CROSS Safety Report
Misleading fire rating on hatches
Retrospective fitting of various amenities including TV aerials, broadband, and satellite connections, may result in new access points being made in walls, ceilings, or through floors. These openings need to be made good using a method that provides the required fire safety properties for that specific situation, including integrity, insulation, and resistance to smoke spread. A reporter is worried that some hatches may not provide all three of these properties.
Key Learning Outcomes
The Regulatory Reform (Fire Safety) Order 2005 defines a Responsible Person who has to ensure that they use a competent professional to do the work
When using a hatch to repair/make good an opening ensure that the hatch meets the criteria necessary for the situation in which it is being used. The criteria can be found by checking with the appropriate fire safety information; if that is not available, the relevant technical guidance or the Responsible Person could be advised.
Hatches may be supplied that have been tested for a period of fire resistance in all or some of the terms of loadbearing capacity, integrity, and insulation. In some situations, the wall, ceiling, or floor that this hatch will form a part of may also require to have integrity, insulation, and resist the passage of smoke for a period, which may differ from the specifications of the hatch.
For manufacturers and suppliers:
Ensure that, for products that offer fire resistance, it is made clear if they provide all the necessary performance characteristics, including integrity, insulation, along with resistance to the passage of smoke when needed
If these products do not, they should be clearly marked as not suitable in certain situations
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The Full Report below has been submitted to CROSS and describes the reporter’s experience. The text has been edited for clarity and to ensure anonymity and confidentiality by removing any identifiable details. If you would like to know more about our secure reporting process or submit a report yourself, please visit the reporting to CROSS-UK page.
The reporter states that a broadband installer is using '2-hour fire rated' hatches to make good ceilings in blocks of flats. It has also been observed that the same '2-hour fire rated' hatches are being used in walls separating flats from the common areas, allowing access to services. The certification of these products indicates that they may only offer 2 hours of protection against 'E' integrity, but offer very little protection against 'I' insulation; in addition, they do not stop the passage of smoke. The case observed in the ceiling of the common area was in a timber-framed structure, where the ceiling was providing fire resistance to the timber structure, therefore this hatch should have the required EI values for the height of the building.
Similarly, the walls to the flats where the hatch had been fitted also required the correct EI values to ensure the correct fire resistance had been provided. The hatches are widely used, and they are being sold as 2-hour fire rated hatches in the marketing literature, which requires the person installing them to both understand fire testing and the requirements of the building that it is being installed. Such practise compromises the compartmentation of the ceiling and the walls, given how the reporter considers that heat and smoke can transfer between compartments as the correct insulation has failed to be installed. The consequence of this is that in the event of a fire, smoke may affect the available means of escape, or heat may transfer into another compartment, spreading fire around the premises and potentially compromising the means of escape.
The cause of this, according to the reporter, is unclear marketing information/anomalous documentation from the hatch manufacturer, exacerbated by the incompetence of the installers. Even though the fire test reports for these products explicitly state that the hatch has not been tested/or offers very little protection towards insulation (I) and does not stop the passage of smoke, such information is less prominently presented or unequally highlighted with other performance points, to avoid navigating the complexity of fire testing and any limitations in performance claims. Those limitations are often in small print and often written in technical language so that non-specialists will not understand what it means. If a person relies only on the marketing information to choose a solution, then they do not get the full picture of the product’s performance. This again raises the issue of the installer/specifier competence to know what the actual product information is and to select the correct product. The motivation behind this practice may be to improve the marketability of a product.
If a person relies only on the marketing information to choose a solution, then they do not get the full picture of the product’s performance
It should be highlighted that whilst this hatch may be used safely in many circumstances, given the fact that most compartment lines are above the false ceilings in blocks of flats, if the hatch is fitted in an area required to offer E and I (such as in the case of the timber-framed building), then the reporter is of the opinion this poses a risk. Related to that, Table B3 of ADB vol 1 predicts that 'only if a suspended ceiling meets the appropriate provisions should it be relied on to add to the fire resistance of the floor' and an inappropriate hatch can compromise that. This raises the question of whether the installer has the necessary information to derive where the compartment line is and what the performance required is so that the product installed matches the performance of the ceiling.
