Common Fire Safety Pitfalls: Fire Doors, Lithium Batteries, and Ongoing Compliance

Even well-intentioned responsible persons fall into predictable traps when it comes to fire safety. Some are long-standing issues that predate recent legislation; others are emerging risks driven by changing technology and working patterns. Here are the most common pitfalls we see in the field -- and practical advice on how to avoid them.

Fire Doors: The Most Misunderstood Element of Fire Safety

Fire doors are arguably the single most scrutinised -- and most mismanaged -- element of passive fire protection in UK buildings. Recent legislative changes, particularly the Fire Safety (England) Regulations 2022, have placed renewed emphasis on fire door compliance, especially in domestic properties. Yet misunderstanding persists at every level.

#### The Legal Position

Under the Fire Safety (England) Regulations, all entrance doors to individual flats that open onto a communal escape route must provide at least 30 minutes of fire integrity. The regulations also require responsible persons to carry out inspections of these doors, either in-house (if they have the competence to do so) or by employing someone with the appropriate skills. Regulation 10 is clear: if you do not have the skills to inspect fire doors yourself, you must appoint someone who does.

A competent fire risk assessor should be identifying fire door issues as part of the fire risk assessment. They should hold qualifications in fire door inspection and be able to assess:

- Door thickness and construction -- Is it a certified FD30 or FD60 door, or a nominal door that provides equivalent protection?
- Intumescent strips and smoke seals -- Are they present, intact, and correctly fitted?
- Gap tolerances -- Fire doors have maximum permissible gaps between the door and the frame. Gaps that exceed these tolerances compromise the door's ability to contain fire and smoke.
- Ironmongery -- Hinges, closers, handles, and latches all affect fire performance.
- Overall condition -- Splits, warping, damage, or modifications that compromise integrity.

#### The Costly Mistake: Unnecessary Replacement

One of the most concerning trends in the industry is companies pressuring building owners into wholesale fire door replacement when maintenance or upgrading would suffice. Cases exist where over a hundred doors were condemned and replaced at enormous expense, when in reality the existing doors were structurally sound -- they simply needed new intumescent strips, smoke seals, hinge replacements, and gap adjustments.

Before agreeing to mass door replacement, get a second opinion from a qualified fire risk assessor who has fire door inspection credentials. The savings can be substantial.

#### Nominal Doors in Older and Listed Buildings

Not every door needs to be a factory-certified FD30 fire door. Many older buildings -- particularly Georgian, Regency, and Victorian properties -- have solid timber doors that were never manufactured as fire doors but can provide equivalent performance. A solid teak door at 55mm thickness, for example, may only need smoke seals, gap adjustments, and updated ironmongery to perform to a 30-minute standard.

A specialist can carry out this upgrading work and issue a certificate confirming the door has been brought to the required standard. This approach is particularly important in listed buildings where replacing original doors would conflict with heritage conservation requirements.

#### Ongoing Maintenance Is Non-Negotiable

Fire doors should be inspected by a competent person at least every six months (biannually). Buildings move -- they expand, contract, and settle. A fire door that fits perfectly on installation day may develop excessive gaps within months. In environments like schools, where doors endure heavy use, closers stretch and hinges loosen. All of this is normal wear and tear, but it must be managed through regular inspection and adjustment.

Article 17 of the Fire Safety Order requires the maintenance of fire safety measures. Fire doors are explicitly covered. If your doors are not on a regular inspection and maintenance schedule, you are not meeting your legal obligations.

Lithium Batteries: The Emerging Risk

The rise of e-bikes, e-scooters, and lithium-ion battery devices has introduced a fire risk that barely existed a decade ago. For fire risk assessors, this is now a standard area of concern on virtually every site visit -- both commercial and domestic.

#### The Problem

Lithium-ion batteries are designed for rapid charging. Unlike the older lead-acid batteries that took eight hours to reach full charge, modern lithium batteries charge quickly -- and that is precisely how they should be used. Leaving them on charge overnight, well beyond the point of reaching full capacity, increases the risk of thermal runaway and fire.

The consequences can be devastating. Lithium battery fires are extremely difficult to extinguish, produce toxic fumes, and can escalate with alarming speed.

#### Where We See Issues

The most dangerous scenarios involve lithium battery charging in the wrong locations:

- E-bikes and e-scooters stored and charged in communal escape routes of residential buildings. This is a major compliance issue -- not only does it introduce a severe fire risk to the escape route, it also constitutes an obstruction.
- E-bikes and e-scooters stored next to fire exits in commercial buildings.
- Batteries left on overnight charge in occupied spaces without appropriate fire detection or suppression.

#### Practical Solutions

For residential properties, some landlords and managing agents have invested in external, purpose-built storage sheds positioned at a safe distance from the main building. If a battery fire occurs in a standalone outbuilding, the heat radiation is far less likely to affect the main structure -- it becomes a contained incident rather than a building-wide emergency.

