The recently published “Determination on the suitability and sufficiency of a fire risk assessment in a hotel in respect of the adequacy of the existing bedroom fire doors” by DCLG (Department of Communities and Local Government) has caused some concern across the fire door industry. The concern being that the ruling may be open to interpretation for ALL hotels in similar circumstances, meaning that intumescent seals or smoke seals are not a requirement on bedroom doors.
What the ruling states.
The ruling in question, undertaken by Sir Ken Knight, the Government Chief Fire and Safety Officer, describes, and applies to a single situation,( the hotel built in the 1980s, contains 215 bedrooms and 8 staff bedrooms which open on to protected corridors, providing means of escape in two directions). The hotel owners disagree with the ruling authority over the requirement of retro-fitted intumescent and smoke seals to all bedroom and staff accommodation doors in order to comply with the Regulatory Reform (Fire Safety) Order 2005.
Sir Ken’s conclusion is that he “can see no justification at present for the responsible person to commit, in an action plan, to the installation of intumescent strips and smoke seals on the existing bedroom doors. However, I consider that consideration should be given to specifying replacements that meet the recognised standard at that time as and when the doors are replaced”.
“To remedy the agreed failure to comply with article 9 of the Fire Safety Order, the responsible person should therefore prepare a new risk assessment for the premises in which the absence of intumescent strips and seals on the existing bedroom doors is recorded and justified.”
The BWF view
The determination has been made with regard to one specific site and the particular set of circumstances at the hotel in question and, as a consequence, its conclusion, that a new fire risk assessment should be undertaken to justify not having to upgrade the bedroom doors to add intumescent fire and smoke seals, should not be open to wider interpretation.
In the document Sir Ken Knight reinforces the importance of intumescent fire and smoke seals, setting out that in order to comply with the Fire Safety Order, any absence of intumescent fire and smoke seals on doors installed before current regulations were in force, must be "recorded and justified" in the relevant fire risk assessment and that consideration should be given to specifying replacements that meet the recognised standard at that time as and when the doors are replaced.
The BWF view and advice remains unchanged. We believe that it is always advisable to fit fire and smoke seals to fire doors, based not only on the position set out in Approved Document B to the Building Regulations but also on the evidence of 15 years of regular testing of our members' fire doors within the BWF CERTIFIRE Fire Door Scheme.
Hotel premises pose all sorts of challenges to the Responsible Person. It is important to remember that hotel residents will be in unfamiliar surroundings and thus more easily disorientated and less aware of escape routes than in many other buildings that they typically occupy, (home, office, workplace etc.). In this environment people and escape routes require greater protection, not less.
A similar determination, in this case requiring a hotel to fit intumescent seals, was made in 2008 and highlights how each case is treated as a seperate issue.
Guidance for determinations under the RRO can be viewed here.
Why seals should be fitted.
For a door to work effectively, the door leaf must be free to move within the frame. In order to do this there must be a gap around the perimeter which may compromise the door’s ability to restrict the spread of fire. Intumescent seals expand to fill the gap when subjected to heat.
As with all engineered safety products, a “factor of safety” is required.
In site conditions it is very difficult to guarantee precise, accurate work and hence doors will often not be able to meet the strictly controlled conditions of a laboratory test. Gaps may be larger around doors – they may be slightly out of square or uneven. Intumescent seals are used to provide this factor of safety.
To ensure the safety and reliability of every fire door, it is always advisable to fit intumescent seals. This includes the retro-fitting of seals wherever possible, especially where there is any doubt about the safety and integrity of the existing fire doors. In some circumstances, this may require the installation of new doors.
You cannot rely solely on active fire protection, such as smoke detectors. Passive protection provided by a correctly installed and properly maintained fire door is always there when needed. Fire and hot gases can easily pass through gaps around the door within seconds.
Whilst we accept that the ruling is based on a single issue, we would stress that other hotels may not be exactly as the one in described, consequently, if a fire risk assessor is in any doubt he or she should recommend that fire doors are upgraded or replaced to satisfy the guidance currently issued by DCLG – which includes the fitting of intumescent and smoke seals.
The full content of the ruling may be downloaded here http://www.communities.gov.uk/publications/fire/firedoors