CROSS Safety Report
Front doors in blocks of flats - security versus safety?
This report shares concerns regarding the provision of security doors to flats without due regard being paid to fire safety requirements.
Key Learning Outcomes
For managers, leaseholders, and tenant management organisations:
- Entrance doors to flats in multi-storey buildings are an essential part of a building fire safety strategy
- Containment of a fire to the flat of origin is a primary objective. The door leading from a flat is critical in a fire situation - it should close behind the occupants after they leave.
- The door construction, the self-closing device, the door furniture, any glazing, intumescent material between the door and the frame, along with cold smoke seals should all be to the standard required for the door in question
- The requirements may vary according to the height of the building, the configuration of the flats, means of escape, and other factors such as the existence of a sprinkler system
For residents of flats:
- Doors to flats can be vital for the safety of residents, should a fire occur
- Proposals to change doors for security, or other reasons, must take fire safety into account
- Replacement doors, their fittings, fixtures, and surround must be to the requisite standard for that particular situation
- Expert advice should be sought, and in most cases, approval must be obtained from the building owner and a Building Control Body
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A reporter states that over the last two decades, security doors have been installed in numerous local authority blocks of flats. However, it is believed that these doors do not conform to fire safety requirements. Issues identified include:
- failure to fit self-closing devices,
- missing intumescent strips,
- no smoke seals,
- non fire-resisting double glazed vision panel,
- fanlight above door comprised of an obscure thin double-glazed unit that is not fire-resisting.
Flat doors, including some that were not fire-resisting when originally installed, have been changed to security doors, without considering fire safety.
Historically, there are issues with fire doors not performing as expected, and there have been programmes undertaken by Local Authorities to address these following findings that arose out of the Grenfell fire. This has led to the publication of Government Advice on the issue.
The reporter states that they have raised these issues with the appropriate authorities but is concerned about the lack of urgency applied to resolve them. Feedback from one authority indicated that they were not concerned, their response being that "[…] the door in question is a ground floor property and as such, there is an alternative means of escape so fire doors are not mandatory". The reporter cites the lack of understanding of the requirements of the Building Act 1984 and the Regulatory Reform (Fire Safety) Order 2005 by building managers being a significant factor that has led to these failures becoming commonplace.
Expert Panel Comments
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Fire exit vs. Fire door
When it comes to doorsets, there can be some confusion as the general public sometimes confuses the meaning of 'fire exit' and 'fire door' (along with their associated requirements). The UK Fire and Rescue Service have dealt with numerous enquiries over the years where these concerns over security doors relate to the doors that access the common areas from outside - these do not generally need to be fire doors.
Notably, there is no need for any conflict between security (including Part Q of the Building Regulations) and fire safety, given how there are certified products available that will achieve both aims and requirements. There are also requirements for doorsets in other relevant Building Regulations guidance, which are included in Approved Documents E, L, and M.
It should be clarified that the fire safety legislation in England and Wales is The Regulatory Reform (Fire Safety) Order 2005 (RR(FS)O 2005). The RR(FS)O 2005 applies to most premises other than those occupied as single/private domestic dwellings, it also covers the common areas of blocks of flats and apartments. Devolved administrations have their respective legislation. The Fire Safety Act 2021 (FSA 2021) which is set to commence has clarified the scope of the RR(FS)O 2005, where in relation to doors it states:
'Where a building contains two or more sets of domestic premises, the things to which this order applies include—
the building’s structure and external walls and any common parts;
all doors between the domestic premises and common parts (so far as not falling within sub-paragraph (a)).'
Role of the Responsible Person
As such, it is the RR(FS)O 2005 that places the legal responsibility of ensuring there are adequate fire safety measures in place in the event of a fire on the Responsible Person (RP, as defined in the RR(FS)O 2005). To address this, the RP must ensure there is a suitable and sufficient fire risk assessment (FRA) for the premises, which will identify the fire safety measures needed and any resulting actions, including those doors as described above.
Where required in blocks of flats, the flat front fire door and associated parts i.e., the self-closing device, smoke seals, intumescent strips, glazing, and door furniture, is an integral part of the overall package of the above-mentioned fire safety measures.
Where any doubt exists concerning this, and any other fire safety measures, the RP for the premises should be contacted in the first instance. This is the ‘person’ who has control over the common parts and is generally, in blocks of flats, the premises management company or organisation.
In addition, as the enforcing authority for the RR(FS)O 2005 for most blocks of flats, advice can also be obtained from the local Fire and Rescue Service (FRS). Information on how to contact them should be available so that a fire safety concern can be raised.
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