TYPE 3 ONGOING, FUNCTIONAL FIRE DOOR INSPECTIONS 20230216

TYPE 3 ONGOING, FUNCTIONAL FIRE DOOR INSPECTIONS 20230216

STEVE ALDRIDGE And now they’ve just created themselves a huge problem. They’ve gone down the road now of replacing  all of the fire doors, which I think is a complete total over…it wasn’t needed if you looked at all of the findings for those fire doors, probably 40% of them were eminently fixable. But they've gone down the road of doing this, so it's trying to get that standardised system. So, I don't know whether that's a good starting point for a discussion.

DANIEL WHITE Yeah, I think one of the problems you're’ going to have is the certification bodies, they all run schemes differently. So, depending on what scheme you're in its gonna have its own set of rules and regulations, which is gonna be different to another one. And I think that's the fundamental problem, because it's never really been regulated and so people have just gone off and done their own thing.

STEVE ALDRIDGE I think this thing that they’ve done with the scaling, because some of the ones that we’ve done, they’re doing effectively the type 1 fire door inspections, but using people that aren't really qualified to do that. But they think they've ticked all of the boxes; therefore, it must be compliant, and I think the thing where we're splitting these out into the type 1 and the competency of that, the type 2, the type 3, this group really is the ongoing one. So  it's had a full type 1 inspection, do we need to be checking things like screws on hinges? Is that part of the ongoing monthly/weekly inspection? Is the hinge in good condition and all screws are fixed, yes, or no? 

DANIEL WHITE You can have very generic questions and answers, because one of the problems you’re going to potentially have is are you gonna get any documentation for that door? So, a house band door blank is different to a flame break which is different to a vichama? 2mins 33secs. And they're all going to have their own individual quirks. So what you may be able to do to a house band you may not be able to do to a flame break.

PAUL BRAY It’s about section 3, ongoing functional fire door inspection, and I think where it said Steve, with the inspections done to type 1 and 2 are more robust and more complicated. This is about what's happening with the doors during their lifetime. So, we need to apply a very simplistic approach to that. But you know, I've already mentioned, where I work, I’m manager for Plymouth Homes. In Plymouth we’ve got 15,000 properties, i do fire risk assessments for 600-700 general needs blocks of flats. So, we've got quite a few fire doors and communal doors that we need to take account of, and we've got a robust system for checking them which is based on a very simplistic view. For people that have been trained to do that, look at, and all our operatives have been trained with all our staff…repairs people. But it’s all about 5 or 6 checks on the door, this is what we’re looking for. Does the self closer operate overcome the latch? Are the smoke seals in place? We might spot a hinge or a screw is missing, but that’s not what we’re looking for, because if a screw is missing from the hinge the door might not shut properly, so we’re gonna be raising that as part of the repair process. 

And I think also what we need to link back to is that the sheet that was given us from the healthcare door type mentions why they're doing that, in compliance with the fire safety legislation, fire safety order and then we need to bring in the fire safety England regulations into this process and look at what they're asking for within that. And I think we will get there but keep it simple. We really need to keep it simple in this group. The other groups will consider what needs to be done, and group 4 will look at the management regime, as far as I see it. I've got lots of information I can share with you at a later time for you to see how we're doing it. We’re using our six tagging system on our communal doors, similar probably to what you you do, Steve. And we've worked really in quite a lot of detail what questions we're asking to be included within that. That creates the dashboard for communal doors to be inspected every three months or whatever criteria we apply to that. 

STEVE ALDRIDGE I think you're right there, Paul. And I think some of the times when we go out and do training, at the end of the day for a regular fight or check, is it gonna stop smoking, is it gonna stop fire, is it actually gonna do what it was designed to do? That's basically a yes or a no. If it's a no, why won't it do that? One of the issues I've got with that is the competency of the people that's doing the fire door check. And I think that that competency, we’re looking at doing this in the software at the moment where there's a basic competency check for the person that's doing the fire door. So, you’ve got a series of questions that you have to answer, and that's either a pass or a fail. If it's a fail, it won't even let you get in there to do fire door inspection. And trying to simplify the actual inspection is great as long as you've got competent people undertaking that. And those two don’t seem to marry up and I don’t know quite how…as soon as you simplify something you’ve got to stop it becoming a tick box exercise.

