AnthonyB

Passing Building Regulations does not mean a premises complies with the Fire Safety Order, principally because the system doesn't really work and many buildings with completion certificates fail to comply because the completion process doesn't thoroughly check for any defects, shortcuts, use of incorrect materials or poor workmanship affecting efficacy, as many premises have found out post Grenfell (which was also certified as having passed Building Regulations at the time despite defective design and works) when subject to enforcement action due to latent defects. If the FRA highlights things that were a requirement of the Regs at the time of conversion but were overlooked there is a need to do something. If the issues weren't a requirement at the time of conversion but are now, as the fire safety legislation (unlike Building Regulations) has no statutory bar and has to account for technical progress and current standards, the FRA has to determine if meeting older standards is still safe or whether modernisation is required - for some matters the old approach can remain valid, for others it has been proven to be too inadequate and some improvement is needed. If it properly complied in 2017 there isn't a lot that should be wrong (however this relies on it being properly done which isn't a given these days) but note that many aspects of fire safety legislation (that have been around for a long time) aren't covered by Building Regulations, just the fire legislation so if compliant on the B.Regs front could still have been lacking since 2017 as they wouldn't have been checked by Building Control

It's not just a good idea but a legal requirement in virtually any premises that is not the interior of a dwelling

I'm guessing the metal door is between the garage and the outside? If so use what you want.

The requirement has nothing to do with Building Regulations (which are indeed not retrospective) but the Fire Safety Order which requires an assessment against current standards, knowledge and technology and has no statutory bar allowing retrospective application of guidance. The fire risk assessment is the means of determining if the difference between the old standards and todays is such that it presents and unacceptable risk. Some approaches used in 1975 would remain acceptable, others have been found to be sadly lacking, often associated with fatalities. A decision tree should be followed by the assessor:

It depends on the reason for failure, also realism needs to be taken into consideration - there could be dozens or hundreds of doors to replace. In the grand scheme of things the front door is the most important as it affects the most people. In the interim even a well fitting standard door will provide some fire resistance (if you keep it shut) allowing escape so it's not as if fire could rip through the premises in minutes.

It would be down to risk assessment - empty does not mean risk free (which is why vacant premises are not exempt from the Fire Safety Order). I'd be looking at things including: Removal of all combustible materials and waste Isolation of gas & electricity security against arson & unlawful occupancy as part of determining if it was tolerable or not

For non domestic applications I suggest you refer to the guide linked here : https://www.fira.co.uk/technical-information/flammability/fire-safety-of-furniture-and-furnishings-in-the-contract-and-non-domestic-sectors

If they are part of a linked system there would be a central control and monitoring panel or link to a BMS PC allowing you to check test results for any defective fittings. If just individual fittings with a self test function then you will have to check the information on the data plate on the side of the fitting or catch one that is faulty or in self test mode so you can see the different LED colour and flash combinations that show this. Whilst you don't have to test them monthly you still have to visually inspect them monthly to see if any are showing a fault code or are completely dead. More info: https://mountlighting.co.uk/technical/self-test-emergency-lighting-explained/

Oh dear, that's not right. If it needs to be linked it should be and why are there going to be false alarms - unless the system is poorly designed or poorly maintained or the shop operator is generally negligent in their work there shouldn't be any. The flats wouldn't false alarm the shops as the communal alarm system only needs a heat detector in the flats. The local domestic system in each flat, which would be liable to false alarming from the hallway smoke alarm if the kitchen or bathroom door is left open and there was lots of steam or burnt food, is local to the flat only and wouldn't affect the shop. Somebody has been very poorly advised - sadly there are a lot out there that really shouldn't be in the fire safety business e..g https://www.hantsfire.gov.uk/company-and-its-former-director-ordered-to-pay-more-than-100000-for-insufficient-fire-risk-assessment/

Hi - this links you to appropriate guidance https://www.fira.co.uk/technical-information/flammability/fire-safety-of-furniture-and-furnishings-in-the-contract-and-non-domestic-sectors

