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AnthonyB

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  1. Fire legislation states: Maintenance 17.—(1) Where necessary in order to safeguard the safety of relevant persons the responsible person must ensure that the premises and any facilities, equipment and devices provided in respect of the premises under this Order or, subject to paragraph (6), under any other enactment, including any enactment repealed or revoked by this Order, are subject to a suitable system of maintenance and are maintained in an efficient state, in efficient working order and in good repair. If it's argued the EL isn't necessary you could argue the maintenance requirement isn't. However that's only Fire Safety Criminal Law - there may be a civil liability if it doesn't work, the borrowed light is poor and someone has an accident - they could use it as the grounds of a claim (which may not succeed, but would have to be defended)
  2. I see far more failed blades/fins than brushes, they just don't seem to last and are easily ragged, ripped, chewed, stripped, perished etc. My personal preference is brush seals
  3. It would be yours as being an employer who also has control of the premises in order to carry out a business you are the primary Responsible Person under the fire safety legislation for risk assessment and compliance. You describe an 'inner room' situation where anyone in the kitchen needs to pass through an access room (the main salon) to escape. This means a fire in the access room could trap someone in the inner room if they aren't aware of it. Three solutions can be used A smoke (not heat) detector/alarm in the access room to give early warning to anyone in the inner room; or The wall/partition dividing the inner and access room stops 500mm below the ceiling so smoke passes over and is smelt/seen; or A suitable sized vision panel (window) is fitted in the door or wall between the inner and access rooms so a fire can be seen early enough to escape 1 is out as you are having false alarms and heat detectors are no use as they are far too slow to activate (you'd be trapped before it went off) 2 is impractical as the wall is already there not something you are planning to add 3 is the remaining solution - fitting a vision panel (or not having a door, or just a saloon style door) Small businesses with premises as small as yours aren't required to have electrical fire alarm systems for life safety/legal compliance purposes as human senses would react quicker than a detector and a shout of fire would be clearly heard throughout, the first trigger for provision is the layout creating an inner room for which your existing smoke alarm solution is usually acceptable, the second is where there are flats above with inadequate fire separation when something more substantial is needed.
  4. Yes as fire & smoke behaviour doesn't change regardless of if it's doors in an internal wall or ones in an external wall.
  5. AnthonyB

