14th June 2017, for the fire safety industry that was almost a 911 event. It is of course the date of the Grenfell Tower fire and for anybody employed in the fire safety industry and watching the horror unfold, it was an unforgetable event that would have far reaching consequences.
Those employed in the passive fire safety sector were already aware that most buildings, old and new, were seriously lacking in the integrity of fire and smoke compartmentation. Trade associations had been shouting aloud on this subject since the introduction of fire safety legislation changes in 2006, so we were not as surprised as we should have been to learn that the composite construction flat entrance doors tested as part of the investigation by the Metropolitan Police failed to consistently meet the 30 minute fire resistance standard.
You can read more about the advice given by MHCLG at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/707800/180516_Letter_to_Manse_Masterdor_Customers.pdf
Furthermore, many in the fire door sector were aware that installation of fire doors was more often than not defective and falling short of the relevant standard.
What happened next?
As far as fire doors are concerned and in my experience, three significant things happened.
MHCLG conducted tests on more composite construction fire doors and then more tests on timber-based fire doors. Information about the results of these tests can be found at https://www.gov.uk/government/publications/fire-door-testing-grp-composite-test-results and https://www.gov.uk/government/publications/fire-door-testing-timber-fire-door-test-results Tests revealed that a high percentage of composite construction fire doors failed to meet the fire resistance requirements whereas all timber-based fire doors reached or surpassed the requirements. Some manufacturers of composite fire doors withdrew from the market and others improved their products, carried out further tests, in line with requirements set out in MHCLG advice notes, and returned to the market.
Following on from Dame Judith Hackitt’s report, a competence steering group was set up to look at the competence of people working on high rise residential buildings (HRRBs). This steering group recently published its interim report and the proposals, if implemented, mean it could be one of the biggest shake-ups the construction industry has seen in decades. This ‘shake-up’ would certainly affect the fire door sector. You can read more about the proposals at http://cic.org.uk/news/article.php?s=2019-08-16-construction-and-fire-industries-set-out-sweeping-proposals
Fire door inspectors saw a large increase in enquiries from building operators and from construction companies, all anxious to ensure that the fire doors at their premises or installed by their contractors are compliant to the relevant standard. And importantly, to them, that ‘a certificate’ can be provided.
So what does this mean?
Whilst it’s certainly welcome that greater focus is now on fire doors being compliant it has also raised some issues. These issues have to be addressed and it is to be hoped that the competence steering group will be successful, over time, in doing much to help.
One important issue is that many building operators, and seemingly fire risk assessors, are often unable to identify which doors at their buildings are necessary as fire doors. Building operators have a legal obligation to carry out suitable and sufficient fire risk assessments, have been since 2006 when the Fire Safety Order was implemented. They are also required, as necessary, to appoint Competent Persons to assist them in this task. The risk assessments must be updated as and when made necessary by changes and clearly a fire risk assessor that cannot identify the fire doors necessary to the fire strategy cannot claim competence. Maintaining fire doors as fit for purpose can be an expensive business so it’s essential that the building operator knows which doors are necessary as fire resisting doors……………….in many buildings there are more sets of blue circular fire door signs than there are fire doors!
Currently, it is to be hoped that the fire door inspector when they are engaged makes the building operator aware of this issue, if not then pockets will need to be deeper than should be the case!
Another main issue is that many fire door installers are not competent at installing fire doors.
When fire doors are purchased installation instructions will be available. It is not possible to install a fire door without reference to the instructions. There is very little by way of standardisation when it comes to installing different fire doors, they each have their own requirements based on the evidence of fire performance for that particular door type. Two doors of similar size and outward appearance may have different installation requirements, such as intumescent seal size, maximum lock size and hinge positions. This is because they are made by different manufacturers or even by the same manufacturer but having differing core constructions. There is currently no legal requirement for fire door installers to have dedicated installation training but, in the case of high rise residential buildings, this is addressed in the ‘Raising The Bar’ interim report.
Raising the Bar
The intention of the working groups set up by the competence steering group is to improve the fire safety integrity of high rise residential buildings. They plan to achieve this by setting nationally recognised requirements for levels of competence required to perform certain tasks related to the construction of these types of buildings. Those tasks would include inspection and consultancy work as well as installation and maintenance work so that fire risk assessors, fire door inspectors and fire door installers are required to demonstrate that they possess the necessary competencies to carry out their work at high rise residential buildings.
