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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: frex on November 25, 2007, 01:15:41 PM
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I have recently been issued an enforcement notice. I agree with certain parts of the notice and had already put the findings in the risk assessment and a plan in place to rectify. However, also on the enforcement notice, it says I have to replace all my existing fire doors with doors that conform to BS8214:1990. The existing doors are all in good condition and well maintained and fitted with self closing devices. The old fire certificate has a statement saying that the FA were satisfied at the time the certificate was issued that the doors satisfied the requirements of BS476-8:1972. According to ADB, items tested or assessed prior to 1 Jan 1988, have to meet BS476-8:1972, so as long as the doors are in good condition, why do I need to replace them?
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You need to check with the Officer who issued the notice. It may be simply that they have used a system of standard paragraphs to compile the report rather than provide a bespoke schedule, as this saves time and is a bit of a catch all- if they are more specific and miss something then you may take them to task.
We could give more direct help if we knew a little more about your premises- use, height, number of staircases etc and if you could give a description of the existing doors- perhaps all your doors need are a little maintenance or the fitting of combined fire and smoke seals sometimes known as "intumescent fire and cold smoke seals".
You are entitled to guidance and advice from the fire officer though, but I am sure we would be happy to advise you further on the forum if we knew a little more about the building and the notice. I would be very interested to see the notice and take a look at the wording - I have been finding some of them extremely confusing for the recipients.
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I would not think you should do. Ask the FSO why you need to do that. The standard has changed for new door sets and what he is asking is that you remove all the doors and frames and replace them. You can only get a certified door set not a certified door. I do not think that this is viable or needed, ptoviding as you say the doors still meet the standard od BS476 Pt 8 which gives 25 mm stops and not intumescent strips and smoke seals, which is the current test standard of BS 476 pt 22. You could upgrade your doors to incorporate these items by routing out the door or providing them on the frame and this would improve performance.
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Many thanks for your replies. The building is a 10 bed hotel, ground, 1st, 2nd and basement providing owners accommodation. I have an action plan as part of my RA whereby I am fitting strips and seals to the door frames. The wording of the notice is as follows:
Areas of non compliance with the regulatory reform (fire safety) order 2005:
Inadequate fire separation between the means of escape and rooms of risk.
Steps considered necessary to remedy the failures:
Provide adequate fire separation between the means of escape and rooms of risk. Provide intumescent strips and smoke seals to those doors that are of a current 30 minute fire resisting standard (BS8214:1990) and that have a maximum gap between the door and frame of 3mm on both sides and top.
All doors that do not meet this standard should be replaced with current standard 30 minute doors and frames. The door or frame should also be provided with intumescent strip and smoke seal.
Where intumescent strips and smoke seals are fitted to fire doors ensure that they fully cover the gap between the door and frame and meet the above standard.
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Provide adequate fire separation between the means of escape and rooms of risk. Provide intumescent strips and smoke seals to those doors that are of a current 30 minute fire resisting standard (BS8214:1990) and that have a maximum gap between the door and frame of 3mm on both sides and top.
It's actually telling there what you need to do ...... fit strips and seals to existing doors that have a gap of no more than 3mm.
It sounds like he's trying to get the doors upgraded to current standards, although really it should have been a recommendation, not enforcement.
As mentioned, have a chat with the Officer that issued the notice for further advice.
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Thanks for the extra information. Yes as other posters have said there should be no reason why your existing doors, if originally tested to BS476, if a good fit and in good condition should not be acceptable, with fire seals. And even that may be questionable as a legal requirement if the frames had 25mm rebates, but fitting seals would be adapting to technical progress and would be a good thing to do.
The fire officer is in a bit of a difficult position- in writing his official letters and notices he really is duty bound to quote the latest standards documents as a benchmark standard and give his best possible advice to comply to the best standard, even though in the real world your duty is to comply as far is as reasonably practicable. I am sure if you speak to him you will find a sensible solution but if you need any further help at any time come back to us.
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Thank you for your replies. I have arranged a meeting with the team leader of the inspecting officer for Tuesday, but I am just trying to get some advice first. The existing doors do not conform to BS8214:1990 as stated on the enforcement notice, but from my understanding of ADB they do not need to, as long as they meet BS476-8:1972. I have spoken to someone I know who is head of building control south west for NHBC, who agrees with me, and wanted to have some opinions from within the fire safety industry as to whether BS8214:1990 can be enforced, when from my understanding, this only gives recommendations on the specification, construction etc of the doors to ensure that they comply with BS476.
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Yes- but it made the important transition from considering the door leaf to considering the door set ie leaf and frame assembly as a whole. Even today many conversions of existing buildings fit fire door leaves to existing frames.
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Jokar
I presume when you say you can only get certified doorsets not certified doors you mean schemes like BWF Certifire?
You can still get door blanks certified to BS476 in your local DIY/Builders merchants
The point about the condition of the doors and frame etc is well made but who knows what lurks hidden from view?
If we are looking at life safety then detection and MoE may have some bearing on the IO's comments
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As far as I am aware and I stand to be corrected by Auntie Lin and others, the test is for a Door in its frame and it is certified as a fire door set. Whilst fire doors can and are exactly what it states on the tin, they will not get a perfect fir in an existing frame and then may not be regarded as a fire door set.
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Spot on Jokar.
If there is nothing wrong with the doors then theres no need to change them. You could install a bunch of new ones that turn out to be rubbish. "who knwos what lurks hidden from view"???
