Fire Door Compliance: Cutting through the red tape

Fire doors play a vital role in building safety, yet compliance with regulations is often complicated by unclear or excessive documentation. In our latest blog  BWF Technical Director – Kevin Underwood, explores the requirements of the Building Regulations 2010, highlighting responsibilities, evidence standards, and the importance of accurate, relevant product certification.

In discussions regarding compliance with the building regulations a subject that often raises its head in connection with fire doors is the complexity of the information provided by manufacturers or installers in support of their work. Too often building control is presented with a pile of documentation, some relevant, some irrelevant, from which they are expected to retrieve the performance data they need. As the installation, replacement or alteration of a fire door is ”building work”, this work must be notified to building control and the supporting evidence used to demonstrate compliance must be relevant to the products used.

The Building Regulations 2010, which apply in England and Wales, state that a person who intends to carry out “building work”, shall give either a building notice, or an application for building control approval with full plans, to the relevant authority before the work starts. Where the building work consists of emergency repairs, and it’s not possible to give a building notice or make a full plans application in time, the person undertaking the work shall give a building notice to the relevant authority as soon as reasonably practicable after work has started.

For the building regulations, “building work” includes the erection or extension of a building, the provision of a controlled fitting, the material alteration of a building or a controlled fitting, or work relating to a material change of use.

External fire doors, fire doors between a flat and an unheated corridor, and fire doors between a house and an unheated garage, are controlled fittings because Part L of Schedule 1 of the building regulations imposes a requirement, i.e. they must achieve a required level of thermal transmittance (U-value). If fire doors in these locations are to be replaced, it may not be necessary to notify building control directly. The “building work” could be covered by a self-certification scheme under regulation 20 and sections 10 or 11 of the table in Schedule 3, which cover the installation as a replacement of a window, rooflight, roof window or door in an existing dwelling, or in an existing building other than a dwelling. Where this regulation applies, the local authority building control are authorised to accept a certificate from the person carrying out the work as evidence that the requirements of the building regulations have been satisfied.

Replacing or altering an existing fire door is considered a material alteration and hence it is “building work” and must be notified to building control. This is because this work could result in either the building in which the fire door is located, or the fire door itself, not complying with requirements B1 (means of warning and escape), requirement B3 (internal fire spread – structure) or Part M (access to and use of buildings) where previously they did, or, where the building or fire door did not comply with requirements B1, B3 or Part M, before the work commenced, being more unsatisfactory after the work is completed.

In all cases, regulation 7 will apply which covers materials and workmanship. This requires that “building work” shall be carried out with adequate and proper materials which are appropriate for the circumstances in which they are used, properly mixed or prepared, and are applied, used or fixed so as adequately to perform the functions for which they are designed.

The draft of PAS 2000, Construction products – Bringing safe products to market – code of practice, which I mentioned in last month’s column, contains a section on product information. It states that construction product information should be accurate, accessible, transparent, up-to-date, useful, comprehensive, consistent and unambiguous and that this information should be supported by accurate evidence and free from misleading claims.

For fire doors, suitable supporting evidence includes, test reports, field of application reports, classification reports, third party product certification documents, technical assessments and declarations of performance.

Where the fire doors are required to have proven performance characteristics other than fire resistance and smoke control, such as enhanced security, thermal transmittance, weathertightness, self-closing and sound attenuation it’s important that the evidence submitted in support of the doorset is for the same design and size, materials, hardware and glazing options for all characteristics.

The fire door manufacturers, blank manufacturers and licensed processors that are members of the BWF Fire Door Alliance all hold third party product certification for fire resistance under schemes operated by Certifire, BM TRADA or IFC.  These schemes provide additional assurance to customers and specifiers that the fire doors they purchase or specify will perform to the standards they require.