Fire door records — what to keep, for how long, in what format

You can inspect every fire door in your building, fix every fault, and have nothing to show for it. If you cannot produce a record, you cannot demonstrate the work happened — and from the perspective of an inspector, undocumented compliance and no compliance look identical.

This is the element building owners most consistently underestimate. It matters more than it used to, though not for the reason most commentary gives: the obligation to inspect has not changed, but the number of doors it reaches did change on 1 January 2026.

What the Code actually requires you to record

It is worth being precise about this, because a great deal of what is written about fire door records in Ontario is not.

For the 12-month tests, records are expressly required. Article 2.7.2.4 of Division B says records of the tests required by Sentences 2.7.2.3(2), (3) and (4) — revolving doors, sliding doors required to swing on their vertical axes in the direction of egress, and electromagnetic locks — shall be made and retained in conformance with Subsection 1.1.2. Those three duties are new on 1 January 2026, and the record obligation came in with them.

For the monthly inspection, the Code is less explicit. A door in a fire separation must be inspected monthly under Article 2.2.3.4(4). Article 1.1.2.1(1) requires records where the Code requires “tests and corrective measures or operational procedures” to be carried out, which is not the same word as an inspection.

We are not going to build an argument on that distinction, and nor should anyone selling you an inspection. The practical position is simpler and does not depend on how the sentence is read: an inspection you cannot evidence is of very little use to you when someone asks you to produce it. We document every opening every time, and we would give the same advice to a building that never hired us.

More doors to evidence than last year

Here is the change almost nobody has picked up. Until 31 December 2025, Sentence 2.2.3.2(1) and Article 2.2.3.3 both opened with the words “Closures in fire separations”. Those words were struck out effective 1 January 2026.

Article 2.2.3.2(1) requires closures to be maintained so they are operable at all times — fusible links and heat or smoke-actuated devices kept undamaged and free of paint and dirt, guides and bearings clean and lubricated, hardware adjusted and repaired to ensure proper closing and latching, inoperative hold-open and automatic releasing devices repaired or replaced. Article 2.2.3.3 prohibits obstructing, blocking, wedging open or altering a closure.

Since 1 January 2026, both of those reach every closure in the building, not only the ones in a fire separation. The population of doors you should be able to say something about just got larger, and if your records only ever covered rated openings, they now cover less of the estate than they used to.

Why “we check them regularly” is not an answer

A fire prevention officer arriving at your building has no way to verify an undocumented claim. They cannot confirm which doors were checked, when, by whom, what was found, or whether anything was done about it.

This is not bureaucratic obstruction. The reason records exist is that fire door condition changes continuously — a door that passed in March can fail in June because a contractor drilled it, a hinge dropped, or someone fitted a wedge. A point-in-time assurance tells nobody anything about the state of the building today.

What a defensible record contains

The Code sets a floor rather than a template. Where it requires a record, Article 1.1.2.1(1) asks for what was done, and the date and time it was done. That is the minimum, and it is thinner than anything you would actually want to rely on.

For each individual opening, we would record:

• A unique identifier. A door number, tagged physically on the opening and matching the record. “The door by the loading bay” is not an identifier — buildings have several.
• Location. Floor, area, and what the door separates.
• Date of inspection. The Code asks for the time as well, where a record is required at all.
• Who carried it out, and why they were competent to. The Fire Code sets no qualification requirement for inspecting a door — Division C, Section 1.2 imposes one for fire alarm systems, interconnected smoke alarm systems, and fire safety plans in a care occupancy, a care and treatment occupancy or a retirement home. Doors are not on that list. Precisely because nothing is mandated, the record should say who did it and on what basis.
• What was checked. The criteria applied, so the scope of the inspection is clear.
• What was found. Including “no deficiencies”, which is itself a finding worth recording.
• Photographic evidence of any deficiency. A photograph settles arguments that a written description does not.
• Corrective action — what was done, by whom, and on what date. Article 1.1.1.2(3) of Division B requires anything that does not operate as intended to be repaired or replaced where the failure would adversely affect fire or life safety, so the correction is part of the obligation, not an optional follow-up.
• Outstanding items and when they are scheduled.

