The 85% Blind Spot: What the Fire Door Industry Needs to Know About the Building Safety Act

As the need for greater awareness and understanding of the Building Safety Act (BSA) persists within the industry, Nicola John, Managing Director of FDM Training & Development, clarifies the crucial responsibilities and implications for everyone involved in the fire door industry.

Eight years on from Dame Judith Hackitt’s Building a Safer Future report, which demanded a systemic overhaul of the construction regulation system, and four years after the introduction of the BSA, our industry still faces misconceptions regarding crucial rules and responsibilities. In fact, a recent survey cited during last year’s FDM roundtable revealed that an alarming 85% of people on the Constructionline register, one of the UK’s most widely used contractor databases, believe the Building Safety Act doesn’t apply to them. They are wrong.

This is a worrying statistic, particularly as the regulatory landscape begins to harden. Last year, the Technology and Construction Court granted the Health and Safety Executive (HSE), acting as the Building Safety Regulator (BSR), its first injunction. No longer a theoretical regulator, the BSR is acting and winning.

Competence as a Legal Concept

Although most people in the fire door industry have heard of Section 35 of the BSA, many still don’t understand what it does or its significance. Section 35 isn’t about best practice or gap tolerances; it makes competence a requirement under building regulations, ending the era of merely ticking boxes and signing forms, and instead demands proof that whoever has done the work is competent to do it.

Much of the confusion across the industry stems from the BSA’s deliberate move away from prescriptive rules toward an outcomes-based approach, which, in theory, is more meaningful but, in practice, leaves most unsure where to start. This general uncertainty also extends to the widely held belief that the act only applies to high-risk buildings, which simply isn’t the case. While, yes, higher-risk buildings are subject to more stringent rules under the gateway process, the core principles of competency and compliance apply to all buildings. If it needs building regulations approval, the legislation applies.

Those involved in the fire door supply chain need to be crystal clear about their responsibilities, as since October 2023, the cost of breaching building regulations has significantly increased. No longer a fine-only offence limited to £5,000, which Dame Judith Hackitt famously described as ‘so small as to be an

ineffective deterrent’, the breaching of building regulations can now lead to a potentially unlimited fine and imprisonment for up to two years.

The Illusion of Compliance

FDM’s 2025 roundtable made it clear that there is still much confusion and fragmentation across the sector, creating a dangerous illusion of compliance.

In addition, last year the Fire Door Inspection Scheme found that, along with gaps, faulty doors and maintenance issues, a worrying 31% of fire doors failed inspections due to incorrect installation. That’s almost a third of fire doors designed to compartmentalise a building and provide a first line of defence in a fire event, wrongly installed from day one. And this competence issue is exactly what Section 35 is trying to address.

Of course, not all competency issues are the result of incorrect installation; often, supply chain economics is to blame for fire door failures, resulting in substitutions for cheaper hardware, fewer safeguards, and a fire door that fails in 15 minutes rather than 30. This can create situations where non-fire-door hardware has been fitted to a fire door, which should never happen. The hardware used on a fire door must always be fire-rated and suitable. Hinges, latches, and closers must all meet current fire-rating standards.

Of course, compliance failures aren’t new, but for a fire door installed after October 2023, these failings can no longer be chalked up to oversights. Under the BSA, an ineffective fire door can now be used as evidence of incompetence, leading to prosecution. Building owners should also be aware that insurance companies are increasingly paying attention to fire door compliance, with non-compliance potentially invalidating property insurance.

As the BSA works to tackle this dangerous illusion of compliance, where documentation may be in place but the safety outcomes aren’t, partial compliance becomes no longer defensible.

Everyone Has a Part to Play

From architects and procurement teams to suppliers and contractors, everyone in the fire door chain should be competent, and the BSA makes everyone involved accountable. The revised BS 8214:2026, published in March this year, places the responsibility for compliance on all professionals involved, asking practitioners to demonstrate understanding and justification for what they’re doing, rather than simply following procedure. The new standard emphasises evidence-based documentation and, as such, is closely tied to the golden thread.

A Golden but Currently Frail Thread

As revealed in Barbara Lane’s supplemental report on the Grenfell disaster, of the 106 fire doors replaced in the building in 2011, none complied with Building Regulations. The smoke seals were found to be inconsistent, and door closers had been removed from the doors, which would have allowed smoke and fire to spread much faster. In this situation, had the golden thread of information been available, these issues are likely to have been flagged and fixed. The purpose of the golden thread regulation is to make chains of failures like this evident before they become catastrophic.

This is why the BSA demands that the golden thread must be accurate, kept up to date and capture all a building’s data. This continuous, digital record of safety applies to every fire doorset, which should have a documented lifecycle from initial specification and manufacture to installation, inspection and modification.

Unfortunately, often held together with a patchwork of data silos and different people storing records on different systems, the golden thread becomes frail.

The construction of a strong and effective golden thread is a challenge, and this thread isn’t yet fully functional. Without a unified hub, the thread will remain problematic, and competence must be proven. An effective golden thread demands digital evidence at every stage and should be continuously updated to ensure no gaps in data. To improve fire safety standards, the industry must remain focused on achieving standardised, accessible data to weave a strong, effective golden thread.

Driving Systemic Change

As Dame Judith Hackitt rightly stated about the oil and gas industry, ‘They sorted themselves out and then went back to government. That’s how systemic change happens’. Both the Grenfell and the Piper Alpha tragedy exposed systemic failures and the question in both incidents was whether the industry would take ownership of the changes needed to tackle these failures.

A profound cultural shift followed the Piper Alpha Cullen report disaster inquiry, embedded in shared leadership and practical training that created a culture of accountability for offshore safety. As is needed in the fire door sector, this cultural shift and raising of standards resulted from hands-on, practical training delivered by experienced specialist leaders.

Similar to the Cullen Report, the BSA is a goal-setting framework, but currently, this lack of detailed step-by-step instruction is causing confusion.

Shaping a Safer Sector Together

The implementation of the BSA is an industry-wide commitment. We all have a part to play in raising fire door safety standards and improving competency. Building managers, accountable persons, and responsible persons should maintain an auditable digital trail and consult the Building Safety Alliance’s Golden Thread Toolkit for guidance. And for fire door hardware suppliers, the upcoming BS 8670-2 will provide the competency framework needed to promote product governance and knowledge, reduce ambiguity and support a more transparent supply chain.

Every day, on every job, every person involved in the lifecycle of a fire door has a choice: to support the infrastructure for an improved, safer fire door industry or not. The frameworks are forming, the standards have been revised, and the regulator is going to court. The BSA is everyone’s responsibility, and those who act now will help to shape a more competent and safer sector for generations to come.