Hi,

It's my first post here but I've been a long time reader - I wonder if somebody could clarify a matter for me.

On one of the sites I'm involved in, there are numerous nominal fire doors which are deemed semi-critical to the fire strategy of the building (I say semi because of the other measures in the building which have improved MoE and early detection and warning (e..g over L3).

These are clearly very old existing doors built way before BS 476 and 8214. They do not have any certification labels or plugs to confirm they have been tested for fire resistance in a furance. They are all 44mm thick and the majority do not have any intumescent seals or grooves to support seals. The majority of the door gaps between the vertical edges and frames are less than 4mm, most are less than 1mm (the areas where these are is deemed acceptable in the FRA as the risk of the door warping and binding on the frame in the event of a fire arguably would have little effect on life safety, as in these cases somebody would have made their escape from such a plant room way before the fire would have been able to affect the doors in such a way. Some doors also have Georgian wired glass which appears to have installed with glazy putty only and no intumescent sealant/seals between the beading and glass.

In their professional assessment (as a technical engineer and experience in FM), the doors in the majority of cases would be satisfactory as nominal FD30 (s) doors, even without the intumescent seals. On some of these intumescent seals are being retrofitted where the door gap is closer to 4mm than 2mm, especially where adjacent to critical escape routes. Certain other remedial works are being implemented where the doors should provide protection against cold smoke (i.e. retrofit of batwing seals / additional of drop down seals where the threshold gap is > 3mm and threshold strips can't be added due to flooring types, trip hazards etc).

However, I want to clarify what judgement the Responsible Person (or whoever is delegated in its stead) is able to do with respect to nominal fire doors. The FRA is being conducted in house and the individual is more than competent. If they are able to suitably determine such a door would likely perform its function as an FD30 door (assessing thickness, frame gaps, penetrations, assessment of non-compliant remedial works (i.e. against accepted good industry practice), closing devices, presence of intumescent material for ironmongery, fire-rated ironmongery etc), in the same way that a fire door inspection would do, is there a need for them to engage external services? They are not officially 3rd party certified by BM Trada or FDIS, or similar. Obviously nominal fire doors should be assessed by a competent individual who is able to assess their suitability for the intended fire compartmentation function - my question basically is what determines competence.

The previous organisational mismanagement of fire safety affairs and the building in general means there is no paperwork to support the doors were ever formally assessed to be nominal FD30 doors. There is neither any evidence of a previous FRA conducted on the site. Since acquisition of the site, there has been a lot of work to establish levels of compartmentation and risk assess and generally improve the fire safety profile of the building - does there need to be any 3rd party appraisal if they can manage this in house and have the technical knowledge? Obviously an FRA can be done in house as liability falls on the Responsible Person (organisation), the question is whether granular assessments such as fire door "compliance" can, and would stand up to scrutiny in court if anything untoward was to happen.

Sorry for the long-winded message, hopefully somebody can help and provide some clarity on the technical legalities of their approach.

Under the Regulatory Reform (Fire Safety) Order 2005 the Responsible Person must carry out a suitable and sufficient Fire Risk Assessment. They must keep relevant persons safe by managing fire safety risks and implement preventative and protective measures. Under Article 18 of the RR(FS)O the Responsible Person should engage one or more Competent Persons to assist them in their duties as necessary. The RR(FS)O describes the Competent Person as somebody that has sufficient training and experience or knowledge and other quailities to be able to properly assist in undertaking proctective and preventive measures.

Where an employee and where an owner or employer has sufficient competence they may carry out the Fire Risk Assessment to the extent that they have the necessary competence. The fire doors should be part of that fire risk assessment and the person assessing them should be able to show they have the necessary competence, but that does not necessarilly mean they must have specific qualifications relating to fire doors. https://www.legislation.gov.uk/uksi/2005/1541/article/18