The door numbering problem

Most buildings have no consistent way of identifying their doors. Records refer to “the third floor stairwell door” and nobody is certain years later which one that was.

This is the first thing we do on a fire door inspection. Tag every opening physically with a durable numbered label, and use that number in every record from then on. It takes an afternoon in most buildings and it makes everything afterwards easier — inspections, repair quotes, contractor instructions, and any conversation with an inspector.

It also lets you see patterns. A door that appears in your deficiency list every quarter is telling you something that a stack of unconnected reports never will.

How long to keep them

For the records the Code requires, this has an answer, and it is in Article 1.1.2.2(1) of Division B. The original or a copy is retained at the building to which it relates:

• for a period of at least two years after being prepared, and
• so that at least the most recent and the immediately preceding record of a given test or inspection are retained.

Those two conditions work together, and the second one catches people out. Two years is a floor, not a licence to discard: if a test is annual, the two-year rule and the most-recent-plus-previous rule land in roughly the same place, but for anything on a longer cycle the second rule is what governs. Article 1.1.2.1(3) adds that records are retained at the building premises for examination by the Chief Fire Official — at the building, not at head office and not only with your contractor.

One record is kept permanently: under Article 1.1.2.2(2), initial verification or test reports for fire protection systems installed after 21 November 2007 are retained throughout the life of the system.

There are reasons beyond the Fire Code to keep more than the minimum. Insurers ask. Purchasers ask during due diligence. And in the event of a fire, the records become evidence of whether the building was being maintained. As a working principle, keep enough history to show a continuous programme rather than a single recent inspection — an inspector wants evidence of an ongoing practice, not a one-off effort the week before they arrived.

Paper, spreadsheet or system?

The Code does not mandate a format, and it settles one question that used to come up a lot: Article 1.1.2.1(4) says electronic records that can be made readily available to the Chief Fire Official on request are deemed to comply. You do not need a binder.

Paper works for a single small building and fails everywhere else. It gets lost, it cannot be searched, and photographs are awkward to attach.

Spreadsheets are a reasonable middle ground for one or two buildings. They break down across a portfolio, and attaching photographs to a spreadsheet row is nobody’s idea of a good time.

A system — whether your own, your contractor’s, or a facilities platform — becomes worth it once you have multiple buildings or a monthly obligation. Twelve inspections a year across four buildings with sixty doors each is 2,880 records annually. That is not a spreadsheet problem.

Whatever you use, the test is simple: if a fire prevention officer asked for the last twelve months of records for one specific door, how long would it take you to produce them? And could you do it standing in the building, which is where the Code expects the records to be?

If a contractor does your inspections

Ask three questions before you engage them.

What does the report contain? Ask to see a sample. A one-page summary saying “37 doors inspected, 12 deficiencies” is not a record — it is a covering note.

Do I own the records? You should. If a contractor’s reports live only in their system and you change providers, you want your history to come with you. Remember that the Code expects records to be at the building, which is difficult to satisfy if they are only ever in somebody else’s portal.

Are deficiencies graded? A flat list of forty items with no priority is a budget problem, not a plan. You need to know what is a code failure, what is developing wear, and what is cosmetic.

Where to start if you have nothing

Most buildings we assess have no records at all. The path out of it is not complicated.

Count and tag the doors. Get a baseline inspection that produces a proper per-door record. Correct the genuine failures. Then run the recurring schedule with records captured each time — which is what a planned maintenance programme is for.

After twelve months you have something no amount of assurance can substitute for: a file showing a building being actively maintained.

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This article is general information, not legal advice. The Ontario Fire Code is O. Reg. 213/07 under the Fire Protection and Prevention Act, 1997, and it is published in full on Ontario’s e-Laws site. We would encourage you to read the articles cited here rather than take any summary at face value, including ours. Your local fire prevention officer is the authority on how they apply to your building.