PAUL BRAY That's the responsibility of the responsible person for the people doing a competent…for us, all our staff has received toolbox talks, they get given a presentation video, it takes at least an hour to give the simple overview of what a fire door is, and then there's ongoing refresher training when necessary, They fill in an electronic form whenever they do a check on the door. So, we're managing the process, so if they overreport because they don't understand what they are reporting on we can monitor and manage that and deal with discrepancies.  I believe we've got a fairly robust system for checking the flat front doors, all our fire doors and then the communal doors. you’re absolutely right, it has to be competent people doing this right. You can't just say to a member of staff check that door, if they don’t understand what they’re checking.

STEVE ALDRIDGE And then the competency of those people comes into the actual assessment. So, it’s a fire door assessment, but if it’s not been completed by a competent person then it’s not worth the paper it’s written on. 

PAUL BRAY I would look at what level of competency you're requiring for a simple check on a fire door and then understand and make sure that the person who is doing the check understands where their level of competency lies. I think that anybody that's incompetent that they know where they're competency finishes. So, they would say ’I don't understand what needs to be done next, I need to refer that’. And that's why you need a standardised form which will identify what you're looking for within the door. I've got mandatory boxes that need to be filled in and then it allows it to be further checked. There might always be somebody, no matter how competent they are, that will make a mistake. As long as you’ve got competent staff, overall, doing that work I believe you should, as a responsible person, be able to say I’ve got a robust system in place for checking those doors. But it all comes down to, the foundations are making sure you’ve trained your staff and they fully buy into why they're doing it. And then that goes right back up to the top of the tree where they've got to have the culture to apply and enforce that.

JIM HANNON Paul, you’re from the client side, aren’t you? PAUL BRAY Yeah, we are. We also do our own installs as well, we’ve got a fire door team with 4 operatives supervised by BM Trada qualified inspector. JIM HANNON There’s not many clients that would be as far advanced as you sound, Paul. The reason why I find this group the most interesting is, because you commented that we’re overcomplicating, and I 100% agree with that. And what organisation can really afford for an accredited person to be checking their doors on a weekly basis. But if you've got somebody who's able to take some quite basic training, really simplified. For me, are clients looking for that MOT type sign-off once a year, by somebody they can say there is an accredited organisation looking at that annually, weekly, monthly, interim inspections being done by their trained staff. So, it’s trying to get the view of the client, because a lot of the clients want to be able to limit their liability by having an organisation take that, but I also think use the in-house people as much as they possibly can. So, it’s a bit of a, I’m jumping on either side of the fence and I’m not a client. 

DANIEL WHITE From my point of view, Jim, what we’re coming across is that a lot of organisations want the first inspection to be a completely intrusive inspection. And then after that, then they can move it on to once we check the fire stopping, we don't need to do that again. So, then it can be more a case of is the door functioning properly? Does it open and close, is the glazing smashed? That type of thing. Also, from a from a liability perspective, the clients would prefer that, because they know that it's being done properly to start off with and as long as the remediation works are picked up on then they can use their own in-house teams, such as Paul's doing, train them up to do these sort of like 6 point checks.

JIM HANNON Yeah, I think that’s great. But do you think a lot of the clients will take a sort of mixture of the two, their own in-house trained people and external consultants, contractors, etc.? 

DANIEL WHITE What they're doing is, some of them are starting off to do it in-house, but they don't realise how long it's taking them. I was doing some surveys for a housing association, and this was one of 10 phases. So, I did phase 6. They’ve miscounted the number of communal doors by 1200. So again, you've got these extra resources that all of a sudden, they hadn’t realised that they’d got, whereas if they’d done it properly in the first place they’d have an accurate number of exactly how many doors. I think that's half the problem as well, because all of a sudden there's now a thousand doors out there they've gotta find a budget for which they just didn't realise they'd had. 

JIM HANNON Or it's the doors that don't need to be fire doors, but historically somebody’s put a fire door, keep shut, and that just created the ongoing… STEVE ALDRIDGE That's a really big issue because we've got a client that thought they had 1200 fire doors and they’ve actually got 400 and they've been checking 1200 fire doors for the last two years. The budgets then, if you’re looking at it collectively on that, you can reduce the budget to spend it where it actually needs to be spent.

