AnthonyB

Cupboards under 1sq.m. can be omitted without a variation, however it's not uncommon to see them fitted anywhere. I know of several homes that have had enforcement action to make them fit them too. There is a risk of spontaneous combustion in linen after being laundered, dried , folded, and stacked particularly where contaminated with oils and similar not removed by washing with paraffin based emollients being a particular issue in recent times - fire risk isn't just the obvious and architects historically aren't the most knowledgeable in relation to fire safety. Ultimately the Fire Risk Assessment will decide if the risk is low enough to omit detection as well as identify the long list of fire safety snagging all too common in premises after refurb (& the meaningless 'sign off')

Usually they are built with them, most kiosks are small enough for the travel distances to be short enough not to need a designated exit. There is the forecourt risk, but you can isolate the pumps from the counter and shouldn't have an incident growing so fast as to cause a problem.

Yes, it's rare outside of high risk environments to need to evacuate whole sites. It's horribly expensive and disruptive in lost time and leads to more people than necessary needing control, moving out of the way of the fire service and possibly shelter and sustenance if the weather is extreme and the incident protracted.

Depending on the size and layout of your shop, the fire detection provision and the contents of the cupboard (e.g. just storage or storage and an ignition risk such as an electrical board) your Fire Risk Assessment (which will now require review as you are carrying out a significant change) may determine a normal door is acceptable, or an FD30 or FD30S fire doorset. Usually if determined to be a place of special fire risk you are looking at FD30 (30 minute fire doorset with intumescent seals) or if needed to preserve a protected escape route the door is on a FD30s door (30 minute fire doorset with intumescent seals & cold smoke brush). If you do need a fire door it would need an EN1154 approved self closer unless infrequently accessed where, as a cupboard, it can be kept locked shut instead. I can't commit for sure as I haven't seen the premises.

The hall detector would be attached to a heat detector and sounder in the flat with separate smoke and heat detectors for the flat itself

It's still not a requirement for the door to have a certification mark, it makes identifying the door more difficult but isn't the end of the world. It's far easier to rebead the glazing with the correct intumescent than replace the door and frame (if they don't replace the frame then any new door certificate would be invalid as certification is for door sets (frame, ironmongery, etc) not just the door.

The face of the building (excluding window openings) should provide at least 30mins fire resistance and window openings should not extend below a height of 1100 mm above the deck level. Surface materials of the facing wall, balcony soffit and balustrade should be of Class 0 rating. The idea is that if fire escapes the flat through the window, occupants needing to pass by the flat can crawl beneath and hopefully escape. If entrance to each flat is afforded via external balcony / deck approach you need to check the width (less than 2m in width is fine). There is a risk of smoke logging if the balcony / deck above is more than 2m. The requirement is for the doors to be FD30 level If its the furthest flat from the stair this may be relaxed.

Yes, discount the largest and it's numbers - e.g. if you had a 100 person capacity exit and a 200 capacity one you would assume 300, but have to discount the larger bringing you down to 100. The 60 is where you only ever had one exit in the first place.

Yes - any building in England & Wales containing 2 or more dwellings comes under the Fire Safety Order 2005 as amended by the Fire Safety Act 2021 and requires a Fire Risk Assessment of all common parts, the exterior of the building (walls, windows, doors, balconies) and all flat front doors). The legislation only requires that the person carrying it out is competent to provide a suitable & sufficient FRA, however in a lot of cases agents aren't competent and use an external specialist, preferably one with third party accreditation or on a fire risk assessors register. Whilst there are some fire safety obligations under the Fire Safety Order that would come up in an FRA which you will have to implement that will not have been previously dealt with by Building Regulations, if your conversion has gone through the correct Building Control process there should be no major issues arising.

