FireNet Community
THE REGULATORY REFORM (FIRE SAFETY) ORDER 2005 => Q & A => Topic started by: brayman on August 22, 2007, 12:11:53 PM
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Our office building has four office suites opening onto a common hall/landing and is about 25 yers old. Prior to the new Order the building had a Fire Certificate and thus the fire doors were adequate, they did not have smoke seals. We have had a Professional (expensive) Fire Risk Assessment and no mention of doors being inadequate was made. This week we had a visit from the local Fire Safety Officer who is now saying that the doors need to be replaced with FD30S doors with smoke seals.
Is the Order retrospective then?
Reading other posts I see that if I fit new doors I should also fit new frames! I can't see anything in the order itslef that specifies door requirements.
Any advice on how to progress this without undue expense would be appreciated.
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You really should go back to your risk assessment and ask their opinion- after all you have paid for their professional advice. If this sort of situation arises, as part of the job your assessor should discuss any difference of opinion with the fire authority on your behalf- after all the fire officer appears to be saying that the risk assessment for which you have paid is not suitable or sufficient?
There is no real reason why a proper fire door installed to the old standards without smoke seals in an office building should not continue to perform an adequate role in your fire protection measures.
They should be provided with three hinges, a self closing device, and be a good fit in the frame with a maximum gap of say 3-4mm around the sides and top of lthe leaf and frame and a maximum gap at the base of about 8-10mm, and close snugly against the rebates. Only if special circumstances are present such as sleeping accommodation or a mixed risk environment, or if the doors were no longer in good condition or a good fit in their frames should there be any compunction to install new doors or fire and smoke seals.
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Brayman - you say the doors don't have smoke seals, but don't mention fire seals, so I'm guessing that they might have them? I don't think you can be obliged to meet today's standards with yesterday's technology, but, if you want to give a measure of smoke control, there are some good retro-fit smoke seals around which will do the job, and won't cost a fortune. If that saves you having to throw more good money at your professional fire risk assessor, I guess it will be worth it. If you want to let me have your address, ASDMA (Architectural and Specialist Door Manufacturers Association) have produced a simple (free) leaflet on fire doors and the RRO, and I can send you a copy (or three).
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I would agree with the above - unless the area was of high risk, the doorset (i.e. frame, door, hinges, etc) was damaged or worn or not even compliant with former standards I wouldn't insist on renewal as a priority.
However where old style doors are seen they are still noted on the risk assessment with a recommendation to replace upon refurbishment. (we work in the property management sector, so suites in multi-occupancies are often ripped out every few years and new doorsets can be included)
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There is a requirement under the fire safety order to take steps to reduce the risk. Also when implementing the preventive and protective measures you should adapt to technological progress and that may be interpreted as fitting smoke seals and intumescent strips if they would reduce the risk.
There should be no precriptive requirements but I would expect a competent fire risk assessor to advise you if your doors needed to be upgraded.
I note that you say you had a professional (expensive) risk assessment carried out. Please dont confuse expensive with suitable and sufficient. There are many assessors out there who really shouldn't be let loose......check their qualifications, if they have offered poor advice ask for a refund.
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Thank you all for your repsonses, I will follow up with the assessors and Auntie Lin's offer.
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The Risk Assessment Company say that the doors meet regulations but recommend fitting new doors! They aren't keen on taking on the Fure Safety Officer.
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Don't be frightened to engage them in debate with this. The decision on the acceptability of the doors lies with the person in charge of the premises, not the Fire Service.
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As has been written above new doors are not the answer if retrofitting strips and seals is acceptable to you.
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Are the doors protecting any sort of dead-end condition/staircase? Is there any detection involved?
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No they are purely to gain access to open plan offices from a common area.
There are smoke detectors in the hall/landing area. The building is about 25 years old.
Thanks for all your considerations, I'm away for a few days now but will pick up anything further when I get back.
Thanks again.
Ian
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But does that common area form part of the means of escape for people on a floor above?
Would be nice to see some simple plans.
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Yes, the common hall/landing is also the means of escape.
Imagine a hall with a room to the left and a room to the right, a set of stairs with exactly the same on the first floor. Pretty basic lego design.
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I would say that if the doors fit snuggly within their frames and close properly on closers then I would note this in your assessment with a view to replace when refurbishment occurs and live with the residual risk.
The FSO will always go with the prescriptive measure of "replace all doors and retro fit seals" etc. I'm sure like me you would love the budget to allow every door in your premises to be FD30S but this isn't always a realistic option.
From my perspective the doors have been suitable for 25 years. They complied at the time of installation. The Legislation isn't retrospective so you have to make you own decision about it. Look at the quality of the existing door and ensure they are still in good working condition whilst assessing them.