    Internal doors in a HMO

    If it's licensed (& it sounds like it is a section 257 HMO* at least at the time of licensing) you need to go to the Local Authority EHO as regardless of what anyone on here says it's totally up to them - currently different Councils have different standards and interpretations of current guidance. If it's fallen out of s257, which is likely as it's now all owner occupied, then it shouldn't be under the license anymore and your best source of advice is Local Authority Building Control as you are effectively making the premises more open plan which affects means of escape within the flat even if the common space is kept protected by the change in door. *a building that is declared an HMO by the local authority. a converted block of flats where the standard of the conversion does not meet the relevant building standards and fewer than two-thirds of the flats are owner-occupied
  6. If they want to pay for it let them go ahead, if not, what proof of the installation date do you have and are there any certification stickers on the top of the door? It sounds OK and yet another case of a Council gold plating requirements when it's not them footing the bill. What size is the block? There is published and draft to be published official Government Guidance allowing lesser standards in smaller blocks where the risk is less.
  7. That would be based on your fire risk assessment which would consider: Persons at risk - able bodied, quick to evacuate, numbers involved, etc Provision of automatic detection & warning - to minimum requirements or exceeding Areas being protected by the doors (protected route, cross corridor, area of special fire risk) & do they even need to be fire doors Overall means of escape provision & layout, including travel distances Any listing requirements that may affect alteration or replacement of the doors Good close fitting doors will still provide a degree of fire resistance and the assessment will determine if this is enough or certified doorsets are required. Lack of cold smoke seals are the first issue, followed by intumescent strips, but there are retrofit solutions for both of these.
  8. I'd agree with Mike, lot's of 'kitchens' these days are little more than tea points, especially in offices, it's a long time since I routinely saw offices with actual kitchens with a cooker or hobs in (it was quite common back in the day) and the associated 30min FR enclosure and fire door, fire blanket and 5lb Powder extinguisher is hardly necessary. Similar principles apply to other premises, like shops.
  9. If it's there it should be subject to a suitable system of maintenance - forget the law, think of the civil liability if it fails when needed and someone has an accident. Commissioning is to prove the installation complies with BS5266 and would form part of the fire safety information that should accompany the building through it's life, but it wouldn't be a breach of fire safety legislation if the certificate is missing (but makes it easier to demonstrate the installation is suitable & sufficient) Periodic Inspection and Test Certificate relates to the recommended paperwork to be issued after the annual discharge test of the system. BS5266 is the appropriate standard for design, installation & ongoing maintenance, BS7671 is the general electrical wiring regulations, I would guess a general electrician is doing the work if they are using IEE Regs model paperwork as oppose to the specific paperwork. I'd agree it isn't required (although doesn't do any harm) at the moment, although LACORS is under review (since 2019 so seems to be stuck in 'development hell')
  10. If it's an existing legacy build then well fitting solid doors are usually accepted under the Housing Health and Safety Rating System for the purposes of the Housing Act. If a new build or an extension/renovation coming under the Building Regulations is being carried out then internal doors have to be FD20 doors (in practice FD30 get fitted) or FD30 between a garage & house if attached. If no relevant Building Work has been carried out it isn't under the jurisdiction of Building Control so go with the EHO.
  11. Depending on the layout of the building it may not have been added as a designated fire exit under Building Regulations and is just garden access - you are best seeking property law legal advice in the first instance
  12. Any standard safety sign material will do - if fire has breached a protected lobby then there are more immediate worries and risks than the sign melting!
  13. BS5839-6 states: "17.3 Additional recommendations for control and indicating equipment for Grade A systems The following recommendations should be met. a) CIE for Grade A systems should meet the recommendations given in BS 5839‑1:2017, Clause 23...." BS 5839‑1:2017, Clause 23 states: "23.2.2 The following recommendations apply to the facilities provided for visual indication of fire signals. ...e) On or adjacent to indicating equipment, there should be a diagrammatic representation of the building, showing at least the building entrances, the main circulation areas and the division into zones. The diagrammatic representation may comprise any of the following: 1) an illuminated mimic diagram; 2) a VDU with an appropriate back up; or 3) a printed, correctly orientated, zone plan (see 3.68)." So yes, they should have one.
  14. BS5839-6 states: "17.3 Additional recommendations for control and indicating equipment for Grade A systems The following recommendations should be met. a) CIE for Grade A systems should meet the recommendations given in BS 5839‑1:2017, Clause 23...." BS 5839‑1:2017, Clause 23 states: "23.2.2 The following recommendations apply to the facilities provided for visual indication of fire signals. ...e) On or adjacent to indicating equipment, there should be a diagrammatic representation of the building, showing at least the building entrances, the main circulation areas and the division into zones. The diagrammatic representation may comprise any of the following: 1) an illuminated mimic diagram; 2) a VDU with an appropriate back up; or 3) a printed, correctly orientated, zone plan (see 3.68)." So yes, they should have one.
  15. Each device (fire alarm, break glass door release) should have the appropriate safety sign with the relevant pictogram and text where there is any ambiguity as to the location & function of these items which would overcome any colour issues. As a risk assessor you should be familiar with BS 7273-4:2015+A1:2021 which defines what safety features are required for electronically held doors and that in most cases you will have both the local double pole override (green break glass) to drop power to the magnet and a fire alarm interface with the controller.
  16. If it's their land they can implement parking enforcement. They don't even need a parking attendant, but can nominate their own people to issue tickets: https://www.uk-carparkmanagement.co.uk/services/parking-enforcement/self-ticketing
  17. It's possible to keep the original doors if the FRA can justify it - several large hotel chains have fire doors of this original type to their bedrooms, only upgrading stair and cross corridor doors - and one large provider when faced with enforcement action to add strips and smoke seals to bedroom doors took the issue to determination and won and the enforcing authority had to withdraw the enforcement notice and legal action as a result. Determinations do not set precedents, but do show that it is possible to follow a different course of action, the current legislation does not expect all aspects of an existing premises to be immediately brought up to current standards and the FRA will determine if there difference between the new & old is such it presents an intolerable risk. Are intumescent seals and smoke brushes good - yes! Do they result in far better fire doorset performance - yes! But did old style fire doors in premises that suffered major fires perform well enough to protect the occupiers and large parts of the property - yes on many, many occasions! Even in flats the draft for the new fire safety guidance (for smaller blocks - the guidance is being split into two documents) allows original fire doors to be retained in certain situations. Hotels in the 1980's usually only had corridor detection and it was found that rebate only fire doors would pyrolyze & char around the edges and whilst still intact and holding back a degree of fire/heat and smoke the smoke produced from the pyrolysis of the door was tarry, thick and heavy leading to a smoke layer in the corridor that wasn't always high enough to activate a ceiling detector. As a result the 1988 revision of the fire alarm standard BS5839-1 introduced for the first time Categories of fire alarm system of which the new minimum category of detection (L3) required detection in bedrooms (in fact any room opening into an escape route) so the alarm would sound way before the old style fire door would be compromised. Most hotels are now even more protected with L2 or even L1 systems and this has formed part of the mitigation case for some hotels.
  18. Firstly the fire regulations apply even if no one is employed there - it's a common misconception that you need to have 5 or more employees before they apply. The only relaxation in the legislation for premises occupied by less than 5 employees is that the fire risk assessment (which must always be carried out) doesn't need to be recorded unless the premises requires a license. Normally the stair would be protected (fire doors etc), but as the 1st floor has an alternative escape and the ground floor rooms are still OK based on travel distance to the front door your fire risk assessment could find that, whilst always beneficial, fire doors/protection is not mandatory.
  19. AnthonyB