I actually answered you back then and we had a conversation. ---- The EL testing was OK, but the smoke ventilation was different. The smoke ventilation system needs to be tested annually by a competent person as per Article 17 of the fire safety order so it is maintained in an efficient state, in efficient working order and in good repair. There is a lot more to this than just testing it operates and requires a specialist contractor (many electricians and fire alarm companies don't maintain them properly either, a smoke vent specialist is recommended)The same Article applies to the emergency lighting however as the annual duration test only differs in duration to the monthly you could argue that you are competent to do the basic test with other competent persons brought in for repairs. ---- Thank you very much for your reply, Anthony. This seems like good news as I can carry out the 3 hour test in the exact same way as the monthly on/off test, and I’m happy to bring experts in to carry out repairs. I’ve looked at the Fire Safety Order, Article 17, and I’m interested in how are you interpreted this document to provide your response, just so I can clearly explain this to my fellow residents... https://www.legislation.gov.uk/uksi/2005/1541/article/17/made Thanks, once again, Gary ---- If you mean not testing the smoke control yourself it's because you are unlikely to have the equipment and competency to ensure it is subject to asuitable system of maintenance and be maintained in an efficient state, in efficient working order and in good repair based on the required maintenance regime in British Standards (which the Enforcers’ Guidance published by the National Fire Chiefs Council advises enforcement officers to use as a benchmark).With the Emergency Lighting you will be able to follow the BS and demonstrate competency as well as having the right equipment for the job.

Obstruction is not the only issue - the stair should be free from combustibles and ignition sources. Two approaches exist: Zero tolerance: Nothing is permitted. Easy to manage, guarantees safety & compliance. Not very homely Managed use:This approach allows strictly defined use of common parts and limits the items allowed, to control fire load and ease of ignition. It includes strict conditions on where such items can be kept. For example, a ‘managed use’ policy might permit residents to: • place pot plants and door mats outside their front doors • have framed pictures and notice boards on walls • store bicycles, prams and mobility scooters in places that are out of the way and not likely to cause obstruction. This approach also has advantages and disadvantages. The benefits include: • by making the common areas ‘homely’, it fosters a sense of pride and value in the block, which can impact positively on anti-social behaviour • it benefits older and disabled people in particular, by allowing them to store mobility aids at the point of access • it allows the specific risk factors in the building to be taken into account. The disadvantages include: • it is more difficult to adopt as it requires a clearly defined policy with a list of ‘dos and don’ts’ • there is more scope for misunderstanding, requiring more education of, and communication with, residents • while it might be possible to minimise accidental fires with an appropriate ‘managed use’ policy, deliberate ignition may still be a significant concern • by allowing valuables to be left on view, it can encourage crime and subsequently increase the risk of deliberate ignition • it is more difficult for landlords to ‘police’, and for enforcing authorities and fire risk assessors to audit • it is likely to require more frequent inspections by landlords/TMC's • failure to adopt the policy effectively could result in liability for landlords/TMC's should a situation occur that places residents at risk of serious injury or death in the event of fire. When adopting a ‘managed use’ policy: • carry out a specific risk assessment taking into account the particular circumstances in the building • consider whether residents are disposed towards keeping ‘rules’, and avoid ‘managed use’ where this is not the case • ensure that there are clearly defined ‘do’s and don’ts’ that residents can easily follow • only apply it where there is a suitable standard of fire protection – particular care should be taken when applying it to situations such as single stairway buildings and ‘dead end’ corridors • limit it to buildings in which the main elements of structure are made of concrete, brick and other non-combustible materials • take notice of instances of anti-social behaviour and avoid ‘managed use’ where there is particular concern regarding the potential for deliberate ignition • generally only apply it to buildings which have effective security, eg access control • never allow storage of combustible material – where appropriate, make arrangements for residents to have communal facilities for storage • never allow items to be left awaiting disposal, not even in chute rooms – even short term presence poses a risk • only allow basic furniture and not upholstered seating • never allow motorcycles, mowers and other gardening equipment containing petrol and other fuels • never allow charging of mobility scooters, batteries or other electrical equipment in common parts – consider providing dedicated rooms for charging, suitably fire separated from the rest of the block • if storage cabinets are appropriate, only permit lockable metal cabinets to be used and never timber or plastic sheds or lockers • never allow residents to store hazardous chemicals, gas containers or flammable liquids in storage cabinets or dedicated storerooms and cupboards • only allow scooters, bicycles, prams and so forth, if there are suitable areas, that will not pose an obstruction, where they can be kept.

