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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: Dinnertime Dave on April 23, 2016, 08:04:45 AM
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3 storey Building used as Hostal
Built in 2012.
Stay put.
Service ducts have 60 minute walls.
Doors to service risers have FD60 with 60m intumescent strips on ground floor and first floor and FD60S on second floor.
Ducts have a mix of low voltage equipment, water and heating pipe work but some on the ground floor have fuse boards.
AOVs in corridors.
Detectors nearby.
Following a recent fire in the ground floor corridor smoke entered the service duct and then leaked into the first floor corridor. Fire officers has indicated that this is due to the lack of smoke seals on doors to service risers and indicates that they should be fitted. Having checked ADB table B2. It states -
Doors enclosing a protected shaft forming a lift or service shaft - Half the period of fire resistance of the wall in which it is fitted, but 30 minimum. Yes, I knew that. But does not indicate smoke seals.
In truth, this is the first time in 14 years I have not seen smoke seals fitted. My questions really are - have I missed something, is the IO reasonable in asking for them?
Dave
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Is the corridor a sleeping corridor? i.e. The riser would be a protected shaft opening onto a protected corridor?
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Is the corridor a sleeping corridor? i.e. The riser would be a protected shaft opening onto a protected corridor?
Upper floors are flats. Fire in the corridor was arson.
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The upper floors, forming part of a protected enclosure of a protected corridor would require smoke seals.
Technically, it could be argued the ground floor doesn't, for the reasons you already cite. However, it strips are already fitted, it is a case of a couple of quid to provide smoke seals.
Reasonably practicable? Yes I would say so.
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As you say it complies with the current guidance within the Approved Document in support of Building Regs 2010.
The Fire Authority should also have been afforded the opportunity to consult on any "additional requirements" they might have had under the RR(FS)O 2005 through the Building Reg/Fire Safety statutory consultation process; I trust they made no comment about the lack of cold smoke seals at that time and a Completion Certificate has subsequently been issued.
Given that the premises complies with the functional requirements of current Building Regulations, benchmark standards (Purpose Built Flats guidance p.69) indicate that fire protection is "adequate".
I would therefore ask if it is reasonable for a fire authority to require the retro-fitting of cold smoke seals in this instance?
Before answering this question it might also be worth referencing the Article 36 Determination published in May 2012, where the lack of seals did not meet current standards.
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As you say it complies with the current guidance within the Approved Document in support of Building Regs 2010.
The Fire Authority should also have been afforded the opportunity to consult on any "additional requirements" they might have had under the RR(FS)O 2005 through the Building Reg/Fire Safety statutory consultation process; I trust they made no comment about the lack of cold smoke seals at that time and a Completion Certificate has subsequently been issued.
Given that the premises complies with the functional requirements of current Building Regulations, benchmark standards (Purpose Built Flats guidance p.69) indicate that fire protection is "adequate".
I would therefore ask if it is reasonable for a fire authority to require the retro-fitting of cold smoke seals in this instance?
Yes, technically you are correct. However, I have learnt through my experience, argue about the matters that are worth arguing about.
For the sake of a simple replacement of seals? Is the hassle worth it?
Possibly a different argument if we were talking about the replacement of doors, or maybe even routing the door or frame.
Before answering this question it might also be worth referencing the Article 36 Determination published in May 2012, where the lack of seals did not meet current standards.
Yes, it sets the benchmark, which to be fair, I agree with. Personally, I am not a huge fan of strips and seals anyway, I think they are very overrated. However, there is a totally different set of circumstances here, which would bring the validity of the determination into question.
Being a riser, are we talking double doors or single doors?
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Yes, technically you are correct. However, I have learnt through my experience, argue about the matters that are worth arguing about.
For the sake of a simple replacement of seals? Is the hassle worth it?
Possibly a different argument if we were talking about the replacement of doors, or maybe even routing the door or frame.
With the greatest respect Jim I am not arguing about this, merely offering an opinion on the question in the original post: "is the IO reasonable in asking for [cold smoke seals]?".
If you were to ask me if it is worth you arguing about? My answer would be that it would very much depend on how many doors per shaft, how shafts per building and how many buildings were in your estate and of course; are you were happy for those in authority to exceed the powers that have been bestowed upon them.
