Can you prove your fire-stopping?

HAALO · Updated October 2026; first published January 2024

As the Principal Accountable Person, you will be invited by the Building Safety Regulator (BSR) to apply for a Building Assessment Certificate (BAC). From the point of invitation you will have just 28 days to upload your Safety Case Report to the BSR web portal using a unique reference code. Your Safety Case Report must adequately describe the fire compartmentation within your building, including the fire resistance between floors, walls and subdivision of enclosed voids.

What evidence sits behind that description?

For many Accountable Persons the honest answer is probably just a basic folder of hard-copy data sheets and in some instances an outdated register that nobody has ever checked or updated. More often than not, no information is available, despite there being materials installed that appear similar to what we expect typical fire-stopping materials to look like. Unfortunately, a building can have fire-stopping that is potentially compliant but be unable to prove it through lack of evidence to support the claim of compliance. Alternatively, a building could have materials that look like compliant materials but are not.

In addition, when was the last time someone physically inspected your fire-stopping? Do you know what condition it is in? Are you confident that there are no new or undiscovered penetrations? Do you know when your fire-stopping should be replaced because the tested lifespan of the products has expired?

Under the Building Safety Act 2022, the liability and burden of proof sit with the Principal Accountable Person.

What the regulations actually ask

The requirement itself is simple. Requirements B2 and B3 of Schedule 1 to the Building Regulations 2010 require that, where needed, elements of the building adequately resist the spread of fire and smoke. Approved Document B, BS 9999:2017 and BS 9991:2024 give guidance on where those fire-separating elements are likely to be required and what level of fire resistance they are expected to meet.

Fire-stopping is what keeps that fire-separating barrier complete wherever openings are made for pipes, ducts and cables and the like to pass through it.

Fire-stopping works can fall under two separate regulation 38 duties, depending on the building and the type of work. Under regulation 38 of the Building Regulations 2010, fire safety information must be handed to the responsible person where the work erects or extends a building or is a relevant change of use. Under regulation 38 of the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023, the client must hand over fire safety and golden thread information for work to a higher-risk building, including works to existing, occupied buildings. On some projects, such as new higher-risk buildings, both will apply. The processes differ: who holds the duty, who receives the information and how compliance is confirmed. But both rely on the same thing: accurate, verifiable records of the fire-stopping actually installed. Without them, neither duty can be properly met.

The Building Safety Act raises the stakes. The Regulator is clear that the Principal Accountable Person must “put measures in place to prevent building safety risks happening and reduce the severity of any incident that does happen”. Compliant fire-stopping sits squarely inside that duty.

What the law does not tell you is how to prove it. That part is left to you.

What has changed since 2024

A lot has moved since we first published this paper in 2024. Four changes matter for fire-stopping.

1. The ‘Golden Thread’ is now law. The Higher-Risk Buildings (Keeping and Provision of Information etc.) (England) Regulations 2024 came into force on 16 January 2024. When we first wrote, they were still in draft. Fire-stopping records are part of the information you must now keep.
2. Gateway 3 requires you to evidence compliance. A Completion Certificate for a new Higher-Risk Building (HRB), or works to an existing HRB, needs as-built information, fire and structural safety documentation, the ‘Golden Thread’, and evidence that any design changes were properly managed during the build process. The Regulator, as the Building Control Authority, has to be satisfied that the evidence is sufficient before it approves completion. Fire-stopping records are not explicitly named in the Regulation, and neither is the format this evidence should take (other than that information should be ‘as-built’). Fragmented or partial fire-stopping records that cannot appropriately evidence what was installed give the Regulator little to be satisfied by.
3. The guidance on handover information is clearer. Since 1 October 2023, the Building Regulations etc. (Amendment) (England) Regulations 2023 have tightened the handover of fire safety information under regulation 38 of the Building Regulations 2010. The person carrying out the work must hand it to the responsible person by completion or first occupation, whichever is earlier. The responsible person must then confirm in writing that they’ve received it and that it’s enough to operate and maintain the building safely. Building control must also be told the handover has happened, within 5 days, or 30 days for competent person scheme work. The 2025 amendments to Approved Document B, in force from 2 March 2025, replaced the fire safety information guidance (Vol 1 Section 17; Vol 2 Section 19). They now set out the minimum as-built and system information for all buildings, and a fuller record set for complex buildings. Higher-risk buildings follow a parallel handover regime under reg 38 of the Higher-Risk Buildings Procedures Regulations 2023 (SI 2023/909), which includes the golden thread information.
4. Product testing is under reform. The government’s Construction Products Reform White Paper, published in February 2026, proposes a safety requirement for all construction products and licensing of the bodies that test and certify them. These are proposals, not law, but the direction is clear: evidence of what was installed, and how it was tested, will matter more, not less.

What has not changed: there is still no ‘prescribed’ requirement for what a fire-stopping record should contain or how it should be structured. Liability for the adequacy of evidence therefore rests with the Principal Accountable Person.

A simple test for your records

Pick any fire-stopping seal in your building. Can your records tell you:

1. Which seal it is, by a unique number?
2. Where it is, on a floor plan?
3. What was specified?
4. What it looked like before, during and after, in photographs?
5. Which named product was used, with its data sheet?
6. Is the manufacturer’s testing information available and in date?
7. Whether that product was appropriately specified to achieve the requirements of the Fire Strategy?
8. When was the work completed?
9. Who installed it, and what makes them competent?