What is your fire saftey strategy like? What is training like? Do you have drills regularly? etc? All these questions will come into making an informed decision about whether the doors need upgrading.
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The doors all close on closers and fit pretty snugly.
Training is an issue as each office suite is occupied by different companies. That is something I am having to work on! We have two new tenants moving in so that should help.
Certianly if any doors were to be changed we would go for the current requierments.
I though it was a bit rich receing a deficiency notice rather than constructive advice.
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Surely it is retrospective, in so far as compliance with any of the old guides does not necessarily mean that you have taken all reasonable precautions. "Adapting to technical progress" could be cited?
If, to meet travel distances, you need to form a protected escape route/storey exit then FD30S doors would generally be required.
Although a reasonable option to me would be just to retro-fit strips and seals to the ground floor doors, depending on the possiblity of a fire in one of the upstairs rooms cutting off the means of escape for the person in the adjacent/opposite room.
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I was under the impression this was a simple design wioth no dead ends, excessive travel distances or high risk areas?.
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Adapting to technical progress... hmmm.
The old doors passed the old BS476 test with 25mm rebates. Then they changed the test to incorporate a positive pressure gradient in the furnace and seals became necessary to pass the new test.
It was not the intention to write off overnight every door that had passed the old test. New work warrants best practice, but if still serviceable leave the old doors in place.
How many of you brigade FSOs drive around in a fire brigade van with no airbags or just a drivers airbag, and no ABS brakes? How many of you demand that your employer replace the fleet of vehicles because most new cars have curtain airbags or ABS? Is this what is meant by adapting to technical progress?
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I was under the impression this was a simple design wioth no dead ends, excessive travel distances or high risk areas?.
It is.
The landing is no more than 10 feet long and the ground floor no longer than 15 feet.
The builders didn't waste any space on those days!
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The Risk Assessment Company say that the doors meet regulations but recommend fitting new doors! They aren't keen on taking on the Fure Safety Officer.
What a cop-out! They ought to be ashamed of themselves...
Can't really give you advice on whether the doors need changing or not - the Fire Officer has seen it and has made a professional judgement - I haven't and so cannot. However, if you have had your own professionals in and their judgement is different, they really should be obliged to support their opinions in front of the FSO. In my opinion, they shouldn't charge you for doing this either!
At the end of the day, if the doors are of a standard that would pass the old BS tests of 25 years ago, they're solid and 44mm thick or more, and there's no significant damage or alteration to door or frame, no glazing, vent grilles or thin panels, then you could probably construct a pretty strong argument that some surface-fitted fire and smoke seals would be enough to give performance near enough FD30S to mitigate the risk. The smoke seals are particularly important - the 25mm rebate was 'standard' for fire doors for years, but will make little difference to the smoke resistance of the doorset and in these circumstances that's really what you're after.
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So long as you can be confident that what you have done is reasonably practicable, and are confident if taken to task by the enforcing authority you have shown due dilligence you have to make a decision yourself.
This also applies if notice is served and you dont agree with the requirements, you have the right of appeal and also the option to request a determination from the secretary of state.
I would also be questioning the credibility of the Risk assessment company based on the comment about taking on the fire safety officer.
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The Risk Assessment Company say that the doors meet regulations but recommend fitting new doors! They aren't keen on taking on the Fure Safety Officer.
What a cop-out! They ought to be ashamed of themselves...
Can't really give you advice on whether the doors need changing or not - the Fire Officer has seen it and has made a professional judgement - I haven't and so cannot. However, if you have had your own professionals in and their judgement is different, they really should be obliged to support their opinions in front of the FSO. In my opinion, they shouldn't charge you for doing this either!
At the end of the day, if the doors are of a standard that would pass the old BS tests of 25 years ago, they're solid and 44mm thick or more, and there's no significant damage or alteration to door or frame, no glazing, vent grilles or thin panels, then you could probably construct a pretty strong argument that some surface-fitted fire and smoke seals would be enough to give performance near enough FD30S to mitigate the risk. The smoke seals are particularly important - the 25mm rebate was 'standard' for fire doors for years, but will make little difference to the smoke resistance of the doorset and in these circumstances that's really what you're after.
Sounds like the RA company has shares in the fire door company.
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This is really where there is a big problem with Risk Assessments. The retrospective application of standards is going to cost an absolute fortune.
To my mind Fishy is right in that if it was OK then, it is OK now. Otherwise we are going to run out of space for discarded fire doors, safety lights, fire alarm systems, glazed panels and partitions, fire extinguishers etc.
Think of the environmental impact?