Frequency of Fire Door inspection for Under 11m Buildings

[richardinnorwich]

Hi everyone, I'm reading some conflicting information on how often Flat entrance Fire doors (not communal areas, lobby doors etc.) need to be inspected and the level of inspection/FRA required. The blocks that I'm asking for are all under 11m and meet all the criteria for the guidance that applies to "small blocks of flats". The articles/sites that I'm getting the info from are non-commercial and government sites, some seem to be saying that beyond an initial inspection, inside and out( gaps, seals, hinges, closer, intumescents etc) to establish that they comply with regs all that is required from that point is an external inspection to make sure it's still a good fit with no obvious signs of damage and that it hasn't been replaced. Other sites seem to be suggesting that they need and inside and out inspection with a check on gaps close etc. Within those differences the time periods for either inspection seems to vary, some saying annually, some every2 or 5 years, some suggesting that it's down to property owner to notify of any issues.

Any guidance would be great, if you could supply a link/reference to the source material so I can reference it that would be even better.

Thanks, Richard 

[Neil Ashdown MAFDI]

Section 2 of this HM Gov guidance document  https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1147631/A_guide_to_making_your_small_block_of_flats_safe_from_fire.pdf   covers the responsibilities of those that own/manage small blocks of flats.

Note that fire safety legislation requires a suitable and sufficient Fire Risk Assessment to be carried out and kept up to date. Checking the adequacy of the fire doors is part of that Fire Risk Assessment and the document provides guidance on this matter. Refer to page 25 for HM Gov guidance about inspection & maintenance of fire doors.

[richardinnorwich]

Hi Neil, thanks for your response and thanks for the link. That document is one of the ones I've already been looking at and for inspection states "preferably annually in the case of flat entrance doors". 'Preferably' is the bit that seems open to interpretation i.e. it's not mandated that there is a fixed time period for inspection for flat entrance doors whereas communal doors states "at least every six months" (no wriggle room).

Also interested to see that they don't specify a gap tolerance for the bottom of the door. Historically I've seen 8-10mm as acceptable but this document says "gaps at the bottom of the doors should be as small as practicable" Any thoughts on that one.

Thanks

[AnthonyB]

On 19/08/2023 at 09:44, richardinnorwich said:

Hi everyone, I'm reading some conflicting information on how often Flat entrance Fire doors (not communal areas, lobby doors etc.) need to be inspected and the level of inspection/FRA required. The blocks that I'm asking for are all under 11m and meet all the criteria for the guidance that applies to "small blocks of flats". The articles/sites that I'm getting the info from are non-commercial and government sites, some seem to be saying that beyond an initial inspection, inside and out( gaps, seals, hinges, closer, intumescents etc) to establish that they comply with regs all that is required from that point is an external inspection to make sure it's still a good fit with no obvious signs of damage and that it hasn't been replaced. Other sites seem to be suggesting that they need and inside and out inspection with a check on gaps close etc. Within those differences the time periods for either inspection seems to vary, some saying annually, some every2 or 5 years, some suggesting that it's down to property owner to notify of any issues.

Any guidance would be great, if you could supply a link/reference to the source material so I can reference it that would be even better.

Thanks, Richard 

The Guide linked to by Neil states:
Six-monthly: • Check all fire doors, other than flat entrance doors, to ensure that they are undamaged and are effectively self-closing

Annually: • Check all fire doors in the common areas to ensure that they remain in good condition and fit well in their frames • Ensure that self-closing devices fitted to flat entrance doors and doors in common areas remain in working order and close the doors effectively in their frames

The guide has s50 status which means in respect of compliance with fire safety legislation:

"1A) Where in any proceedings it is alleged that a person has contravened a provision of articles 8 to 22 or of regulations made under article 24 in relation to a relevant building (or part of the building)—

(a)proof of a failure to comply with any applicable risk based guidance may be relied on as tending to establish that there was such a contravention, and

(b)proof of compliance with any applicable risk based guidance may be relied on as tending to establish that there was no such contravention."

Which essentially means that it would be wise to follow the regime in the guide!

[richardinnorwich]

Hi Anthony, thanks for your response, it's good to know that the document has a status and provides evidence of compliance.

The section that I quoted was out of the document Neil referenced "fire safety in small blocks of flats"

I already stated that there are no common area doors, only flat entrance doors. The whole section (page 24, right hand side) states:

"Maintenance of all fire doors. It is important that all fire doors and their self-closing devices are checked on a regular basis (at least every six months in the case of fire doors within common parts, and preferably annually in the case of flat entrance doors) to make sure that they maintain the protection to escape routes"

I agree it would be wise to follow the guide but the guide isn't giving a specific time period just "preferably annually". If it said "preferably annually but a minimum of once every 2 years" that would provide a definitive timescale, but it doesn't hence my query.

