Short answer: The M&E or services installer is responsible for reporting every opening they make, the fire-stopping contractor for sealing it correctly and recording it, and the principal contractor for coordination and a complete logbook during construction. After handover, the Responsible Person under the Fire Safety Order must keep fire safety facilities properly maintained.
Why is responsibility for penetrations so often unclear?
At least 3 parties are involved in every fire-stopped penetration: the services installer who makes the opening, the fire-stopping contractor who seals it and the principal contractor who has to keep the overview. Because the work happens in separate steps by different companies, a penetration easily falls between 2 parties.
You know the situation: in week 12 the electrician pulls an extra cable through a wall that was sealed in week 9. Nobody reports it, the fire-stopping contractor has already left site and a month later a suspended ceiling goes in. At the inspection the compartment wall turns out to be breached, and then the discussion starts about who should have spotted it.
What does the law in England say about responsibility for penetrations?
In England, the Building Regulations 2010 place duties on the client, the principal contractor and every contractor to make sure building work complies, including requirement B3 on internal fire spread. Once the building is in use, the Regulatory Reform (Fire Safety) Order 2005 makes the Responsible Person accountable for maintaining fire safety facilities.
During construction, Part 2A of the Building Regulations 2010 sets out dutyholder duties in England. Under regulation 11N the principal contractor must plan, manage and monitor the building work during the construction phase and coordinate the work of all contractors. Under regulation 11L each contractor must make sure its own work complies and must provide sufficient information about that work to others.
After handover, article 3 of the Fire Safety Order defines the Responsible Person: in a workplace, usually the employer; otherwise the person who controls the premises, or the owner. Article 17 requires that person to keep the premises and the facilities provided under the Order under a suitable system of maintenance. In buildings with 2 or more sets of domestic premises, article 6 now also brings the structure and common parts within scope. For higher-risk buildings in England, the Building Safety Regulator acts as building control.
Which party is responsible for what?
In practice the split per role is fairly clear, as long as you record it for each penetration. Problems start when nobody knows which penetration belongs to which party, for example because an opening was made after the fire-stopping contractor finished or the details sit in separate lists.
| Party | Responsible for | Typical risk |
|---|---|---|
| M&E or services installer | Making the opening and reporting where it is | New opening after sealing not reported |
| Fire-stopping contractor | Sealing with a suitable, tested system and recording it | Sealing without a photo or product details |
| Principal contractor | Coordinating, assigning work and keeping the logbook complete | Overview scattered across lists and emails |
| Client | Arrangements for planning, managing and monitoring the project | Fire-stopping not planned into the programme |
| Building control (BSR for higher-risk buildings) | Checking compliance with the Building Regulations | Late sight of concealed work |
| Responsible Person | Maintaining fire safety after handover, including during refurbishments | Logbook not updated after handover |
Many clients also ask for fire-stopping contractors with third-party certification, such as FIRAS from Warringtonfire or the BM TRADA Q-Mark Fire Stopping Installation Scheme. That is industry practice and a contract choice, not a legal requirement.
Where does it go wrong in practice?
It almost always goes wrong at the handover points between parties, not during the sealing itself. A fire-stopping contractor can only seal what they know about, and a principal contractor can only check what someone has recorded. When that handover is missing, an opening in the compartment wall stays unnoticed until the inspection.
- A services installer makes an extra opening after the fire-stopping contractor has finished.
- Penetrations are reported by WhatsApp or email, without a location on the drawing.
- Several fire-stopping contractors work on one project, each with their own list.
- A ceiling or riser is closed before anyone has recorded the seal.
- During a refurbishment after handover, the maintenance team does not know a logbook exists.
How do you record who is responsible for each penetration?
