Flat entrance door and building control

[Guest NickLondon]

I am the leaseholder of a flat in a “higher risk” building (over 18m). 
 

After a recent inspection (as mandated by the building safety act) I received a report from the managing agent of the building that my door needs to be replaced and I am responsible. I have checked my lease and I am indeed financially responsible to replace it. 
 

I want to get this done as soon as possible so I can sell my flat without worrying about the door being raised as an issue during the sale. 
 

But the managing agent and the lease advice service state I need building control approval to replace my door - see https://www.lease-advice.org/faq/i-own-the-front-door-to-my-flat-and-want-to-replace-it-what-do-i-do/
 

I contacted the local authority but they say higher risk building are dealt with by the Building Safety Regulator and sent a link to this application process for which the requirements are mind boggling and way beyond my abilities https://www.gov.uk/guidance/managing-building-control-approval-applications-for-higher-risk-buildings

I have contacted A LOT of fire door installers. None will complete this application for me as ALL of them say it is not necessary. They all say because they have 3rd party certification such as BM Q-mark or Warrington FIRAS they are able to certify the install. “We have installed thousands of doors and it’s fine” kind of thing. 
 

BUT to be sure, I contacted the Building Safety Regulator. They said:

“Fire door replacement can be undertaken as part of a ‘competent person scheme’.  This means installers who are registered within a scheme can self-certify certain types of building work instead of this work requiring building regulations approval from a third party such as BSR.”

The schemes they named are: Blue Flame Certification, CERTASS, Certsure, Fensa, NAPIT, ASSURE

But everyone tells me these have nothing to do with Fire Doors so few (if any) are members of these schemes. Even the couple that happen to be a member of one say they think this is nonsense as they wouldn’t know what to do because it just doesn’t apply.

So… how on earth am I supposed to get a fire door installed that has both the correct certification AND satisfies building control? It just seems impossible!

Does anybody understand how this is supposed to work?

[Neil Ashdown MAFDI]

It seems the Building Safety Regulator might have approached the competent person scheme issue without undertaking due diligence.  Have any of the members of the competent person schemes agreed to quote for the work?

[Guest NickLondon]

I’ve spoken to a couple who were in competent person schemes. One had fensa membership but didn’t do the right doors… they all had upvc frames which isn’t right for what I need. Another had certass but hasn’t got back to me (and I reckon won’t as he didn’t understand how certass applied to fire doors when I asked).

Certass themselves in the meantime say their members aren’t covered to self certify on higher risk buildings. And fensa says similar on their website.

Loads of others had BM Trada or FIRAS specifically for fire door installation but aren’t in any of the schemes BSR listed.

The whole thing is a huge mess seemingly and the BSR seem clueless. But it is them that need to be satisfied. 

[Neil Ashdown MAFDI]

Thanks. I will keep digging and if I find anything useful I will post it on here if I can. 

[Mike North]

The first question is what is wrong with the door?

I am seeing far too many supposedly competent inspectors saying that because a door isn’t up to modern standards that they need to be replaced, they don’t, often some minor modifications can make them acceptable.

As long as the installer is competent, they need not have 3^rd party accreditation, but for doors you need someone like BM Trada or FIRAS if want a certified installation. As far as I know FENSA only deal with external doors and windows

[Guest NickLondon]

The door definitely needs replacing. As does the frame. It can’t be repaired sadly.
 

BM Trada and FIRAS are not a substitute for building control approval for a Higher Risk Building. Unless the Lease advice service and the BSR have both got it wrong. 
 

I spoke with somebody at BM Trada also. They couldn’t tell me either way. 

[Guest NickLondon]

I don’t know why my previous reply didn’t show. 
 

But I have spoken to BM Trada and they cannot confirm that their certification is acceptable by BSR instead of building control approval.

BSR are if the opinion BM Trada is not a substitute for building control.

BSR say only the “competent person schemes” are able to install doors without building control.

It just makes no sense. But then there have been no additions to the “competent persons scheme” list since 2014… so it seems very dated with no acceptable scheme for fire doors, especially given the Building Safety Act 2022 but such an emphasis on fire safety. 
 

Having said that, BM Trada used to be on the list but was removed in 2018. I have no idea why!!!

[Guest NickLondon]

I got confirmation direct from the Building Safety Regulator re. Replacing a flat entrance door in a Higher Risk Building - hope this helps somebody.

1) Yes, replacing a flat entrance door does require building control approval - on any building (Higher Risk or otherwise)

2) No, BM Trada Q mark / Warrington FIRAS cannot self certify in place of building control approval. BM Trada and FIRAS are not “competent person schemes”, and it seems the existing “competent person schemes” which can self certify (CERTASS and Fensa) will not cover work for their members on Higher Risk Buildings 

3) The PAP (principle accountable person) for a Higher Risk Building must be involved with the coordination of the works to consider the impact on the Safety Case

So it would appear any installer that tells you that building control approval is not needed to replace a flat entrance door is incorrect. It is absolutely needed. 

[Neil Ashdown MAFDI]

Interesting and difficult in some circumstances.