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FD20 doors

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The issue I am having is this as it stands I do not believe the fire doors installed in my property are indeed fire doors, because of their standard of installation. 
 
I live in town house, with a floor above 4.5m and therefore it is a requirement for the house to have a compartmentalised staircase to provide a safe escape route in the event of a fire. 
 
The building control requirements are for an FD20 door, but no FD20 doors exist as it is impossible to test to. The doors installed are therefore FD30 door leafs, this has been confirmed by the confirmation of a BWF certificate on the top of the leaf and confirmation from Premdor.  
 
However this is where I believe, and have had confirmed by numerous other industry professionals, that compliance with Building Regulations ends.
 
The manufacturers certificate stipulates the way in which the door has been tested and how it must be installed to work as a fire door. It gives very similar information to the BWF's own guidance.
 
I did the 5 step check on the doors and this is a summary of what I found: 
 
Four of my door leafs do indeed have a certificate, One of the doors has a damaged certificate, therefore inline with the BWF guidance and Premdors Certification and Guarantee this door does not comply and can not be used as a fire door. 
 
The gaps to the undersides of my doors are close to if not in excess of the 10mm maximum allowance for doors. In fact my Kitchen door is actually 20mm. This exceeds the manufacturer's allowance and the BWF's and building regulations.
 
The doors as installed are certified as fire doors on the basis that an intumescent strip is installed. This is because, as the manufacturer's certificate states, they have been tested as fire doors with an intumescent strip and are therefore required to have one. The intumescent strips installed are faulty, loose or missing and therefore do comply with the manufacturer's certificate and therefore are not compliant as the manufacturers certificate relies on these being in place. 
 
The hinges, to comply with the BWF certificate the manufacturers guidelines and the british standards, need to be CE marked to comply with all of the aforementioned. The hinges as installed do not have CE marks, there is no proof of one and such they do not comply and therefore are not fire doors. 
 
The doors also, as part of the manufacturer's certificates, need to be sealed. None of the doors are sealed fully and therefore do not comply. 
 
Building control are insisting that the doors do not have to be installed in this manner, and that it is only reasonable provision that needs to be provided, yet there is no proof that the doors will satisfy an FD20 rating because it is impossible to test or prove, it has only ever been proven as a fire door as tested.
 
Building control are also insisting that as long the door hinges are not aluminium they will sign them off and that the CE marks are a trading standards issue. As I understand it hinges used on fire doors are covered by a harmonised European standard (hEN) and british standard which states they have to be proven to be fire resistant and therefore must be CE marked to prove this, this is written into law. No fire door hinges can be sold on the european market without a CE mark and yet building control are insisting that it's not a requirement and as long as they aren't aluminium they don't care. 
 
They also are adamant a gap greater than 20mm under my kitchen door is acceptable and that the gaps around the other doors satisfy as well. They also aren't concerned by the damage behind the hinges where one door is split and gaps are present. 
 
My concern is this, the doors as they stand, do not meet any level of standard set out by the BWF or any manufacturer or fire safety site, they do not comply with european or british law (hinges primarily) and the only people saying they are fine are those from building control who have also been paid to provide LABC warranties on the property. 
 
They have also told me in an email that they will be issuing a completion certificate once the external works (which were built level with my DPC) are corrected.
 
Included is a link to an album showing the installation of the doors briefly.
 
Thank you for any help
 

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The Building Regulations are clear. Performance of Fire Doors should be in accordance with the tests BS 476-22 or BS EN 1634-1 and the Building Regulations also state that the test evidence applies to the 'complete installed assembly'. 

Therefore the fire door installed at your house should be compliant with the relevant fire performance test for that particular door leaf. The door leaf manufacturer will be able to provide a data sheet showing the installation requirements including all ironmongery, intumescent seals and fire stopping around the frame at its junction with the supporting wall. Only doors installed in compliance with the fire performance test evidence are acceptable.  

If the fire door is not installed in this way, what evidence is there that it will provide the required fire separation performance?

