaker with no clear standard.

Inspecting without a remediation process — conducting quarterly inspections and filing reports, but with no system for tracking defects through to completion. The inspection without remediation creates a documented record of things you knew were wrong and didn't fix — which is worse than not inspecting at all from an enforcement perspective.

Confusing the duty holder with the duty doer — the Responsible Person holds the duty. They can delegate the doing. They can't delegate the responsibility. If something goes wrong, "I told the caretaker to do it" is not a defence unless you also ensured the caretaker was competent, equipped, and supervised.

For a step-by-step guide to conducting fire door inspections as a non-specialist, see our practical guide to checking fire doors.

Getting It Right

The Responsible Person question is ultimately about accountability. Someone needs to own the fire door inspection cycle for each building — scheduling, conducting, recording, remediating, and evidencing. Whether that's the freeholder, managing agent, RMC, or RTM company depends on the management structure. But the worst answer is "we're not sure."

Three things to clarify:

1. Who is the Responsible Person for each building in your portfolio? Document it.
2. Who physically conducts inspections? Ensure they're instructed, equipped with a checklist, and know how to report defects.
3. Who manages remediation? Ensure there's a clear path from "defect found" to "defect fixed and evidenced."

Check your regulation 10 obligations per building →

FireDoorReady is being built to give managing agents a single system for managing fire door compliance across their portfolio — scheduling inspections, delegating to on-site staff, tracking defects through remediation, and maintaining the evidence trail the Responsible Person needs. Join the waitlist →

This guidance applies to England. Scotland, Wales, and Northern Ireland have separate fire safety legislation and different definitions of duty holders.

This article is general guidance, not legal advice. Consult a fire safety professional or legal adviser for advice specific to your buildings and management arrangements.

Sources

• Fire Safety (England) Regulations 2022, regulation 10 — legislation.gov.uk
• Regulatory Reform (Fire Safety) Order 2005 — legislation.gov.uk
• Regulatory Reform (Fire Safety) Order 2005, Article 3 — Meaning of "responsible person" — legislation.gov.uk
• Regulatory Reform (Fire Safety) Order 2005, Article 22 — Co-operation and co-ordination — legislation.gov.uk
• Regulatory Reform (Fire Safety) Order 2005, Article 17 — Maintenance — legislation.gov.uk
• Fire Safety (England) Regulations 2022: fire door guidance — GOV.UK
• Commonhold and Leasehold Reform Act 2002, section 96 — legislation.gov.uk