Small Care home and requirement for fire doors

[Daffodil]

As I have said before I am new to this and I welcome any comments that would be helpful.  I have come across a situation that I am unsure where I stand or how to progress it, if it should be at all.

I went to a detached house that is used as a care home for 3 challenging children.  They have a bedroom each on the 1st floor.  There are two members of staff on site at any one time, they work 24 hour shifts so they sleep overnight, one upstairs in their own room and one downstairs in their own room. 

At night the kitchen and lounge doors are locked for security reasons, leaving the route down the stairs to the front door the only means of escape, this is within the 9m in a bedroom and overall 18m for a single direction of travel (as per the sleeping guide) the 18m for independent people (as per the healthcare premises guide) and over the 9m suggested in the residential care premises.
They have a linked part 6 system in all rooms and there is emergency lighting.

It was identified in the fire risk assessment that illicit smoking takes place in the children?s bedrooms and the staff try to manage it.

None of the doors are true fire doors, they appear to be a solid construction but there are no strips and seals that you would expect in a modern property and there are no self closers.
I have asked for self closers and have been challenged by them stating that they have been classified as a C3b care home and are a domestic situation.

I do not see this as a family unit as the staff are rotating every 24 hours.  In every guide I have read due to the dead end self closers and automatic fire detection is required.  I appreciate that they are only guides but in my opinion there is a situation where a fire could start in a bedroom and the occupant may not remember to close the door behind them, particularly at night when evacuation may be slower, this could lead to the escape route being affected by smoke.  The bedroom downstairs could be the worst case as the smoke from here would funnel up the stairs.  So far I have invited the responsible person to justify in their Fire Risk Assessment why they would not need to protect the only escape route with self closing devices. 

Am I being unreasonable?  Am I asking too much? Is there a way to justify not having self closing devices? I would like your thoughts and reasoning behind it please.

[Dinnertime Dave]

Have a read of this offers some decent guidance for small care homes-

http://www.csiw.wales.gov.uk/docs/Fire_Safety_Guide_for_care_homes_sept_03_final_e.pdf

[nearlythere]

Perhaps the following?

Fire precautions in housing providing NHS-supported living in the community
AN UPDATE OF HEALTH TECHNICAL MEMORANDUM 88

I can email a copy.

[Daffodil]

Thanks Dinnertime Dave I have had a look at the link and the two paragraphs that sem to fit the best are;

3.4.3 In small premises no requirements are made.                                    Is there a definition for a small premises?

3.4.5(a) In two storey buildings, where the first floor is a single subcompartment,
there is no need to provide an alternative means
of escape to the ground floor or for the stairway to be in a
protected shaft if all the doors opening onto the stairway (except
those from low risk sanitary accommodation) have self closing
devices.

This implies that requiring self closers is the right thing.

Nearlythere, I have read HTM 88 and i found this

11.2 Means of escape in one or two storey premises
is relatively simple. There are few provisions necessary
beyond ensuring that each habitable room either
opens directly into a final exit or into a hallway or
stairway which itself leads directly to a final exit

I could agree with this if the risk was low, my thoughts are with illicit smoking occuring in te rooms this is not a low risk.

I am being quite particular with this as by not having self closers and good stout doors could turn everything I have thought to be correct about protecting single direction of travel , particualily with sleeping risk, on its head and totally confuse the issue for me.

[William 29]

Have you also read this?

http://www.google.co.uk/url?sa=t&rct=j&q=hm%20government%20guide%20to%20fire%20safety%20risk%20assessment%20residential%20care%20premises&source=web&cd=3&ved=0CC8QFjAC&url=http%3A%2F%2Fwww.cfoa.org.uk%2Fdownload%2F18502&ei=84iqU6zHBOOo0wWZ6YD4BA&usg=AFQjCNGTZ76sQogm4MNjq7fGgA8zbgibUA&sig2=O6fp52lRo0H0rO0hf5txgg&bvm=bv.69620078,d.d2k

[William 29]

I haven't seen the premises but the omission of self-closers may not concern me given you have interlinked AFD in every room. The self-closers can also be burdensome and trap or limit movement around the house (they disconnect them then anyway), we should avoid premises like this becoming institutionalised, I have seen them with full part 1 AFD including call points and fire exits signs over the doors and full EL systems?

Although not a domestic premises is the management any different to a domestic setting with a family with kids that smoke and they have a bedtime routine of closing doors at night, making sure smoking materials are extinguished etc? Plus you have trained staff I assume, full AFD and I bet the white goods are PAT tested?

[Daffodil]

Thanks all

I am still having a bit of trouble getting my head around it as it goes against most of what I was taught, however from a risk based approach, thanks to your input I feel more comfortable with what they have in place. I am however encouraging the RP to justify the deviations from the norm in the fire risk assessment.  Not only for my satisfaction but I would hopw with the justification a subsequent auditer would not be as overzealous as I.