It's not adequate. A common area only system will not provide the required audibility to rouse sleeping occupiers without sounders (& a heat detector usually as well so a flat fire in a flat where the occupant is out is detected before it affects the common parts) in at least the flat internal hallway to achieve 85dB at the bedroom doors as a minimum (should be 75dB bedhead but the 85dB at the bedroom door is a commonly accepted variation to avoid the need to extended into the bedroom). This assumes the premises require a full evacuation strategy. Sounds like you need a new better FRA as well!

The LACORS guidance is useful, as is ADB as it is a single large dwelling - not flats and the relevant part for dwellings should apply..

If dealing with existing healthcare premises the MHCLG Healthcare Premises FRA guide goes into a lot more detail and is probably worth a look.

Yes, with some exceptions - see BS7273-4

At one point of time in history the only way glass could have the required integrity was by being wired - clear glazing simply didn't exist. Back in the day it made identifying fire resistant glazing straightforward - wired = FRG, clear = not! In existing premises where 30 minutes performance is required and has been provided in the past for this purpose (usually as part of fire certification) it's reasonable to accept it (although there are many queuing up to condemn it and supply new glazing). Really old fire glazing with very thin wire can have issued with relation to impact safety, but usually is OK for fire. A lot of fire door courses are black & white (not all)- today's standards or fail - but the real world (& much of the official government guidance) is far more pragmatic.

It was once considered acceptable to meet the FD20 requirement by installing an FD30 door blank & frame but omitting the intumescent and some doors used to be dual certified for this (FD30 with seals/FD20 without). The builders probably think this is still the case, but is no longer permitted, see these links for starters: https://www.nhbc.co.uk/binaries/content/assets/nhbc/tech-zone/nhbc-standards/tech-guidance/6.7/fd20-fire-doors-eng-wales.pdf https://www.jbkind.com/uploads/pdfs/JBK_Fact_Sheet_FD20_and_FD30.pdf

The guidance says no - any use in this situation would have to be mitigated with a rationale as to why it doesn't compromise safety in that specific situation. Ultimately a court or determination would decide if it was suitable to meet the legislation.

The beauty of the current legislation is that that is completely acceptable, not like the old days of more rigidity.

Usually you's see it, but it's not always been the case. Even now fire lifts can open into the corridor as long as they are within 7.5m of the stair door The shaft will generally always be protected in relation to the walls, often being brick & block, the vulnerability being the doors , which whilst some will give 30 minutes fire resistance are poor at stopping smoke. In some buildings in the past it was common to fit a self closing fire door in front of the lift opening to overcome this, particularly with concertina and open lift car doors, but it's less common in flats as they weren't covered by fire safety legislation until 2005

Some resources: https://historicengland.org.uk/images-books/publications/fire-resistance-historic-timber-panel-doors/ http://planning.islington.gov.uk/aniteim.websearch/(S(oi0ozvrsrr24fx45pongzcze))/Download.aspx?ID=243092 https://envirograf.com/product-category/fire-doors/fire-door-upgrades/

Blue 60 is for frames not glazing, so that's out - it ideally needs to be a solution designed & tested for glazing such as Envirograf Products 79 & 109. If the doors are third party certified blanks with the glazing being added later on site then in most cases that's the certification gone out of the window (excuse the pun!) as most manufacturers only allow glazing to be added by the manufacturer themselves during production or by accredited installers at their workshops to a defined spec. Depends on the remit of the consultant - if just risk assessing, then solutions would potentially be out of their scope (& training), if specifically carrying out fire door inspections then you would be more entitled to expect a detailed action plan - although the training of some door inspectors seems to be so brief that 'replace everything' seems to be their only answer to all problems!

There isn't an N at the moment. Different parts will include reference to glazing in different contexts, e.g. Part B for fire, Part L for energy performance/insulation, etc https://www.gov.uk/government/collections/approved-documents

Yes as the door will be used by less than 60