FireNet Community
FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: rn976 on June 24, 2008, 03:05:42 PM
-
In the same vain as the compromised fire doors and in the same area of front doors to flats, but this time can any one help with a simple question.
For a door installed post 1990 (BS8214:1990)but with 25mm stops and evidence of good FR to door whilst I belive the RA should identify the need to upgrade the door to SS & SC should the effectivness of the door become compromised, has any one knowledge of documentation that says the existing standard is OK until that time?
-
RN976
There is no standard as such to cover this. Other than the fact that no legislation is retrospective. In my opinion it is about what you are willing to live with as with (as an organisation) as residual risk and for what period of time and reasons at to why you are not upgrading sooner.
A definitive strategy for addressing this issues (including timescales) should be in place within your organisation. I
In an email I received form Fire safety reform at the DCLG the following advice was given:
"There is no specific legal requirement to install intumescent strips or smoke seals in existing fire doors that were not fitted with them when they were first installed in the building. What measures need to be taken in a particular premises should be based on the results of risk assessment. It may be reasonable to upgrade doors or replace them if the level of risk justifies it. Alternatively it may be more appropriate to wait until the doors are replaced or refurbished in the normal course of building maintenance.
Where seals have been fitted, they should be adequately maintained"
-
There is the RRO that says you have to do what is reasonably practicable to protect relevant persons. Can you honestly says it is not reasonably practicable to fit strips and seals and a self closer?
If you have an alarm system that will evacuate the whole building then this may be acceptable to some people with just self closers. (You really want that door closing behind the person escaping from the affected room)
-
no legislation is retrospective.
But from the day the RRO came out it applied regardless of any prior acceptance/certificates/standards. By not being retrospective that surely just means that we can't prosecute you under the RRO for failings prior to the RRO coming out, but if they were still failings on the day the RRO came out, then we can prosecute/enforce.
-
Imagine a major housing association wiht thousands of flats maisonettes etc with front doors opening onto common areas. I would not expect them willy-nilly to start upgrading old 1" rebate doors. However it may well be reasonably practicable when they start putting in double glazing etc to budget for door repalcements.
THe question is will the front door stop fire and smoke passing. ifnot then it is repair or replacement time. IMHO if for example the damage is from forced entry with limited damage around the lock then a good repair to the rebate would be acceptable and a replacment with intumescent strips smoke seals etc is not needed. My RA is that the door will do what is needed, not does it meet published standard. If it does meet the current BS then this is clear supporting evidence it will work.
-
Why should a major housing association be treated any different to a smaller landlord?
-
no legislation is retrospective.
But from the day the RRO came out it applied regardless of any prior acceptance/certificates/standards. By not being retrospective that surely just means that we can't prosecute you under the RRO for failings prior to the RRO coming out, but if they were still failings on the day the RRO came out, then we can prosecute/enforce.
But there never was legislation requiring some doors to be fire doors so retrospectiveness is not an issue. The legislation was, and still is, to provide an adequate means of escape. What was considered adequte then may not be considered adequate now.
-
Why should a major housing association be treated any different to a smaller landlord?
Its not that they should be treated differently, i think enforcement officers just need to realise that these associations are different to smaller landlords.
The expenditure for these associations to upgrade all of their doors with strips and seals would be huge, especially when they are trying to juggle budgets between complying with the RRO, completing the governments 'decent homes' scheme and carrying out normal maintenance works. It will no doubt take these associations with 800+ blocks longer to bring their buildings up to this standard compared with Joe Bloggs who owns 1 block of 4 flats. With that in mind whilst it would be great to have strips and seals on all flat doors it just isn't at all practical for it to happen as quickly as they may like.
-
It is not a different standard for large and small RPs. The standard is reasonably practicable. Finding a budget and managing a massive door change programme may not be reasonably practicable. Doing a quick inspection of the doors when they become due for decorating and doing any repairs or replacements at that time is IMHO reasonably practicable.
Can we turn it round Civvy FSO or any enforcing officers. What would make you think you were into legal failure territory and start drafting an enforcment notice? What would the notice say?
-
Having lots of properties is not an excuse for not complying with the legislation. Imagine if some large company insisted that they had so many staff surely they cannot be expected to give them all protective workwear where required. Do you reckon the HSE would swallow that? I am being slightly antagonistic here, because I would not expect everything done at once, however I would like to see something more solid than "we will do it when we get round to it or when we do something else"
As far as enforcement goes, Article 8 would suffice, linking it to meaning of general fire precautions:
(a) measures to reduce the risk of fire on the premises and the risk of the spread of fire on the premises;
If the premises was not operating as stay-put then article 14 would do, means of escape.
As we are all aware it is up to you/them to prove it is not reasonably practicable to do more than was/is done.
-
Having lots of properties is not an excuse for not complying with the legislation. Imagine if some large company insisted that they had so many staff surely they cannot be expected to give them all protective workwear where required. Do you reckon the HSE would swallow that? I am being slightly antagonistic here, because I would not expect everything done at once, however I would like to see something more solid than "we will do it when we get round to it or when we do something else"
As far as enforcement goes, Article 8 would suffice, linking it to meaning of general fire precautions:
(a) measures to reduce the risk of fire on the premises and the risk of the spread of fire on the premises;
If the premises was not operating as stay-put then article 14 would do, means of escape.
As we are all aware it is up to you/them to prove it is not reasonably practicable to do more than was/is done.
Quite right CivvyFSO
As ever communicate with your local fire officer, agree a suitable and reasonable timescale to get failings or deficiences rectified. If its got to be done, then its got to be done, the issue wont go away just because there isnt enough cash to sort it!.
An RP shrugging their shoulders and saying " cant do that cos I cant afford it" is not acceptable, instead enforcers are looking for the RP to say something like " I cant afford to replace all the fire doors this year, however i will do 50 % this year and the remaining 50% next year" or whatever it may be.
Fire Officers generally are reasonable people, but you have to give them all the facts so that they can assess the overall picture and decide (along with the RP) what is a reasonable timescale.
The order applies to large companies just as much as it does small.
-
CivvyFSo and Midland Retty
I agree with what you are both saying, the point i was trying to make is that it WILL take large associations longer for these issues to get sorted than smaller landlords but like you say Midland Retty, as long as a reasonable timescale is in place than there should be no problems.
-
I think you are living in cloud cuckoo land if you expect the housing associations to retrofit perfectly acceptable doors installed to CP3 with intumescent strips and seals without some form of company policy and long term plan. Whilst I accept that doors that are unsuitable or poorly fitted should be replaced as a matter of urgency when identified as part of the FRA doors which will do for now are not even close to being on a priority list.
-
What you are calling 'perfectly acceptable' doors have been tested under BS476 conditions, and are more in the region of being a FD20 door. With a 4mm gap they don't even manage 20 mins. Also, CP3 is from 1971, the fact that technology has progressed in the last 37 years shouldn't make much difference then?
-
No, quite frankly. Not to a companys policy. It might mot perform in the way a modern door does but it will perform. If all doors need upgrading the government would make it a legal requirement under the order. And it isn't.
The brigades need to understand that you cannot retrospectively upgrade all buildings in the UK in one day, companys HAVE to take finance into consideration and budget carefully to allow upgrade over a period of years.
Serious life safety issues obviously require immediate attention but other items require a more considered approach with regard to budget and seriousness of the deficiency.
-
Budget should be no more of an issue to someone with 40,000 properties than it is to someone with 1 or 2 properties. It is relevant to the rental income, and the associations income is probably more stable that Mr Joe Bloggs' who is probably just renting out for 10 months out of each 12.
-
I'm afraid i have to agree with Big T on this, what you want & what you will get with this ain't gonna be the same. If the orginisations RA justifys the existing doors being ok but states that in the future, doors will be upgraded when required, to current standards then how can you argue?
-
What you need to remember is why intumescent and cold smoke seals are now fitted.
The old BS furnace tests were not pressurised furnace test and it was identified that in a real fire the pressure within the room increases. Therfore it was necessary to simulate real fire conditions in the testing of fire resisting doors so a pressurised furnace test was introduced. The result was that doors that had passed the old test failed under the new test. The solution was to provide the intumescent and cold smoke seals.
Therfore the old fire resisting doors you will find, particularly on flats may not provide half hour fire resistance and will unlikely to stop the spread of smoke.
What length of fire resistance time the old tested doors will provide can not be assessed it may be 20 minutes or it could be less than 10 minutes who can be certain.
What length of time do you base your fire risk assessment on ?.
I recently visited a 20 storey block of council flats following a malicious fire in the bin room. All the fire resisting doors in the building are old style fire resisting doors with no seals. In this incident the smoke spread from the bin room fire as the door was open, then through a set of fire resisting doors across the corridor and entered 4 flats via the old style fire resisting front door seting off the smoke detectors within the flats.
This was not a particularly large fire although plastics were involved. If this was a fully developed flat fire then smoke spread would have been more extensive and possibly affected more flats and the staircases.
If you have a stay put policy How do you convince occupants to remain within their flats if smoke is entering from the lobby.
I understand that costs may be a consideration but if you know that some thing may not perform as previously expected you are obliged to identify it as a significant finding in the risk assessment. How you overcome the problem is a different matter and will need to be decided separately as some sort of phased upgrade programme.
I will always recommend the provision of intumescent and cold smoke seals as they can be life savers.
-
Ok, so we identify that All fire doors require upgrade as a matter as priority. We have 50,000 flats. cost to upgrade £600 (conservative estimate)
Thats £30,000,000. We publish an excess of around £20,000,000. We have to conform to descent homes by 2010 plus a mirread of other tosh.
How do i fix this many doors.
Answer. I can't. Not today anyway
So the solution is an upgrade over a period of years. 10 possibly. Maybe more.
And this just covers doors. It does not cover sheltered schemes with no fire alarms, flats with insufficient fire resistance with regard to floors, flat entrance doors which are not fire rated AT ALL. Flat doors containing non fire resistant glazing etc etc. These are more important issues with greater consequences than a flat entrance door without intu strips and seals.
Sorry to wee on your bonfire but regardless of what you think large landlords (especially social landlords) Have a large array of hoops to jump through and we can't spend 18 months financial excess on front doors that comply with CP3 but not ADB.
-
What length of fire resistance time the old tested doors will provide can not be assessed it may be 20 minutes or it could be less than 10 minutes who can be certain.
What length of time do you base your fire risk assessment on ?.
I will always recommend the provision of intumescent and cold smoke seals as they can be life savers.
Yes a door with smoke seals will perform better than a door without. But how much better? None of us can quantify the benefits of retro fitting smoke seals. Too many officers are going around requiring door upgrades willy nilly without thinking it through on a risk based approach. The fire offiers just tend to look at the building they are in at the time without having to think through the financial consequences and implications.
If Fire Officer A in town 1 visits a property and serves a notice thats fine for that building but it may deflect the landlord from dealing with a more serious issue he has identified in Town 2 where the fire service has not yet visited. The officers should consider the organisations corporate plans before taking action.
But why should relevant persons suffer a poor standard of safety in their home due to the companies financial constraints? You cant put a price on a life they say. But thats the way it works. Big organisations managing budgets should prioritise their expenditure on a risk based approach. Even the fire service does this in the determination of fire cover and operational response. So why should it be wrong for Big T to manage his budget in the same way?
Ok, so we identify that All fire doors require upgrade as a matter as priority. We have 50,000 flats. cost to upgrade £600 (conservative estimate)
Thats £30,000,000. We publish an excess of around £20,000,000. We have to conform to descent homes by 2010 plus a mirread of other tosh.
How do i fix this many doors.
You dont. You carry out a risk assessment and produce a plan to improve those doors that are highest risk - taking all risk factors into account. Provded your improvement and repair budget is a reasonable proportion of your turnover and you have a contingency to deal with crisis issues as they arise no judge in the land would criticise you.
-
Glad you agree.
All assessments cover fire doors and include the corporate plan which in turn will be signed up to by all parties throughout the company, all assessments are reviewed and the plan will evolve with time
-
What length of fire resistance time the old tested doors will provide can not be assessed it may be 20 minutes or it could be less than 10 minutes who can be certain.
What length of time do you base your fire risk assessment on ?.
I will always recommend the provision of intumescent and cold smoke seals as they can be life savers.
Yes a door with smoke seals will perform better than a door without. But how much better? None of us can quantify the benefits of retro fitting smoke seals. Too many officers are going around requiring door upgrades willy nilly without thinking it through on a risk based approach. The fire offiers just tend to look at the building they are in at the time without having to think through the financial consequences and implications.
If Fire Officer A in town 1 visits a property and serves a notice thats fine for that building but it may deflect the landlord from dealing with a more serious issue he has identified in Town 2 where the fire service has not yet visited. The officers should consider the organisations corporate plans before taking action.
But why should relevant persons suffer a poor standard of safety in their home due to the companies financial constraints? You cant put a price on a life they say. But thats the way it works. Big organisations managing budgets should prioritise their expenditure on a risk based approach. Even the fire service does this in the determination of fire cover and operational response. So why should it be wrong for Big T to manage his budget in the same way?
Ok, so we identify that All fire doors require upgrade as a matter as priority. We have 50,000 flats. cost to upgrade £600 (conservative estimate)
Thats £30,000,000. We publish an excess of around £20,000,000. We have to conform to descent homes by 2010 plus a mirread of other tosh.
How do i fix this many doors.
You dont. You carry out a risk assessment and produce a plan to improve those doors that are highest risk - taking all risk factors into account. Provded your improvement and repair budget is a reasonable proportion of your turnover and you have a contingency to deal with crisis issues as they arise no judge in the land would criticise you.
I'm not sure I picked up on the number and location of doors you are referrng to for assessment for possible upgrading but you could maybe carry out research of relevant CoPs to determine where fire door are not needed. Just because a fire door is there it does not mean that it is there for that reason. It could be , and I have found this, that bulk buying of a door type can be more cost effective. Sometimes FR doors are installed because they are more robust than egg box types but do not neccessarily need to be FR.
Just a suggestion.
-
Jayjay writes
"I recently visited a 20 storey block of council flats following a malicious fire in the bin room. All the fire resisting doors in the building are old style fire resisting doors with no seals. In this incident the smoke spread from the bin room fire as the door was open, then through a set of fire resisting doors across the corridor and entered 4 flats via the old style fire resisting front door seting off the smoke detectors within the flats."
We always look at bin stores They are well known as risk areas which defeat some parts of sterile common areas planning. We go down the route of sort out the bin stores. maintenance of self closers. move to speperate external bin stores in worst cases, regular/frequent inspections by caretakers (briefed on why/what they are inspecting for)
Yes some 1"inch rebate doors aren't very good but as long as we check at decorating time and have some sort of thought through plan for upgrading I would be happy argue in court/tribunal or even in front of coroner we we were not in breach of law.
-
That is good risk assessment, make a decision and the onus of responsibility is on you.
-
Met with fire officers regarding upgrades at a care home,agreed 5 years was reasonable period for completion of work.
-
I would be happy argue in court/tribunal or even in front of coroner we we were not in breach of law.
I am sure that would make you feel loads better if you were in a coroners court.
-
Use of word happy not appropriate. I have been in coroner's court and they are not happy. However I could look at family of deceased and say I believed we met our legal requirements. If I could not in all honesty defend our position I would be banging on my chief execs door as a matter of urgency.
There is no obvious answer to how long to upgrade old doors to new doors. Redone says his fire officers say 5 years. I suspect if asked off the record they would admit this was plucked out of the sky as something the Fire Authority and the
RP could both live with.
-
On another note.
I've just been reading 5588-1 and read that some glazed elements in doors are fire resisting in integrity only and this glass cannot be used between flats and common corridors / stairs as they are non insulating.
If flat doors are made up from these glazed elements, is it something that companies / landlords should be addressing when upgrading doors with smoke seals and intumescent strips?
Would the fire service enforce this?
Your opinions please
-
Georgian wired glass is widely accepted in escape routes despite offering no insulation properties. Your typical high rise council flat building would be rife with georgian wired glass.
I would suggest that it is down to risk assessment again. If there is something on the opposite side of the glazing where the lack of insulation could be a problem then it should be addressed, however this is extremely unlikely. Something that can be more of an issue is how the glazing is fixed in place. The weakest link can be the rebate/beading etc if not installed correctly.
-
And to answer your question, I cannot see any FRS enforcing pyro glass where georgian wired is in place. (in this sort of scenario.)
-
Much appreicated,
cheers CivvyFSO
-
Dear all many thanks for all comments very useful