    Mr

    Do you mean the wall behind the cooker as oppose to the back of the cooker itself? What is the wall constructed of and lined with currently? Tiling or other heat insulation behind cookers is common as the heat from the appliance will, over time, damage and degrade a standard plasterboard and stud internal wall. Also certain linings on walls could be a fire risk if subjected to prolonged heat. You don't have to use tiles, however whatever is there should be non combustible.
  20. HI, The equipment is the same for a Part 1 commercial and Part 6 Grade A residential system, but the installation standards do vary depending if it's commercial or residential as they are covered by separate British Standards. If the mixed system is being installed as per LACORS on the basis of a non Building Regulations compliant conversion (inadequate compartmentation & smoke control facilities) then usually the whole building requires cover, even the independent one.
  21. This isn't an uncommon situation and focuses on property and land legislation - where an escape route goes onto another person/entities land there usually needs to be a legal agreement, license, easement, deed of variation or similar to allow right of access for escape without trespass. Where no agreement exists a landowner is entitled to deny access. You will need to contact a specialist on land/property law for advice.
  22. Yes, like any other communal service like common area lighting, cleaning, external landscaping (if gardened), block insurance, etc it would be a typical Service Charge item.
  23. Look here; https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/937931/ADB_Vol1_Dwellings_2019_edition_inc_2020_amendments.pdf
  24. 900mm if there is any chance a wheelchair may need to pass, more if large numbers need to pass
  25. They can insist, but they can't instigate legal proceedings unless it falls under s257 of the Housing Act, namely: - a building that is declared an HMO by the local authority. a converted block of flats where the standard of the conversion does not meet the relevant building standards* and fewer than two-thirds of the flats are owner-occupied *if the conversion was completed before 1 June 1992, it should comply with Building Regulations in force as of 1 June 1992 Only where the particular authority has included these properties in an additional licensing scheme do they require a license. They can only make you do this by issuing an Housing Health and Safety Rating System (HHSRS) Improvement Notice under the Housing Act The recipient may make an appeal to the First-tier Tribunal (Property Chamber) against an improvement notice or a prohibition order. An appeal against an improvement notice could include an appeal on the merits of the works required by the notice. If the Fire Safety Order is to be used then only the Fire & Rescue Service can take Enforcement Action and on receiving an Enforcement or Prohibition Notice you can appeal it via the Magistrate's Court or where you agree that there is a need for improvements to fire precautions but disagree on the technical solution to be used, they may agree to refer the issue to the Secretary of State for Communities and Local Government for independent determination under article 36 of the Order.
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