TYPE 2 COMPLIANCE INSPECTIONS OF EXISTING FIRE DOORS MEETING

TYPE 2 COMPLIANCE INSPECTIONS OF EXISTING FIRE DOORS MEETING

NEIL A fire officer highlighted it, I think I found it on social media…we were just saying how we agree with making it into three different types of inspection. Our concerns are going to be whether the competencies are out there to handle the volume of inspections required of those different types, because it's one thing having the criteria to inspect to, it's another thing understanding what you're looking at and what you're gonna record.

SAZ That’s exactly my concern as well. In terms of residential buildings, if you are looking at buildings, then you've got buildings you’ve got building safety over 18 metres. You do your type 1, you do your type 2, then you get onto your type 3. But the issue is like the competency based and, I mean you've got these tight timescales, you've gotta do an annual inspection. But I'm just thinking going forward it’s actually having the competencies and whether…and the cost of doing it and the time to do all that resources is a big issue. I think it’s a really good document. I’m wondering that whether there needs to maybe be some changes…I’m just thinking about the single flat door being inspected and how difficult that it is already to do and with this additionally how it works. You could apply it, but I think that's the issue, the competency of people available to do all this and the cost of doing it.

ALAN OLIVER Yes, absolutely. Also, another issue with converting it to housing is the issue of composite doors, because it's easy in healthcare where more than 90% of the doors are timber and the remaining doors tend to be steel doors or specialist clean doors. But with composite doors, that’s an elephant in the room that we’ve got to include this. 

NEIL Composite. So, in the group we've chosen, existing fire doors, where we've known evidence unless you know that door because you've worked in the industry, you've actually come across that door before. You're gonna be pretty clueless, really. And you're gonna air on the side of caution because we know with confidence there with the mixture of materials that composite involves, there's no characteristic we can hang our hat on to say, well, that’s a nominal door, that'll be all right. 

ALAN OLIVER Yeah, and that it’s probably only been tested from one side, where’s the fire door test evidence? But by the way, I would prefer someone else to take the lead on this, on the type 2 inspection text because clearly, I'm not an expert on housing. That's not my background. I would prefer someone who feels very, very confident in the requirements for housing and how the current type 2 text can be either altered or added to. Would anyone like to volunteer to take that role? 

I think we need someone not just for today's meeting, but someone who might hold their hand up and volunteer to head up this group for as long as it takes to get it signed off.

SAZ Just an idea. And I’m not volunteering cause I’m flat out with other stuff at the moment, otherwise I would. But just wondering if it's possible that what we might do is all go away, have a look at it and put our to ideas together, insights centrally, and then sort of look at those that way because although we can have discussion here, it might be something that people need to say, OK, through each section, what are your thoughts on this and come back with those ideas. And then you've got something to work with rather than that text that we're reading. Is that a good idea? Would that help to try and move it along, actually have some sort of action plan in terms of everybody's got it already, but everybody needs to come up with some suggestions, how they think it should be worded or any changes or how they think it could be adapted. And then come back with that. And then we look at all of that and then we can start working with that. I'm just thinking that might be a way to approach this.

NEIL I think you're right, Saz, because let's face it, George hasn't really briefed us other than to have a chat about what we've got in this document for half an hour and then meet again. So, I think you're dead right. We all read at different paces, so it is a good idea to individually look at it and contact each other somehow with our findings.

SAZ I think that's the way to do it, it gives everybody a chance to have a good look, think about what they're doing and how it might work, what the pitfalls are, the risks are, the issues are, what the ways round are and how we might adapt it or use it. And if we put all that together and then send that in somewhere centrally collate it all and just saying, OK, this is what we've had back against each of these texts, if we do it against each of those sections. So, it's clear about what section we're talking about, that would probably be a better way of doing it. So what we really need is, I think Jiss was on the call in a minute ago, but he’s gone now, but I think we should ask for another meeting to be set up in a couple of weeks’ time, give everybody a couple of weeks to have a look at it, come back with their queries, but we need to get it centralised. We could send it to Jiss saying, OK, this is my comment about this particular section, can you bring it together? Let's have another one of these meetings and go through each one of those and what people have set to see how it works.

