Hi, I’m hoping someone can help clarify fire door regulations for us? Much of this post is providing context; the final two paragraphs are where my questions are.
Our leasehold development consists of 3 x three-storey blocks (all under 11 metres high) built in 1986 — one block has 9 flats (3 on each floor), and the other two blocks (which are joined, but have separate access doors) have 6 flats each (2 flats per floor). All flats open onto communal stairwells, with one access door from outside into the blocks, with no secondary means of escape and no fire alarms in communal areas. We have a Residents Management Company and we employ a Managing Agent to carry out maintenance.
We have had three surveys in the last few years with the intention of upgrading all flat entrance doors where necessary, along with communal doors, including riser cupboard doors to comply with the latest fire regs.
All but one flat entrance door is the original door from 1986, and has been designated as a notional fire door. The first two surveys stated that upgrades such as reactivating painted-over intumescent strips, replacing letter boxes, hinges, concealed closers and spyholes etc would be satisfactory. We’ve recently had a third survey which states that all flat entrance doors and frames should be replaced with new.
So I’m trying to find a definitive list of requirements for fire doors in blocks of flats, but the government advice is a little vague. They make a distinction between blocks over / under 11 metres, but it’s not clear what difference that actually makes and what does or doesn’t apply to us as blocks under 11 metres. E.g. on this page fire door checks are only listed as necessary for buildings over 11 metres. Buildings under that height only need to give ‘information’ to residents, which seems to imply that the annual surveys we’re paying for are not actually required. Similarly, this fact sheet states that the 2022 Regulations applies to buildings over 11 metres in height. But it also states that for buildings below 11 metres, all fire doors should be “capable of providing adequate protection”, with no detail of what that constitutes. Likewise, this LFB page also states that the 2022 regs only apply to blocks over 11 metres.
I’ve looked at the Guide for small blocks, but the scope of those guidelines are for blocks with a maximum of 6 flats, so as one of our blocks has 9 flats the guide doesn’t apply to us. So, I’ve looked at the Purpose-built Blocks guidance, but it’s from 2011 and doesn’t seem to include a list of requirements for fire doors (I confess I didn’t read all 193 pages in detail though).
So, can anyone point me in the direction of a definitive list of requirements for fire doors for three-storey blocks under 11 metres? I’m hoping for a simple bullet-pointed list which lays out the specifications required. Does such a thing exist?
It would also be good to understand if there is a minimum acceptable specification? Is there any leeway or some degree of subjective interpretation of regulations allowed, which would explain the differing results in the surveys we’ve had? Our previous Managing Agents emailed us in January 2023 informing us that the surveying arm of their business had met with the Head of Building Control of the local council and “agreed the requirements for the upgrade of notional doors”. This sounds like the regulations are up for negotiation and are judged on a case by case basis? Unfortunately we changed Managing Agents soon afterwards so have no record of what was agreed.
Thanks in advance,
Ian