Featured in Fire Risk Management, September 2011 issue
Peter Barker, Senior Consultant at Chiltern International Fire, discusses the role of site surveys within the education sector.
The intention of the Regulatory Reform Fire Safety Order (RRFSO) was that the designated duty holders could carry out a mandatory fire risk assessment without having to employ a fire safety specialist in all but the most complex of buildings.
For educational establishments, the complexity, type of occupancy and other responsibilities typically held by duty holders mean that the role of risk assessment is often passed to an external consultant. A competent fire risk assessor is a person with enough training and experience or knowledge and other qualities to enable them properly to assist in identifying appropriate preventive and protective measures for a particular building. Preventive measures are typically management and system –based, while protective measures are designed into the building, ie passive and active protection. A fire risk assessor without this level of competence will typically only identify problems. There is a significant difference in how this ultimately influences the response of the duty holder when it comes to addressing existing fire safety measures.
Furthermore, educational establishments are at higher risk of arson attack – data published year on year by the Department of Communities and Local Government (DCLG) indicate a disproportionately high rate of arson in schools when considering other building types. Also, the occupants cover a wide age range and have different levels of familiarity with the building. It is also possible that a proportion of students will have special needs that may impede their ability to evacuate the building without help. The risk assessor must therefore have enough experience to take this into account within the overall assessment for the building, to be able to specify preventive and protective measures commensurate with the existence of the risk. They may also have to weigh the existence of the risk against the cost, effort and difficulty of implementing those measures.
Compartmentation
The principle of compartmentation is key to the fire safety of buildings: a building is constructed with fire-resisting compartment lines that essentially contain the fire to the room of origin, to limit its size and spread and to allow the occupants to escape from the building. For a school after the fire incident, this will help minimise disruption, as other areas can continue to function whilst the affected area is reinstated.
Compartmentation is not restricted to the containment of fire alone. Smoke control will also need to be considered. Smoke is often the first thing to be noticed by the occupants and generally instigates the first alarm. Smoke may also impede evacuation from the building - as visibility deteriorates, the build-up of carbon monoxide and other toxins can affect breathing and cause asphyxiation. The effects of smoke inhalation will be felt sooner by younger pupils who breathe more rapidly than adults. It is imperative therefore that compartment lines are adequately maintained to provide resistance to fire and smoke and to protect the escape routes from the building.
For a building to operate, you must be able to move between compartments. The function of a fire door is to facilitate this movement around the building or to allow the passage of persons, air or objects, whilst maintaining the fire-resistance of the compartment line when closed. Given the level of traffic and severe wear and tear that fire-resisting doorsets encounter within a school environment, it is hardly surprising that they are highlighted within the fire risk assessment as needing attention.
Fire resistance
It is relatively easy to identify that a fire-resisting door is unlikely to provide the required level of fire resistance, if the risk assessor has a basic knowledge of this specialist product. Identifying confidently that a door is capable of providing a specified level of fire resistance against a particular test standard is less straightforward, especially when the doors are of unknown age, origin or construction.
It is for this reason that a large number of risk assessors will record that the fire doors are deficient and need to be brought up to current fire resistance standards. Arguably, the risk assessor has done his job by making this statement. He has recognised the need for a fire-resisting doorset, highlighted a potential problem in terms of its fire resistance capabilities and has brought to the attention of the responsible person that action is needed to ensure that the protective measures in place are sufficient with the overall fire risk for the school.
The difficulty is that the responsible person now needs to respond to the findings of the risk assessment. The logical response is ‘how do I bring my doors up to the current fire resistance standard?’ when perhaps it should be ‘why do I need to bring my doors up to current fire resistance standard?’
In the UK, the test standards in question are BS 476: Part 22: 1987 and BS EN 1634-1: 2008. Generally speaking, schools and educational establishments within the UK vary greatly in age, with many having an older core building with modern annexes and newer buildings added over time. A wide range of construction methods and materials can be found in a single school and there will be many school buildings which comply with Building Regulations which have been superseded since the original school was built.
Building Regulations are not applied retrospectively. If a building was signed off before 1987, with fire doors tested to BS 476: Part 8: 1972, they do not become obsolete because the test standard has been updated. In fact, it states in Approved Document B that doorsets tested or assessed to that standard prior to 1987 are acceptable. The difficulty generally lies in the fact that very little information on the manufacture and installation of fire doors is recorded after the building has been signed off by the appropriate authority - something which is now recognised by the introduction of Regulation 38, which is discussed later in this article.
Significant findings
If a competent fire risk assessor has identified the fire doors as deficient, it is likely that local fire and rescue services would also highlight this during an inspection of the building – and if the doors are obviously deficient they may issue a notice of deficiency or enforcement notice.
There are many reasons why a fire risk assessor may require a particular doorset to be brought up to current fire resistance standards, although a different response may be needed for each scenario: e.g.
- There is no indication that the doors were installed as fire doors, but the use of the building and means of escape require a doorset with proven fire resistance performance.
- The doors appear to have been installed as fire resisting doors, but are likely to be more than 25 years old.
- It is likely the doors were installed as fire resisting doorsets, to the current fire resistance test standard, but there have been subsequent modifications that may have reduced the fire resistance performance.
