Fire door regs for 3-storey flat blocks under 11 metres

[Ian London]

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

[Mike North]

The height is irrelevant to fire door inspections,  ALL fire doors should be inspected by a competent person a minimum of every six months and maintenance carried out on all defects.

 

Fire Safety (England) Regulations 2022: fire door guidance (accessible) - GOV.UK (www.gov.uk)

 

As for the different interpretations of the doors, it is a lot less work for the inspector to say that the door must be changed than listing the deficiencies and the required remedials to bring the door back to compliance.

Unless there is a chain of custody, the history of the door is time consuming and difficult to track down, you pays your money and you takes your choice.

[Neil Ashdown MAFDI]

Guidance can be found at https://assets.publishing.service.gov.uk/media/65e9def95b6524001af21bcc/Fire_Safety_in_Purpose_Built_Blocks_of_Flats_Guide-update.pdf

The Case Studies might prove useful as might Section 54 on Compartmentation, 55 to 59 on Means of Escape and 62.12 onwards on Fire Doors. 

[AnthonyB]

You shouldn't need to ask this as you should have a Fire Risk Assessment in place that has answered this for you - as the Responsible Person I'd recommend the Resident's Management Company instruct it as some agents will use the cheapest provider and you usually end up with an FRA that either misses critical areas & puts you at risk or is OTT and costs you thousands in unnecessary work. I was asked to do an FRA by an RMC after their agent said they needed to spend tens of thousands on a fire alarm and ne doors - in reality all they needed to do was change a couple of windows so they could be used as openable vents for smoke control.

For example in your case your doors are most likely to only need repair if they are in essence the original '86 fire doors (notional doors as below).

[Ian London]

Thanks for your replies everyone.

I have a few specific questions. 

1. Routine checking of fire doors

In the document that Mike North linked to above, item 2.3 states that "regulation 10 applies to all blocks of flats that incorporate common parts", but in 2.4 states that regulation 10's routine fire door checks (flat entrance doors every 12 months and communal doors every 3 months) "are only required in blocks of flats in which the top storey is more than 11m above ground level (typically, a building of more than four storeys)". 

So, as our blocks are under 11 metres, does this mean that we don't need to have routine fire door checks?

 

2. Self-closers

When are concealed door closers compliant? Our flat entrance doors all have concealed self-closers fitted. Most of them need to be replaced as they aren't strong enough to fully close the doors anymore.

Is it correct that new concealed closers are compliant when fitted as replacements to existing notional fire doors? But not compliant to be fitted to new fire doors — new doors can only have overhead self-closers?

In section 6 of the same document linked to above, photo 5 shows a concealed self-closer (the same type that we currently have fitted) — this photo implies that concealed self-closers are compliant?

 

3. Electrical riser cupboard doors

Our previous managing agent, who told us that they had met with the Head of Building Control of the local council and “agreed the requirements for the upgrade of notional doors”, commissioned the upgrade of our electrical riser cupboard doors whereby intumescent strips were fitted and the thickness of the doors were increased (see photo below).

In the recent survey, these doors were failed for the following reasons: "Door has had 6mm GypRoc applied to rear face to increase thickness from 40mm to 46mm. Fixed to rear face using drywall screws. Replace door to current regulations."

Who is correct? Our previous managing agent led us to believe that the upgrades they had done brought the doors up to current regulations. If this is not the case, it's frustrating as it means we are paying twice for the same thing.

 

 

Thanks for your help

Ian

[AnthonyB]

On 31/08/2024 at 12:07, Ian London said:

Thanks for your replies everyone.

I have a few specific questions. 

1. Routine checking of fire doors

In the document that Mike North linked to above, item 2.3 states that "regulation 10 applies to all blocks of flats that incorporate common parts", but in 2.4 states that regulation 10's routine fire door checks (flat entrance doors every 12 months and communal doors every 3 months) "are only required in blocks of flats in which the top storey is more than 11m above ground level (typically, a building of more than four storeys)". 

So, as our blocks are under 11 metres, does this mean that we don't need to have routine fire door checks?

 

2. Self-closers

When are concealed door closers compliant? Our flat entrance doors all have concealed self-closers fitted. Most of them need to be replaced as they aren't strong enough to fully close the doors anymore.

Is it correct that new concealed closers are compliant when fitted as replacements to existing notional fire doors? But not compliant to be fitted to new fire doors — new doors can only have overhead self-closers?

In section 6 of the same document linked to above, photo 5 shows a concealed self-closer (the same type that we currently have fitted) — this photo implies that concealed self-closers are compliant?

 

3. Electrical riser cupboard doors

Our previous managing agent, who told us that they had met with the Head of Building Control of the local council and “agreed the requirements for the upgrade of notional doors”, commissioned the upgrade of our electrical riser cupboard doors whereby intumescent strips were fitted and the thickness of the doors were increased (see photo below).

In the recent survey, these doors were failed for the following reasons: "Door has had 6mm GypRoc applied to rear face to increase thickness from 40mm to 46mm. Fixed to rear face using drywall screws. Replace door to current regulations."

