nigelh

I think my last post was awaiting moderation when you replied @AnthonyB, and I'm conscious that I'm probably mixing Fire Door specific questions with Risk Assessment questions on this thread. The new assessor has provided some extra info by email (I'm taking this communication as a positive), and he seems to be highlighting two areas of concern . First is his statement about compliance of the doors during original installation: It is my belief that a block built in 1988 should of had fire seals fitted at part of the flat door set though I am unable to prove this. Personally, I don't think it's approporiate to make these kind of assertions without evidence, but I am interested to know whether there is any validity to the assertion. So far, the earliest reference I can find for a requirement for intumescent strips & smoke seals is BS 8214:1990 (which is after these flats were built & signed off). If there's anything in earlier applicable regulations I would be interested to know about it. Second is his general concern about smoke control: The main reason for the flat door upgrade request is the layout of the block. Although only 2 story and a stay put fire strategy there is no compartmentation of stars from landings, as the diagram and accompanying notes below state "Where, in Diagram (b), the lobby between the common stair and the dwelling is omitted in small single stair buildings, an automatic opening vent with a free area of at least 1m2 is required at the top of the stair, which is operated automatically on detection of smoke at any storey in the stair." Taken from current building regulations. A fire in a flat will smoke log the whole of the common area at an early stage of fire and prevent a person wishing to leave to make a safe escape. There is no automatic smoke venting. There is also more than 2 flats per floor. I do recognise that smoke control is of importance, but the current building regs are not retrospecively applicable and the same government guidance document linked previously seems to address this too: 62.8 Flats opening directly onto stairways As indicated in Appendix 1, previous regulations and guidance have permitted flats to open directly onto stairways above the limits in height currently considered acceptable. The introduction of common lobbies in these buildings is not a realistic proposition. A possible approach to this situation when found in existing buildings is as follows. Benchmarks for existing blocks of flats with flats opening directly on to a single stairway Up to four storeys in height, should be acceptable in most situations, provided the stairway has openable windows or vents. Up to six storeys in height, should be acceptable, providing the walls enclosing the stairway are 60 minutes fire-resisting, flat entrance doors are at least ‘upgraded FD30S’ doors and the stairway has openable windows or vents. Within flats there should be internal entrance halls protected with fire-resisting doors to the kitchen and lounge, but not necessarily bedrooms. Over six storeys, should not be accepted without additional measures. These are likely to include AOVs and ‘replacement FD30S’ front doors, but might include fully protected entrance halls within the flats and automatic fire detection. The advice of specialists will be necessary. also the related 62.11 which only recommends the need for AOVs for blocks over 6 storeys, and: 62.23 The following is general guidance only and will depend on the specific circumstances in a block. It refers to flat entrance doors, but a similar approach could be undertaken when considering other doors in the common parts. Benchmarks for existing blocks with a single stairway and with acceptable travel distance, but doors opening directly onto the stairway: Up to four storeys, ‘notional FD30’ doors should be acceptable. Up to six storeys, doors should be at least ‘upgraded FD30S’. Over six storeys, doors should be ‘replacement FD30S’. In all these clauses, there is no recommendation for upgraded FD30S doors in a 2 storey block. The only issue I'm aware of in our block for complying with the `Up to four stories` guidance for any of these clauses is that the management company have failed to replace the lockable handles on the openable windows with non-lockable handles as was requested in the previous risk assessment. As things stand, I am inclined to push back on this because unless I'm missing something, the new assessment appears out of sync with all previous assessments and the government guidelines in relation to the flat entrance doors. My intention would be to start by trying to draw the assessors attention to the relevant parts of the government guidance, but the assessor lists himself as 'TIFireE' which seems to suggest the Institute of Fire Engineers is the appropriate professional body. I think the new assessors are based quite close to you @AnthonyB (S8 0EX). Don't know if you know much about them - feel free to DM if preferred.

Could anyone confirm whether the original requirement for intumescent strips & smoke seals came in as part of BS 8214:1990 please? These flats & doors predate the introduction of that standard, but the new assessor is indicating that he beleives the lack of seals indicates the doors were not been installed correctly in the first place (although went on to say he has been unable to prove it).