They do look like the original fire doors that are to the standard of the time with the upgrades as already mentioned. They would be acceptable under both the existing flats guidance and based on the draft for consultation would still be acceptable under the new small blocks of flats guidance produced to account for the Fire Safety Act's amendment of the fire safety order. Unless you see something in writing from the Council that you have verified is really from them I'd do nothing and even if something does then I'd ask a competent person to look at their rationale & put forward a rebuttal if needed. Could be a confidence trick, wouldn't be the first fire safety related one I've heard of.

Why not? If it's the highest set of doors on the stair they don't need to be fire doors.

The existing (outgoing) fire safety in purpose built flats guide states this. It's draft replacement for small blocks (G-2) takes a similar approach, I'm not sure what it's replacement for large blocs will says although it's normally required for large blocks regardless of borrowed light, but secondary to issues such as fire doors (so they could be done later on in another budget period)

I think there are several legal and ethical issues here, especially if it isn't a secure unit with Deprivation of Liberty authority and plans. Locking the rooms as part of emergency lockdown is one thing, all the time is another!

You would need a fire safety specialist to assist the design team as this would be a complex development spanning various different guidance (ADB, BS9999, BB100, etc) and thus requiring a bespoke design fire strategy.

Unless large numbers are involved you are probably right that it's OK - the fire exit argument may be a screen for a wider parking dispute.

In small buildings only one exit stair is perfectly legal - rope ladders are not! The stair would need to be a protected route. To answer your questions in full would warrant carrying out a Fire Risk Assessment of the site - which should have been carried out as a legal requirement for both the commercial and residential parts, the commercial one having to consider the effects of a fire on the flats above.

Yes if the fire risk assessment deems it necessary to meet the Fire Safety Order as amended by the Fire Safety Act. One big change with the FSO was it removed the 'statutory bar' of older legislation which allowed a building to retain outdated precautions as long as it was unchanged from when first approved (which could be decades ago). As a pre-1991 house conversion, if two thirds of the flats are rented and it doesn't meet at least the 1991 Building Regulations it would be classed as a s257 HMO under the Housing Act and this usually results in a requirement for a mixed fire alarm system and in some council areas a license (but not lots as it would come under 'additional licensing' which is optional for Councils). If it isn't a s257 HMO then requirements would be determined by the Fire Risk Assessment (a legal requirement for any building of 2 or more dwellings). The new draft Government Guidance for FRA in small blocks of flats is quite sympathetic to older blocks and doesn't automatically require alarm systems or even newer doors. It should be noted that the Fire Safety Act places a special status on the guidance for buildings containing dwellings that make it proof that an offence has been committed simply by showing the guidance wasn't followed rather than needing to show any resultant risk.

I think you've asked this somewhere else and I answered there!

Couple of problems for the Council: - They are environmental health experts with limited fire safety knowledge limited to matters they enforce under the Housing Act, which is HMO's and the interior of individual flats and houses, this is a purpose built block under the Regulations at the time (Still CP3 but robust compartmentation & stay put as a result, just with better smoke control methodology) and not a conversion that would come under s257 of the Housing Act (most of which are former single houses) - It's completely outside of their jurisdiction, the Fire Safety Order applies and in purpose built blocks the fire service are the lead enforcer (although joint enforcement teams do exist) They are wrong and would likely loose a determination or appeal- your FRA would have identified if you needed a mixed system fire alarm solution.

If the appearance of the doors is the issue there are loads of compliant decorative timber and composite fire doors you can install - you aren't limited to a bland & plain leaf - so you could change the doors and remain compliant (although strictly speaking the frame must be certified with the door for full reliability as fire doors are usually tested as doorsets with a particular frame)

There will be nothing left to list too if a fire is allowed to spread through the building, so much heritage is lost by fire due to short sightedness.

If it's just a door to the public highway then the Council are taking rubbish as there never was and still isn't such a requirement.

The doors or the signs? The signs have to been green, the doors don't.

Glad to hear it! Sometimes it's right to question things and in any case the law isn't prescriptive so alternatives can be OK if shown to be effective.

Could a glazier cut a sheet to size? May be cheaper than replacing the whole lot.