Hotel Fire Doors

[Davidrh]

Can anyone help
I have a fourty bedroom hotel that complied with all fire regulations and has been yearly inspected
Our local fire officer now require us to fit smoke seals on all our door including bedroom doors
I fully understand the need for safety but is this really necessary and is it a legal requirement.
Can the local fire office enforce this requirement

[Redone]

See prosecutions section, regarding smoke in escape route of care home (sleeping risk).

[kurnal]

Under previous legislation the fire authority were unable to enforce improvements to premises once they had issued a fire certificate. Standards became frozen.

The new fire safety order swept that away and requires the responsible person to carry out a risk assessment and apply the principles of prevention in controlling hazards. One of these principles is that you should adapt to technical progress.

In the 1980s it was realised that the old fire tests for doors were unrealistic as they did not replicate what really happens when a room is involved in fire- the bouyancy of the hot smoke and gases , and thermal expansion cause an increase in air pressure within the room that pushes smoke and hot combustion products out around the door. It was then found that fire and smoke seals were necessary in order for doors to withstand the effects of fire for the designated period.

So there is good reason for doing it- there are seals available that can be fitted in minutes without any woodwork subject to gap sizes etc. See www.envirograf.co.uk for example. You could produce an action plan to carry out the improvements on a risk based phased basis- like doors to staircases first, then doors in dead end corridors, then doors in other rooms starting from the top downwards.  

Legally you could perhaps have some grounds to  challenge the requirement if your doors were in very good condition and well hung, as good as the day they were installed but because of the principles of prevention the odds would be stacked against you convincing the magistrate on appeal.

[jokar]

Firstly, I agree with Kurnal as to the logic of the upgrade to fire doors but and it is a big but you can not be required to do it.  It is a great recommendation and will do all those things that Kurnal has mentioned in the post.  What you need to do is have a Fire Risk Assessment undertaken and follow the outcomes of that process with one of the outcomes being that you upgrade the fire doors.  Fire door sets are tested to a standrad and the old BS 476 standrad did not have intumescent strips and smoke seals as part of it.  The latest test version BS 476 part 22 does have so all new door sets are fitted with both strips and seals.  Door sets to the old standard passed the test and will still provide protection although not to the latest standard.

[Davidrh]

Ref my first question.
Is there specific information on hotel bedroom doors rather than exit door.
We have excellent self closing fire door on all our bedrooms and the question of smoke seals has never come up before during FB inspections.
Apart from the costs of doing this (which to be done properly measures in the Thousands) the disruption to the hotel would be significant.
Also I am concerned that the very act of installing shields will compromise exisiting fire doors
I am all for compliance and in no way wish to compromise fire safety at the hotel but is there not a principal of "reasonable & practical" .
I am also confused by a report from the fire safety reform think tank that states that
"There is no specific legal requirement to install smoke seals in existing fire doors that were not fitted with them when they were first installed in the building."
There surely has to be a common sense approach balancing safety with practicality

[FSO]

So, slight change of circumstances, would heat detection within a hotel room still be acceptable???  It was acceptable at the time.

My stance would be yes for strips and seals on all corridoor seperation, stairwell doors, rooms of higher risk and take a sensible approach on the bedroom doors.

My view only of course.

[The Colonel]

David

Your right there are no legal requirements for your doors but it is good practice to upgrade them if possible and to give a bit more protection to escape routes. Either carry out a fire risk assessment or have a competent assessor do one for you, then you can go back to the Inspecting officer with possibly an alternate solution, there may be alternatives or your doors may be quite good. Get another opinion.

Check out the link in Kurnal's post with regard to Envirograf they do well over 100 products. Many of the smoke and intumescents seals can be fitted without any need to route doors or frames and can be fitted within minutes without disruption to guests or the busines, they are also available in different colours. And costs are reasonable, a client recenlty fiited them to his hotel doors for around £20 a door plus labour

[CivvyFSO]

DavidRH, just for clarity, are you talking about doors between the rooms and the corridor?