You would think this stuff should be fairly straightforward for Leaseholders, but it most certainly isn't. Our Managing Agent is still demanding 'certification'. Every company I have spoken to has stated that they are not able to provide certification for a notional fire door as there is no test evidence for it. Our situation is still ongoing. As I didn't receive the 2023 FRA until late 2024, a new risk assessment has come round in early 2025. The Managing Agent selected a different assessor for the new FRA. On the positive side, I was able to ensure he inspected my door as part of the assessment. He was happy with the condition of the door, the operation of the closer, and even seemed satisfied with the gaps. On the less positive side the new assessor seems to take a different attitude to existing notional doors in general. He seems to be suggesting that even existing notional fire doors should have ALL the features of an FD30S door - like fire rated glass with intumescent instead of the georgian wired glass in the existing doors. This does not seem to fit with the guidance that was linked earlier in the thread including things like: 62. Blocks of flats that do not meet the current design benchmarks for means of escape 62.16 Upgrading existing doors simply because they are not fitted with intumescent strips or smoke seals, or fail to meet some other requirement of current standards, should not be made a generic recommendation applicable to all existing blocks of flats 63.23 Benchmarks for existing blocks with a single stairway and with acceptable travel distance, but doors opening directly onto the stairway: Up to four storeys, ‘notional FD30’ doors should be acceptable. Up to six storeys, doors should be at least ‘upgraded FD30S’. Over six storeys, doors should be ‘replacement FD30S’. And this guidance is also highlighted in other published advice: https://www.gov.uk/government/publications/check-your-fire-safety-responsibilities-under-the-fire-safety-england-regulations-2022/check-your-fire-safety-responsibilities-under-the-fire-safety-england-regulations-2022 In particular, the guidance advises that ‘notional’ FD30 doors, which satisfied earlier standards for flat entrance doors, will usually continue to be acceptable for compliance with the Fire Safety Order unless there is a need to improve their fire performance to compensate for a specific building design, or shortcomings in other fire precautions. The new FRA does not indicate any 'abnormal' risks in the property to suggest there is a reason to diverge from the guidance. I do not believe there has been any material change to the risks in the property. So now I'm now in the situation where all previous risk assessments in this building up to and including 2023 (from at least 2 different assessors) have viewed the existing notional doors as acceptable providing they are in good condition and well maintained, but the new assessor seems to have formed a diiferent opinion and backs the managing agents demand for certification. I'm currently trying to discover / understand why he has taken a different opinion on this. Are these opinions contestable in any way? I undertsand that the local Fire Service should be the final arbiter, but is there a process for Leaseholders to raise concerns about FRAs?

Thanks to both of you for the responses. I was hoping I'd get replies on both the Risk Assessment and Fire Door sides of things so your opinions a greatly appreciated. The government guidelines that @Neil Ashdown MAFDI provided the link to is one of the first documents I found a while ago and have been using to try to guide me on this, so it's good to have it's continued relevance confirmed. One of the difficulties I've had with this process was the apparent discconnect between what the guidelines say and what the Managing Agent was saying, and I'm grateful for the confirmation from @AnthonyB that the FRA and my interpretation of the guidelines are in alignment and that the existing notional doors continue to be acceptable from a fire safety perspective as long as they are in good condition and properly maintained. I do also appreciate that this should be considered the minimum requirement, and that it may well be beneficial / advisable to go beyond those minimum requirements and have some improvements made. The other difficulty seems to be that during initial calls with contractors they often seem to show little or no interest in what the FRA has said about the doors, and without seeing either the FRA or the door in question will just jump to their preferred solution which is usually a new doorset. I originally posted this question in December, but it got lost while awaiting moderation, so after speaking to a mod I reposted after the holidays. There has been some progress since December in that the Managing Agent has back-pedalled a bit on the demand that ALL doors are replaced and seems to be accepting that remedial work and /or improvement work may be acceptable for some doors providing evidence of there efficacy can be provided. I'm not yet clear on exactly what evidence they expect - my understanding is that no-one can certify or gaurantee notional fire doors due to the lack of test evidence for them, and the most I'm likely to be able to get is an opinion. I do intend to get at least a couple of people to look at the door and give opinions, because although things like door gaps can be objectively measured, things like the condition of the door seem a bit more subjective and perhaps not something I should try to judge myself. I would like to ensure I have the best understanding possible about what is required in order to be able to ask people the right questions. My understanding (feel free to correct me) of what is required to maintain an existing notional door is that it needs to be in good condition, well fitting in the frame (gaps within tolerance etc) and fully closing and latching on the automatic closer. The current closer does seem a bit of a grey area and may benefit from a replacement - I've seen terminolgoy that says the door 'must close from any angle', but then guidance for testing from fully open and from 15 degrees. The existing perko seems to work consistently based on that testing process, but would likely struggle to overcome the latch from very small angles (say 5 degrees). The combination of 62.16, 62.21 and the fact the FRA has not made an explicit recommendation to upgrade the doors seems to suggest that adding intuescent strips and smoke seals is not a hard requirement, and this seems to fit with what @AnthonyB has said. I can certainly see why it might be seen as beneficial even if not mandatory. So far I have found one person who seemed competant and willing to look at the door with a view to assessing it for remedial work rather than replacement. He indicated verbally the he felt it could be maintained, but I'm waiting for a quote to outline exactly what set of fixes plus upgrades he is suggesting. ...I'm still trying to find other people willing to look at the door and quote for possible remedial work.