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You could contact the fire door inspection service at http://fdis.co.uk/  and have an inspection which will provide a written report which you could use to appeal against the building control decision. You also check out the https://www.planningportal.co.uk/info/200128/building_control to see if there is any help there.

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Guest 123

There are errors in what you are saying but people on here have a vested interest in their response. 

1 fire doors never fail in testing due to gaps at the bottom. They always fail at the top. Indeed if you read fire brigades reports there is always up to 100 mm of clear air at the bottom of a room in a fire. Under door gaps started being asked about so people started testing with a 10mm gap. Nobody knows if 20mm is ok but I believe it would be.

2 building regs clearly states hinges just have to be all metal construction to hold a fire door in fire situation. The CE marking is just again what the door manufacturer tests with before CE they would just be metal hinged so there is historically loads of evidence that a metal hinged is fine. Indeed once the intumescent goes of it will hold the door in place not the hinge. 

3 you clearly have intumescent fitted in the frames it may look badly fitted but when it expands what you have is fine.

4 as for 20 minutes tests manufacturer s do do them for big developers and even some developers do them themselves. I have seen a 35mm door with no intumescent pass a 20min fire test. (Barratt s hold the test certificate on a vicaima door.)

Our fire regs testing has gone on for years and years so there is loads of evidence out there for different things it does not all rely on the manufacturer test evidence. Sometimes an expert has to weigh it all up. 

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Interested by comments from Guest 123. Fire doors undergo testing for fire separation performance and manufacturers product data sheets enable installers to replicate the test conditions at least in terms of the product installation. The fire performance tests are conducted to British and European standards and of course the real-life fire that could occur in a building may differ to the fire conditions used for the test.

The door manufacturers product data sheet says:

1) Door to frame gaps: 4mm maximum at the vertical edges and top edge. 10mm at the threshold. 3.5mm between the meeting edges of double doors.

2) Hinges shall be CE marked for use on timber fire resisting doors. In addition the blade height is to be 100mm (+20mm -10mm), blade width 30mm (+/- 3mm), blade thickness 3mm (+/- 0.5mm) and knuckle diameter 13mm (+/- 1mm). Hinge fixings to be a minimum of four steel screws no smaller than No.8 by 32mm.

The product data sheet also states ''........certification is conditional on these instructions being complied with in their entirety.........failure to do so will invalidate this approval and may jeopardise the fire performance of the door''.

British standards and other guidance documents have been produced to help ensure that fire doors are installed correctly. These documents are authored by experts in the subject. I believe that when installing, repairing or maintaining fire safety devices such data sheets and guidance documents should be complied with. When working in the field of fire safety decisions made and work carried out should surely be backed up by performance data and best practice guidance. If we don't follow such data and guidance how can we evaluate likely fire performance. 

Footnote: a) Guest 123 seems to be contradictory  in paragraphs 2 and 4. b) Timber fire doors vary in their core construction and framing construction (therefore fire separation performance will also vary) and so parallels should not be made between different doors. 

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This is the response I have received from the mayor of North Tyneside:

"I have liaised with our Building Control team who have provided me with the following information.

 I would advise that the Building Regulations require nothing to be done except for the purpose of securing reasonable standards of health and safety, i.e. reasonable provision must be made.

 The guidance in approved document B Vol 1 requires the installation of FD20 doors in the property in question. This guidance also mentions the use of steel hinges resistant to fire for a set period, min  800 degrees C. The hinges installed in this case exceed that requirement, i.e. 1400 degrees C.

 The industry standard, including guidance from the Building Control Alliance, is for such doors to be used in situations such as the one which exists on this site. This is widely accepted practice throughout England and is accepted as providing a sufficient level of protection to escape routes within dwellings. This is also accepted without objection from the Department for Communities and Local Government (DCLG); the government department which oversees Building Regulations and was confirmed by them only  last week in response to this query. This has been the case for many years, i.e. the use of such doors in this situation unsupported by fire tests or independent certification.

