Hi
I am an owner/occupier of a purpose built flat in Leeds that currently has the original flat entrance notional fire door in place. The Management Company (and Managing Agent used) are responsible for the communal areas, but I am responsible for my own door.
The Managing Agent had a Risk Assessment done a while ago and after initialy providing some guidance to leasholders about checking our fire doors, they subsequently told leaseholders "the doors are not fit for purpose and must be replaced", but having chased them for a copy of the Risk Assessment their latter statement does not appear to tally with the recommendations of the Risk Assessment or my understanding of the fire safety guidelines. I understand that there are also lease terms that may affect whether the Managing Agent can enforce this, but I'm really only asking here about the Fire Safety aspects to ensure I understand that side of things.
The flats were purpose built around 1989 with a single building containing a total of 18 flats which are are split into 3 'blocks' each of which has 6 flats over 2 floors served by a communal entrance and staircase. My understanding of the guidelines for risk assessment was that for a property of this size & type, existing notional fire doors would not ordinarily need replacing (or even 'upgrading to fd30s') as long as they are well maintained.
My door was not inspected as part of the Risk Assessment, but a sample of doors were.
The parts of the risk assessment that comment on the fire doors says:
17.1 Is the design and maintenance of means of escape considered adequate. NO
More specifically:
....some issues highlighted about other aspects of the communal area....
Is the fire resistance of flat entrance doors considered adequate, and are doors maintained in sound condition? YES
Are suitable self-closing devices fitted to flat entrance doors and, where fitted, maintained in good working order? NO
FLAT FRONT DOORS
Compliant: 10% of flat doors where sampled. Although there was no certification on the fire door, the fire doors provided reasonable protection as the following was observed:
The doors had three hinges
The front flat doors are notional fire doors and have 25mm door stops provided.
The doors have Georgian wire glazing with no damage.
The doors did not have intumescent strips or smoke seals.
The doors where good fitting
Perko door closers were fitted to all sampled doors.
Deficiency: Not all sampled doors fully latched without interference.
Deficiency: Although it’s not a requirement to check the apartment doors within article 10 of the Fire Safety (England) Regulations for this development as it’s under 11m, the responsible person still has a duty to put in place general fire precautions in any premises covered by the Fire Safety Order, regardless of the building’s height.
It is recommended that all leaseholders are provided with an information sheet explaining what checks they should be carrying out to their apartment door to ensure all doors are kept to a good standard
And in the Action Plan that forms part of the assessment:
17.1 As some of the samples flat doors did not fully close without intervention, the Property Manager or block director must check to ensure that all flat doors fully close and latch. Any deficiencies must be actioned and fixed by a competent person. Records of the fire door checks are to be available for inspection.
17.1 It is recommended that all leaseholders are provided with an information sheet explaining what checks they should be carrying out to their apartment door to ensure all doors are kept to a good standard.
As existing notional fire doors, they clearly do not comply with regs for certification etc that would be applicable to any new fire door. In addition to the lack of intumescent strips and smoke seals, they don't have intumescent around hinges / locks etc and hinges / locks probably pre-date the standards that would be required for new ones. I also appreciate that as my door was not inspected I can only view the Risk Assessment recommendations as a general 'what is required' rather than any statement of whether MY door is ok or not.
So, a few questions:
From a fire safety perpective, is there anything in this risk assessment that indicates that the doors must be replaced to remain compliant with fire saftey regs? If there is, could someone explain what I'm missing please.
Is there any requirement for an existing notional flat entrance door to be retro-fitted with intumescent strips and smoke seals? My understanding of this was that it CAN be done (possibly as part of an 'upgrade to FD30S' if that was recommended in the risk assessment) but was not a requirement unless highlighted as such. Whilst the risk assessment has made observations about their absence, it does not appear to be recommending that the doors must be upgraded.
The situation around strips/seals seems to be muddied by the fact that the original door frames have a 10mm x 2mm groove in them, but were never fitted with any kind of strips/seals - I'm assuming that fitting the doors in this way must have complied with fire safety & building regs at the time of construction or the building wouldn't have been signed off?
I've tested the automactic closer on my door (from what I understood to be the recommended fully open and 15 degrees) and the door fully closes and latches on the existing Perko closer. I understand that it may be possible to add an overhead closer rather than removing the existing perko if any improvement are required in this area, and that perkos have been frowned on for some time. If the closer is working as I have described, is there a requirement to do this?
As part of reviewing my own door, I beleive the frame gaps (at the sides towards the bottom of the door) are now outside the recommended 2-4mm - they are a bit high on one side and a bit low on the other. It seems likely that a competant person could resolve this by rehanging / packing hinges to even out the gaps. What level of competenance is required to carry out this type of remedial work?
If I wanted to consider adding strips / seals to this door, what level of competance is required to do so? I've seen self-adhesive 'Therm-A-Flex' intumescent products that look like they would fit the existing frame grooves, and separate 'batwing' stype self-adhesive smoke seals. The combined intumescent & smoke seal products all seem to require a deeper groove than the one tha already exists, so would probable require routing of frame or door.
I've started trying to get people to look at my door, but navigating this topic as an individual leaseholder seems quite tricky.
A local FDIS inspector will only look at it if I book out an inspector for a full day which is circa £450. This may make sense to building managers etc who can have many doors inspected for that price, but doesn't seem to work for an individual leaseholder.
There are plenty of contractors around who are happy to quote for a full replacement certified doorset (all pretty expensive as they seem to have to comply with new PAS24 regs etc), but there seem to be fewer who want to consider remedial work to existing notional fire doors.
For some, it sounds like they assume a minimum of 'upgrade to FD30s' is required.
Thanks in advance
Nigel