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However, there is a totally different set of circumstances here, which would bring the validity of the determination into question.
I accept that any Article 36 Determination is specific to the individual circumstances of the case in question.
Notwithstanding, the premise of the outcome of this determination is:
"The enforcing authority has not demonstrated ... that the responsible person has failed to comply with the requirements of the Order by not fitting intumescent strips and smoke seals ... It has not demonstrated that the level of risk associated with the lack of intumescent strips and smoke seals places relevant persons at significantly increased risk".
Which supports the general principle from the "Decision tree for action plan when existing premises do not comply with
current standards" (PAS 79:2012, p.23): "do departures from current standards create unacceptable risk?".
Therefore, even if the premises did not meet current standards (which I think we agree it does), the question would be: does the lack of cold smoke seals create an "unacceptable risk" when the construction supports a "stay put" policy and it has smoke detection/AOVs within the corridors?
In my opinion IOs need to make a clear demarcation between what are enforceable "requirements" and what is unenforceable "good will advice"; if indeed they actually know the difference themselves!
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The proof of the need was confirmed by the smoke spread during the fire. If the bedroom doors require smoke seals as they do then the risers certainly do - linking all floors, many multiples of rooms and often different purpose groups.
I have encountered this issue many times, i believe it is an error of omission in table B2 and contributed to major smoke logging of upper floors in a fire I am aware of in a 7 storey stay put building- though this was exacerbated in the room or origin by sparkies knocking the hell out of the fire stopping at the base of the shaft in the plant room.
In respect of student flats very often the bathroom wall comprises a plastic and 12mm plywood bathroom pod, forms three sides of the "protected shaft" and is another weakness that seems to be overlooked at the approvals stage.
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Thanks for the replies.
I find it quite interesting, I have alway thought that the doors needed the strips and seals fitted including the bottom of the door on the upper floors. This is the only building I have come across where they are missing and deliberately so, as I have said they are on the doors on the top floor. This prompted me to look in ADB.
It works out at more than a couple of quid. The building has over 60 doors to upgrade. However, the occupants have quite complex issues including drug/alcohol dependency. Others have mental health issues, add to this the previous fire was arson in a corridor. Then the lack of smoke seals becomes more of an issue.
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60 doors?
I presume they are not all riser doors?
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The proof of the need was confirmed by the smoke spread during the fire.
With respect, the proof of the need would be if persons were put at unacceptable risk of death or serious injury resulting from the lack of smoke seals; I am not convinced this is the case from the information we have been provided.
The problem here appears not to be the lack of smoke seals on riser doors but more that the corridor was petrol bombed, or similar such event which was outside the parameters of the Building Regs design.
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[quote author=Dinnertime Dave link=topic=7049.msg75243#msg75243 date
Doors enclosing a protected shaft forming a lift or service shaft - Half the period of fire resistance of the wall in which it is fitted, but 30 minimum. Yes, I knew that. But does not indicate smoke seals
Dave
[/quote]
As a further aside let us remember that the EN for lifts only requires fire resistance on the landing side of the door but many lifts are being installed- especially those manufactured in Greece - with a reservoir and pump containing 200 litres of flammable hydraulic fluid in the base of the shaft. When I raised this as a concern in one particular building I was told that type approval regulations prevented the use of a FR fluid and AI and fire service folded and accepted it. The cost of conducting tests on the lift using a different fluid was deemed onerous.
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60 doors?
I presume they are not all riser doors?
Yes, some are 600mm, others are 850mm and 1 set of double doors at 1200mm. 60 is only 20 per floor.
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As a further aside let us remember that the EN for lifts only requires fire resistance on the landing side of the door but many lifts are being installed- especially those manufactured in Greece - with a reservoir and pump containing 200 litres of flammable hydraulic fluid in the base of the shaft. When I raised this as a concern in one particular building I was told that type approval regulations prevented the use of a FR fluid and AI and fire service folded and accepted it. The cost of conducting tests on the lift using a different fluid was deemed onerous.
Once again the Approved Document in support of Building Regulations allows this (rightly or wrongly); if this is an oversight, which I personally do not believe it is, it should be addressed at a national level and not left to individual IOs/Fire Authorities to deal with on an ad hoc basis.