If the answer to any of these is no, you have an evidence gap. In our view, anything less than all nine cannot show that a compliant solution was installed.

Why it matters

Reliance. Passive fire protection (compartmentation) is often the last line of defence against a fire event. Indeed, in some buildings there are no active fire safety systems. Fire-stopping of penetrations in compartmentation is crucial, as it could be the difference between fire and smoke spreading into an adjacent area, putting an occupant’s life at risk.

Compatibility. Take one scenario. Sometimes, sprinkler pipework in buildings is plastic, made from CPVC (chlorinated polyvinyl chloride). It can deteriorate if it comes into contact with the wrong fire-stopping product. The problem does not show up on first installation, and before it became a known issue in the industry it was often overlooked.

Condition. Fire-stopping materials do not have an indefinite lifespan; they are often only certified for a specified period and require regular inspections to identify any product deterioration. Issues with other building elements may also result in deterioration of a fire-stopping material, such as leaks, thermal expansion or environmental conditions. Good records allow building managers to identify, inspect and repair fire-stopping seals.

Suppose a concern is raised about the compatibility of fire-stopping products with the sprinkler pipes in your building. You hold a file of data sheets, but no record of where each product was installed. You may struggle to identify which penetrations are affected. That is a significant roadblock to understanding the extent of the issue and the risk to occupants.

That is a single scenario. Unfortunately, the information gaps we find most often are simpler: no comprehensive register, no data sheets, or not even a survey to show whether any fire-stopping exists. With no available evidence to provide confidence in the as-built condition, it can only be assumed that there is a potentially serious unmitigated building safety risk.

Poor records cost you in other ways too.

• What you can’t verify, you may end up needing to replace. An entry that reads “FR mastic”, with no named product and no data sheet available, cannot necessarily be relied on. On detailed review, which may include sample testing, it may be that the only conclusion you are able to reach is that the fire-stopping material may need to be replaced.
• Later work depends on it. When a service is added or a repair is made, it is important to reinstate a seal in accordance with the original tested detail to have confidence in the system’s performance. Not having this information may result in the entire seal needing to be replaced. A competent subcontractor is unlikely to be willing to certify their work without confidence in the original materials.
• The record is what gets examined. At completion, on a sale or refinance, or when the Regulator asks, data and records may come under scrutiny.
• It tells you where to look. If you have a robust record of your fire-stopping, it supports you in creating structured inspection and maintenance regimes.
• It shows you understand the risk. If you have a comprehensive record of fire-stopping that is reviewed at regular intervals, it demonstrates that you understand one aspect of compartmentation risk.

Still no standard. Set your own.

There are still no prescriptive requirements for recording fire-stopping, only industry best practice. We still see fire-stopping registers that would not survive close examination. Too often a contractor fixes a sticker to each area it can recall sealing, but the records that sit behind that seal tag are poorly detailed and do not really show the full picture of the works completed. This is a real industry tragedy, because the tools, information and training to become competent are all available, but management and enforcement of expectations is often where it falls short, resulting in an argument over ‘what is actually required’ on completion of the works.

Our view: don’t wait for a standard to be prescribed. It may never happen. Decide what evidence you consider you need, ask for it, and build it into the commercial terms of your project at the outset, so you can confidently demand it at completion. Remember ‘Claim – Argument – Evidence’: your safety case makes the claim, the reasoning supports it, and the fire-stopping record is the evidence. Without the last, the first two don’t stand. The tools already exist: proprietary survey and recording software that lets installers record each seal as the work is done.

1. On new builds: set expectations at the outset of the project. You have the opportunity to build your completion requirements into the contract. Use the best practice guidance widely available to help you understand what good looks like and appoint competent consultants to support you where there are gaps in your knowledge.
2. On existing buildings: the starting point is a clear picture of what has been installed and what records exist to prove it, followed by a plan to close any information gaps. Competent consultants can help with both. We are wary of arrangements where the same fire-stopping contractor surveys the building and then carries out the works. In our view, a contractor’s survey carries more weight when someone independent and competent has reviewed it.
3. Named, tested products only. An entry that reads “FR mastic”, with no product and no data sheet, is not evidence. In fact, it may well point to the fact that you don’t have an appropriate Building Safety Management System (B-SMS) in place – which is a key part of your Safety Case for the building. Adopt the principles in the Construction Products Reform White Paper. Use competent people to help you understand what compliance looks like.
4. Check competence yourself. Any competent contractor should be able to prove their competence through training records and third-party accreditation schemes. Check that the installer shown on the QA records aligns with the certificates of competence that you were provided with.
5. In writing, up front. Incorporate expectations into the project documents at the outset. Do not negotiate at completion.

These are the questions our Operational Readiness work starts from. Where the Safety Case Report itself needs authoring or review, the Safety Case Partnership, wholly owned by HAALO Ltd, specialises in that work.

This paper sets out HAALO’s professional perspective on this matter at the time of drafting. It is meant to be general information, not advice or legal/ financial opinion on any specific building. The content of this paper should not be relied upon and we always recommend the reader retains its own professional advisory team.

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