Hi I am an owner/occupier of a purpose built flat in Leeds that currently has the original flat entrance notional fire door in place. The Management Company (and Managing Agent used) are responsible for the communal areas, but I am responsible for my own door. The Managing Agent had a Risk Assessment done a while ago and after initialy providing some guidance to leasholders about checking our fire doors, they subsequently told leaseholders "the doors are not fit for purpose and must be replaced", but having chased them for a copy of the Risk Assessment their latter statement does not appear to tally with the recommendations of the Risk Assessment or my understanding of the fire safety guidelines. I understand that there are also lease terms that may affect whether the Managing Agent can enforce this, but I'm really only asking here about the Fire Safety aspects to ensure I understand that side of things. The flats were purpose built around 1989 with a single building containing a total of 18 flats which are are split into 3 'blocks' each of which has 6 flats over 2 floors served by a communal entrance and staircase. My understanding of the guidelines for risk assessment was that for a property of this size & type, existing notional fire doors would not ordinarily need replacing (or even 'upgrading to fd30s') as long as they are well maintained. My door was not inspected as part of the Risk Assessment, but a sample of doors were. The parts of the risk assessment that comment on the fire doors says: 17.1 Is the design and maintenance of means of escape considered adequate. NO More specifically: ....some issues highlighted about other aspects of the communal area.... Is the fire resistance of flat entrance doors considered adequate, and are doors maintained in sound condition? YES Are suitable self-closing devices fitted to flat entrance doors and, where fitted, maintained in good working order? NO FLAT FRONT DOORS Compliant: 10% of flat doors where sampled. Although there was no certification on the fire door, the fire doors provided reasonable protection as the following was observed: The doors had three hinges The front flat doors are notional fire doors and have 25mm door stops provided. The doors have Georgian wire glazing with no damage. The doors did not have intumescent strips or smoke seals. The doors where good fitting Perko door closers were fitted to all sampled doors. Deficiency: Not all sampled doors fully latched without interference. Deficiency: Although it’s not a requirement to check the apartment doors within article 10 of the Fire Safety (England) Regulations for this development as it’s under 11m, the responsible person still has a duty to put in place general fire precautions in any premises covered by the Fire Safety Order, regardless of the building’s height. It is recommended that all leaseholders are provided with an information sheet explaining what checks they should be carrying out to their apartment door to ensure all doors are kept to a good standard And in the Action Plan that forms part of the assessment: 17.1 As some of the samples flat doors did not fully close without intervention, the Property Manager or block director must check to ensure that all flat doors fully close and latch. Any deficiencies must be actioned and fixed by a competent person. Records of the fire door checks are to be available for inspection. 17.1 It is recommended that all leaseholders are provided with an information sheet explaining what checks they should be carrying out to their apartment door to ensure all doors are kept to a good standard. As existing notional fire doors, they clearly do not comply with regs for certification etc that would be applicable to any new fire door. In addition to the lack of intumescent strips and smoke seals, they don't have intumescent around hinges / locks etc and hinges / locks probably pre-date the standards that would be required for new ones. I also appreciate that as my door was not inspected I can only view the Risk Assessment recommendations as a general 'what is required' rather than any statement of whether MY door is ok or not. So, a few questions: From a fire safety perpective, is there anything in this risk assessment that indicates that the doors must be replaced to remain compliant with fire saftey regs? If there is, could someone explain what I'm missing please. Is there any requirement for an existing notional flat entrance door to be retro-fitted with intumescent strips and smoke seals? My understanding of this was that it CAN be done (possibly as part of an 'upgrade to FD30S' if that was recommended in the risk assessment) but was not a requirement unless highlighted as such. Whilst the risk assessment has made observations about their absence, it does not appear to be recommending that the doors must be upgraded. The situation around strips/seals seems to be muddied by the fact that the original door frames have a 10mm x 2mm groove in them, but were never fitted with any kind of strips/seals - I'm assuming that fitting the doors in this way must have complied with fire safety & building regs at the time of construction or the building wouldn't have been signed off? I've tested the automactic closer on my door (from what I understood to be the recommended fully open and 15 degrees) and the door fully closes and latches on the existing Perko closer. I understand that it may be possible to add an overhead closer rather than removing the existing perko if any improvement are required in this area, and that perkos have been frowned on for some time. If the closer is working as I have described, is there a requirement to do this? As part of reviewing my own door, I beleive the frame gaps (at the sides towards the bottom of the door) are now outside the recommended 2-4mm - they are a bit high on one side and a bit low on the other. It seems likely that a competant person could resolve this by rehanging / packing hinges to even out the gaps. What level of competenance is required to carry out this type of remedial work? If I wanted to consider adding strips / seals to this door, what level of competance is required to do so? I've seen self-adhesive 'Therm-A-Flex' intumescent products that look like they would fit the existing frame grooves, and separate 'batwing' stype self-adhesive smoke seals. The combined intumescent & smoke seal products all seem to require a deeper groove than the one tha already exists, so would probable require routing of frame or door. I've started trying to get people to look at my door, but navigating this topic as an individual leaseholder seems quite tricky. A local FDIS inspector will only look at it if I book out an inspector for a full day which is circa £450. This may make sense to building managers etc who can have many doors inspected for that price, but doesn't seem to work for an individual leaseholder. There are plenty of contractors around who are happy to quote for a full replacement certified doorset (all pretty expensive as they seem to have to comply with new PAS24 regs etc), but there seem to be fewer who want to consider remedial work to existing notional fire doors. For some, it sounds like they assume a minimum of 'upgrade to FD30s' is required. Thanks in advance Nigel