Preparing safety case reports fire doors not marked

Help to prepare safety case reports

This information is for Accountable Persons (APs) of high-rise buildings to assist them in preparing safety case reports including fire doors for Building Assessment Certificates.

The safety case report must demonstrate that all reasonable steps have been taken to prevent building safety risks happening from fire doors not marked and reduce the seriousness if they do.

Fire doors in high-rise buildings

Fire doors are an important safety measure in higher-risk buildings.

They can help prevent the spread of fire (and smoke) and from the compartment where it starts. They also provide a barrier between people and the fire during any evacuation.

Fire doors is shorthand for fire-resisting door sets or fire-resisting door assemblies. A door set or assembly is made up of the door, frame and furniture such as locks and handles.

Some doors look like fire doors but may not be marked or identified as such. This example assumes you have checked and confirmed a fire door is needed in that location and for that purpose.

You could do this by referring to the building’s fire risk assessment or a competent person such as a fire risk assessor.

You could use a similar approach if you know it is a fire door, but it has replacement fittings that you cannot confirm maintain the integrity of the fire resistance.

As with other examples, the possible responses listed are not exhaustive. The key thing is to investigate any problems and resolve them.

Scenario

You may have doors which need to be fire doors but do not appear obviously marked or identified as such.

Background and possible reasons

There are a number of possible reasons for this:

fire door markings may have been missed
it could be an old fire door that isn’t marked
it looks like or has some features of a fire door but
isn’t on

Short term responses

The first thing to do is to investigate whether it is a fire door or not.

You could do this by checking records. Bear in mind that what is actually there may differ from the records.

For example paperwork may refer to a previous door or a door may have been modified (with new locks for example) since it was fitted.

You might find information in the building’s health and safety file if it was built recently.

Alternatively, other records or the contractors who fitted the door may have information. You, or a competent person can inspect the door.

You could also do some basic checks yourself. For example, you could check markings haven’t been missed. Labels are often on the top edge of a door and not visible from ground level.

Alternatively, plugs (circular disks) might be found on the hinge side of the doors.

You could also check basic features of the door. These won’t prove conclusively that it is or isn’t a fire door, but may help you work out next steps.

For example, you could check the thickness of the door or the number of hinges.

if it is less than 45mm thick (30 minute door required) or 54mm (60 minute door required) it is unlikely to be a fire door
if it does not have 3 hinges it may not be a fire door

Although signs or a notice would not be acceptable as a long-term solution. However, they may be helpful as an interim measure

Consider whether any other measures are needed to manage the risk until the problem has been fixed.

Additional responses

There are a number of possible outcomes to your investigations.

You may be able to confirm it is a fire door. If so, make sure you record the details for future reference.

You may not be able to confirm it is a modern fire door. But confirm it meets previous standards or appears to meet some of the requirements for a fire door.

If this is the case, you should assess whether the door can be considered to be a fire door. These are sometimes referred to as ‘notional fire doors’.

Whoever does this will need to be competent – you may need a consultant or contractor to help you.

You will find further information on notional fire doors in Fire Safety in Purpose Built Blocks of Flats.

If you have a large number of the doors or doors with the same replacement fittings, you could consider getting one tested to see if it meets the requirements for a fire door.

There will be a cost involved, but if it passes it could be cheaper than replacing a large number of doors.

One property owner had replaced key locks with card operated locks on over 200 doors but could not evidence that the fire resistance of the door had been maintained.

They had a door tested, it passed and saved them having to replace the doors. A comparatively small cost saved them a large amount of money.

If you can regard the doors as notional fire doors, or they pass a test, record the details as you would for any other fire door.

If you cannot treat it as a notional fire door, it fails a test, or it is obviously not a fire door, you will need to prioritise and schedule for replacement.

Some doors will be a higher priority than others. For example a door to a staircase enclosure will likely be a higher priority than a cupboard door which residents don’t have to pass when evacuating.

You should also consider whether any interim measures are needed until the replacement work has been completed. If so, you should put them in place.

Ongoing management

Whatever the result of your investigations, you should ensure you have a system for checking that any fire doors fitted are appropriately labelled and evidence recorded.

You should also manage any changes to fire doors, such as new locks, to ensure they do not affect the fire resistance of the door.