Ed Controls, project management and quality control software for construction, links every penetration as a ticket to a fixed location on the drawing and to fixed project roles. That way each penetration shows who does the work, who is accountable and who needs to stay informed, so nothing depends on a separate list.
| Role in Ed Controls | Usually | What that role does |
|---|---|---|
| Accountable | Principal contractor | Creates tickets, assigns them and closes them |
| Responsible | Fire-stopping contractor | Seals, adds photo and product, sets the ticket to Completed |
| Consulted | Services installer or fire engineer | Provides information about the penetration |
| Informed | Client or facilities manager | Follows progress without acting |
A ticket moves through the statuses Created, Started and Completed, so you see for each fire compartment which penetrations are still open and who they are with.
How does this work in a building that is always being refurbished?
At UMC Utrecht, one of the largest hospitals in the Netherlands, refurbishment and new penetrations are a daily event. The hospital has divided the roles clearly: its in-house fire team seals small openings, and fire safety firm HooVos handles large renovations and new build and monitors the quality of the in-house team's work.
Both parties work in the same logbook in Ed Controls. Gerwin Hoogendoorn, head of HooVos: "I consider Ed Controls to be the most user-friendly compared with other systems." Jan Linnebank, project manager at UMC Utrecht: "To be honest, I don't know how we'd manage without Ed Controls." Read the full story in Managing fire safety.
Who is this approach suitable for?
This approach suits projects and buildings where several companies make, seal and check penetrations, and where responsibility has to be clear for each opening. It adds little for small jobs where 1 company does everything itself, because there is no handover between parties where a penetration could be lost.
Suitable for:
- Principal contractors coordinating M&E installers and fire-stopping contractors on one project
- Fire-stopping contractors who seal and record penetrations for several clients
- Hospitals, universities and property managers with frequent refurbishments
Less suitable for:
- Small jobs where 1 party does all the work and there is no handover
Frequently asked questions
Is the M&E installer responsible for sealing their own penetration?
That depends on the contract. Often the services installer makes the opening and a specialist fire-stopping contractor seals it with a tested system. Either way, the installer should report where they made an opening, so it is sealed in time and recorded in the logbook before a ceiling or riser is closed.
Who is responsible if a penetration is damaged after handover?
After handover the Responsible Person under the Fire Safety Order must keep fire safety facilities under a suitable system of maintenance. In practice that means making sure contractors working in the building later repair any breached compartment wall or floor, and that each repair is checked and recorded.
What does building control do with fire-stopping penetrations?
Building control checks whether building work complies with the Building Regulations, including requirement B3 on internal fire spread. For higher-risk buildings in England that role sits with the Building Safety Regulator. Photos, product details and locations for each penetration help show compliance for work hidden behind a ceiling or inside a riser.
How do you stop new penetrations going unreported?
Make reporting as easy as possible. If an installer can create a ticket on the drawing straight from site, with a photo of the opening, the penetration goes directly to the fire-stopping contractor and the principal contractor. Nobody then has to reconstruct afterwards which openings were added during construction or a later refurbishment.
What does Accountable mean in Ed Controls?
In Ed Controls, the Accountable party keeps oversight of a ticket, assigns it to a Responsible party and closes it once the work is done. For fire-stopping that is usually the principal contractor or the fire-stopping specialist who manages the logbook, while the installer sealing the penetration is set as Responsible for the actual work.
Read more
- Fire-stopping logbook: what should it record and who keeps it?
- How to check fire-stopping penetrations before handover
- Fire safety software from Ed Controls
Sources
- legislation.gov.uk, Building Regulations 2010, regulation 11N (principal contractor)
- legislation.gov.uk, Building Regulations 2010, regulation 11L (contractors)
- legislation.gov.uk, Fire Safety Order 2005, article 3 (Responsible Person)
- legislation.gov.uk, Fire Safety Order 2005, article 17 (maintenance)
- legislation.gov.uk, Fire Safety Order 2005, article 6
- Building Safety Regulator, building control FAQ
- Fire Safety Search, FIRAS installer certification scheme
- BM TRADA, Q-Mark Fire Stopping Installation Scheme
- Ed Controls, Managing fire safety (UMC Utrecht and HooVos)
Last updated: 12 October 2026
