TYPE 1 – COMPLIANCE INSPECTIONS OF NEW FIRE DOORS 08-03-2023

Type 1 - Compliance Inspections of New Fire Doors 08-03-2023

STEVE WYPER I’ve dived in on this one because it’s a topical issue at the moment, Dived in on this one because it's a topical issue at the moment. Uh, we've had to bring in outside consultants to start asset tagging and doing a review of fire doors and initially someone else in the business was supposed to be taking care of it and of course it came back to the compliance department. So, very topical, but we’ve also been drawn into some new build stuff that, again, should be dealt with by our surveyors and we've realised that, basically, we went to one site and saw 20 out of 20 incorrectly fitted brand new fire door sets, all of them to damage to the point of needing replacing.  So I thought, right, there’s a group on fire doors, I’m going to jump into that. We need help. People have probably been to architectural college or surveyor training 5 to 30 years ago, just weren’t aware of things like following the manufacturers instructions, install instructions, wow, you know, how radical could that be.

I’m at Reading Borough Council. I was with Sovereign until 5 months ago, and they were doing a very tricky re-org, which our department wasn’t part of, but it just made it a little uncomfortable. You’re doing projects with people and they suddenly disappear

GEORGE It’s probably worth just explaining quickly who we are, just before we move on.

STEVE WYPER I’m Building Safety Manager at Reading Borough Council. Predominantly brought in to look after the taller buildings, but getting dragged across the business, depending on what the needs are and assisting all departments now, as my colleagues in compliance are. We've got 7 high-rise, but in the 11-18 metre space we've probably got at least another 20 buildings. We haven't measured them all yet.

ELLIOTT DAWSON Distinction Doors/FDS, I'm now sales director but was brought in to lead up the FDS side. So FDS is a fully, when I say fully compliant, it’s belt, braces over 106 bidirectional tests now to EN 1634 standards now have door data tagging, so fully compliant with the golden thread which I’m sure we’ll come onto. We sell through a fabricator network throughout the entire country, which means we can facilitate a product that is replicated and 3rd party accredited under BM Trada from Land's End to John O'Groats. So, you will get the same product whether you are in Land's End to whether you're in John O’Groats.

JIM HANNON Pretty much the same as Elliott, without as much money. We’re a manufacturer, installer, maintainer, we’ve got guys that are covered under Blue Skies certification and FDIS. We created our own app for data tagging, so similar to what Elliott is doing, but on a smaller scale.

IAN CAVANAGH Of Independent Fire. I'm a fire door nerd, basically. We do inspections, existing buildings, new buildings, we do clerk of works inspections, we look at fire doors up and down the country. We go from land’s End to Orkney, so whereas Elliott stops off at John O’Groats, we go a bit further. We’ve been to Orkney and Belfast is I suppose the furthest west we’ve been up until now.

CLIFF I'm a BIM manager, that's the building information management side of this, and I'm interested in how this information is gathered digitally and put into a database so that it can be found and people can access it when the information is needed.

GEORGE So, I’ll show my screen and we can then work off the draft. So this is the text that's been drawn out from the NHS guidance, and the principal thing that we want to really do here is to identify anything that isn't appropriate for resi. So, we're not looking to author the thing again, although if there are things in it that you want to contribute to or change or emphasise, then this is an opportunity to do that. But at the moment, I'd just like you to read through this and tell me if there are things in here that you think are inappropriate for resi.

IAN CAVANAGH I’ve got a comment on the first paragraph. I look at a lot of new build sites, a hell of a lot, and I have two guys that work for me who also look at a lot of new build sites for me. I am yet to see a fully compliant third-party certified installation, ever. So we need to be very careful about saying that third-party certification schemes should be satisfactory, because in my experience they are fundamentally flawed.

GEORGE Understood. That was the point that Neil has made as well. So, third-party certification is not enough on its own.

IAN CAVANAGH In my experience. It’s an experience based on experience, hot on any particular opinion. It’s an experience-based opinion.

GEORGE So we need to probably qualify that. Does everybody else agree or do you the challenge that?