I have known IOs require lifts discharging directly into the corridors of sheltered housing complexes be lobbied because the lift doors were not fitted with strips and seals (very common and compliant with current standards); the implications of this to a large housing association runs way beyond a "couple of quid".
Again I would cite the Article 36 Determination published in May 2012 as an example of the "official" Government position on such matters; the AI and/or the IO in your anecdote clearly didn't have the stomach to take this to determination.
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Isn't there something about adapting to technical change? In this case the effect of the change in lift technology is to create a significant fire loading in a lift shaft which was historically a pretty sterile area and separated from the plant room. Worse still on the EN the benchmark is for the lift to descend to ground floor and stop with even the non FR doors open. In danger of going off topic but I see this as a significant risk in what should be a protected shaft and the authority having control should review and make a judgement based on the risk to the building and not code hug what it happens to say in general guidance.
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The proof of the need was confirmed by the smoke spread during the fire.
With respect, the proof of the need would be if persons were put at unacceptable risk of death or serious injury resulting from the lack of smoke seals; I am not convinced this is the case from the information we have been provided.
The problem here appears not to be the lack of smoke seals on riser doors but more that the corridor was petrol bombed, or similar such event which was outside the parameters of the Building Regs design.
A couple of comments:
I'm not quite sure why one would assume that arson is "...outside the parameters of Building Regs design"? Our guidance to the Reg's usually assumes that you might have a fire of significant size, from whatever source - it (in my view) makes no presumption about what the initiating event might be. The only nod that they might make to such events is that it's custom & practice not to consider the initiation of two significant fires in different places in the premises at the same time.
As regards the "unacceptable" risk... at the risk of being pedantic in England & Wales at least that isn't exactly what the legislation says. it states that offences are caused where occupants are put... "...at risk of death or serious injury in case of fire...".. It doesn't mention high, low, significant or unacceptable. So far as I understand it the courts would tend to use that level of risk that would be achieved using good practice & modern standards as the benchmark - hence we generally aim to comply with that, unless we can demonstrate that they are inapplicable or inappropriate to apply to the particular situation in question, or we adopt an alternative approach that achieves the same level of fire risk by other means. The May 2012 determination is a good example... I'm personally sure the fact that the hotel in question had smoke detectors installed in all the bedrooms (which enhances the level of safety over and above the heat detectors that would normally be installed in those locations) was a contributing factor in that determination being granted.
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Whilst acknowledging the 2012 determination, there is a significant difference. The hotel will carry out simultaneous evacuation. This is a block of flats/bedsits with a delayed/stay put procedure. Based on the risk to the residents ironically caused mostly by their own lifestyle, I will be recommending that smoke seals are installed. The doors are also poor fitting so most require work.
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I have encountered this issue many times, i believe it is an error of omission in table B2
The draft BS 9999 2016 is a direct lift from table B2.
Maybe its worth raising at the consultation?
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The doors are also poor fitting so most require work.
Whilst I stand by my original response to your initial question (as a general principle), the fact that the doors involved are not close fitting into their frames is very significant information not included in the original question.
In light of this new information it now seems reasonable to me for the fire authority to require cold smoke seals to compensate for the lack of a natural seal between door and frame that close fitting door should afford and; recommending the fitting of such seals is a good call on your part Dave.
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DD
Are the doors full height and kept locked?
I have known a fuse box flare and set fire to the cleaners brushes etc smoke leaking into the corridor gave it away (Handy Storage!)
regards
davo
ps to answer the question, I suggest get a quote........
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So far as I understand it the courts would tend to use that level of risk that would be achieved using good practice & modern standards as the benchmark - hence we generally aim to comply with that, unless we can demonstrate that they are inapplicable or inappropriate to apply to the particular situation in question, or we adopt an alternative approach that achieves the same level of fire risk by other means.
Exactly Fishy, but the whole point is that the premises DOES comply with the standards and good practice prescribed in the current Approved Document in support of Building Regulations 2010.
My understanding is that the fire authority never suggested that an offence may have been committed under Article 32 (1) (a), merely that cold smoke seals were required under the Fire Safety Order despite not being required under Building Regulations 2010; however, the original post did fail to mention that the doors concerned were ill fitting.
