AnthonyB

Do you own the pavement outside? You may need to approach the Council & Building Control first

For an easy to understand up to date summary of the law as it applies to small blocks of flats see this: https://www.gov.uk/government/publications/making-your-small-block-of-flats-safe-from-fire As it's a pre-1991 conversion the technical content may not be applicable in which case you will need this guide (which is a bit out of date in some areas but is the current guide until an update comes out): http://www.cieh.org/library/Knowledge/Housing/National_fire_safety_guidance_08.pdf In theory you can carry out the FRA yourself, particularly if straightforward premises, but it's recommended a risk assessor on the national register is used. Don't use domestic smoke alarms in the common areas until the outcome of your FRA - if a 'stay put' compliant building you aren't supposed to have any and for a conversion requiring an evacuation policy you need a proper Grade A system. Inside the rental flat you meet the minimum requirements of the Smoke & Carbon Monoxide (England) Regulations with a smoke alarm in the hallway and if you use gas/wood/coal a Carbon Monoxide alarm in any room with an appliance using them in (excludes gas cookers) and both can be battery only (mains type preferred though as would cover to the kitchen and living room but this isn't mandatory if existing) Fire extinguishers are not considered necessary in domestic premises generally, but a fire blanket is recommended (but not a legal requirement) in the kitchen

The evidence is in Approved Document B & the Government Purpose Built Flats Guide. You might not like the requirement, but it's there. If it's your flat & you are being compelled to do the work or it's going to be done on your behalf and recharged you could always take the matter to a First Tier Tribunal. If you are the freeholder then your the one legally responsible and you can choose to do what you want - but you need to evidence why it's OK as by acting outside the guides Article 50 of the Fire Safety Order states this tends to prove the Order has been breached for prosecution purposes. Is it the biggest risk being ground floor - probably not. Is the window to a low risk area such as a bathroom or toilet? Also do you have ground floor escape windows - these could mitigate the issue as you then have an alternative escape to the lobby.

There will be a difference in judgement as it's a non prescriptive system - some assessors play it safe and err to modern standards others actual risk assess and take a pragmatic approach as supported by the guidance. Ultimately if matters ever went to legal proceedings it's up to the Court (or the Secretary of State if a determination is sought prior to prosecution to resolve a difference of opinion between enforcer and RP as to an acceptable solution) to decide what was correct in a particular case.

It's not on an open deck, but an enclosed area so the exemption for windows will bottom sills above 1100mm not needing to be fire rated doesn't apply as the lobby will be quickly filled with toxic gases, smoke and elevated heat upon failure.

Partly. Sadly I'm not often down that far in the country but with a new BS5839-1 fire detection and alarm system (don't put wired domestic smoke detectors in, you'll just need to replace them again) that has automatic detection as well as just manual call points then it's quite possible that, if in good order, existing older style fire doors to protect the stairway (i.e. open onto it unless a toilet) and to separate the warehouse from the office block may be tolerable.

New standards are not retrospective as a matter of course, but do have to be considered in a risk assessment - "It was OK originally" is no automatic defence anymore. The FRA should consider the difference in protection between the new & old ways of doing things, also accounting for the size, layout, occupancy & type of preemies and any other compensatory measures in place. This is why small older blocks don't need to replace old style fire doors, but may need to fit modern self closers. Without seeing the construction of the existing cupboards and the meters within it's impossible to say that they do or don't need changing (you can post photos on here which would help) but it's not a given they need replacing - options the risk assessment has are: - Do nothing - risk is tolerable - Upgrade existing cupboards - Replace to current spec

It's completely false that all doors in a commercial building need to be fire doors and it's absolutely not permitted to wait on a roof for rescue - this has never been legally acceptable, you must have sufficient means of escape that do not rely on fire service rescue. In fact nothing much said other than possibly the electrical cupboards is correct. What fire alarm & detection system do you have - that can help in some situations. I suspect you may need a new FRA! Where in the UK are you - if I could see the premises I'd have a better idea of what's needed.

Ah - four floors, that makes a difference, unfortunately they are correct.

If it's a residential system to BS 9251:2021 then the BS clearly states you can exclude these areas unless required by the fire strategy or an FRA

It's up to you as you (or your company) are the one who is prosecuted if the measures are inadequate. A risk assessment should take a holistic approach to an existing building to see whether existing original precautions are adequate or whether modernisation is really needed to ensure safety of relevant persons. If it doesn't contain special fire risk (e.g. boilers, kitchens, electrical rooms, high risk processes) and isn't opening onto a protected escape route then there is no apparent need for a fire door, although I'll caveat that I didn't do the FRA and haven't seen the building. Do the people who did the FRA also provide and install fire doors?