ELLIOTT DAWSON I'm far from challenging because I do tend to agree, and it's only recently that people have even needed to have an accreditation. When you say third-party accreditation, they're not fitted to, do you mean that they don't have the Trada or FIRAS?

IAN CAVANAGH No, I’m talking about BM Trada, Blue Sky, IFC, FIRAS. Any of them, I’m talking about third-arty certified installers. I’ve yet to see a complaint installation. The last one we looked at, I think it was 60 door sets. The door sets were third-party certified manufacturer, they were wrong as well, but the 60 doors had something like 160 faults across them. So an average of four faults per door.

ELLIOTT DAWSON Were they being captured…I can only speak from our experience, We now will only operate a third-party certified, somebody who has basically TRADA, certification, and part of our golden thread is that they have to take pictures at several phases of the install to ensure that it is installed to the fitting instructions of our field of application.

IAN CAVANAGH I have no idea what pictures they took, but Elliott, I can show you pictures that have been taken as part of an installation process that don’t show faults. A picture is just a picture, and I can make a picture look like something it's not. We need to be very careful about the whole third party certified process, that’s my point.

JIM HANNON It's a difficult one because I think you're going to get good and bad, and as soon as you get an industry where people think they can make money quickly, you're going to get people jumping on the bandwagon and it’s jump on a course, oh, I'm OK. There you go. People sign off doors from a drive-by site view. I don't know what the alternative is though, because the quality clerk or works that used to be around back in the day aren't there anymore. The third-party organisations, I’m not going to name the organisation, we’re accredited under FIRAS, BM Trada, Blue Sky, so take your pick, whichever one it might be. But 18 months went past and we didn't have an inspection, an audit. That's not without us asking, they just weren't coming out from their office. Now I get it, everyone's gone through COVID, but they were doing audits online which is crazy. You need to have people that were coming out of their office and they've not done it, and I don't think they've come back in full force even now. I'm not completely disagreeing with Ian, not at all. But I also think the third-party schemes have to pull their socks up and I think fundamentally they're not a bad system, but they just need to improve because I don't know what the alternative is.

The other thing with the drawings and the instructions, we started to do for our own installs a pilot install. We’ll take a record of what structure it’s going into and create a bespoke installation guide, because if you’ve got a wall that’s a critical wall with big metal anchors into that wall, it’s very different to another situation. So should there be a little bit more emphasis on how you're fitting that door into that property, rather than having generic install. Not everybody is going to necessarily understand the field of application. It’s making sure that, and it's a bit difficult if you're only supply only, how do you make sure that you're going to do that on every job? But that's up to the third-party installer to make sure they're translating the field of application into that situation and raising up if it can't be done for whatever reason, and what hazards they might experience.

IAN CAVANAGH I think a lot of installers would consider themselves very lucky if they actually got their hands on a field of application, to be honest, Jim. Based on my own experiences, even with new builds. And it sometimes takes a lot of persuasion to actually get that document. We shouldn't forget, of course, that every door set that is delivered by anybody nowadays should automatically have installation instructions. It should be there, and installers shouldn't start the job if they don’t have those instructions to hand. So, we shouldn't get away from that either. A lot of people are getting away with a lot of stuff, and manufacturers are partly to blame for it.

ELLIOTT DAWSON Ours are in the data tag that are on the doors. IAN CAVANAGH Yeah, but you shouldn’t have to rely on electronic data, should you? ELLIOTT DAWSON Well, you shouldn’t, but it’s one way of ensuring that it’s always there. IAN CAVANAGH It’s only one way. But it wouldn’t take a lot to print it off and give it with the door set, would it? ELLIOTT DAWSON Yeah, but anything could happen with that door set travelling to one particular place or being put up, whereas when it's physically attached to every single door. You're not telling me that the installers don't have a phone or something that can easily read that information. IAN CAVANAGH Absolutely, not at all. Yeah, most do. That's part of the problem with installers, isn't it? They spend more time on the phone, on Facebook, than they do taking care of the installation that they are currently faced with. Everyone has access. Yes, of course they do. But we shouldn’t rely on electronics.