Finally, it is also highlighted that issues that are compromising the integrity of compartmentation, and thus the reliability of the fire strategy, are indicative of a trend, given the similarity in the recently published Report ID: 1039 'Fire compartmentation detailing issues'.
Concept explanation, functional requirements, and guidance provisions
Appendix B in Approved Document B (ADB) provides a synopsis of the performance concepts employed. Paragraph B19 clarifies that 'Fire resistance is a measure of one or more of the following:
- Resistance to collapse (loadbearing capacity), which applies to loadbearing elements only, denoted R in the European classification of the resistance to fire performance.
- Resistance to fire penetration (integrity), denoted E in the European classification of the resistance to fire performance.
- Resistance to the transfer of excessive heat (insulation), denoted I in the European classification of the resistance to fire performance.'
Further clarifications can be found in Section 5 of BS EN 13501-2:2016 (Fire classification of construction products and building elements, Part 2: Classification using data from fire resistance tests, excluding ventilation services), a document which additionally defines the fire performance characteristic for smoke leakage (S), as 'the ability of the element to reduce or eliminate the passage of gases or smoke from one side of the element to the other'.
This incident is of concern when taking into consideration that a building must satisfy the functional requirements as they are set out in the Building Regulations 1984. Related to this report, requirement B3 has two related clauses about limiting internal spread. Clause (3) states for fire spread that 'where reasonably necessary to inhibit the spread of fire within the building, measures shall be taken, to an extent appropriate to the size and intended use of the building, comprising either or both of the following –
sub-division of the building with fire-resisting construction;
installation of suitable automatic fire suppression systems'.
Additionally, when it comes to smoke spread, Clause (4) in the same requirement outlines that 'the building shall be designed and constructed so that the unseen spread of fire and smoke within concealed spaces in its structure and fabric is inhibited'.
From this last clause, it is indicated that smoke spread is of interest only in concealed spaces and within the structure’s fabric. So it is up to the responsible person for making these changes to decide if the hatch is going through a concealed space or through building fabric that could act as a conduit for smoke spread and use the appropriate materials and products. If the cable services hatch is considered a penetration through fire resisting construction, whose elements have no internal voids to offer routes for smoke spread, then the integrity and insulation criteria are of interest, given how these hatches have no load bearing role to address the criterion of resistance.
ADB vol 1 paragraph 7.20.b clarifies that service cables should comply with Section 9 of the same document. Section 9 has ES (integrity and smoke) ratings only for ducts and flues, not cable service installations. The initial paragraph that refers to service cables in that section, 9.24.b, is under the theme of fire-stopping and part of it states:
'b. Openings through a fire resisting element for pipes, ducts, conduits or cable should be all of the following.
As few as possible.
As small as practicable.
Fire-stopped (allowing thermal movement in the case of a pipe or duct).'
A clarification follows that any 'materials used for fire-stopping should be reinforced with (or supported by) materials rated class A2-s3, d2 or better to prevent displacement' in some cases, which brings up the performance metric of the Reaction to Fire Class, which can be its own source of anomalous documentation in the market literature. Finally, it is mentioned in 9.26 that 'proprietary, tested fire-stopping and sealing systems are available and may be used. Different materials suit different situations and not all are suitable in every situation', with further guidance found in publications by the Association for Specialist Fire Protection (ASFP), in the section for additional reading at the end of this report. The same guidance is provided in ADB vol 2.
What is different in ADB vol 2, is that in Section 10 it is clearly outlined that 'The performance of a fire-separating element should not be impaired. Every joint, imperfect fit and opening for services should be sealed. Fire-stopping delays the spread of fire and, generally, the spread of smoke as well'.
There are also three concepts around the issue of product documentation. In the ASFP Guide for Ensuring Best Practise for Passive Fire Protection in Buildings, these are clarified in Section 3. In order to demonstrate the performance of a product, fire test reports can be used that refer to the actual product and not any of its variations. To assess the variation of a tested product, an assessment, or expert judgement report can be used that expresses the opinion of a competent authority or a person on the likely performance of a product. Finally, a certificate of a third party can be used where a reliable third party validates the claimed performance of a product. Selective presentation of performance claims can be based on any kind of these documents.