- The doors are of timber joinery construction with panels and glazing and require a fire rating because of their location in the building. It is possible that the doors are also heritage or at least have sentimental or aesthetic appeal.
- The doors are marked as fire-resisting doorsets (via third-party certification plugs or labels) but wear and tear/damage have meant the fire resistance performance of the door has been compromised.
- The doors are likely to have a 30-minute fire rating, but because of the change of use of the building, the door needs to be rated for 60 minutes fire resistance.
For a doorset to pass the BS 476: Part 22: 1987 test, it must be have the appropriate leaf construction, installation and associate ancillary components such as hardware, intumescent seals and fire-rated glass and glazing system (if present). An error in any one of these elements can significantly detract from the fire resistance capabilities of the doorset.
There are numerous different door types and constructions and in terms of upgrading there isn’t a one size fits all approach. This is why it is critical to be able to identify the manufacturer of the door design, to source the test evidence and assessment of performance for the door, to identify how it is constructed and what intumescents, hardware and glazing etc are permitted. This will also establish unequivocally that the door is of fire-rated construction. Without this information, the task of establishing the fire resistance of the door becomes difficult, as it requires making a judgment on unknown factors as to whether it will perform in test conditions.
Investigative Surveys
It is no coincidence that since the RRFSO came into force in 2006, Chiltern International Fire (CIF) has seen a sharp rise in the number of requests to establish the fire resistance performance of doors to current test standards. The majority of these requests are in response to a fire risk assessment that has identified the doors as deficient – and there is no supporting evidence of specification or performance.
Regulation 38 (formerly regulation 16B) of the Building Regulations was introduced at the same time as the RRFSO and requires that where building work involves the erection or extension of a relevant building or a relevant change of use, fire safety information is given to the duty holder at the completion of the project, or when the building or extension is first occupied. The intention is to help the duty holders with risk assessment, as the information will provide a record of the fire safety measures designed into the building. However, before 2006, there was no requirement to record fire safety information, so once the building had been signed off by the relevant authority, it was deemed to be compliant and archiving supporting information on items such as fire doors was not considered necessary. In most cases, this information would be provided by the builder to building control - the owner or manager of the building would never see it.
Third-party certification of products and services offers not only a means of assisting compliance with legislation, now including fire risk assessment, but also provides a level of confidence in the manufacture of the product. Above all it provides traceability and is therefore very useful for identifying that the element is fire-resisting without having to use the services of a specialist company. It is strongly recommended that third-party certified products are used within educational establishments.
However, there is no requirement for fire-resisting doors to be third-party certified and marked. . The only signage required is to identify the door as a fire door, in accordance with BS 5499-5: 2002 (eg Fire door keep shut, Fire door keep locked or Automatic fire door keep clear). While it is hoped that the signage is fitted to a door with known fire resistance performance, it is not the same as a plug or label denoting third-party certification.
The most robust way of identifying the fire resistance of a doorset to current test standards is by fire resistance testing, which obviously defeats the object, as the door would need to be replaced. The next step is to gather as much information on the doorset by taking core samples, potentially removing glazing beads and architraves, and identifying the presence of internal framing, hardware and intumescents to assess its overall condition. Essentially, enough information has to be gathered for the surveyor to make a judgement on how the door may perform if tested to the relevant standard - and herein lies another important point, the surveyor must have enough experience of the different door constructions on the market to be able to assess the door’s fire resistance performance and identify what measures are needed to enhance or reinstate its fire resistance capabilities.
CIF has carried out several surveys on upgraded doors where the advice has been given by someone with insufficient experience. The results are wide-ranging, with the common thread that a lot of money has been spent and very little achieved. Unfortunately, in a number of cases, the fire resistance of the doors has actually been reduced.
When a building element, such as a fire-resisting door, is judged against a test standard, it is done independently of the building, the fire load, compartment size and overall management and evacuation strategy. The performance is being considered in terms of British or European test standards. It is highly likely that depending on the location of the particular door in situ, it will never experience that same fire exposure as that experienced under standardised laboratory conditions. A fire risk assessor with enough knowledge and experience of passive fire protection and fire development within a building should be able to make a judgment on the adequacy of the fire door – this is in fact the process of risk assessment. Risk assessment is not about identifying elements of the building construction that fail to meet current fire resistance test standards and expecting them to simply be replaced. If this were the case, a lot of schools would need to be reconstructed.
It is possible that a competent fire risk assessor will identify certain areas of the school that must have fire doors with the highest possible level of fire resistance in terms of the current standards eg chemistry, information technology, home economics or design technology departments, and may well suggest seeking advice from a specialist. Should this be the case, it is strongly advised that the credentials of the company offering this type of survey are thoroughly checked out.
Conclusion
The process of risk assessment is considerably more straightforward if the performance of the existing fire safety measures is known. This has been recognised by the introduction of Regulation 38, which should reduce the burden on the duty holders when responding to the findings of the risk assessment. It should also make the job of risk assessment more straightforward, as it avoids the need for surveys and inspections by a third party.
However, for the majority of schools that were deemed to be compliant at the time of construction, it pays to have the fire risk assessment carried out by a competent individual who can appropriately assess the risk, to identify the shortcomings in the existing fire safety measures. Where safety is concerned, it’s often wise to call on the services of an expert to put them right.
PDF: Risk assessment and fire resistance: who, how and why?
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