Fire Officer Recommending the replacement of old flat entrance doors

[William 29]

From the description given it is unlikely that these doors were ever classified as fire resisting; I'm sticking to my earlier response that they should be replaced. Have one tested is the only answer.

If they were constructed in line with CP3 1971, they would have been required to be 30mins FR.

[Suttonfire]

It may be the case that the doors would not achieve 30 mins fire resistance when tested to current standards. However, isn't the whole gist of the current guidance that we should not be making decisions based upon whether doors conform to current standards - with the idea being that we make a judgement based upon whether they will be suitable within the environment in which they are located, and having taken into account the risks specific to the property.

Even if the door sets fail a modern 30 minutes test, would the effort and expense involved with replacing all of the (currently well fitting) doors be disproportionate to the risk? Would the availability of a alternative means of escape not be considered a significant mitigating factor?

It sometimes seems that rather than doing a risk assessment specific to a property it is easier to take the safe approach and suggest that anything which can not be confirmed as compliant should be replaced. However, my interpretation of the purpose built flats guide is that this approach should be avoided if possible.

[William 29]

It may be the case that the doors would not achieve 30 mins fire resistance when tested to current standards. However, isn't the whole gist of the current guidance that we should not be making decisions based upon whether doors conform to current standards - with the idea being that we make a judgement based upon whether they will be suitable within the environment in which they are located, and having taken into account the risks specific to the property.

Even if the door sets fail a modern 30 minutes test, would the effort and expense involved with replacing all of the (currently well fitting) doors be disproportionate to the risk? Would the availability of a alternative means of escape not be considered a significant mitigating factor?

It sometimes seems that rather than doing a risk assessment specific to a property it is easier to take the safe approach and suggest that anything which can not be confirmed as compliant should be replaced. However, my interpretation of the purpose built flats guide is that this approach should be avoided if possible.

I think you have covered that pretty well. 

[Golden]

I fully agree with the risk assessment approach but my interpretation of the guidance is that the doors should have a notional fire resistance of 30 minutes which in my opinion means that at some point in their life they were classified as 'fire doors' and that secondly they are in good repair. My doubt in the situation you are describing is that these doors were never fire doors and most panel doors fail very quickly in a fire - if this is a single panel it will probably warp very quickly once heated which will mean the panel will come out of its housing and be exposed to the heat of the fire/furnace. From my assumptions of the doors you have described I would doubt that they would last very long at all if subject to the current test. A housing association that I know tested a 30 year old door recently that lasted 21 minutes and in my opinion that was a good result and I would have no qualms about accepting this however the local EA didn't; if my interpretation of your doors are correct then I doubt they would last half that long. Where do we draw the line?

Cast your mind back to Lakanal. It is not usually a single failing in a building that results in loss of life but a number of failings that combine to produce an unforeseen result. My feeling on your situation is that these flats open directly onto both staircases without protection from effective fire resistance and in this situation you cannot possibly have a 'stay put' policy for the flats meaning that you would have to evacuate which could only be plausible with a FD&A system.

[Tom Sutton]

If they were constructed in line with CP3 1971 the front door of flats would be a type 3 fire door defined below.

4.3.1.3 Type 3 door.
The door or each leaf thereof, when fitted in a 25 mm (approximately l in) rebated frame should satisfy the requirement of test as to freedom from collapse for not less than 30 minutes and resistance to passage of flame for not less than 20 minutes.

The door should   either a single leaf swinging   in one direction only, or a double leaf with each leaf swinging in the opposite direction from the other leaf, and with rebated meeting stiles.

The door should be fitted in frames having a rebate of not less than 12 mm (approximately 1/2 in) and should be fitted with an automatic self-closing device which may (except where otherwise recommended) consist of rising butt hinges.

[Golden]

CP3 also requires the fitting of self-closers therefore the doors were never fitted in accordance with this standard?

[Tom Sutton]

Type 3 they could be rising butt hinges.

[Golden]

I was kinda including them as it was the 70's where anything goes!

[Davo]

Assuming a decent smoke fit, what about intumescent paper. We did all our doors (30+) with FRS approval

davo

[Tom Sutton]

I think the point Suttonfire is trying to make is because there is an alternative escape and the front doors are substantial, well fitting doors  which may not achieve 30 minutes FR, do they need to be upgraded. I think he has a good point.

I would first wait for the Enforcement notices then persuade the RP to go for determination which I think he would win.

[colin todd]

Tam, determinations should ideally be sought BEFORE an enforcement notice is issued, but I suppose that this depends on the FRs not being obstinate, arrogant and unreasonable. (i.e. about 4 FRS in E&W!).

[Mike Buckley]

Judging by the number of determinations published by the CLG the determination course is very infrequently used, however under the legislation once an Enforcement Notice has been issued then the only way forward is to appeal through the Courts.

However it is nice to known that Colin believes that although the majority of FRS in England are obstinate and arrogant they are however reasonable. I suppose that the four who are not arrogant and obstinate make up for it by being unreasonable! 

[Tom Sutton]

Point taken, I was simple saying determination could be a way to go and I think they would win.

[colin todd]

Determinations in E&W are rare in part because you effectively have to acknowledge a breach-the determination can only deal with arguments about the technical way to resolve the breach.  It is different in Scotland but then they work well with the business community so don't need determinations.

[Auntie LIn]

Just two points to drop into the melting pot.   First - you don't say how thick the panels are (see Toddy's smack to my wrist) and secondly - intumescent paper??? You should be finding proof that it actually works in the circumstances you are planning to use it in.   I did a job some years ago where it had been used throughout a building where people were moving trolleys, files, trays etc and it got scraped very quickly.   I guess when it was tested, it was done in a pristine condition so you've got no idea at all what effect any sort of blemish to the surface of the paper might have.   I cannot believe that anyone living in a flat and arriving home from holiday in the wee small hours is going to ease their Boadicea's chariot of a suitacase carefully through the door just in case they might damage the surface.