NEIL That would be great because you want to put it all in one folder so we can look at each other's work and come back with what we think is the right document.

SAZ Yeah, that is my suggestion of how we move forward on this to get these things done. I think really all four of them should be run that way. It'll be a bit quicker, and I think you'll get some good ideas and then we can, because if they use that and then cross reference against each other and it says what people are doing, they could get that standardisation flowing all the way through rather than just this section, you need a full standardisation through the whole lot.

ALAN OLIVER The idea is that each group would look at one section and then we'd look to put it together and then we'd to give it a robust peer review, holistically. But I think for the time being, we need to just focus on one section to make it as easy as possible to get the thing moving. Is it fair to say, Saz and Neil, that you two seem to be taking the lead on this and I’m just wondering…we do need a leader of this group. And as I say, I don't think it should be me. Would either Saz or Neil or somebody else volunteered to be the leader of this group, in the short term at least. 

NEIL I can be the leader. My problem is, and we’ve probably all got the same problem, as things are, the world we live in now post Grenfell, there’s not enough hours in the day. ALAN OLIVER Have you got any evenings or nights? Could you like not sleep for one night or something? GARY BAGE I mean, the same. I would lead, but I’m going through a big merger with Optivo and Southern Housing at the moment and as you can imagine it’s all systems go. It’s pretty hectic at the moment, especially, as Neil just said, there’s not enough hours in the day. I’m already working quite late. I wouldn't be able to give it the time that it deserves to lead.

ALAN OLIVER Right. We could look for a leader from somebody from another group, maybe. Maybe another groups got too many people vying for who wants to be leader? I don't know, but we should be so lucky. I know we’re all extremely busy. 

IAN C Just to be clear. I just don’t have the time to dedicate to be the leader. I’d love to, because I think it’s an important factor. But if I can just ask a question. In all of this, the whole thing, not just what we’re looking at here, are we going to consider competence? Because it's a huge issue that I feel is often overlooked. We come across so many instances where people are looking at fire doors that really should be nowhere near.

ALAN OLIVER Absolutely. If you look at section 1.4 of the existing document it makes a big thing on establishing competence and understanding who is competent to do which types of inspection. So yeah, when it comes to type 2 inspections competencies are a massive issue because it's all very well inspecting the functionality of a door, but to understand whether it's suitable and sufficient for its location in terms of fire performance, that shouldn't be down to amateurs, as everyone in this group fully knows. 

IAN C Yeah, it's a holistic approach, but it applies to new build as well. There’s a lot of stuff to look at, but of course with new build, I feel quite strongly on this, it’s very much a black or white scenario with new installations and new build it either complies or it doesn't. When you've got existing buildings, that's when the issue becomes a bit more holistic. But it’s far too easy for inspectors, and I hate to do that but I'll use it, inspectors to gain a qualification that in the real world doesn't mean a lot.  I don't know how it's resolved because there's hundreds of millions of doors, probably, out there that need looked at and we’re maybe short of properly skilled people. I don't know, but it needs to be addressed. I’m very firmly that the opinion that the new regulations that have been brought in are a step back. This new inspection of the communal doors, particularly, three monthly, it’s a step back. That's what we're talking about here, 11 metres plus buildings, we’re talking about high rise, and realistically we know what's going to happen. The head of housing or the head of development or whoever's responsible is gonna give that work to someone that really doesn't know what they're doing. And there's always gonna be the pressure…

So, competence. You can't get away from it in whatever we do, and particularly when you're looking at all the buildings, existing doors and what have you, when you don't have the certification in place. You’ve got to use your, I hate to use the word expertise, I don’t consider myself an expert. 

SAZ This is the problem though, Ian. The fact that is gonna be that competency is the big issue, but it's also a lack of resources and the cost and also what competencies are we looking at? I think back in MHCLG days when they had working groups looking at things. If you recall they actually developed a document for the competencies for the building safety managers, and they had that come to competency framework. So, you're looking at something similar for the door inspection side of things as well. So that needs, something like that would need to be developed. And as I said, again, some housing associations or registered landlords are going to think this is overkill because it’s so costly. Having spoken to a number of organisations in terms of their approach and what they're doing, they're trying to give it all over to professionals who can actually have a look at the doors over the next couple of years because they just haven't got the staff, the resources and the competency, and there’s that risk that's associated with it all and that's a huge issue for the whole sector.

