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Green Building Bible, Fourth Edition
Green Building Bible, fourth edition (both books)
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    • CommentAuthorArtiglio
    • CommentTime4 days ago
     
    Good day all

    Not a green matter but one i’m struggling with. My local council consiistently accepts fire risk assessments from assessors they engage that give the build date for a block as “around 1970” rather than using the actual date of 1953-5, it then uses the building regs from that date. Conveniently stating the doors are fire resisting , which they are patently not as i replaced mine some years ago.
    Is there a reference available (preferably on line) where changes are listed over time? I’ve found very little other than a data sheet for a 1951 fire door.
    Any help appreciated.
    My issue is that the council has used this to avoid the fire safety works that will be required for the 2005 fire safety order act , and the costs will be astronomical against what they would have been say 10 years ago.
    • CommentAuthorMike1
    • CommentTime3 days ago edited
     
    The key question surely is not what were standards at a particular point in time, but 'do the fire precautions in place meet current standards and best practice'. If not, they should be upgraded unless the deviations are of minor consequence. After Grenfell, I would think that the press would be interested if a council takes any other view.

    See also BS8214 for specifics on fire doors (first edition 1990, latest 2016, I think).
    •  
      CommentAuthordjh
    • CommentTime3 days ago edited
     
    Posted By: Mike1The key question surely is not what were standards at a particular point in time, but'do the fire precautions in place meet current standards and best practice'.

    Well it would be nice if that was the situation, but that's not the law as I understand it. :cry:
    • CommentAuthorMike1
    • CommentTime3 days ago edited
     
    The law doesn't demand exactly that; however in respect of doors, the guides (for example https://www.gov.uk/government/publications/fire-safety-risk-assessment-sleeping-accommodation) do say that 'Fire doors should be installed and maintained in accordance with BS 8214:1990'. Following the current version would seem to be prudent, at the least.
    •  
      CommentAuthordjh
    • CommentTime3 days ago
     
    Posted By: Mike1The law doesn't demand exactly that; however in respect of doors, the guides (for examplehttps://www.gov.uk/government/publications/fire-safety-risk-assessment-sleeping-accommodation" rel="nofollow" >https://www.gov.uk/government/publications/fire-safety-risk-assessment-sleeping-accommodation) do say that 'Fire doors should be installed and maintained in accordance with BS 8214:1990'. Following the current version would seem to be prudent, at the least.

    I'm sorry, I can't find that quote (or anything resembling it) in that document. Where is it please?
    • CommentAuthorMike1
    • CommentTime2 days ago
     
    Sorry, I should have been clearer. It's in the 'related document' Guidance on fire safety provisions for certain types of existing housing by the Local Authorities Coordinators of Regulatory Services in 2008. Page 22.
    •  
      CommentAuthordjh
    • CommentTime2 days ago
     
    Ah, that explains it. What I did find in the original referenced document was this statement on p5: "Where building regulation standards are subsequently raised it is not currently envisaged that further works would be necessary." So that seems to explicitly rule out any idea of keeping up to date with regulations. Which is the situation as I understand it.

    But none of that is relevant to Artiglio's problem I think. But if the fire risk assessment uses a date of 'about 1970', implying that there should be fire doors fitted then the second document you referenced does provide an answer for him I think. Because it says on p22:

    "The specification for the doorset on site should be
    identical to that specified in the test report for the
    doorset, which will be available from the manufacturer
    or supplier. Variations in any detail from the test
    specification may adversely affect the performance
    of the door."

    Which seems to imply to me that part of the duty of the fire risk assessor, in the case where there is supposed to be a fire door fitted and which in this case they are relying on, then the assessor should obtain the spec of the fire door from the manufacturer and check that what's installed matches that specification. If there are no fire doors, as Artiglio says, then they won't be able to do that. So at that point they would have to report it in the fire risk assessment and if they haven't done that then there's a clear failure of assessment to point out to the fire authority responsible for enforcement (copy to the local MP I suggest).
    • CommentAuthorArtiglio
    • CommentTime2 days ago edited
     
    Good evening gents

    Thanks for the input. My council commissions the Fire Risk Assessment from a contractor . I’ve previously flagged up the use of an estimated build date of 1970 and asked why the buildings actual construction date is not used. The council tells me that there is no mechanism for them to advise the contractor of the date and that in the absence of a plaque on the building the assessor will make their own estimation.
    The doors are patently not fire resistant as i replaced the one on my flat when the tenant damaged it having locked themselves out. In the latest FRA there is no written reference to the flat doors just a couple of pictures in the appendix. The council says that this is because of covid a decision not to ask tenants to come to the door (which is fair enough) , the council relying on the doors having been deemed FD30 in a previous FRA.
    Almost comically i had the councils compliance officer attend the building about 4 years ago and he instantly condemmed my door because it was only 34mm thick ,( the flat has crittal door frames and are set for 34mm doors) only after seeing the certification sticker on the door did he grudgingly accept it.( my having sourced a thinner fire door)
    When asked why he thought the original 34mm on the other flats were acceptable given his comments , i got a rather flustered response and never heard from him again.
    The council use the major works exemption to put off changing the doors , claiming the council are doing the works on a risk based priority.( A very similar block about 200 yds from A fire station had the works completed over 10 years ago) It seems that there is an effort to ignore the true status of the doors.
    I was hoping to find that in 1970 that building regs required FD30 doors but that in 1954 they did not. Many buildings at the time were built using the bare minimum of timber as a hangover from rationing/ post war rebuilding.
    As mentioned in a previous comment it seems that a very laissez faire attitude has/does exist in the social housing sector ,grenfell being the prime example.
    I have raised it with my MP, ( before Grenfell) his response was that he could not interfere in local council policy.
    • CommentAuthorMike1
    • CommentTime2 days ago edited
     
    It would be pretty unusual for a 1970s fire door set, which never(?) had intumescent seals (as far as I recall they weren't common until the mid 1980s), to be manufactured and installed in full compliance with BS 8214:1990, which requires them.