JIM HANNON But even down to the site agent, if you if you've got a new build that site agent should be given the details of how those doors are being installed. So, it’s about sharing the information. I don't think there's anything wrong with the data tag, brilliant, that might be great for one guy. Another guy you know needs to actually read it, he might have a a 1980s phone. It happens, you know. So sharing that information to all the all the people involved, you're not hiding away. If somebody wants to go and pull off architraves and do their investigation, they've got the evidence there as to how that door should have been fitted. And it's not rocket science.

IAN CAVANAGH Well, it all goes back to effectively, Regulation 38, that's what it goes back to, sharing the relevant information. And, of course, it’s the fact that in general main contractors haven’t complied with Regulation 38 that’s lead to the whole golden thread concept, because if Regulation 38 had always been adhered to properly, as it should, and clients were aware of their rights and main contractor’s responsibilities to comply with building regs, then we wouldn’t have the problems we’re faced with in a lot of instances.

GEORGE think the critical thing with this is just to pick out anything that isn’t right for resi.

ELLIOTT DAWSON I mean 1.3, I don’t think anybody that’s not accredited should be fitting a door anyway.

IAN CAVANAGH I disagree, strongly. The best installation I’ve ever seen is by a guy who will never be third-party certified, never, because he’s too small and he can’t afford it. What we should be leaning towards as an organisation, what we should be shouting out to those that make decisions is that people installing fire safety products, life safety products, should be qualified. Personally, individually qualified. That’s what we should have.

STEVE WYPER That’s where I want to go with it as well. From the customer’s side, one of the things missing for me is clarity about what a competent installer looks like. A certification scheme would be good, and like your man is a one man band, I take you point, he could be the best fitter on the earth. However, he could then have someone else come out, inspect his stuff, and audit him at some stage, depending on what level he wants to work at. If he just wants to work in little local HMO's for people, that's fine. If he wants bigger contracts, we’re not big, we’re one small local authority. But the confusion for me, and I was going to ask you if there is something further down the document about, and it says establishing competence on that next page 13. But that’s the thing about how, without having to go and look over everyone’s shoulder on every site, and I know we’ve still got a responsibility as the ultimate client, but a point has been made about clerks of works and how a lot of expertise has gone out of the industry for that sort of a role, and employer’s agents as well, so we’re having to rely on other people.

The other thing is, when we do find something’s wrong we need them to be big enough, or backed up by enough industry association insurances or something, to get it put right and quickly.  We don't want to be having a fight with someone having to go to legal. We just want to get a solution and we want it there tomorrow. So from the client side, I'd make those observations about just being clear about who's fitting them, who's supervising, because the fitter themselves, if there’s a supervisor who's actually supervising, and it's a competent fit, and that's being regularly sampled and there’s a QA process, not too bad.

GEORGE OK, so what you’re saying, Ian, is that the person who is fitting should be personally qualified? IAN CAVANAGH Yes. Now, the people that organise NVQs nowadays, they’ve realised this, and so have the apprentice organisations. So anyone now that is doing a level 2 or above NVQ in carpentry and joinery, certainly site joinery, will do the NVQ qualification on fire door installation. Which has been available for a number of years, but of course no one's done it because it was optional, but it is now mandatory. GEORGE Does joinery cover all of the fire doors? Because if they are steel fir doors, for example. IAN CAVANAGH It’s timber based. The daft thing is that there is no guidance out there on the installation of steel fire doors, it doesn't exist. There is no BSA 214 equivalent to steel doors. So basically you can fit them how you want.

GEORGE OK. Should we press on with the document? Are we happy with that?

JIM HANNON I feel like I'm disagreeing with Ian on everything, and I'm really not. I think you're absolutely right and I completely agree. It's more about giving the guy the experience to get the training right and make sure that he can do the job and I completely agree with that. The only thing I'm a little concerned with is when it comes to the insurance level, and I think Steve mentioned that all your insurance are going to be looking for that third-party accreditation so that they've got to be able to have something they can pin their hopes on that that’s going to be sufficient. So it comes back round to: are the third-party schemes sufficient for what we’re trying to do here. No, they’re probably not, but what’s the alternative? You’re individual guy, having plenty of experience and ability, when it comes to an insurance claim are the insurers going to cover that guy? Ian, that’s probably something you’re aware of, maybe some of the individual guys have discussed it with you, I’d be interested to know.