My reference to unacceptable risk is from the "Decision tree for action plan when existing premises DO NOT comply with current standards" (PAS 79:2012, p.23): "do departures from current standards create unacceptable risk?" and; along with the reference to the 2012 determination was used in that context.
With regards to my comments on the parameters of design, corridors are generally designed on the assumption that they will me managed as relatively fire sterile areas; the fact that they are not always so managed and/or an arsonist might actually introduce a fire loading (a good example would be the scrotes who set fire to tyres within single stairways of high rise residential blocks).
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DD
Are the doors full height and kept locked?
I have known a fuse box flare and set fire to the cleaners brushes etc smoke leaking into the corridor gave it away (Handy Storage!)
regards
davo
ps to answer the question, I suggest get a quote........
Yes the doors are all full height and all were locked by key.
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Exactly Fishy, but the whole point is that the premises DOES comply with the standards and good practice prescribed in the current Approved Document in support of Building Regulations 2010.
My understanding is that the fire authority never suggested that an offence may have been committed under Article 32 (1) (a), merely that cold smoke seals were required under the Fire Safety Order despite not being required under Building Regulations 2010; however, the original post did fail to mention that the doors concerned were ill fitting.
My reference to unacceptable risk is from the "Decision tree for action plan when existing premises DO NOT comply with current standards" (PAS 79:2012, p.23): "do departures from current standards create unacceptable risk?" and; along with the reference to the 2012 determination was used in that context.
With regards to my comments on the parameters of design, corridors are generally designed on the assumption that they will me managed as relatively fire sterile areas; the fact that they are not always so managed and/or an arsonist might actually introduce a fire loading (a good example would be the scrotes who set fire to tyres within single stairways of high rise residential blocks).
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Thank you idlefire for a very good point clearly made. I had initially jumped to the conclusion that the absence of seals had caused the corridor smoke logging, things are rarely so simple! But the discussion has identified the issue of perspective.
There is the perspective of enforcement and I agree with your position on this and the status of national guidance in determining whether due diligence has been exercised and the use of the decision tree in this regard. The fire service has little option but to follow such guidance. Enforcement activity is only half of the picture and usually reactive and retrospective in its application.
The legislation of course requires the RP to carry out a fire risk assessment and many on this forum are employed to carry out such assessments and make recommendations based on a far wider spectrum of issues than the Building Regulations and the standards that the fire service may be able to enforce.
I would not want to see fire risk assessors limited to the strict application of legally enforceable guidance - we need to identify the right standard of fire safety for the protection of relevant persons. And it was from this perspective that my comments were based. Hopefully a competent FRA would identify the justification for this, but like my lift example the RP is likely to be told by Building Control that they don't need to do this and ignore the recommendation.
That's up to the RP of course- they own the risk. But very often there are other weaknesses that are overlooked or not seen by the BCO
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The legislation of course requires the RP to carry out a fire risk assessment and many on this forum are employed to carry out such assessments and make recommendations based on a far wider spectrum of issues than the Building Regulations and the standards that the fire service may be able to enforce.
I would not want to see fire risk assessors limited to the strict application of legally enforceable guidance - we need to identify the right standard of fire safety for the protection of relevant persons. And it was from this perspective that my comments were based. Hopefully a competent FRA would identify the justification for this, but like my lift example the RP is likely to be told by Building Control that they don't need to do this and ignore the recommendation.
Whilst I agree with these comments 100% I do feel the need to add a caveat, apologies in advance if this appears a pedantic point that patronises:
In the same way that I believe a fire authority should clearly differentiate between what is enforceable and what they are offering as "goodwill advice", so too must a competent fire risk assessor differentiate between what preventative and protective measures must be applied to comply with the Order and any additional measures that they are recommending.
I know of many instances where this demarcation has not been clearly made in fire risk assessments and IOs have taken the opportunity to impose a much higher standard on the RP than they would otherwise have been able to enforce; citing that the RP is required by the Order to implement all the preventative and protective measures identified in their fire risk assessment.
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Agreed idlefire, a well respected contributer here uses scores out of 20, which I gratefully adopted with permission.....
davo