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BS 476: Part 8 was a test standard, not a code of practice or performance standard, so unless you have test certificates for the doorsets you cannot 'prove' that the doorsets would have the relevant performance or not. BS 8214 guides you in designing a door construction that is to be tested, and gives recommendations for the installation and maintenance of such doorsets; it doesn't tell you how to assess whether existing doorsets comply.
Having said all the above, if the doors are solid timber, 44mm thick or more, are unglazed, aren't large, have steel hinges, are single leaf, have less than 3mm gaps across the head and long edges, you might be able to pursuade the FB that they are good enough. English Heritage used to have a publication that gave useful 'best practice' advice, that you might be able to use, and TRADA do "Fire resisting doorsets by upgrading", or you could try getting some supporting technical evidence from those companies that offer products to be used for upgrading - just Google "fire door upgrade".
Even if you replace the doors, don't get too hung up about the frames - if they're fairly decent close-grained timber, are 32mm thick or more and there are no gaps between frame and wall they should be OK. Again - use the TRADA document or the manufacturer's literature to support performance.
It would be a different matter for FD60 doors - no-one has ever been able to convince me that you can upgrade these reliably and if they're protecting high risks then replacement must be a serious consideration.
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I look after primarily sleeping accomodation. As with most Enforcement notice you are at the mercy of the enforceing brigade. Fire doors installed to CP3 which are in good condition without intumescent strips or cold smoke seals are acepted in some counties, other counties are insisting upgrading doors or retro fitting. The whole things a sham to quite honest. In my opinion the doors installed many years ago are of better quality than the crap they sell you these days.
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I look after primarily sleeping accomodation. As with most Enforcement notice you are at the mercy of the enforceing brigade. Fire doors installed to CP3 which are in good condition without intumescent strips or cold smoke seals are acepted in some counties, other counties are insisting upgrading doors or retro fitting. The whole things a sham to quite honest. In my opinion the doors installed many years ago are of better quality than the crap they sell you these days.
I have some sympathy with those of you who have to cope with these inconsistencies of approach. IMHO the only way to deal with this is to appeal against notices where you don't feel the requirements are justified. The lack of appeals is partly to blame for the often poor quality of enforcement notices.
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I too sympathise with those who find themselves subjected to inconsistent enforcement. What about this though........?
The Regulatory Enforcement and Sanctions Bill introduced to Parliament on the 8th November wants to give fire authorities the power to impose 'on the spot' fines for fire safety breaches. There is some good and pragmatic thinking behind this and I do not know how it is going to be put into practice.
On the spot fines make sense where there are strict black and white rules and no place for risk assessment, such as the public highways. But I'll be interested to see how we are guided to apply these in the world of risk assessment and informed (or otherwise) judgement.
have a look here:
http://bre.berr.gov.uk/regulation/enforcement_sanctions_bill/
and see what you think
Stu
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On the spot fines make sense where there are strict black and white rules and no place for risk assessment, such as the public highways. But I'll be interested to see how we are guided to apply these in the world of risk assessment and informed (or otherwise) judgement.
Stu,
You only have to read some of the threads on this forum to see examples of over zealous inspecting officers. I find it a little worrying.
Also, will it work anything like parking enforcement will I get a performance related bonus?
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So an on the spot fine is issued but is the premises safer than it was before! An enforcing officer has recently stated that he will not accept a fire door set as it has no certification. There is nothing wrong with the door set but the school concerned has no paper trail for the doors which met a standard of years ago. Is this an on the spot fine, or a Stop Notice. I agree with Stu that black and white issues are seemingly easy, but although there is a Fire Consulatncy called Black and White Fire safety, in my years I have never come across a black and white solution, therefore surely there can be no on the spot fines levied unless that failure is no Fire Risk Assessment which is the legal requirement. However, as noticed many times before on this forum, it is not only the question of an FRA but the quality of it as well.
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I have had a quick look at the Bill. Yes it makes a case for fines instead of court action.
However there is another aspect of the bill which is setting up the Local Better Regulation Office the job of which is to ensure that regulations are imposed uniformly across the country. In the consultation document it uses a case where a large firm with sites in different authorities used the system to get overall approval for their action. One authority took the firm to court for using the overall approval and not obeying the local ruling. The authority lost and had to pay £15000 costs.
Part 1 of the Bill sets up the means for establishing cross authority approvals via Primary Authorities. Schedule 3 lists the Designated Regulators which includes the Fire Authorities however the designated enactments does not include the RRO.
I can see this heading the way of the fire authorities particularly over the different interpretations of the guidance notes.
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I am worried about hi-jacking the objective of this thread and think that, if there is discussion to be had in this area, we should have a separate thread. I'll start one off....
In the mean time please return to the main thrust of this thread....
Stu
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Thanks for all the replies. I had a meeting with the team leader of our local FB. He said that he has an obligation to make it clear in writing that the current doors do not meet the latest standard, and under the new laws, an enforcement notice is the only official way of doing it. He said that he is not really bothered about the doors and if I give him an action plan of replacing the doors over 2 years or so he will be happy and this solution will satisfy the enforcement notice. I am quite happy with this as I had started replacing the doors already, as I redecorate each room etc, but couldn't afford to do them all in 6 months.
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I am pleased you have reached a satisfactory conclusion but either that team leader has a great deal to learn about the fire safety order or- more likely- he has used the Bluff and Persuasion Act 1872 to extract himself from a hole.