In search of the Silver Bullet and beware the Vested Interest.
Part 2: Implementing improvements in fire door safety
In last month’s issue we looked at the published findings from the Interim Report of the Hackitt Review and how the current state of fire doors at our buildings line up against those findings.
To recap, Dame Judith’s report called for a change of culture with regard to the installation of fire protection into our buildings and these findings are certainly aligned to evidence from fire door inspectors’ findings. The theme running through (timber-based) fire door non-compliance is poor installation so this month we look at what interested parties have so far suggested in terms of practical solutions to this widespread problem.
The problem of poor fire door installation has been publicly recognised by trade associations. Here’s some of what the Door & Hardware Federation said in their news article entitled ‘DHF welcomes tougher Building Regulation and Fire Safety recommendations’. You can read the full article at http://www.dhfonline.org.uk/news/dhf-welcomes-tougher-building-regulation-and-fire-safety-recommendations/99.htm ..........................“The issue of competence is crucial to fire doors as to many other systems within the building. In the case of fire doors, however, the system is uniquely vulnerable to damage caused by use and abuse. This necessitates a high level of maintenance activity, which must be continually undertaken by competent persons throughout the life of the building, not solely during the construction phase or major refurbishment. We would like to see these four elements (manufacture, installation, repair and maintenance) become mandatory requirements to deliver simplification and underpin building regulation.”They also said………“We propose that any fire - or smoke - resistant door should be a factory-prepared door set, manufactured under a third-party certification scheme, which is itself accredited by UKAS. Installation and maintenance of the door sets should be undertaken only by companies certified to do so under a UKAS-accredited third-party certification scheme.”
BWF-Certifire at their website http://www.bwfcertifire.org.uk/news/latest-news/1 consistently publish details about how to increase the knowledge and understanding of fire door safety for building operators, landlords and residents. FDIS have published an infographic warning landlords, building owners and tenants about ‘life threatening fire door faults’ at http://www.fdis.co.uk/latest-news/life-threatening-fire-door-faults-uncovered-by-fdis-inspectors and the Guild of Architectural Ironmongers in their article ‘Calls for forgotten professionals to be bought back in to the construction process’ says that "the GAI, in its submission to the Hackitt Review, has highlighted the need for mandatory fire door inspection in the UK and for larger fines for non-compliance, a process that is already in place in the USA and Australia". You can read the full article at http://www.gai.org.uk/news/gai-response-to-hackitt-enquiry
The Association for Specialist Fire Protection in its article ‘ASFP endorses Building Regulations and Fire Safety Review findings’ says that……..”To address the competency issue, the ASFP is working with the Institution of Fire Engineers to provide training and competency evaluation for all stakeholders involved in the design, specification, installation and maintenance of passive fire protection”. You can read the full article at http://asfp.org.uk/webdocs/News_ASFP_endorses_Hackitt_Review.php
So its clear that the problem has been recognised and that there are various suggestions being made as well as training and competence related action being taken to bring about the required improvements highlighted by last month’s Fire Door Monthly blog. It will be necessary to look at these in more detail to try and assess how they might help to eradicate the non-compliance issues that we currently see in fire door installation and maintenance work at the large majority of our buildings.
The role of fire door professionals in the construction process
The Guild of Architectural Ironmongers are right to raise the issue about engagement of suitable professionals at an early stage in the process of fire door specifications and installation work. Non-compliance issues with many fire doors can be traced back to the original specification, or the lack of it. Fire door assemblies or door sets where the components are unsuitable are very likely to fail to meet the required fire and cold smoke performance and the required level of durability either in day to day service or in a fire event. Common examples revealed by certificated fire door inspectors’ inspection reports are unsuitable self-closing devices that fail in their purpose of closing the door leaves correctly, incorrectly installed and sized seals, incorrectly installed glazed vision panels, and door leaves that lack the durability qualities required by their day to day use.
Where the client engages the services of a certificated fire door inspector or a qualified architectural ironmonger, for example, at an early stage then a suitable specification for procurement and installation can be provided. As a result and subject to inspection of the installation work the fire doors at the building will then be fit for purpose. This is a key factor in the construction process and one that should not be ignored. Involvement of suitably competent persons to provide adequate specifications will have the required positive impact on the end result.
Fire door safety
FDIS and BWF-Certifire are quite right to keep on with their campaigns to increase awareness about the importance of correctly installed and maintained fire doors. Local authorities and social landlords would do well to heed this advice and inform tenants in blocks of flats about their obligations regarding use and maintenance of flat entrance doors and about how they can spot problems and report them. Fire safety in blocks of flats is such an important issue that flat dwellers must understand the importance of flat entrance doors that self-close correctly and that also provide adequate protection against the spread of cold smoke.
The Guild of Architectural Ironmongers’ call for mandatory fire door inspections seems to be a reasonable approach given the high level of non-compliances revealed by certificated fire door inspectors in recent years. Fire door inspections as part of the build and refurbishment process at blocks of flats and other high risk buildings would most definitely improve fire safety and should be carefully considered by the Hackitt review panel. If post works inspections were conducted before handover they would probably become the single most effective driver for improvement in the quality of fire door installation in such buildings.