IAN CAVANAGH It’s never really come up, to be honest, but anyone who is installing doors, if they’re doing it as an individual, should have their insurance in place, obviously. If it’s a company, I'm not saying that companies shouldn't have third-party certification. But what I'm saying is that a third-party certification scheme alone is not robust enough. The very fact that one manager, and I use that term loosely, but one manager can oversee 20 installers, none of whom need to be qualified whatsoever. They just need to physically be able to fit a door, I just find it ludicrous, and the whole concept of third-party certification and that concept to me it's just…

JIM HANNON I agree, it’s just making sure that companies, the organisations, have some sort of third-party accreditation.

GEORGE I’m gonna press on now. I guess, to some extent, that’s what you’re saying here, Ian, to make sure that the individuals have got competence.

IAN CAVANAGH Well, that’s a problem, how do you truly judge competence. Generally, you would say via qualifications, wouldn’t you?

GEORGE Yeah, by qualifications, OK. So how about this next one? Have a quick read of that.

IAN CAVANAGH I would remove the BRE/LPCB reference, personally. It's too specific. According to the 1.5, it’s just for timber. GEORGE Is there an alternative which is composite?

ELLIOTT DAWSON Coming from a background of doing both to now we only do composite, there should be no differentiation between timber and composite anymore really, if the door is fit for purpose then it’s fit for purpose, whether it’s timber or composite.

IAN CAVANAGH Anybody who is inspecting a door shouldn’t really be referring to any particular document, BRE/LPCB, whatever it is, the door should comply in every respect and you shouldn’t have to refer to any particular document to decide whether or not that door is compliant and operating correctly.

GEORGE I saw the exchange this morning between Alan Oliver and Neil, and Alan made a point on that. He was saying that he felt that it was appropriate to leave that in, but think let's discuss it.

ELLIOTT DAWSON Is it not more appropriate to have it inspected to the way the door should be fitted and be tested, rather than…so, it will have its margins. That’s what it should be tested against, not an industry standard.

IAN CAVANAGH But it’s not an industry standard, that’s the problem with it, it’s a very specific scheme that only certain people are members of. I’ve you’re going to mention one scheme you should mention them all. My opinion would be is that you should say…details based on a UKAS accredited inspection team, a scheme that is audited by UKAS, for its quality, its standard. You’ve got to be very careful about specifying a scheme. It’s restricted and it favours certain organisations, which is wrong.

CLIFF I can't see anything that ties that back to the architect specification. There’ll be a door number and a plan, you’ll be on site looking at that door and how do you know if it’s the correct door? It should have a unique door number tied back to a door schedule, a 9 month schedule.

GEORGE Good, OK. How about these? You can read these afterwards and come back with anything that we've missed, but I'd just like to be able to get as far through it as we can.

IAN CAVANAGH You can’t say that timber has to be free from knots, because certain timber has knots in it, that’s a fact. But in general, it’s correct.

CLIFF The date of installation. It could be on the door, when you install a boiler, there's usually a panel there and you actually start writing on there when it was installed, so then you know when it needs to be serviced…maybe have the oil changed in the door closer, every so many years. That would depend on when it was installed, I suppose. 'm just thinking if this is an audit trail under the Building Safety Act, when something goes wrong they'll want to know was it serviced in time and that would start from when it was installed. That clock will start ticking when it's installed.

JIM HANNON This document, is it about making sure its meeting legislation, or is it trying to go above and beyond?

GEORGE I’d say it’s above and beyond, it’s to make the building safe. It’s not specifically around just achieving the minimum standards, no.

ELLIOTT DAWSON Then do you go back to, and I’m sorry to keep harping on about it, the tag then holds that data from date of installation and then that's when there's automated notifications for maintenance. We've found from experience, if you leave anything on the door that can be taken off, whether it's social housing, new build, whatever, people will take it off. IAN CAVANAGH Especially those labels that say do not remove.