For commercial premises, establish clear policies on:

- Where lithium battery devices can and cannot be stored
- Charging protocols (supervised, time-limited, never overnight)
- Safe distances from combustible materials and escape routes
- Staff awareness and training

Your fire risk assessment should address lithium battery risks explicitly. If it does not, raise this with your assessor at the next review.

Fire Safety Policies: The Document Nobody Has

The Fire Safety (England) Regulations have reinforced the requirement for a fire safety policy -- a document that has long been expected in commercial premises but is now being explicitly asked for in the domestic sector too.

A fire safety policy is distinct from a fire risk assessment. While the assessment identifies risks and recommends actions, the policy sets out how you manage fire safety on an ongoing basis. It should cover:

- Your evacuation strategy (simultaneous, phased, stay-put, or defend-in-place)
- How the fire alarm system works and how it is activated
- Emergency procedures before, during, and after a fire
- Roles and responsibilities for fire safety within your organisation
- Training requirements and frequency
- Maintenance schedules for fire safety systems

When a fire risk assessor arrives on site and asks for a copy of your fire safety policy, a blank stare is not a good start. If you do not have one, your assessor should be able to help you create one -- but do not wait until the assessment to start thinking about it.

The Fire Log Book: Proving Your Compliance

A fire log book is your evidence trail. It demonstrates to the fire risk assessor -- and, more importantly, to the fire and rescue service -- that you are actively managing and maintaining your fire safety systems, not just relying on annual service visits.

Your fire log book should record:

- Weekly fire alarm tests (with date, time, call point tested, and result)
- Monthly emergency lighting checks
- Regular fire door inspections (visual checks, ideally monthly or quarterly in-house, with professional inspection biannually)
- Fire drills (with date, time to evacuate, observations, and lessons learned)
- Fire warden/marshal checks (escape routes clear, extinguishers in place, signage visible)
- Any fire safety incidents or near-misses
- Maintenance visits for alarms, emergency lighting, extinguishers, and other systems

Without a log book, you have no evidence of ongoing compliance. Article 17 of the Fire Safety Order requires maintenance -- but it also implicitly requires you to demonstrate that maintenance has been carried out.

Personal Emergency Evacuation Plans (PEEPs)

The Equality Act requires employers and building managers to make reasonable adjustments for people with disabilities. In fire safety terms, this means having Personal Emergency Evacuation Plans in place for anyone who might need additional support during an evacuation.

PEEPs are not limited to people with permanent disabilities. They should also cover:

- Temporary impairments (a broken leg, post-surgical recovery)
- Pregnancy, particularly in later stages
- Medication side effects that may cause dizziness, nausea, or impaired coordination
- Cognitive or sensory impairments (hearing or visual)

Employees have a duty to inform their employer of any condition that might affect their ability to evacuate. The employer then has a duty to put a plan in place -- which might include assigning a buddy, identifying an alternative escape route, or positioning an evacuation chair.

Speaking of evacuation chairs: they must be maintained. An evacuation chair that has sat on a wall bracket for ten years without inspection may be seized, corroded, or otherwise unfit for purpose when you actually need it. Article 17 applies here too.

Beyond PEEPs, you should also have in place:

- A FEEP (Fire Emergency Evacuation Plan) covering your overall evacuation procedures
- A BEEP (Building Emergency Evacuation Plan) covering non-fire emergencies such as bomb threats, gas leaks, or structural concerns

The Consequences of Non-Compliance

This is not about fear-mongering. It is about understanding the legal framework you operate within.

The fire and rescue service can inspect your premises without prior notice. When they do, they will review your fire risk assessment and check whether you have acted on its findings. If they find the assessment itself to be inadequate or insufficient -- for example, if it fails to identify primary risks -- they will require you to commission a new one.

If they find that you have a sound assessment but have not acted on its recommendations, the consequences escalate:

- Informal advice for minor issues
- Formal notification requiring specific actions within a set timeframe
- Enforcement notices under Article 30 of the Fire Safety Order
- Prohibition notices under Article 31 -- which can restrict or prevent the use of premises until works are completed
- Prosecution -- with unlimited fines and, in the most serious cases, custodial sentences of up to seven years

The fines are no longer capped. The courts assess penalties based on the severity of the risk, the culpability of the responsible person, and the financial means of the organisation.

Moving From Reactive to Proactive

The UK fire safety sector has historically been reactive. Major incidents drive legislative change, which then drives compliance activity. The pattern is familiar and unfortunate.

But as a responsible person, you have the opportunity to be proactive. A thorough fire risk assessment carried out by a competent assessor, combined with a robust fire safety policy, a well-maintained fire log book, up-to-date training, and a genuine commitment to acting on recommendations -- this is what good fire safety management looks like.

It protects your employees. It protects your tenants. It protects your building. And it protects the future of your business. The cost of getting it right is always less than the cost of getting it wrong.