IAN C Absolutely. But just coming back to, when you’re looking at existing doors you've really got to have the knowledge and you’ve also got to look at it holistically as well. it’s not just a case of, oh, the gaps 5 millimetres, it should be 3. 

SAZ Again, you can't say that, It depends on the manufacturer and the actual, you have to look at the manufacturers guidelines on that where you've got those gaps and how big those gaps are. So you can’t just say, oh, it's supposed to be 3, you’ve got to actually understand that door to be able to say whether that gap is an accurate and correct. 

IAN C Yeah, absolutely. But with existing doors, when very often you're not gonna have any certification whatsoever, you're gonna have no details, no guidance. It comes back to competence. 

NEIL And then there's the matter of how critical that door is to the strategy for the building. Some flat entrance doors will open onto a small lobby, where the risk is lower, other flat entrance doors will open onto an escape route, where risk is high, all of that matters.

ALAN OLIVER All the stuff that you're coming out with right now, this is all really, really good stuff and it's all relevant. Saying that I wanted somebody else to be a leader, can I take the leadership role back, but ask everyone in their limited time to just put down these sorts of bullet points that you're coming out with? And I will look to try and edit them and then send them out to people, as a way forward. Or does anyone think there's a better way to do it?

NEIL I think it's great, Alan, that you're the leader. And what I intend to do is critique your Section 2 part to compliance inspections and send it to you by e-mail, so you've got it as a central bank of information. I'll put my alterations in red or something, so it's easy to follow. And then we have another meeting.

SAZ Should we all do that, though, because we're all gonna have different opinions as people are on here haven't spoken yet, they will have their own opinions about this. ALAN OLIVER If everyone can do a similar exercise to what Neil is suggesting it’s definitely a good way forward. Send it to Jiss and copy me in, or vice versa. 

DAMON BOWEN I'm just digesting this document that's been sent out. Yeah, there's some very interesting points and I kind of concur with what's been said, to be honest. It would be good to each go through these sections and make notes. And then come together again and discuss those issues that we might have found with each section individually. 

DAVID LESLIE I haven’t actually seen the document, so I was being really quiet. So, I've got a couple of backgrounds, but I used to work for a local authority fire service in their enforcement section. So, the kind of inspection of fire doors and things like that is something I’ve been kind of involved in for years. So yeah, once I've had a look through the document I'll put some thoughts down and then send it over.

KALOYAN MARKOV Just to say something that I believe is important about this group, because this type 2 is probably the most difficult one of the checks. And actually, what would be the aim and potential outcome of this check, because if it’s a new door and you’re doing type 1, essentially, you’d look for any deficiency that will be repaired. But if you’ve got a type 2 the outcome could be, potentially, that the door isn’t fit enough to be a fire door at all. So can we have any kind of threshold or framework that will say, wait a minute, this door is going beyond everything acceptable to be repaired and it should be replaced. Because if we haven’t got some kind of boundaries, we potentially would end up having accepted different kind of doors in different housing providers and not…So, what's the aim? What will be potential officially potential outcomes of any type to check?

ALAN OLIVER You're giving me the impression that your housing stock has got a load of issues, and probably the starting point is to find out why you’re in that position and then…

KALOYAN MARKOV I need to interrupt you because it’s the wrong impression. I’m trying to cover all the ground because of my previous experience with a housing association, Now, I'm working for a Council and it's not that I experience such difficulties. I'm just trying to cover all the bases being part of this group, just trying to work towards something that will be useful for the entire sector. Not just for my organisation and because of my previous experience I know it's really tricky.  In many cases you could be in a position to make difficult decisions, that’s the main point. It’s not for where I’m working now. 

NEIL I think what Kal is saying is where do you draw the line? Where do you give up a fire door and say it’s just not a fire door? The answer is there's no answer, because it's risk based, isn't it? Every door, even egg box door, has some capability to resist fire, if only for single digit minutes. So, it's all about the risk that that door is addressing.

