Is there a legal requirement to retrofit CE marked hinges to existing fire doors?

[Guest Peter]

I own a flat in a purpose built 5 storey, 9 flats block built in 2004. Following a fire survey we have been advised that all 20 fire doors are in good condition but need new intumescent strips and replacement hinges (no standard information on existing hinges). All hinges are identical. All hinges are substantial and in good condition. I am a director of the management committee and have a joint responsibility for the safety of the building. My view and that of some of my fellow directors is that this expense is unreasonable and unnecessary.  The building needs other essential work and we regard replacement hinges as a low priority and low level of risk. Do we have to replace the hinges in the short term?

[AnthonyB]

No, if the original hinges approved at the time of installation are in good order and the correct rating for the weight for the door they should be fine - CE marking on new products is not retrospective. Sadly poorly trained risk assessors and unscrupulous fire door companies are costing leaseholders lots of money on things that add no fire real safety advantage.

[Neil Ashdown MAFDI]

As Anthony has said, Construction Product Regulations are not applied retrospectively. There is no requirement to replace existing hinges because they don't have a CE or UKCA mark. Current building regulations (Approved Document B Appendix C) require that:  

[Guest Simon]

Hi, I am a director of a Residents Management Company.  We manage seven four-storey blocks of  flats, built during 2010 to 2012. The flat entrance doors are fitted with three Eclipse adjustable self-closing hinges marked “BS EN 1634 1 HOUR” (image attached).

We commissioned a Fire Door Inspection Report which stated for each door “Replace Door Closer With Fire Rated Type to Current Regulations (Comment: Install an overhead closer compliant with BS EN 1154)”.

I’d be grateful if you could advise whether it would instead be acceptable to (a) adjust the tension on the hinges to ensure they fully close (b) if this is not possible, replace them with “like for like” hinges.  It appears that these hinges can still be obtained from Screwfix.

My concerns with installing new overhead closers are (1) it would more expensive (2) there would then be both overhead closers and self-closing hinges on each door (3) it would appear to go against the following advice from the Fire Protection Association: “… It is essential that the door closer chosen for any specific application or use has been tested in combination with the full fire doorset to ensure that the entire ensemble works effectively as a whole and offers the required level of fire resistance”

Many thanks.

[AnthonyB]

In theory if these are the original correct hinges fitted as part of the fire doorset at the time of installation and are in good order and shut the door flush in frame then they remain acceptable. If truly adjustable they are an improvement on single chain door closers (which aren't) and aren't explicitly forbidden like a traditional rising butt hinge would be. However they are deprecated in some industry guidance so the fire risk assessor should set the acceptable benchmark.
If any are worn beyond adjustment then they could be replaced like for like as still sold and do have test evidence although replacement with standard fire door hinges and a separate EN1154 closer may be preferred. 

https://www.ironmongerydirect.co.uk/product/adjustable-self-closing-fire-door-spring-hinge-102-x-76-x-3mm-polished-chrome-pack-of-3-692924?vat=1&GSP=true&gad_source=1&gclid=CjwKCAjwwLO_BhB2EiwAx2e-3xZjdaWmx_G4CPBW-VTNHS1EbwQua2O8OZedFbdegbS8FR5xUh4vaBoCvCAQAvD_BwE

[Neil Ashdown MAFDI]

Building Regulations mandate that flat entrance doors must self-close from all door-open positions.  The issue with spring hinges is that they often fail to do this completely and reliably. 

https://assets.publishing.service.gov.uk/media/67d2bb074702aacd2251cb94/Approved_Document_B_volume_1_Dwellings_2019_edition_incorporating_2020_2022_and_2025_amendments_collated_with_2026_and_2029_amendments.pdf

This is why guidance at the Code of Practice: Hardware for Fire Doors & Escape Doors requires self-closing devices that meet BS EN 1154 power size 3, as a minimum requirement. 

https://www.firecode.org.uk/Code_of_Practice_hardware_for_fire_and_escape_doors_issue_5.pdf 

[Guest GUY KILBY]

Hello. I live in a high grade,  7 apartment building. It was constructed in 2002. A resent fire door survey failed the door hinges on the basis that they have no CE rating stamp. The doors are large, very heavy and high grade solid oak. The inspector said they were excellent. They have 4 heavy duty brass barrel hinges. 
I see in a previous post that 2002 was mentioned as pre regulation. Does that mean we don’t need to change them? 
 

 

 

[Neil ashdown]

Refer to the earlier post in this thread. In such circumstances, there is no requirement to replace hinges for the sole reason that they do not carry a CE / UKCA mark.

[Guest guest12345]

Hello!

I've inherited a door in a flat that I bought in mid 00's, which was a rental property.

I'm now looking at renting it out again to 4 sharers, and checking regs.

I've only changed the locks since bought (no other mods) and assume it was compliant at the time of buying it from the previous owner (it's an ex-council, 1930-50 constructed, single storey flat in a low-rise council-owned building)

• is very solid...perhaps oak (seems to be at least 30 years old - maybe older)
• has 2 x very solid looking gravity hinges, which are sort of self-closing (but don't close from 15º)
• has no seals
• has a viewinghole
• has a standard letterbox + knocker that looks aluminium
• has a couple of ringers (that now don't work, but don't want to remove/alter the door further)
• has what seems to be a formerly-glazed panel, but now replaced with what could be fairly thin plywood and painted on both sides.

Is there a suitable way to make this FD30S compliant without wasting a very solid and long-lasting door/hinges? I envisage:

• potentially adding a hidden-frame/chain...or overhead door-closer
• intumescent smoke/fire strips
• intumescent threshold strips
• intumescent steel letterbox
• intumescent sheets retrofitted around latches/locks, and hinges
• potentially get new viewing hole with intumescent sheet in surround
• potentially get a custom pyroglass panel fitted with intumescent seals/beading/tape/fixtures

Does this make sense? Is it worth it? Or do I send a very solid chunk of wood to landfill that has been doing a solid job for at least 30 years (and possibly longer!)

[Neil ashdown]

It would very likely be possible to upgrade the fire resistance and smoke spread restriction of your flat entrance door but the term FD30(s) can only refer to either a door with product certification (which yours probably doesn't have) or a door that has been inspected/assessed by a suitably competent person as a Notional FD30(s) or Nominal FD30(s) door.

Before you decide on any action, it would be worth consulting the UK Gov guidance whilst considering the location of the door in the block, fire evacuation strategy and potential risk from fire to the occupier(s) of the flat and other residents at the block.  https://www.gov.uk/government/publications/making-your-small-block-of-flats-safe-from-fire/a-guide-to-making-your-small-block-of-flats-safe-from-fire-accessible   and    https://www.gov.uk/government/publications/fire-safety-in-purpose-built-blocks-of-flats