Existing Notional Fire Door Remedial Work or Replacement?

[nigelh]

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:

1. 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.
2. 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.
3. 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?
4. 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?
5. 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?
6. 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

Edited January 3 by nigelh
comment on depth required for combined seal

[Neil Ashdown MAFDI]

Your situation is shared with many owners of flats in the UK. There is guidance on this matter at  https://www.gov.uk/government/publications/fire-safety-in-purpose-built-blocks-of-flats

My own opinion, as provided to similar clients, is that you would be wise to engage the services of a carpenter/joiner that has demonstrable competence and experience working with timber-based fire doors. They can inspect the flat entrance door and carry out sensible upgrades to make sure the door self-closes completely and reliably. Also fitting suitable intumescent edge seals & smoke seals, making sure gaps between the door and frame are within the 2mm to 4mm guidance and that the door is aligned with its door frame.  There may be other issues but an inspection check by a competent person should reveal these.

[AnthonyB]

Based on the guidance cited by Neil and the information you give then original 1989 fire doors still in original working order would be tolerable. Perko chains are frowned on as they can't be adjusted and over time loose the ability to close the door fully flush in frame from all angles as required and if failing must be replaced and ideally should be replaced with EN1154 compliant closers (the biggest issue with the fire doors at Grenfell wasn't them being original 70's doors but that many did not self close).

Some old rebate only doors can indeed be upgraded with intumescent strips and cold smoke seals & this is usually indicated in bigger blocks and isn't essential in small blocks like yours.

So, as the FRA correctly says your existing doors are fine. The only slight (common) error is that they think that as under 11m the Responsible Person for the block doesn't have to check flat front doors - they do under Article 17 of the Fire Safety Order as amended by the Fire Safety Act, just that they don't have to have checked every single one (or made best endeavours to) in a 12 month period as per the Fire Safety (England) Regulations, just aspire to getting round them all in a year.

I cover Yorkshire if you need any further assistance with this matter.

[nigelh]

Thanks to both of you for the responses.  I was hoping I'd get replies on both the Risk Assessment and Fire Door sides of things so your opinions a greatly appreciated.

The government guidelines that @Neil Ashdown MAFDI provided the link to is one of the first documents I found a while ago and have been using to try to guide me on this, so it's good to have it's continued relevance confirmed.

One of the difficulties I've had with this process was the apparent discconnect between what the guidelines say and what the Managing Agent was saying, and I'm grateful for the confirmation from @AnthonyB that the FRA and my interpretation of the guidelines are in alignment and that the existing notional doors continue to be acceptable from a fire safety perspective as long as they are in good condition and properly maintained.  I do also appreciate that this should be considered the minimum requirement, and that it may well be beneficial / advisable to go beyond those minimum requirements and have some improvements made.

The other difficulty seems to be that during initial calls with contractors they often seem to show little or no interest in what the FRA has said about the doors, and without seeing either the FRA or the door in question will just jump to their preferred solution which is usually a new doorset.

I originally posted this question in December, but it got lost while awaiting moderation, so after speaking to a mod I reposted after the holidays.  There has been some progress since December in that the Managing Agent has back-pedalled a bit on the demand that ALL doors are replaced and seems to be accepting that remedial work and /or improvement work may be acceptable for some doors providing evidence of there efficacy can be provided.  I'm not yet clear on exactly what evidence they expect - my understanding is that no-one can certify or gaurantee notional fire doors due to the lack of test evidence for them, and the most I'm likely to be able to get is an opinion.

 

I do intend to get at least a couple of people to look at the door and give opinions, because although things like door gaps can be objectively measured, things like the condition of the door seem a bit more subjective and perhaps not something I should try to judge myself.  I would like to ensure I have the best understanding possible about what is required in order to be able to ask people the right questions.

My understanding (feel free to correct me) of what is required to maintain an existing notional door is that it needs to be in good condition, well fitting in the frame (gaps within tolerance etc) and fully closing and latching on the automatic closer.  The current closer does seem a bit of a grey area and may benefit from a replacement - I've seen terminolgoy that says the door 'must close from any angle', but then guidance for testing from fully open and from 15 degrees.  The existing perko seems to work consistently based on that testing process, but would likely struggle to overcome the latch from very small angles (say 5 degrees).

The combination of 62.16, 62.21 and the fact the FRA has not made an explicit recommendation to upgrade the doors seems to suggest that adding intuescent strips and smoke seals is not a hard requirement, and this seems to fit with what @AnthonyB has said.  I can certainly see why it might be seen as beneficial even if not mandatory.

So far I have found one person who seemed competant and willing to look at the door with a view to assessing it for remedial work rather than replacement.  He indicated verbally the he felt it could be maintained, but I'm waiting for a quote to outline exactly what set of fixes plus upgrades he is suggesting.

...I'm still trying to find other people willing to look at the door and quote for possible remedial work.