Smoke seals on service ducts.

[Dinnertime Dave]

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

[Jim Scott]

Is the corridor a sleeping corridor? i.e. The riser would be a protected shaft opening onto a protected corridor?

[Dinnertime Dave]

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.

[Jim Scott]

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.

[idlefire]

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.

[Jim Scott]

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?

[idlefire]

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.
 

[idlefire]

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!

[kurnal]

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.

[Dinnertime Dave]

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.

[Jim Scott]

60 doors?

I presume they are not all riser doors?

[idlefire]

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.

[kurnal]

[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.

[Dinnertime Dave]

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.

[idlefire]

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.