GEORGE Yeah, I don't think there's any question that we think it's a good idea to capture that information, but I think it's also the case that the tag might stop working, or the company that’s storing that information in 10 years time may no longer exist. I think we need back up. I’m into everything digital, but you can’t be completely reliant on it.

ELLIOTT DAWSON I do agree, but we’ve got three fail safes in there. You’ve got the tag, the tag has to be working at time of install, that is then instantly uploaded onto a separate server. The server is backed up in three locations and has a 25 year independent hosting cycle. I agree with everything you've just said, George, but for those reasons that's why we've done ours independently so that we don't hold the data. One company doesn't hold the data as such, but it's there and it's there independently for 25 years.

GEORGE No, I appreciate that. But that in itself, I don't think is completely, 100% foolproof, whereas we need something that's a back-up, even if it’s just a PDF. ELLIOTT DAWSON But that’s the database. When the door is installed, the customer has a database of all the installation dates automatically uploaded from the date of that installation. GEORGE And how many databases in a building…If you’re a landlord and you’ve got a hundred different asset types in the building, each of which has got its own database, how practical is that for them? ELLIOTT DAWSON Absolutely. But they don't even need to look at this database. It's an autogenerated maintenance or a referral aid for them, ιf somebody ever questions that door and whether it conforms or not, whether it's compliant.

GEORGE Right. So anything here at all? Is 2 to 4 millimetres about right? ELLIOTT DAWSON It goes back to the field of what they’ve been tested, you could have 6 mil, you could have 1 mil. IAN CAVANAGH In the field of applications it generally does say 2-4 mil. ELLIOTT DAWSON Yeah, but it depends what it’s been tested to. IAN CAVANAGH Yeah, but regardless of what it’s been tested to, it will generally say 2-4 mil in most fields of application. Certainly for timber doors. The most important consideration is smoke. If you’ve got a combined fire and smoke seal, very often a 4 mil gap is too big. Not just on timber, on any. ELLIOTT DAWSON Ours is 5, we’ve tested up to 6 mil on our seal. IAN CAVANAGH Right, so in that case you use a specific combined seal with a higher brush. ELLIOTT SAWSON Yeah, it’s just for compression as well, it gets better results. That’s the point, surely you need to be checking what that door was tested to.

STEVE WYPER Elliott, with your doors, does the brush have to be in contact with the frame to achieve that? ELLIOTT DAWSON It’s part of the seal, it’s part of the frame. Whether it’s the threshold…STEVE WYPER OK, so the brush in contact with the leaf then. That's generally one of the things we're encouraging our guys to look for on inspections is if you see air between the brush and the door or frame, it's unlikely to work as a smoke seal. So that's an additional to our kind of two to four parameter, if you know what I mean. What we’re looking into is is it likely to work. We can't change all of our doors, we can't afford it. So we're like, is it likely to work? Is it repairable within reasonable parameters or are we…and put it in a programme that within so many years it will be renewed. Or if it's likely to fail, that's got to be on the list now for replacement.

ELLIOTT DAWSON Yeah, agreed. But again, you're coming back to new legislation versus old. Probably 90 plus percent of your doors will not have been bidirectionally tested, so I fully appreciate money is the key driver in all of this and without ever cutting corners you have to prioritise your first batch to change. But if these doors are probably only 6 or 7 years old, if that, they’re probably not bidirectionally tested. STEVE WYPER Yeah, but they wouldn’t need to be if they’re flat front doors, they only open one way. ELLIOTT DAWSON No, it goes back to in the past it was the most onerous side, now you can have a fire on either side of that door. Not for the seal, for the actual fire test.

IAN CAVANAGH Personally, I don’t feel the bidirectional issue is relevant to whether or not the smoke seals are working. ELLIOTT DAWSON No, that wasn’t for smoke seals, that was for when you’re looking to remediate your doors in general.

IAN CAVANAGH On the hinges, George, minimum Grade 11 for a fire door.