Fire door compliance: Cutting through the red tape

Fire doors play a vital role in building safety, but compliance with regulations can often appear overly complicated. Here, 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 about compliance, a recurring issue is the complexity of information provided by manufacturers or installers in support of fire door work. Too often, building control is presented with a large bundle of documentation – some relevant, some not – and must extract the performance data they need.

BWF Technical Director, Kevin Underwood

As the installation, replacement or alteration of a fire door is considered “building work,” it must be notified to building control, and the supporting evidence used to demonstrate compliance must be relevant to the products installed.  The Building Regulations 2010, which apply in England and Wales, state that a person intending to carry out building work must submit either a building notice or a full plans application to the relevant authority before work begins. Where emergency repairs make this impossible, the person undertaking the work must submit a building notice as soon as reasonably practicable after work starts.

For the purposes of the regulations, “building work” includes:

• The erection or extension of a building

• The provision of a controlled fitting

• The material alteration of a building or controlled fitting

• Work relating to a material change of use

  
  

External fire doors, doors between flats and unheated corridors – and doors between houses and unheated garages – are considered controlled fittings because Part L of Schedule 1 imposes a thermal performance requirement (U-value). When these fire doors are replaced, it may not always be necessary to notify building control directly. Such work may fall under a self-certification scheme (Regulation 20 and Schedule 3, sections 10 or 11), covering replacement of windows, rooflights, roof windows or doors in existing buildings. In these cases, the local authority may accept a certificate from the installer as evidence of compliance.

However, replacing or altering an existing fire door is considered a material alteration and therefore “building work.” It must be notified to building control because such work could cause the building or fire door to no longer comply with requirements B1 (means of warning and escape); B3 (internal fire spread – structure); Part M (access to and use of buildings); or make a non-compliant situation worse.

In all cases, Regulation 7 applies, covering materials and workmanship. This regulation requires that work is carried out using adequate and proper materials, suitable for the circumstances, properly prepared and fixed so as to perform their intended function.

As previously mentioned, the draft of PAS 2000: Construction Products – Bringing Safe Products to Market – Code of Practice includes a section on product information. It states that construction product information should be accurate, accessible, transparent, up-to-date, useful, comprehensive, consistent and unambiguous – 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 fire doors must meet additional performance requirements – such as enhanced security, thermal transmittance, weathertightness, self-closing or sound attenuation – it’s essential that all supporting evidence applies to the exact same design, size, materials, hardware and glazing options for all required characteristics.

Members of the BWF Fire Door Alliance – including fire door manufacturers, blank manufacturers and licensed processors – all hold third-party product certification for fire resistance under schemes operated by Certifire, BM TRADA or IFC. These schemes provide additional assurance that the fire doors specified and installed will perform as required.

To find out more about the BWF Fire Alliance, see www.firedoors.bwf.org.uk.