    Some of the companies I worked for back in the 80s did a lot of work upgrading fire doors with intumescent strips & glazing (though without smoke seals, which became common later still) for various clients.

    No doubt you could look up the British Standards to find publication dates.

    Of course if the 1970s door sets have been retrofitted, they'd then fail the 'identical to the manufacturer's test report' criteria...

    But ultimately it is indeed the assessor who must make a risk assessment, taking into account recognised guidance such as that mentioned above.
    • CommentAuthorMike1
    • CommentTime2 days ago
     
    Posted By: ArtiglioI was hoping to find that in 1970 that building regs required FD30 doors but that in 1954 they did not.
    It's not that simple. Knowledge of what makes a fire door effective developed over time through scientific testing, and the British Standards subsequently evolved in response to those results. Consequently what was deemed an appropriate fire door changed too.
  1.  
    Posted By: djhAh, that explains it. What I did find in the original referenced document was this statement on p5: "Where building regulation standards are subsequently raised it is not currently envisaged that further works would be necessary." So that seems to explicitly rule out any idea of keeping up to date with regulations. Which is the situation as I understand it.

    That is how I have understood things. Buildings are put up according to the regs. of the day and so remain regardless of regulation changes. However if work is done (replace rather than repair) then current regs must be followed. (The get out using repair is an old dodge because there is no laid down %age of when repair becomes replace (other than the insulation regs.))

    So in this instance I would expect the 1950s doors to be acceptable unless changed where current regs. doors would need to be fitted.

    Posted By: ArtiglioI’ve previously flagged up the use of an estimated build date of 1970 and asked why the buildings actual construction date is not used. The council tells me that there is no mechanism for them to advise the contractor of the date and that in the absence of a plaque on the building the assessor will make their own estimation.

    I would have thought, regardless of any council mechanisms for the council to inform the contractor of the date of build, I would have thought that it would be due diligence on behalf of the contractor to enquire about the date. Also when the council put out for tender to do the fire assessment risk I would have thought the date of build would be contained within the description of the building along with the specification of the work to be done.
    •  
      CommentAuthordjh
    • CommentTime2 days ago
     
    Posted By: ArtiglioMy council commissions the Fire Risk Assessment from a contractor . I’ve previously flagged up the use of an estimated build date of 1970 and asked why the buildings actual construction date is not used. The council tells me that there is no mechanism for them to advise the contractor of the date and that in the absence of a plaque on the building the assessor will make their own estimation.

    As mentioned in a previous comment it seems that a very laissez faire attitude has/does exist in the social housing sector ,grenfell being the prime example.
    I have raised it with my MP, ( before Grenfell) his response was that he could not interfere in local council policy.

    I wouldn't have thought a specific 'mechanism' would be required for a landlord to tell an assessor of an error in their report and ask them to correct it. A letter would suffice, I'd have thought. As Peter says the duty of care of the assessor and for that matter the council ought to ensure that such information is taken into account. I believe the enforcement responsibility for assessments lies with the fire authority, which depending where you are may be more or less associated with the council. Hence my suggestion of writing to them with a copy to the MP. Post Grenfell I think the situation is somewhat different to pre-Grenfell and a fire authority having a letter on file with a copy filed elsewhere may perhaps provoke them to action.

    I believe the fire order et al do contemplate upgrading old buildings to newer standards, specifically with regard to fire safety, as an exception to the general principle of the 'use the building regs of the day' notion. The details are in the document.
    • CommentAuthorArtiglio
    • CommentTime1 day ago
     
    My view is that the use of an estimated 1970 build date rather than the actual 1953-5 is that the assessor could then not deem the doors to be fire resistant. The door sets are the originals on 4 of the 6 flats. Mine is the only one with intumescent and smoke seals, fire rated letter box etc. It is though only hung on two hinges but on councils advice i contacted the fire service wh said that it would be fine ( verbal nothing written) . The original door i removed was no more than 2 sheets of 6mm ply on a 15mm framework with the old corrugated card to hold the panels apart away from the lipping / frame.
    You couldtell by the weight of the dooor when you opened it that it had no substance and sounded hollow when you tapped it.
    It really does seem that the council is knowingly accepting the doors as fire doors to avoid replacement until it suits them. Over the 16 years since the fire safety order act the cost of doors in section 20 notices ( for long term contracts) has increased from 600 to over 1400 pounds each. Add on ( the hopefully cheaper cupboard doors in the corridors) and there are 15 doors in total, my liability is for 20% of contract cost, hence my wanting works done asap rather than see costs escalate ever higher.
    •  
      CommentAuthordjh
    • CommentTime1 day ago
     
    Posted By: Artigliodeem the doors to be fire resistant

    There doesn't seem to be any way a fire risk assessor can 'deem' the doors to be anything. S/he has to check them physically and check that against the original paperwork. If I've understood the various documents that have been linked correctly.
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