[AnthonyB]

It is vague, but gives you an aspiration, I would suspect it would be interpreted similarly to 'best endeavours' in 11m+ buildings, that you should try to get round them all annually. Ultimately the Responsible Person has to decide how they want to approach this and take their chances! 

[Neil Ashdown MAFDI]

"Also interested to see that they don't specify a gap tolerance for the bottom of the door. Historically I've seen 8-10mm as acceptable but this document says "gaps at the bottom of the doors should be as small as practicable" Any thoughts on that one".

The code of practice for timber-based fire doors BS 8214 requires a 3mm maximum threshold gap for doors that are required to provide restricted smoke spread, otherwise for a flexible seal to be installed to seal the gap.  Generally, in terms of fire resistance performance most fire door manufacturers require the gap to be 8mm to 10mm max. 

The UK Gov guidance appears to be suggesting a pragmatic approach. 

[Meady]

Hi All, am I right in saying that the additional checks (over and above those performed during a FRA) only apply to buildings 11m+ and 18m+?

The Gov guidance I am looking at, to me, reads that blocks less than 11m only require the "Information to residents" section to be added to their management plan??  But I confess to be no expert in this area!!

https://www.gov.uk/government/publications/check-your-fire-safety-responsibilities-under-the-fire-safety-england-regulations-2022/check-your-fire-safety-responsibilities-under-the-fire-safety-england-regulations-2022

[Guest Joe]

On 22/08/2023 at 19:54, AnthonyB said:

The Guide linked to by Neil states:
Six-monthly: • Check all fire doors, other than flat entrance doors, to ensure that they are undamaged and are effectively self-closing

Annually: • Check all fire doors in the common areas to ensure that they remain in good condition and fit well in their frames • Ensure that self-closing devices fitted to flat entrance doors and doors in common areas remain in working order and close the doors effectively in their frames

The guide has s50 status which means in respect of compliance with fire safety legislation:

"1A) Where in any proceedings it is alleged that a person has contravened a provision of articles 8 to 22 or of regulations made under article 24 in relation to a relevant building (or part of the building)—

(a)proof of a failure to comply with any applicable risk based guidance may be relied on as tending to establish that there was such a contravention, and

(b)proof of compliance with any applicable risk based guidance may be relied on as tending to establish that there was no such contravention."

Which essentially means that it would be wise to follow the regime in the guide!

Hi Anthony, 

This is a really interesting statement; and something I’ll find very useful, I often receive questioning with regards to at what level guidance should be followed etc. I noted you refer to “S50 Status” could you clarify this for me? I’ve tried to do some research but can’t seem to find much on this. 

 

Much Appreciated 

Joe 

[AnthonyB]

1 hour ago, Guest Joe said:

Hi Anthony, 

This is a really interesting statement; and something I’ll find very useful, I often receive questioning with regards to at what level guidance should be followed etc. I noted you refer to “S50 Status” could you clarify this for me? I’ve tried to do some research but can’t seem to find much on this. 

 

Much Appreciated 

Joe 

Guidance

50.—(1) The Secretary of State must ensure that such guidance, as he considers appropriate, is available to assist responsible persons in the discharge of the duties imposed by articles 8 to 22 and by regulations made under article 24.

[F1(1A) Where in any proceedings it is alleged that a person has contravened a provision of articles 8 to 22 or of regulations made under article 24 in relation to a relevant building (or part of the building)—

(a)proof of a failure to comply with any applicable risk based guidance may be relied on as tending to establish that there was such a contravention, and

(b)proof of compliance with any applicable risk based guidance may be relied on as tending to establish that there was no such contravention.]

(2) In relation to the duty in paragraph (1), the guidance may, from time to time, be revised.

[F2(2A) Before revising or withdrawing any risk based guidance in relation to relevant buildings the Secretary of State must consult such persons as the Secretary of State considers appropriate.]

(3) The Secretary of State shall be treated as having discharged his duty under paragraph (1) where—

(a)guidance has been made available before this article comes into force; and

(b)he considers that the guidance is appropriate for the purpose mentioned in paragraph (1).

[F3(4) In this article—

“relevant building” means a building in England containing two or more sets of domestic premises;

“risk based guidance” means guidance under paragraph (1) about how a person who is subject to the duties mentioned there in relation to more than one set of premises is to prioritise the discharge of those duties in respect of the different premises by reference to risk.]