LAURA SMITH I work for Gentoo Group which is a housing association in the Northeast. We're doing things very similar to Paul. And I think we need to be, this is going to be a functional check of the doors. So obviously where doors are not required to be a fire door, we make sure that's raised up through the fire risk assessment process so that we can then decategorise those doors in the correct way and make sure it's not required to be a fire door and it's fully documented why it’s not a fire door. Because it is ongoing maintenance and there is requirements by just simply having things marked up as fire doors. I don't think historically people have realised the significance of that, because it is ongoing costs, but we’re undergoing the process now where we're introducing new IT systems and our fire door checks are one of the first phases of this new IT system, and it is about getting that right balance of being a functional check rather than an in-depth. I think a lot of people were saying, oh, you would need to go into checking the fire stopping, and we've made it very clear that should be the first phase. This is a functional check; this is the ongoing element of it. 

Where it’s a new fire door install, obviously I think you start the process again and you would need to do the first inspection again, making sure it's been installed correctly. But I think we need to make it very clear in this, this is the ongoing element, it's not where you need to check every component of that. And like Paul, we've got an in-house team that we've got trained up now to do those ongoing checks to make sure that they are competent in doing so. But unlike yourself, Paul, where we need new fire door installs, we go to a third-party accredited contractor to do those because we haven't got the resources currently in-house to do those installations. So, we go outside for that at the moment.

STEVE ALDRIDGE Laura, could you give us an idea of what you actually check on a regular fire door check? 

LAURA SMITH Yes. So we would check the door leaf to check it for damage, we check the self closer, we don't go down to the extent of checking all four screws within the hinges, but we would have a look at the hinges to make sure they're not leaking and we check to make sure the glazing's not damaged, in some of our blocks that's a common occurrence. So, we check those. And we also have the janitors in our buildings trained up so that they can check that on a daily basis as well. And it's just the main components around the self closer, the hinges, the door leaf, and just make sure the doors closing appropriately, looking at the intumescent strips and seals as well. So, we've got a little bit more than six points on our checklist, but it's not an onerous check. It is simply a functionality check of that door. But then we have, when we're installing the doors, we expect a full checklist from the installer to make sure that that door has been installed appropriately. We include gaps on the regular check

PAUL (guest) 17 mins 30secs I’m a little bit different from all you guys, I'm a fire risk assessor and doing fire door inspections but do it at a lot lower level. So, I'm talking at block management rather than estate management. And it almost seems like there’s two levels required because the level at which I work, there’s no one inspecting the doors. There’s not a caretaker, it’s just a block. I’m checking them and I’m trying to get to a point where we're doing the checks as minimal as possible because obviously my times expensive and these people just don't pay it. That very simple 6 point check where you can do a block in a couple of hours is one level and then there’s the proper inspection which maybe gets done once a year, once every two years. I don't know what that time scale is at the moment because I don't know what the markets prepared to pay because at the end of the day, we can legislate all we like and say you have to have this. At your estate level I understand it, you've got the setup there, but at the lower level, maybe one or two blocks with a local management company, they are not going to do it. 

And that’s my concern with this, the legislation is there, i’m a fire risk assessor, most of my customers haven’t had a fire risk in 10 years when i get there. So, there's a great risk that it will just be ignored because it's too onerous, and then nothing gets done. I know I’m coming from a slightly different angle than you guys, but that’s my feeling on it. It almost needs to be two inspections, that very simple once a year you go around. I don’t think weekly is a realistic thing on some of the smaller estates that i operate on. 

STEVE ALDRIDGE I think you're right, Paul, it does have to be simple and there's different levels. I think the issue with that from my perspective is that I can near on guarantee clients, if you come up with a scheme, they will hang their coat on the cheapest option, which is gonna be the quick regular fire door check. If it hasn’t had the other ones behind that, those fire door checks are at best not really worth much, but at worst dangerous. Because the door, if it's not been installed properly, it's not acting as, all the things that you know, that’s the danger. We have it with clients where you can either do a full fire door inspection, you can do a quick fire door inspection if you like. ‘Well, we’ll go with the quick one. We’ll sort the other ones out later’. It’s always the cheaper option and ticking the box that we’ve kind of got to get over. 

PAUL (guest) What I've been trying to do with that situation is rather than work on an inspection basis, work on an annualised or contractual basis, so that they're signing up for, let’s say it's 2 a year, on the doors. The first one is done by me. The second one is done by them but using my software or whatever. That they would have access to a very simple that they would need to then take images or whatever. I then sign it off as the simple one and then I go back the one after that and do the extensive one to make sure that at least they're getting 1 a year where it's up to standard.