If the proposals contained in the report are implemented those working on HRRBs will need to undergo recognised training and CPD. This is to be welcomed as it represents an improvement on the current situation where no dedicated qualifications are necessary or where certification has been attained, but that it refers only to the contracting company or organisation………not the person actually carrying out the task.
I have no doubt that raising the bar in this regard will be a good thing, in the future, for those living in HRRBs and there’s a good argument for extending the proposals to cover buildings such as some hospitals and residential care facilities.
Always a concern when making changes that are intended to become mandatory is that the consequences may make certain situations worse than before………..be careful what you wish for!
Clearly trying to introduce benchmark competence levels for all of the different trades and roles involved in the construction of HRRBs will be a huge task. Doing it successfully will be even more of a task.
Taking fire doors as an example and limiting the focus to HRRBs alone, will the regulatory body overseeing competence be able to ensure fire doors are installed competently across the complete sector?
Bearing in mind that it could possibly take the failure of just one fire door to cause harm to others in a fire situation, will the regulator be able to ensure that small scale fire door replacement work, by one flat owner for example, will be in-scope as well as would be the case for new-build or large scale refurbishment projects?
Will all fire door installers require a CSCS card even if their normal fire door installation and maintenance work is carried out on a small scale at existing buildings rather than at construction sites?
Will existing fire door installers be disenfranchised by requirements for third party certification?
These installers may already have the necessary competences but it could be that they only install or maintain a small number of fire doors, they may be a small business or sole trader and the cost of attaining third party certification may, for them, be prohibitive. Clearly, excluding such competent persons would fall under the heading of ‘unintended consequences’.
There are already a limited number of fire door training options available. These include installation and inspection for example and setting a benchmark for the quality of that training is to be welcomed. However, as a consequence it may be necessary for previously qualified fire door installers and inspectors to undertake additional training at extra cost. Such training must be easily accessible and affordable as well as of sufficient quality. Anything other than that may lead installers to move out of the fire door sector, on to work where additional training is not a necessity.
If accredited third party certification for fire door installers, maintainers and inspectors becomes a mandatory requirement, there will be a definite need for the quality and depth of such certification schemes to be improved.
There are still instances where the work of a third party certificated contractor or supplier fails to meet the relevant standard meaning that the client is short-changed in terms of quality of the work as well as price paid.
Also, there is still a tendency amongst some contractors and clients to value the certification over the quality of the work. This box-ticking attitude must not be allowed to prevail.
Certification is not always a guarantee of quality. It ought to be.
The fire door inspector will check new fire doors are compliant. This particular FD60 door carries third party certification identification but the necessary intumescent gasket protection has not been installed. That's a clear non-compliance.
Clearly, what matters is that fire doors are installed and maintained compliant to the relevant standard. The challenge is how we get there.
In the past twelve months or so many clients across the housing and healthcare sectors are insisting that new fire door installations are subject to inspection by an independent fire door inspector. Whether this trend will continue remains to be seen but in my experience clients are comfortable with the added level of assurance this provides. Instead of relying on contractor or 'building control' sign-off, the client has a full inspection report listing all compliant and non-compliant fire doors. All non-compliance issues are described so that all parties can be clear about the remedial work necessary to achieve compliance.
In my experience most non-compliance issues that arise are due to either an inadequate specification for the works or incompetent installation works. Both are a result of a lack of knowledge and training. Compliant fire door specification and installation is certainly not rocket science but it does require particular specialist knowledge gained by sufficient training and experience. There are already competent persons within the fire door industry that have that knowledge and by tapping in to it the fire doors installed in HRRBs and similar buildings can be compliant and therefore buildings made safer.
So we can see that up-skilling is necessary across the workforce, top-down and bottom-up. From fire risk assessors and inspectors to installers and their supervisors. Good quality training will be essential in achieving a more highly skilled workforce and the more accessible and affordable that training, the better the workforce.
In her report Dame Judith Hackitt was clear that a culture change is needed to ensure building safety is prioritised. This should be the mantra running central to how we all ‘Raise that Bar’.