KALOYAN MARKOV Yeah, but then we need highly experienced and knowledgeable people everywhere to assess all the doors. So, it's difficult to achieve this, I believe.

NEIL The fire door inspector is a technical guy assessing that fire door for its likely performance, and he's looking at 30 minutes as a minimum usually, and sometimes he can't say 30 minutes, it’s what he calls an unknown. So, when it goes on to the fire risk assessor who says I can either live with that door or I can't live with that door, and if I can't live with that door, I'm either going to remediate it or I'm gonna replace it. That's not our job. Our job is a technical guy that advises on the fire door. 

DAMON BOWEN But the majority of fire risk assessments that I've come across would usually say, oh, it is advised that a fire door inspector is consulted to ascertain their thoughts on whether that door is suitable for either 30 minutes or 60 minutes or whatever the duration of that door is. Now, my main issue as a fire door inspector is when you might see a door that has correct gaps and it's got all the ironmongery certified, etc. It might have been a remediated door that was a timber, what looked like a solid core door that has had three hinges put on. It's got stripped, it's got a door closer etc. But when tapping that door, you can pretty much tell that it's a hollow core door. From what one person taps that door to another, another person might go, oh, that sounds alright, I would say that that's suitable as a fire door, and the next person who also might be a certified fire inspector might have a completely different view on that. It’s a really sticky situation for any fire door inspector to put their name on the line to say that, yes, that's going to last for… My whole thing on the notional status is I don't agree with that whole notional status because it's so wishy washy, and it's a bit sketchy, in my view, to put my name behind something to say that I think that's going to last for a notional 30 minutes. Because as far as I'm aware notional can mean anything from 5 minutes to 30. So that whole ‘notional’ is a bit of a cop out in my eyes. 

IAN C If I can just interrupt there though, the whole thing about notional doors, if we're gonna say that they're just not acceptable, which in essence is kind of what you're saying, we'll just have to face facts. You've got several hundred million doors across the country that need to be replaced now and the country can't afford that. And you’ve got to bring in the risk, it’s risk-based. And there's a very good video that's part of the BWF installation awareness course where they test 3 doors in a rig. And two doors are pretty much decent, and one of the doors has no intumescent seals, though it’s fitting very well. Now, one would think that door would fail very quickly, but it actually lasts 20 minutes. So a door with no seals, all be it well fitted, it lasts 20 minutes. Which conveniently, of course, marries up with the old FD20 which is stupidly still in building regs. You can have FD20 doors even though you can’t fit them. 

So, it’s a risk-based task, looking at doors. Maybe when a fire risk assessor states that a fired door inspector should come in and look at the doors. Yes, maybe they should, but then the fire risk assessor should look at the report, if it's suitable and sufficient, look at the deficiencies that are there. Then look at the building, look at the detection system, look at the use of the building, the number of people there, whether it's managed, whether it's not managed, all those things, and say, yes, the risks are acceptable. We’re never going to get to a utopia where 80%, 90%, anything like that, even that 50% of existing doors are compliant, we’ll never get there. if we’re gonna try and kid ourselves that we are, well then, we might as well just shut up shop. Go home. We're never going to do it. What we've got to do is get the risk or the additional risk down to an acceptable standard. And I'm pretty sure that the various enforcement authorities around the country, the various Fire Brigades, they would pretty much agree with that type of desire, to get the risk down to an acceptable standard. Because again, they know that the money isn't there to just replace all the fire doors and up to standard. 

What we’ve got to concentrate on more, and this is a different group, it’s over in group one, we have to ensure that every single new installation, whether it's a new build or it's an existing building where new doors are being replaced, we have to ensure they are 100% compliant at the point of installation.

NEIL Can I just quote something that Alan’s written in page 28 of this section we’re talking about.  It says competently assessing older doors is an important skill in support of responsible spending. But critically, the level of inspection needs to be suitable and sufficient for the type and use of building and location (risk rating) of doors. That's what this group is all about, isn’t it? What this section is all about. So that should be the sentence we bear in mind throughout the work we do in this particular section.