Gov advice note 16 for owners of fire doors in blocks of flats etc

[Suttonfire]

See https://www.gov.uk/government/publications/advice-for-building-owners-on-assurance-and-replacing-of-flat-entrance-fire-doors

As I understand it, the note is suggesting that landlords should obtain test data for existing flat entrance doors and common area fire doors etc.

Yet the purpose built flats guide sets out that existing 'notional fire doors' are acceptable in many circumstances. How on earth is, for example, a large social housing provider supposed to obtain test data relating to existing flat entrance doors in blocks which are decades old. This seems to go against the whole principle of accepting notional doors (although the guidance note refers to the purpose built flats guide which sets out this approach). I'd be interested to hear any views.

[Fire Monkey]

And the Fire Risk Assessor is going to gain access to all of the privately owned flats (to inspect the front doors) in a block of flats how?

[Messy]

Thank goodness I don't work in the residential sector any more. This looks completely unworkable

As Fire Monkey has said, access to all flats will be required, and how many landlords, leaseholders or tenants will have any test certification - or any reference to it?

This will only serve to add a couple of zeros to the cost of a FRA, with very limited benefit!

[Suttonfire]

I have a social housing client who is responsible for 1000s of flats who is very worried about this. I have referred them to the guidance relating to 'notional' fire doors in the PBF guide, and it is their view that the new gov advisory is 'raising the bar' in relation to what the enforcing authority would expect.

This is a huge departure from the PBF guidance and totally unrealistic to expect a housing authority to be able to obtain this type of information for the numbers of flats which they manage. It also seems to be setting up the fire risk assessor for a fall. How much weight would this type of gov advisory note hold in relation to the PBF guide?

Am I still doing the right thing by using the PBF guide as my main reference publication when assessing blocks of flats?

[Fishy]

This has generated a rueful smile.  I pointed out the potential issues with this 'notional' description applied to fire doors (where we use it nowhere else in fire safety) years ago... http://www.crisis-response.com/forum/index.php?topic=6744.0 .

Has this 'raised the bar'?  Emphatically, yes, and this is only one aspect of fire safety in existing residential buildings where this is likely to be the case.  The landscape is changing, & we need to get used to it...

[Suttonfire]

I can't see how this guidance can co-exist with the PBF guidance in relation to flat entrance doors  - completely opposite advice (although the advisory note also states that landlords etc 'may want to refer' PBF guide ).

Unless the PBF guidance is revised or is no longer considered to be 'current' guidance, surely as a risk assessor it is still valid to work in accordance with it (whilst applying the guidance from the 'advisory note' where it is more practical to do so, i.e. for a landlord who is responsible for a couple of flats  - rather than an Authority responsible for 10000+).

[AnthonyB]

The last formal guidance on FRA in resi said that the PBF guide was still valid and acceptable.

The latest doom and gloom on fire doors failing also seems to have involved testing a door with fires on both sides, which is rarely the conditions they would be exposed to particularly in the life safety phase of a fire.

I try to get in a sample of flats every time, it's hard work but doable with plenty of notice and cooperations with the TMC/Freeholder/Agent in putting the effort in and even if they don't, if there are signs of life in one of the flats it doesn't hurt to knock on the door and politely ask to look, it's never failed me yet. The biggest problem is when you don't get help with access and on the day all the residents are out at work.

Too many people think residential is an easy job to FRA, yet it's far from that, most of my troubleshooting work currently occurs on the back of cringeworthy FRAs that have been rumbled by an RP or FRS as not being up to the job.

[Animal]

This thread seems to have caused more uncertainty than Brexit.

Firstly it is advice, nowhere in the document does it state you must follow this guidance implicitly.
Nowhere does it say if you cant get the original data specification on the existing doors does it say you must replace them with new FD30S door sets.

A notional fire resisting door is a twenty/thirty minute door which is not fitted with strips and seals, even if you fit strips and seals it is only an upgraded notional door not an FD30S door set.

So a new 30 minute fire door blank purchased from the local builders merchant is a notional door.
Where a notional door is fitted the PBF guide gives guidance on where they can and cannot be accepted (risk assessment).

Nowhere in the advice document does it say you cannot accept a notional door.

The reason no other guidance document refers to notional doors other than in PBF is because no other guides on other types of premises have been published since the PBF guide.

The reference to PBF guide  for fire resisting doors still allows you to make a a professional opinion on what you see and justify your assessment of said doors.

When the government produces guidance and where it could cost the greater public pound notes it carries out an impact assessment, I do not believe this was done before this document was produced.  

It is very easy to read this document and take the view that all flat entrance/stair/cross corridor doors etc. must be modern certificated doors. I am of the opinion this is not what this document implies.

It does refer to the words benchmark guidance so we must refer to guidance on new doors and existing doors.

So to put this in to context would you have accepted three brass hinges on a fire resisting flat entrance door before this new advice was published and who now would want them replaced with steel hinges?

Who would  accept a recently fitted self closing device and a new letter box that was not tested with the door for certification?

I wonder if fire resistant cat flaps advertised on the world wide web are still acceptable as they are not mentioned anywhere?

A random thought!