Fire door sets and third party certification
The DHF has proposed that all fire doors should be factory-prepared door sets, manufactured under a third-party certification scheme, itself accredited by UKAS. They also propose that installation and maintenance of the door sets should be undertaken only by companies certified to do so under a UKAS-accredited third-party certification scheme.
The advantage of fire door sets over fire door assemblies is that the door set manufacturer takes responsibility to ensure all components of the fire door set are compatible and suitable. In my experience fire door sets are much more likely to result in a compliant installed fire door than fire door assemblies procured and installed by a builder on site. I would always recommend fire door sets over assemblies even in refurbishment projects where consideration is often given to retaining the existing door frames. The quality and compliance advantages outweigh any cost savings. However, there is still a need to ensure the product is fit for the type of end use, wear and tear and the treatment its likely to be subject to in the built environment, so correct specification remains as important as ever.
Third party certification schemes covering fire doors have been around for many years and members of such schemes must subject their products, processes and work to periodic audits by the scheme provider. There are separate schemes for products, for installation and for maintenance and repairs. Members must have a suitable quality management system and must maintain records to demonstrate that products are manufactured or installed and maintained such that the product or installation/maintenance work meets the specified requirements in terms of design and performance. Audit requirements will involve periodic inspections but will vary depending on the scheme provider, a third party certification scheme provider for fire door installers may make as few as two days of site inspection visits and one office audit each year. This number may be increased subject to certain requirements. Members may be required to demonstrate that product based training has been undertaken, this would usually take the form of training provided by the particular product manufacturer and the scheme member must demonstrate that products used for fire door installations have suitable evidence of performance as part of the record maintenance requirements. Scheme rules, requirements and the provision of training will vary from scheme to scheme.
How effective certification schemes are at ensuring a consistently compliant product and /or installation/maintenance work will depend on the diligence of the scheme member but where the periodic audits find non-compliances the member will be required to take action to resolve any issues concerning them. Furthermore the marking and labeling system used allows traceability back to the installer and manufacturer. This has been useful to fire door inspectors and enables reporting of non-compliances back to the third party certification scheme management.
If the DHF are looking at third party certification as the answer to ensure consistently compliant products and installation or maintenance work then there would most certainly be a requirement to demonstrate that such certificated products and installation or maintenance work consistently meets the requirements for a compliant fire door. Fire door inspections have revealed defects in third party certificated fire doors both in terms of the product and the installation work so its important to understand that they offer no inherent guarantee of quality.
So whilst I support third party certification schemes as a way of improving competence levels and quality controls I cannot agree with the DHF in supporting their call for it to become mandatory. To do so would disenfranchise the many fire door installers and fabricators that undertake their work carefully and with due diligence. A mandatory third party certification requirement for fire door installation work that prevents other stakeholders that have undertaken suitable training or have the necessary knowledge, experience and practical skills carrying out such work would clearly be unacceptable.
However, it is clear that a benchmark standard is required and the recently published standard BS EN 16763 : 2017 ‘Services for fire safety systems and security systems’ sets out a minimum requirement for such work. My interpretation is that it defines requirements in terms of competence level, quality management and documentation without necessitating membership of certification schemes that may be cost prohibitive for some smaller businesses.
Competence and quality control
In their article, referenced earlier in this article, ASFP report that they are working with the Institution of Fire Engineers to provide training and competency evaluation for all stakeholders involved in the design, specification, installation and maintenance of passive fire protection. Widely accessible training for fire door installers and maintainers is most certainly a necessity and where such training proves to be well delivered resulting in improved competence levels that can be transferred to on-site installation and maintenance procedures this would I am sure receive support across our industry.
So looking at the above its clear that there is no silver bullet, no ‘one-fix’ solution. Having highlighted what is wrong it will be necessary to implement a range of practical improvements to ensure fire doors are installed and maintained correctly to provide the required levels of fire and smoke protection. The key ingredients will be:
1) Adequate specification
2) Compliant installation and maintenance
3) Pre-sign off inspections
I would suggest that such improvements would be best achieved by implementation of a simple to follow system that aims to achieve compliance as a way forward. Starting with high rise and complex buildings (from a fire safety point of view) our aim should be to ensure that every installed fire door will meet the specified fire safety requirements. To achieve that aim four essential elements are necessary to the process of specifying, procuring and installing the fire door. These are described in the tables below:
Specifiers, manufacturers, installers and inspectors that have sufficient specialist knowledge and experience already possess the necessary competence levels to meet the requirements set out above. However, various companies and organisations provide training and education for those that carry out such fire door related work and third party certification schemes covering products and installation are operated by a limited number of certification providers, some of which offer initial training.
Thinking about how improvements can be best achieved I believe regulation change may be necessary to make inspection and sign-off of fire door installation works in certain types of buildings a mandatory requirement. Without mandatory inspection it will be impossible to ensure an acceptable level of fire and smoke protection is achieved. Inspectors must of course be competent and training is available to enable building authority employees or private sector service providers reach a suitable level of competence.
The above recommendations are based on my views from my own experiences, it will be interesting to hear those of other stakeholders.
We are now presented with an opportunity to improve fire door safety at our buildings. Let’s hope we can move forward with that aim as paramount and held above any vested interests.