One of the most common sources of confusion around smoke ventilation maintenance is not what needs to be done - it is who is responsible for doing it. The regulatory framework defines several distinct roles, each with specific duties, and getting this wrong can leave critical gaps in your maintenance programme.
This article sets out the key roles as defined by the Regulatory Reform (Fire Safety) Order 2005, the Building Safety Act 2022, and the SCA Guidance on Maintenance of Smoke Control Equipment.
The Building Representative
The SCA Guidance uses the term Building Representative as a catch-all for the person or position responsible for the building’s fire safety. Depending on the legislation and the building type, this role may be held by:
- The Responsible Person under the Fire Safety Order 2005 - defined as the employer (in a workplace), the person who has control of the premises, or the building owner where no other person has control. The Fire Safety Act 2021 extended scope to structure, external walls, and flat entrance doors in multi-occupied residential buildings.
- The Accountable Person under the Building Safety Act 2022 - applicable to higher-risk buildings (HRBs) in England (at least 18 m in height or at least 7 storeys, with at least 2 residential units). Where there is more than one AP, the Principal Accountable Person (PAP) coordinates the duty.
- Persons with duties under Article 5 of the Fire Safety Order - the Order extends some duties to any person who, in connection with carrying on a trade or business, has to any extent control of premises, or who has obligations under any contract for maintenance or safety of the premises. This is distinct from the BSA “duty holder” concept under the design and construction regime.
The Building Representative does not need to be a smoke ventilation specialist. But they do need to understand their obligations, appoint competent people to carry out inspections, and ensure that the system is maintained in efficient working order.
Under the Fire Safety (England) Regulations 2022 (Regulation 7), if a fault on a smoke control system in a high-rise residential building cannot be rectified within 24 hours, the Building Representative must report it to the local fire and rescue service electronically. This reporting duty cannot be delegated.
The Nominated Person
The Nominated Person is appointed by the Building Representative and is responsible for daily operational checks of the smoke control system. This is typically a member of the building’s facilities or concierge team.
Their role is practical and observational: visually inspect the control panel each day to confirm normal operation, report any fault indications, and maintain basic records. They do not need specialist smoke ventilation training, but they do need to understand what the panel displays mean and how to escalate a fault.
The key requirement is consistency. A Nominated Person who checks the panel every day will catch power supply failures, communication faults, and detector issues within 24 hours. A Nominated Person who checks intermittently may miss a fault that leaves the building unprotected for days or weeks.
The Competent Person
The Competent Person carries out weekly, monthly, and quarterly inspections. The Regulatory Reform (Fire Safety) Order 2005 defines a competent person as someone with sufficient training and experience or knowledge to assist in undertaking preventive and protective measures.
For smoke ventilation, this means the Competent Person must have training on the specific system installed in the building - not just general fire safety knowledge. They need to know how to activate the system zone by zone, how to interpret the panel responses, and how to identify and log faults.
Weekly inspections by the Competent Person involve functional testing: actually operating the system, verifying that dampers open and close, that fans run, that air movement is detectable, and that the system resets correctly. This is a significant step up from the daily visual check and requires someone who understands how the system is supposed to behave.
Monthly inspections add physical inspection (checking for corrosion, debris, tampering) and power supply testing (simulating mains failure and running on backup power).
The Competent Maintainer
The Competent Maintainer is a specialist - a maintenance organisation with appropriate training, skills, knowledge, experience, and behaviours for maintaining smoke control systems. They carry out the 6-monthly inspections.
BS 7346 Part 8 sets the standard: the competent maintainer must have specialist knowledge of smoke control systems, adequate access to spares, and sufficient information regarding the system.
The 6-monthly inspection is where the real engineering assessment happens. The Competent Maintainer reviews the system logbook to verify that regular checks have been conducted. They test all cause-and-effect sequences against the original design. They measure airflow rates through smoke dampers. They inspect power supplies, battery conditions, LV distribution circuits, and secondary power transfer mechanisms.
At the end of the inspection, they issue a maintenance certificate that clearly states whether the system has passed, passed with advisories, or failed.
The Maintenance Engineer: Manufacturer-Trained or SMR01 Registered
The annual inspection must be carried out by a Maintenance Engineer whose competence is demonstrated through one of two routes: direct training by the smoke control manufacturer, or SMR01 registration. SMR01 is the SCA’s independent, UKAS-accredited registration scheme (audited via KIWA) that assesses the knowledge, competence, and quality levels of smoke control maintenance organisations.
The annual inspection is effectively a full recommissioning of the system. It includes everything in the 6-monthly check plus a complete verification against the original fire strategy, cable installation inspection, shaft cleaning, and a check that no unauthorised modifications have been made to the system.
The SCA strongly recommends that only organisations meeting this competence standard, manufacturer-trained engineers or SMR01 registered, are employed for smoke control maintenance. A list of SMR01 registered organisations is available from the SCA website.
Where Responsibility Begins and Ends
A common mistake is to assume that appointing a maintenance provider transfers responsibility for the system’s condition. It does not. The Building Representative retains legal responsibility at all times. The maintenance provider’s role is to inspect, test, report, and certify - but the obligation to act on their findings sits with the Building Representative.
If a maintenance certificate states that the system has failed, the Building Representative must take immediate action: review the fire risk assessment, implement interim measures (which may include a waking watch or revised evacuation plan), report the fault to the fire authority if required, and commission the necessary remedial work.
If a maintenance certificate states the system has passed with advisories, the Building Representative must address those advisories within a reasonable timeframe - typically before the next scheduled inspection.
How to Structure Your Maintenance Programme
Based on the SCA guidance, a properly structured maintenance programme for a smoke ventilation system should include:
- A Nominated Person appointed and trained to carry out daily panel checks
- A Competent Person with system-specific training to carry out weekly, monthly, and quarterly inspections
- A Competent Maintainer contracted for 6-monthly specialist inspections
- A Maintenance Engineer, manufacturer-trained or SMR01 registered, contracted for the annual full commissioning check
- A system logbook maintained at the building with records of every check, fault, and resolution
- Clear escalation procedures so that faults are reported and acted on promptly
If you are unsure whether your current maintenance programme meets these requirements, the SCA Guidance on Maintenance of Smoke Control Equipment provides the full framework. It is available from the Smoke Control Association website.
Contact Vent Trade if you need advice on structuring a maintenance programme or finding a manufacturer-trained or SMR01 registered provider for your building.
Sources
Official guidance and standards referenced in this article:
