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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: Suttonfire on September 01, 2014, 02:02:57 PM
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Hi All,
I would appreciate your views on the following scenario:
A local fire officer is demanding that the front entrance doors within a block of 3 storey flats are replaced due to them not being '30 minutes fire resistant'. Now, whilst the doors are not traditional notional 30 minute doors (they are all incorporate a large single panel -thus 44mm core thickness is not achieved), the doors all appear to be in sound condition, and given that they are all uniform it is likely that they met the required standard at the time of installation. Furthermore, each flat has access to an external fire escape stairwell at the rear of the property, meaning that even if the main common escape route (accessed via the flats entrance doors) is compromised the residents will be able to use an alternative means of escape.
In view of the above would you consider that requiring the replacement of the doors is not proportionate to the risk, particularly given the presence of an alternative means of escape?
Thanks
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A few questions. Is there any FD & A and is the external properly protected below and to the sides? Sounds to me like the IO doesn't fully understand the issues here. I'm getting a bit fed up with the FD suppliers banging on about fully compliant fire doors - what happens when the BS/EN changes in a few months/years time - are they going to insist all of these newly fitted doors are replaced or modified?
In my opinion, and from experience, I'd much prefer a 30 year old solid door to some of the rubbish that is sold these days (however is carefully designed for maximum profit and will pass the BS test).
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Hi,
No communal detection and not all doors opening on to the external escape stairs are fire rated. However, the cost of replacing all of the doors from the flats and windows which can not be confirmed as non fire rated would, in my view, not be proportionate to the risk. thanks
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I'm going on very little information here but I'm afraid that given there is insufficient evidence that these were ever fitted as proper fire resisting doors (and despite my earlier comment that the IO may not understand the issues) I'm coming around to his/her point of view and that they should be replaced. There is insufficient protection to both staircases and a fire within a flat could affect both; given the lack of FD & A in the communal areas the fire could burn for some time and affect other flats in the block before residents were aware of the danger. If this is the case then there is no argument in my opinion and that it is reasonable that the internal staircase doors should be upgraded or FDA fitted and a simultaneous evacuation policy be adopted; the cost in either case is only a few thousand (3 floors - 9 flats?) which is not disproportionate to the risk. Fire alarms obviously attract testing and maintenance costs so a 'whole life' costing should be looked at.
I would also be checking the current protection between the flats and the internal staircase and between floors and if I could satisfy myself that there was a case for stay put then this makes the external redundant and there would be no need to protect. You could always send off a door to be tested however this would probably cost more than replacement. I'd repeat that having not seen the doors/building this opinion is only based on the information so far.
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Thanks for your views.
Just to add some further information there are actually 40 flats In total 8 self contained entrances). I can not prove the fire resistance standard of the door sets but feel that the wholesale replacement of the doors or the installation of a communal fire alarm system based upon presuming non compliance would be excessive. However, I do appreciate the response.
I wonder if I could gauge further opinion?
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Tom, a few questions.
How do you know his name is Tom Golden? do you know him personally or are you just making a guess?
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My apologies - I saw the 'Sutton' in the header and thought it was you! Post amended.
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No apology needed I just thought you may have confused SuttonFire with me, just another from the south tun (village)
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Just to lob in my three penn'orth here. Is it worth doing a proper survey of the doors? I'm very wary when people start 'demanding' replacement doors (and I come from the fire door industry). You're often far better off with original doors which fit properly than some of the attempts I've seen to replace with modern stuff. Too few of the 'operatives' fitting these doors (or worse still, doorsets) know hay from a bull's foot how to do the job properly. Without actually seeing any of the doors I obviously can't give a firm opinion, but there may be scope for some fairly straightforward upgrading of the existing doors (although no doubt the FO's cover my back policy doesn't acknowledge this).
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Lin, the alarm bell that rings in the post is the large single panel- it probably needs to have its thickness and fit checked. Its fine if it was an original 30 min door to BS 476-1 (which my granny told me about) but it may never have been of much cop.
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What is the date of construction and I assume they are purpose built flats?
Colin's point above noted but if the doors are 30mins and have an effective self-closer, sounds fine to me on what you have presented.
The fire officer can "demand" all he likes but has he put his money where his mouth is and served a Notice?
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Is the fire officer demanding or recommending?
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Thank you to all for your responses so far. I can provide the following further information:
I have been advised that the construction date is circa 1972 (purpose built flats).
The rear exit doors on to the external stairwell are a combination of aged doors incorporating g/w glazing, and more modern double glazed doors and windows.
The flat entrance doors within the common areas (deemed inadequate by the fire officer) are fairly weighty doors incorporating a solid wood (44mm depth) outer edge (which is around 100mm thick) and a large central panel (I will attach a photo shortly).The doors are not fitted with self closers (which we have recommended). The doors are well fitting within the frames.
The block is comprised of several separate entrances with a maximum of 6 flats (over 3 storeys) in each common area. All flat entrance doors appear to be identical, and as far as the managing agent is aware, they are the original door sets (40 flats in total).
The travel distances to the escape routes on all floors is limited and the layout of the escape routes very basic.
Based upon this I considered it reasonable to assume that the doors met the required standard at the time of construction. Taking this into account, and given the availability of an alternative exit from every flat onto the external stairs, I personally do not see it is being risk proportionate to presume non compliance and require the replacement of all flat entrance doors (both in terms of financial cost and the difficulties of actually getting the residents to agree to it). At the moment a notice of deficiencies has been served rather than a formal enforcement notice; however, I have since presented the above view (on behalf of the managing agent) to the fire officer and his opinion has not changed.
Thanks again for you input - I would appreciate any further views based on the above.
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Without looking what you have detailed seems fine and the doors should provide the notional 30mins. What I think you may find is that you will have to provide some evidence that the doors are 30mins, maybe by sacrificing one of the doors to look at the construction.
You could try the other approach of getting the fire officer to state why he is so sure they are NOT 30mins FR without further evidence. I would argue given the construction is 1972 the doors are likely to have met the standard of the day and provide 30mins. The problem is some fire officers assume the worst without any concrete evidence to support this. For example I have seen some recommending common fire alarms based on the assumption that the compartmentation can not be guaranteed given the build date of 1960's, 70's etc when there is no clear evidence to support this other than the age of the block.
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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.
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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.
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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.
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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. :)
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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.
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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.
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CP3 also requires the fitting of self-closers therefore the doors were never fitted in accordance with this standard?
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Type 3 they could be rising butt hinges.
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I was kinda including them as it was the 70's where anything goes!
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Assuming a decent smoke fit, what about intumescent paper. We did all our doors (30+) with FRS approval
davo
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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.
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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!).
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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!
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Point taken, I was simple saying determination could be a way to go and I think they would win.
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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.
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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.
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"solid wood (44mm depth) outer edge (which is around 100mm thick) and a large central panel (I will attach a photo shortly)."
Auntie Lin these dimensions were mentioned in an earlier post. If the door is single panel with a 44mm outer edge I'd assume it must have a decent amount of timber to hold in a large central panel. There is a lack of information regarding the doors and I remain of the opinion that they could not support a 'stay put' strategy - even given the secondary escape route. I've never been a great fan of intumescent paper, or paint, for upgrading doors in sleeping accommodation.
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I'd seen that, but I didn't see mention of the thickness of the panel. It's not easy to measure so often gets missed and then described as "thin" or "slightly sunken" or "thick in the middle and thin at the edges" - none of which help to evaluate the potential performance.
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Are we talking 40 fire doors or 40 fire door sets?
Re-reading, starting to feel twitchy..........
davo
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Hi All,
Furthermore, each flat has access to an external fire escape stairwell at the rear of the property, meaning that even if the main common escape route (accessed via the flats entrance doors) is compromised the residents will be able to use an alternative means of escape.
In view of the above would you consider that requiring the replacement of the doors is not proportionate to the risk, particularly given the presence of an alternative means of escape?
How likely is it that a fire could affect both staircases simultaneously ?
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Kurnal its difficult to know without full details of the apartments but the discussion should be centered around whether this is suitable for 'stay put' where the doors are possibly sub-standard? How long is it going to take the fire service to arrive and control any fire - would both MoE be compromised by this time? Its a good discussion point and I'd just like to add that I'm often in favour of keeping older style FR doors but something is bothering me about this situation!
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Its certainly an interesting one. Most unusual from the point of view of every flat having access to an alternative means of escape, it would be interesting to look at the layout. From the description it sounds like an alternative that is directly accessible from each flat without the need to enter the communal areas? That would be worth a lot in my view.
I am finding it difficult to reconcile the comment on proportionality. It sort of implies that if one occupier had put a pvc door on their flat this would be unacceptable and full weight would be applied to them to re -instate it but if all 40 flats have the same it is disproportionate to make every one change because of the cost? To me in that case its not a consideration, if the non fire rated doors are a problem then they need to be replaced.
I would also assess each existing door against the tests carried out by IFC on behalf of English Heritage. The reports are still in the public domain and have been referred to in this forum in the past.
To me this block sounds like it could predate CP3 1971, remember the previous 1962 edition only covered buildings over 80ft high. Sounds even a bit like a typical 1930s building.
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I have dealt with something similar in a building converted into flats (sheltered housing) 3 floors, but only one flat per floor, they each had an alternative to a separate stair. Front and back door were FD30S, but a panel next to the front door was UPVC with a ventilation plate in it. I accepted this but they did have an L2 fire warning system.
Guess though as an inspecting officer if I put it on the file it has been accepted it's OK, don't know how I would treat it as an assessor
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Hi All,
Sorry, I have been away. Just to respond to Kurnal's point earlier, I can confirm that the occupants of all flats have access to external fire escape stairwell, which they can reach without having to enter the internal common areas. The block is purpose built, and as far as the managing agent can ascertain all 40 flat entrance doors are the originals (and all still in sound condition).
When looking at which additional risk control measures are practicable for this property I am considering the cost and effort involved with replacing the 40 flat entrance doors, weighed up against the risk (which I feel is not great given the short travel distance on the internal stairwell and the availability of a totally separate external means of escape).
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They are flats and therefore a sleeping risk - are you proposing a stay put strategy?
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I would think a major question would be, could a fire in a single flat knock out both means of escape? If so then protection would be needed.
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My reason for banging on about this one is that in my opinion the time factor has to be a major consideration in the risk equation. The proposal I believe is for stay put therefore the amount of time available to stay put is the key factor and it is almost irrelevant whether these doors were classified as fire doors when they were fitted. What is relevant is the judgement of the risk assessor and RP in deciding how long the doors are going to last in a fire situation - therefore what is the 'notional fire resistance' of these doors which should be based on knowledge of how doors behave in a fire. Remember there is no detection or alarm in a stay put situation so those above the fire may be sleeping soundly while the fire grows.
Agreed there are other issues with the alternative escape route but there are no details on the layout of the flats with the alternative - for example would a fire in the lounge/bedroom/kitchen where the room door has been left open (common occurrence) have direct contact with both the internal and the alternative?
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Absolutely agree Golden. The OP would be best to follow the approach set out in the LGA guidance written by Colin Todd with particular regard to the flowchart. Compare the building against benchmark guidance both contemporary and current, identify both strengths and weaknesses of the design and then make a decision if the building can safely support a stay put strategy and if so any further work needed to achieve a stay put strategy, if not what additional work needs to be done to achieve a full evacuation strategy.
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OK, just come across a Brigade where they claim not to recognise the LGA Guide!
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I have indeed followed the approach in the purpose built flats guide. Having taken all factors into account (and having recommended several practical risk reduction measures - including the fitting of adequate self closers to the sound doors in place) feel that a stay put policy is preferable to a full evacuation policy, which would necessitate the installation of a communal fire alarm system (likely with multiple system control panels) and would be very difficult to manage.
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OK, just come across a Brigade where they claim not to recognise the LGA Guide!
You wouldn't care to enlighten us would you? It would make an interesting Court case!
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Michael, I have come across a case where an officer could not recognize a fire door, so nothing surprises me.