Expert Panel Comments
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Selection of appropriate test criterion
This is recognised as a quite common situation. The initial cause of this, which is incomplete product information in the market literature, is also an issue with the performance characteristic of Reaction to Fire Class, or third-party accreditation. Product labels should be unambiguously clear in what performance characteristic (R,E, or I) a particular product offers resistance against. Responsible suppliers give clear warnings and disclaimers about the limitations of the use of their products. Simplified claims of a time performance according to a specific standardised test without any reference to the criterion tested sound technical but can be misleading. These claims go against the cultural change needed in the construction industry, as was mentioned in the Hackitt review.
It should additionally be considered that the choice of an appropriate product can be complicated further because when making alterations through a ceiling or other compartment boundary, any access panel needs to satisfy all the requirements of that compartment additional to fire, which are set out in other Approved Documents, usually for Acoustics and Structural needs.
It has also been noted by panel members that these issues of unsuitable products are regularly identified by the Fire and Rescue Service when auditing, considering this report as an extension of the common 'fire rated foam' problem. The core issue is that the breaching of fire compartmentation, caused by fixings through plasterboard walls or other construction, is a major issue that can undermine the fire strategy of buildings and appropriate care should be given.
Passage of smoke
Another possible source of confusion can be the requirement for the passage of smoke. While it is expected that openings made good will resist the passage of smoke, there is no metric defined in such cases. Such metrics can be found, however, for fire doorsets in Appendix C of ADB in the form of the Sa classification (according to BS EN 1634-3). Given how some of these hatches may be hinged, a possible pitfall could be that the requirements for fire doorsets are advised. This will depend on the intent of the component’s function, but may sometimes be inaccurate. It should be noted here that the fire resistance of doorsets, in particular, does not have an insulation 'I' requirement. It is presumed that the reason for not needing 'insulation' is because doors tend to be in locations where there are no combustible materials close to the opposite face of the doors, so fire spread by heat conduction is less likely. Given how a ceiling hatch could have combustible materials above it, it is not certain that the same logic would apply to hatches. Additionally, doors are never really expected to form part of the fire protection to the structure, whereas in the case mentioned, the ceiling hatch is part of the protection to the timber structure above. Appropriate care should be given that the understanding of the component’s function is clear and the desired performance characteristics are satisfied.
Appropriate care and understanding appear to be issues revolving around the competence of the people involved. On the top level, the Responsible Person under the RR(FS)O 2005, usually the building manager (or their representative), needs to be aware of how the building is designed and constructed. If there are certain parts of the building structure that are needed in order to achieve the necessary fire resistance (e.g. compartmentation or protection to structure) then they need to have restrictions in place to make sure people don't make any alterations without dealing with them appropriately. Following that, the person who is doing the work needs to follow the guidance of the building manager. If they are, for example, cutting a hole in a board that needs a specific fire resistance, then they need to ensure that the hole is sealed with an appropriate product and that the work is carried out to an appropriate standard; those will depend on the nature of the construction and the type of hole being created. Reciprocally, the building manager would need to be confident that the person has done the work appropriately, and there is a certain level of competence needed to do that. At present, these areas are not well controlled, yet it is expected that the Building Safety Bill will address these aspects.
This is one of the issues which was identified in the Hackitt review, with Chapter 7 of the final report being dedicated to issues related to products. Further on this topic, the Inquiry into the Grenfell Tower fire has shone a light onto the way a number of products used in the building were tested, labelled, and marketed in effectively a dishonest manner. There is ongoing government work on the issue through the Independent Review of the Construction Products Testing Regime. There are also industry initiatives such as The Code for Construction Product Information by the Marketing Integrity Group of the Construction Products Association, so developments should be expected that will address such concerns. In the interim, what should be ensured is that manufacturers and suppliers have a consistent basis for their claims on fire performance and to ensure that specifiers are trained and competent in extracting and promoting the appropriate performance specifications.
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