The Fire Safety Act 2021 became law in April 2021 and clarifies which parts of multi-occupied residential buildings apply under the Regulatory Reform (Fire Safety) Order 2005. It does not stipulate in detail the sort of features that all premises need to have. Instead, it places the broad duties to help keep people safe from fire upon the “Responsible Person”.
The “Responsible Person” (for example, building owners or landlords) is now legally responsible for ensuring their buildings are fit for purpose and fire safe. This includes the requirement for competent persons to undertake frequent fire doorset surveys and replace defective parts.
This has generated an overwhelming requirement for fire door inspectors such as ourselves to carry out full fire doorset surveys on multi-occupied buildings.
Thousands upon thousands of doorsets.
Professional fire door inspection begins with identifying the original manufacturer and reviewing their certification. However, many buildings contain fire doors for which the certification has disappeared (or never existed in the first place). This creates legal uncertainty and moral dilemma for the owners.
The term ‘nominal fire door‘ is used where an existing fire door’s fire presumed performance cannot be proven but it is assumed, following satisfactory assessment of the doorset and installation, that the door will be of a suitable standard to act as a fire door.
But is this a satisfactory answer?
It is illegal to place a fire door on the market without it having suitable formal evidence of performance so why should we accept an existing “nominal door” without it?
Making a Judgement About a Nominal Fire Door
For some, reaching a decision on whether a door can be accepted as a nominal fire door may be as simple as checking that the door is solid with no apparent defects, but is that enough?
A solid core is very important, as however, is the condition of the door, its edges, and correct intumescent and smoke door seals (of course without the certification, the inspector cannot determine if the intumescent strips are correct) Hinges, screw fixings, self-closing device (door closer), other ironmongery and installation will be assessed
There is very little guidance available about nominal fire doors. The British Standard BS 8214:2016 ‘Timber-based fire doors Code of practice’ does not offer clarity on Nominal Fire Doors.
Nominal Fire Doors Should Be Risk-Assessed, But Should We Allow Them?
After spending a lifetime of manufacturing fully certified fire doorsets, our answer can only be no. But is this practical?
There is no circumstance where we can suggest using a nominal fire door in a non-critical location. If the door was designated a fire door, then it forms part of the means of escape. Therefore, it is critical.
However, if they are not considered, the demand asking us to inspect and replace every fire door immediately is an impossible challenge to meet.
So, Should We Allow Nominal Fire Doors?
The answer is still no, but in terms of practicality we have little choice but to say yes, providing a programme of replacement is agreed.
This debate will continue to roll whilst arguably occupants are at risk.
We would suggest the pragmatic approach is to ensure all nominal fire doorsets on main escape routes and those leading onto it are replaced.
Thereafter a schedule of replacement works is agreed over a reasonable period to replace all nominal fire doorsets.
As with making any decision that potentially affects life safety careful consideration should be given to all available options.