Roller Shutters as final exits in places of assembly

[SidM]

3 storey building half occupied by a clothes warehouse and the other half occupied by a church.  The ground floor of the Church's half of the property is unoccupied and the church uses the first and second floors.  There is a potential for 200 people in total on both these floors.  The clothes warehouse has low numbers and occupies ground and first floor only.  The church has two staircases including a communal staircase.  The clothes warehouse has 3 staircases including the communal staircase.  Both occupiers operate different hours and need use of the communal staircase (one becuase of travel distance and the other because of numbers).  The final exit from the communal staircase is a roller shutter operated on a key fob which is held only by the church pastor.  The owner of the clothes warehouse does not want a key fob; he wants the roller shutter removed, full stop.  His argument is that it was installed without his permission.  The church want to keep the roller shutter for security reasons and argue that there should be no problem if both occupiers have a key fob and the shutter remains open when the premises is occupied by whichever part is using it.

My question is: are roller shutters permitted in such a situation?  Page 81 of the Small & Medium Places of Assembly Guide seems to allow roller shutters provided they are locked open yet page 82 says roller shutter gates should not form any part of the emergency exit system.  What do I recommend, remove the roller shutter or allow it as it is so long as they guarantee it remains open and that in the in the event of a power failure the shutter will remain open?

[nearlythere]

........page 82 says roller shutter gates should not form any part of the emergency exit system. 

I take this to mean that persons evacuating the premises should not have to operate a roller shutter in order to escape. Roller shutters are now common external security barriers which are secured open during material times.

[PCURRAN]

The Building Regulations would not prevent the use of a roller shutter on a escape route providing the roller shutter is not obstructing the exit route when the premises is occupied. The main issue is one of management of the situation and insuring the availability of the escape route.

[afterburner]

To over emphasise what has already been said, the roller shutters need to be open and secured in the open position from opening time in the morning until closing time at night. The FRA should detail the management processes to ensure that this happens everytime and all the time.
Once everyone leaves the roller shutters can be closed and secured.

[nearlythere]

To over emphasise what has already been said, the roller shutters need to be open and secured in the open position from opening time in the morning until closing time at night. The FRA should detail the management processes to ensure that this happens everytime and all the time.
Once everyone leaves the roller shutters can be closed and secured.

I have to clarify your statement for you afterburner. The roller shutters need to be open and secured so during those times anyone is on the premises where that escape route is required for those persons.  eg staff, after hours workers etc.

[afterburner]

No problem with your clarification NT, what I meant by opening time was the arrival of the first employee with access to the premises and closing time exactly that, closing the place up for the night by the last person leaving. Yes we're chanting the same message.

[Mike Buckley]

I agree with the point that the roller shutter is acceptable with the provisos above. If I remember correctly gates in the roller shutter are not. These are doors in the actual roller shutter which would need to be up to fire exit standard and this cannot be achieved. The logic being that if the roller shutter is locked open when the premise is occupied it effectively does not exist and cannot hinder escape, whereas if the roller shutter gate is in operation the roller shutter itself must be closed and the gate restricts the MOE.

As far as the dispute between the church and the factory owner is concerned who is the Responsible Person for the communal areas of the building? This is the person who needs to carry out the FRA and decide on the appropriate measures. Unless the factory owner actually owns the building I wouldn't think he has any say in the provision of the roller shutter. If he is concerned about the security of his factory he can take measures within the area under his control.

[Clotty]

As an inspecting officer I would accept this situation with the proviso that, as mentioned above, at all times persons are in the building that the shutter remains locked open, however I would expect the management of the roller shutter to be included in the risk assessments of both occupiers.  With regards to their dispute, thats down to whoever owns the building.  Don't forgat that under article 22 they are required to cooperates and coordinate with eachother, and as such the shutter should not have been fitted without consultation with all those that it would effect.