[Suttonfire]

It states that: 'Landlords or building owners should replace flat entrance doorsets if they suspect they do not meet the fire or smoke resistance performance in the Building Regulations guidance'

Also, point 9 states generically in relation to existing flat entrance doors that 'Flat entrance fire doors should have test evidence demonstrating they meet the performance requirement in the Building Regulations guidance for fire resistance and smoke control from both sides.' I would interpret that advice as suggesting that an existing notional fire door would not be sufficient.

Obviously it comes back to being competent to do a risk assessment and apply professional judgement; however, part of arriving at that judgement is taking into account new guidance which applies.

[Fishy]

This is new government guidance; prompted by the events and findings post-Grenfell.  I'm not sure there's much ambiguity that this is more current than the LGA guide and that the concept of a door with 'notional' fire resistance doesn't feature in MHCLG's thinking?  That's a good thing, in my view, because I was always uncomfortable that it was a flawed concept (see my earlier link to a previous forum discussion - I won't reproduce my concerns here).

As I said, the whole landscape around residential fire safety has changed, rapidly, and will change further.  Societal expectation has increased substantially, and Government has picked this up.  This document is only one of a whole suite of guidance that has been issued by the MHCLG's Building Safety Programme and which is available here: https://www.gov.uk/government/collections/grenfell-tower.  If you look here: https://www.local.gov.uk/fire-safety-purpose-built-flats the LGA themselves say that they will be reviewing their guidance, and refer people to the MHCLG / DCLG published guidance.  Is this a licence to print money for the fire door industry?  Probably, but we have to remember that these are not 'normal' times in this aspect of fire safety.

Continuing to use the LGA guide in preference to all the DCLG / MHCLG guidance that has been produced (on this matter, and many others) since the tragedy is insupportable, I would suggest?

[colin todd]

Calm down dears.  it is sad that following the terrible tragedy of 72 deaths in a fire, we have a further tragedy, namely the death of rational thinking and common sense.  Fish face may be right that it will never be resurrected.  Who knows.  In the meantime:

1.  The Minister told the house that the PBFG remains current.  It is in Hansard.  He has not as far as I am aware changed his mind in the current hysteria.

2.  The EP guidance all came out of the latest hysteria regarding the failure of a proprietary door to achieve 30 minutes fire resistance in a fire test that does not simulate any real fire.  It is not intended to imply you change all old doors.

3.  The scope of the guidance states that it is to help people who WANT TO REPLACE THEIR FIRE DOORS.  Those with common sense and a store of beta blockers to calm their nerves do not want to replace their fire doors so the note is irrelevant.

4. There is a certain irony that those who bought certain brands of new doors to replace doors that would achieve 15-20 minutes fire resistance ended up with some new doors that achieved 15 minutes FR.  That is a trading standards issue but barely impacts on fire safety.  Even the EP say the issue is LOW RISK.

5. The notional fr concept was not new.  it existed (e.g. in relation to lath and plaster ceilings) donkeys years ago.

6. The adoption of the notional fr concept was agreed by the DCLG, CFOA the Office of the Chief Fire and Rescue Fire Adviser, the Housing sector,  a number of individual fire brigades.  Were they all wrong?   That is because it is well known  by anyone with practical experience, as opposed to theoreticians, most of who cannot even explain the relevance of 30 minutes as opposed to 20 minutes,  that 5 minutes domestic doors often survive a burn out.

7. Failure of a fire door in an FR test does not mean that there is a big gaping hole where the door used to be.  It can mean a little lick of flame on the safe side lasted for 11 seconds and then went out, never to return, or that a cotton pad taken up to the door and held there will begin to smoulder.  If residents in a block of flats are wearing a cotton jumper, intend to get on a set of steps (having done their working at height training) lean as close as they can to the top of a door to a flat in which there is a post flashover fire IN THE HALLWAY, they should be afraid, very afraid.  Other wise, their loss of sleep should arise from the question as to where the money is going to come from to replace 7312873893817831 doors, rather than find food for the starving.

[Mar62]

One of the issues that is cropping up is WHO is actually responsible for replacing the flat entrance door. A managing agent i know where i have questioned the condition of the doors (1960's doors, self closers all removed, old letter plates, no seals, some doors warped, cat flaps cut in etc ). They are now embroiled in the row with residents and resident committee as to who pays. The flat owners / leaseholders apparently own their front door and are refusing to replace but the managing agent is responsible for the common parts. So much so they went to see a lawyer who now wants ?2000 per block just to study the leases. They have been going round in circles for months.

[Fishy]

One of the issues that is cropping up is WHO is actually responsible for replacing the flat entrance door. A managing agent i know where i have questioned the condition of the doors (1960's doors, self closers all removed, old letter plates, no seals, some doors warped, cat flaps cut in etc ). They are now embroiled in the row with residents and resident committee as to who pays. The flat owners / leaseholders apparently own their front door and are refusing to replace but the managing agent is responsible for the common parts. So much so they went to see a lawyer who now wants ?2000 per block just to study the leases. They have been going round in circles for months.

...which is partly where recommendations 3.1 and 3.5 of the Hackitt Report stem from.  The maintenance of flat entrance doors is mentioned as a particular issue, in the narrative that accompanies 3.5.

[colin todd]

Mar, tell the client to come to me.  I will advise them how to proceed  for ?1000 per block.

[Fishy]

Mar, tell the client to come to me.  I will advise them how to proceed  for ?1000 per block.

A thousand questions per block?  Sounds about right...