Are you in a standard semi detached house? If so no & no.

No, if it's a stay put block and the cupboard is in it's own fire compartment there is no need for detection even if it did open to the stairs, far less so with an exterior door!

Independent tests by the Building Research Establishment indicate a typical 25 year life (varying by type of device) for detectors and it would be unwise to exceed this although, as long as the devices function during service tests & aren't causing false alarms, there is nothing to make this mandatory. 10 years, often stated by maintenance firms, is purely the warranty period of some manufacturers.

Would the door ever feasibly be locked when someone was inside, requiring the key to escape? If so then really it should be a thumb turn.

Find a new BCO! How many floors is it and what's the planned layout - these are the usual triggers for sprinklers in a single dwelling under Building Regulations. https://assets.publishing.service.gov.uk/media/639ae7e98fa8f5069839c7d7/Approved_Document_B__fire_safety__volume_1_-_Dwellings__2019_edition_incorporating_2020_and_2022_amendments.pdf The Fire Safety (England) Regulations are outside their jurisdiction, won't apply once a single dwelling and even whilst still flats have limited practical scope whist vacant and certainly have nothing to do with requiring sprinklers/mist https://www.gov.uk/government/publications/fire-safety-england-regulations-2022

How many floors? The appropriate guidance is here http://www.cieh.org/library/Knowledge/Housing/National_fire_safety_guidance_08.pdf

The fire risk assessment you have to carry out (you are responsible for legal compliance of the office whilst leasing it and employing people there, not your landlord) would not only address fire risks and required precautions in your office but also the effect of a fire in your office on the flats above. From your description it sounds like this has been looked at in the past and the fire separation deemed inadequate hence why the fire alarm in your unit is also covering the flats. In theory as the system controls and power are in your demise they are under your control for maintenance - this is the default fire safety law position - however this can be overruled by contract law - if your lease includes a service charge and that the fire alarm system in common is a service charge item then the landlord should be maintaining it. There is a legal requirement for cooperation between different Responsible Persons (which can include the landlord where they retain control over an aspect of the building) so your landlord may be breaking the law. If you have fire safety concerns then you should contact the fire service Business Fire Safety Team. If you have landlord/tenant/lease related issues you should contact an appropriate lawyer.

In a block that small 30 minutes fire resistance is usually acceptable which it sounds like it has (notional 30 minutes can be achieved by lath & plaster under timber so asbestos under timber would be better). A small shared lobby wouldn't need to have smoke control and the only requirement would be that the flat front doors were fire doors to the standard applicable at the time of conversion. Stay put would usually be acceptable, no common alarms needed. If there is a stair and landings in common it may be needed to apply the guidance used in your FRA but that only applies where the conversion doesn't give the same standard as a post 1991 build - it's possible in the smallest blocks that were converted before 1991 to still meet the standards that were introduced then. If a common alarm is required then yes it must be mains powered. Residential risk assessment is highly specialised with each case determined on it's merits and whilst there are general trends based on a properties age they aren't hard and fast.

It's nothing to do with Building Regulations which wouldn't apply to an existing building not undergoing alterations - it's a fire safety legislation issue A proper Fire Risk Assessment will determine to what standard the doors need to be - depending on the size and layout of the block older standard fire doors are fully acceptable if still in working condition. The amended Fire Safety Order includes flat front doors, windows and external structure as the responsibility of the freeholder or RMC to assess and ensure are adequate for the risk. Doors that aren't to the appropriate standard must be remediated, usually at the cost of the flat in questions owner and the freeholder/TMC is expected to ensure this is done with an expectation for them to resort to civil legal action or enforcement action via the local authority if needed.

Are they, presumably being new boards, in a non combustible housing, i.e. all metal? They certainly aren't a defined area of special fire hazard.

No, it's not retrospective - as long as it is in safe, efficient working order you are fine.

It's your house, you can do as you wish, you aren't required to.

If the tamper seal on the safety pin is intact then you should be OK. Of course as you should be having these serviced annually the service engineer would have checked this for you. If you are really worried get it serviced again early or weigh it. If it's more than 10 years old it needs other corrective action anyway.

As the Council are the enforcement body then if they are happy with good fitting solid doors to bedrooms and only a fire door to the kitchen then that's all you need to do - this sounds like a Housing Act HHSRS issue so different guidance applies compared to if you were carrying out work under Building Regulations