Who is correct? Our previous managing agent led us to believe that the upgrades they had done brought the doors up to current regulations. If this is not the case, it's frustrating as it means we are paying twice for the same thing.

 

 

Thanks for your help

Ian

1. Routine Checking of Fire Doors. Regulation 10 of the Fire Safety (England) Regulations does not override the inspection &  maintenance regime required under Article 17 of the Fire Safety Order, it just sets a mandatory minimum interval between checks for taller buildings. For smaller blocks the HM Govt guidance is:

 

2. Concealed single chain uncontrolled non adjustable concealed closers (often called 'Perko's' after the original manufacturer's brand name Perkomatic) have been frowned upon since the 90's and positively discouraged since the 2000's due to issues in performance and long term reliability, but (as usual as evidenced by Phase 2 of the Grenfell Report) HM Govt shied away from explicitly disallowing them on existing buildings, happy that there non compliance with EN1154 stopped them being used on newer builds - only rising butt hinges are specifically disallowed. So as long as the closer shuts the door fully flush in frame overriding any latches it is acceptable in an older building under Article 50 guidance, which means you can't be held in breach. If they are no longer effective then they will require replacement with a modern closer (often to avoid damaging the door/leaving a hole the Perko is left in place with the chain cut and an overhead closer fitted)

 

3. Upgraded door. The door upgrade method you have shown has been used for decades under the Fire Precautions Act and HMO Guidance and even has some test evidence behind it and will enhance the performance of the door. It's not possible to say you are guaranteed to get the full 30 minutes of a certified new door, but subject to risk assessment it's acceptable and as I've previously answered current HMG guidance will accept older and upgraded doors in smaller blocks so you would not be in breach.
Unfortunately fire doors became big business after Grenfell and dozens of companies have  jumped on the bandwagon  with many only having staff that can do a pass/fail inspection against a new door standard rather than work holistically in conjunction with the fire risk assessor

[Ian London]

Thanks for your reply Anthony, really helpful.

[richardinnorwich]

Hi Ian.

I'm in a very similar role to you and with very similar mid 80s built flats in similar configurations (no 3 flats to a floor though) all ours fall under the small block scenario. I share your frustrations in finding a definitive source of information, I had a very similar post to yours a while back.

I have to say this forum is the best resource I've found over the last six years for good information on various fire topics and although you might not get a definitive answer on here you will get people pointing you to relevant sources of information and giving you good solid opinions based on their knowledge and experience.

I find it incredibly frustrating that multiple government publications on the same topic differ and aren't crystal clear on what needs to be done. We have 'notional' flat entrance fire doors that are of a good fit and in good order, whilst according to the current regs there is no obligation for us to upgrade or replace them as they are classed as satisfactory we took what we thought was a common sense approach to improve the existing doors and upgraded as follows;

- Made sure that all door edges had no more than a 4mm gap

- Fitted new CE marked hinges

- Fitted New intumescent letterboxes

- Fitted Intumescent brush strips

- Fitted intumescent hinge pads

- Wrapped all locks/spyholes with intumescent sheet, backed all ironmongery with same

- Max 3mm gap at bottom of door, the best solution we found was to fit a hardwood threshold, avoided issues with carpet height and hassle of drop down bars and future repairs.

- Intumescent mastic seal between door frame and brickwork.

-Checked overhead closers operated correctly and adjusted/replaced where necessary.

Think I've listed everything.

Hope it helps

 

 

[Neil Ashdown MAFDI]

Very helpful, thanks for sharing. They seem to be the most appropriate actions and avoiding the need for replacing doors unless necessary.

Edited September 9 by Neil Ashdown MAFDI
To add more info

[Ian London]

Thanks Richard, that's a huge help.

[Ian London]

On 30/08/2024 at 20:53, AnthonyB said:

you should have a Fire Risk Assessment in place

A quick question about Anthony's comment here before I go back to our Property Manager.

How long is a Fire Risk Assessment valid for? e.g. should we have one done every year, the same as the fire doors should be checked?

And should the person carrying it out have qualifications / certification?

[AnthonyB]

On 18/09/2024 at 19:30, Ian London said:

A quick question about Anthony's comment here before I go back to our Property Manager.

How long is a Fire Risk Assessment valid for? e.g. should we have one done every year, the same as the fire doors should be checked?

And should the person carrying it out have qualifications / certification?

A fire risk assessment must be reviewed by the responsible person regularly so as to keep it up to date - the interval is not set in legislation but usually expected to be annually - a full new assessment isn't required unless there is reason to think the existing one is invalid or there has been a significant change in the matters to which it relates including when the premises, special, technical and organisational measures, or organisation of the work undergo significant changes, extensions, or conversions.

Some Responsible Persons will have their external competent provider re-assess annually, others will review themselves in house and only reassess if there are changes or 3-5 years have passed. Both can be seen to be valid approaches & I have clients that work in both of the above - some bring me in annually, others every 2-3 years. 

[Ian London]

Thanks very much Anthony, very helpful again.