[Davidrh]

Hello and thank you all for your help

The doors I have the main concern with are the room doors. ie between the corridor and the rooms which are all self closing hotel bedroom fire doors and as I have said have never been an issue with the FSO before.
The other think that concerns me is that I have the immpression that the FSO is not to sure of his ground anyway.
When I quiried this requirement he said he would have to go away and ask a colleague and then came back with the blanket statement that he has been told that all doors marked in red on our fire plan must have smoke seals

[kurnal]

So have they served an enforcement notice requiring you to this or is it a goodwill recommendation?

Do you have smoke or heat detectors in bedrooms?

Have you carried out a risk assessment and if so have the fire authority commented as to whether it is suitable and sufficient?

[Davidrh]

Hi Kurnal
No enforcement notice just as you put it a goodwill recommendation
We have heat detectors in the rooms and yes I know what you are going to say.. but hotels really really struggle with smoke detectors (false alarms)...believe me its not easy to convince customers not to smoke even though we are a non smoking hotel (all areas) again I site the need for a common sense approach balancing safety with practicality.
We have carried out a full risk assesment and the fire authority seem happy with it

[kurnal]

Hi Kurnal
No enforcement notice just as you put it a goodwill recommendation
We have heat detectors in the rooms and yes I know what you are going to say.. but hotels really really struggle with smoke detectors (false alarms)...believe me its not easy to convince customers not to smoke even though we are a non smoking hotel (all areas) again I site the need for a common sense approach balancing safety with practicality.
We have carried out a full risk assesment and the fire authority seem happy with it

If the fire authority have accepted your risk assessment and not been concerned enough to undertake any enforcement procedures other than for good will advice then is their letter of goodwill advice not simply ensuring that the moral burden of responsiblility is sitting on your shoulders?

They appear to be formally telling you that everything is ok but could be better, there is some residual risk and it may be practicable for you to make improvements but its down to your judgement as to what is reasonably practicable taking into account difficulty, cost, disruption etc and if the problems grossly outweigh the benefits then your duty of care is met.

Theres really no need for false alarms in a properly designed and maintained alarm system but theres many threads on that.

I would think a risk based action plan as I outlined earlier would go some way to proving due diligence.
 
In all honesty many of your peers are in a similar position,  some just dont want to or unable to spend the money to address the hazards after many years secure under the Fire Certificate control,  whilst others take a realistic view of the risk and put together an action plan for improvements based around other  risk and refurbishment etc.

Its all down to your judgement and its your responsibility at the end of the day.

[nearlythere]

I thinks one of the problems with this issue is that many people seem to think that the provision of a smoke seal will solve a problem of smoke leakage around a door. This is not the case.
One of the properties of a fire door is that it has to be capable of withstanding the passage of smoke at ambient temperatures. Some people seem to think that one of its properties is a smoke seal fitted.  Bunging on a smoke seal does not necessarily provide smoke sealing. A good fitting fire door without a smoke seal can be just as effective.

[jokar]

It goes back to understanding fire and its compontents parts and what protection is afforded by various methods including doors and strips and seals.

[stevew]

If I can first pick up on post from nearlythere.

Can't think that I have come across a perfect sealing fire door without a smoke seal fitted.

In the run up the introduction of BS5588 Offices and Shops and subsequent introduction of BS476 31.1 in  the early 80's it was recognised that the gap between the leaf and frame offered no significant smoke stopping qualities.

The revisions to the above specified a maximum leakage rate of 3 metres3/hour/metre at a pressure of 25Pa.  A standard that could only be achieved by a flexible smoke seal.

On the matter of whether or not to fit smoke seals to hotel bedroom fire doors I consider it vital to fit seals to such doors.  If any of my staff were carrying out an assessment on behalf of a hotel client I would expect a recommendation to fit smoke seals to selected fire doors including those to bedrooms.  

As Kurnel rightly implied.  From 01.10.2006 existing fire standards would have needed to be reviewed taking into account new/revised benchmark standards in conjunction with the new RRO guide for such premises.

Suprised the FA did not include the provision on an enforcement notice.  I sense an inconsistency!!!  Confused as to how a FA can issue a goodwill comment on smoke seals in such circumstances. under the current regime.  

Davidrh, the only legal requirement is to undertake a 'suitable and sufficient' assessment of the risk.  If you or your assessor feel that a case can be argued for not fitting smoke seals then go for it.  In my opinion you will fail.  Is it worth taking the chance?