The DCLG have also previously confirmed that to provide reasonable compliance all that is required is a reasonably robust door, not necessarily a fire door. This is deemed sufficient to protect the escape in dwelling as part of the overall fire safety measures within the dwelling which also includes management of the property by the householder i.e. closing doors at night etc. Many non-fire rated doors satisfy this requirement. 

 The standards being quoted by the owner are in excess of that required to show compliance with the Building Regulations. I understand that there have been many points raised regarding the suitability of the installed doors, not least of which revolve around the suitability of the hinges. In particular, that the hinges are not in accordance with the Construction Products Regulations (CPR) as they are not CE marked.

 This is not a requirement under the Building Regulations; indeed I would point out that Building Control have no enforcement powers with respect to CPR, CE marks, British Woodworking Federation or British Hardware Manufacturers requirements.

 They all have their own guidance/standards but it is not incumbent on Building Control to enforce them.  Building Control only has to ensure reasonable provision has been made; hence the use of a reasonably robust door is acceptable.

Building Controls’ remit is to make a judgement on whether the objectives of the Building Regulations have been met. A degree of flexibility is built into the Building Regulations guidance documents to assist with this.  As mentioned previously, the widely accepted industry practice is to install doors such as these in this typical situation.

This has been confirmed in my recent conversation with the Department for Communities and Local Government, Building Regulations Division (DCLG) and previous technical information from the Building Control Alliance (BCA).

Regulation 7 of the Building Regulations whilst referring to CE compliance also allows other avenues for compliance, i.e. past experience can be taken into consideration.

You also makes reference to Regulation 38 of the Building Regulations (Information to be provided by the person carrying out the work/Fire safety information).This only applies to relevant buildings, the definition of which relates to the Regulatory Reform Fire Safety Order (RRFSO). This is not applicable in this case, i.e. it does not apply to dwellings. Dwelling houses are not covered by the RRFSO.

As you are concerned about the quality and acceptability of the works it is recommended that you take this up with Persimmon Homes as a civil matter and/or pursue with Trading Standards if not successful in dealing directly with the Contractor.

 I understand that the dwellings have been and will be issued with completion certificates once the inspecting surveyor is satisfied that the Building Regulations have been complied with."

I find it hard to believe that they can ignore the damage to the doors and frames let alone the unsatisfactory installation.

 

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Any fire door should be installed correctly and be well fitted if it isn't then it will defeat the purpose of the door. However the BCO/AI who completes the final inspection has a degree of flexibility to decide if any items meet the required standards and provide the completion certificate. 

It's only when the Building Regulations and another piece of legislation clashes, resulting in the enforcing authority, challenging the Building Control. But unfortunately many times a satisfactory result is not achieved and the owner has to put matters right. 

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Approved Document B of the Building Regulations sets out the requirements for 'providing early warning of a developing fire, satisfactory escape routes, preventing fire spread both within and to other buildings and providing good access and fire fighting facilities for the Fire Services'

In this case the regulations appear to have failed. 59eee5de6e685_AppendixBFireDoors.PNG.1fe1087a119a1750bc438b7ef792f9b8.PNG

The question really comes about from Appendix B clause 3 which says unless it’s tested then it must be 800 plus - despite clause 1 saying the entire set should be tested - yet another contradiction in the Regs themselves.

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Guest Dan

Approved Documents are NOT regulations, they are guidance to assist a professional in carrying out his duty.

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Fifty/sixty years ago, guides and the building regulation guides referred to FD20 fire doors and cross corridor, smoke stop doors, where FD20 doors, fitted with cold smoke seals.

Consequently manufacturers produced FD20 doors but over time, less and less guides referred to FD20 doors, therefore manufacturers thought it made more sense and reduced costs to only test to FD30 standard, which of course can be used as FD20 door.

Nowadays very few if any fire doors are tested to the FD20 standard its all FD30 standard. I would imagine  any door tested to the FD30 standard which fails but passes the FD20 level could be termed an FD20 door but would it be economic to produce them as they are very rarely called upon.

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