PAUL BRAY I think you’ve made some valid points, Paul and Steve, about the technical process. I think there will be landlords that go I'm only gonna do the minimum, but they will be challenged either by the Housing Authority, the regulator or the Fire and Rescue service. And the worst-case scenario will be following an incident where there's been a fire and something has failed. So, they'll be looking at their records though. So maybe it's a bit like the Grenfell situation where everybody seems to think they're gonna get away with it until there's a disaster. But that's the bit that I always use with my employees when I'm talking about when I want something done. When you’re in the coroner’s court at the inquest  trying to explain why you did or didn't do something. Unfortunately, it may be that it will take time for that to happen before the less diligent landlords will start putting systems in place. But also, we go back to the type 2 check, it’s really hard to find the records of a notional fire door and then accept that as being a compliant door. So you do have to do it as a mix of the type 2 check and the type 3 check. Is the door fit for purpose? Does it look alright? If it looks like a fire door and has most of the components of a fire door, then it will do its job. 

We need to have faith in that and then as a landlord you keep that as your records for checking. Also, you can’t check every single door with that robust level of inspection you might use at level 1 (or even at level 2), but you sample some doors, so you get an agency in to do that. The most important part is keeping the door check process in place and keeping records of it to show due diligence and the phrase that they used in the regulations is about best endeavours as well. So, act as a responsible landlord and you'll be treated like a responsible landlord, act as somebody that's trying to escape liability and responsibility then you will get caught out. And hopefully the whole process of this whole thing, of weeding it out. One other point is the residents have got a voice in this. The regulations talk about the residents having the reporting system in place, landlords will need to do that. Residents, if they don't get given the support that they need from their landlord, have got other avenues to go down there written in legislation. So hopefully we'll start weeding that out.

JIM HANNON Paul’s made some really good points there and, as I say, it's the reason why I wanted to be in this group. I think for me it’s the extremes for various areas. The extremes of clients. From Paul’s point of view, if we had dealings with a client like Paul, that’s one extreme, and the other extreme is somebody who's like, well, it’s OK, it shuts, that’s it. And it’s the same with the door inspectors. There’s a lot of people, like anything new, they’re jumping on the bandwagon, they’ll do an online course and then they’ll go out there and put the fear of God into people. It’s trying to get the right balance. Definitely use the staff that you’ve got once they’ve got the quite basis training they need. It’s that ongoing once a year, clean bill of health, almost like an MOT. The other comment that I thought was quite interesting was the residents’ voices. I completely agree. Without naming clients, there’s some clients that when you make sounds lime that they almost faint in shock that you’re suggesting to speak to the residents. Give the residents a bit of training as well. Again, with ongoing inspections, should there be something where a resident could raise a fault with their door? I feel there should be, but not every client that we are dealing with would have the same view.

STEVE ALDRIDGE Very true. Looking at this from a software perspective, there’s lots of software packages out there. Do you think it would be useful to have a kind of algorithm within this that we use in other risk, basically red, amber, green system. So, if a fire door has had types 1-4 checked, effectively it's got a green and it's compliant. If it’s got a regular check and it hasn’t had a type 1 or type 2 it gets an amber. So  rather than looking at the individual check, it's the cumulative checks that make the door compliant. 

JIM HANNON I think you gotta be very careful. We spent the last five years building our app, and there’s so many people doing exactly the same. What I've come to learn is that it's like anything, a computer's great, but it's the person using it that has got to have the ability. So having something built into the system that flags up. Yes, I think there's an element that you could do in certain areas, raise that up as being a high profile. I do believe that it comes down to the person doing the survey has to have the appropriate training to also work with that system, whatever that system might be.

STEVE ALDRIDGE I’ve been in the asbestos industry for 30 years, so you don’t have to remind me of that one, I can assure you, for competency. 

PAUL BRAY We use a report that's created from all the information that's gathered, we use a mobile system. Our operatives, when they carry out a check of a front door and fire alarm checks, whenever they go there for whatever reason, they have to carry out a fire door check. From that we create a report, and we also identify the ones that haven’t been checked before. This is a quick dashboard of what we’ve got, I’ll just show it to you as an example. This is based on lots of questions that get asked at that forum stage. (shares screen). One of our date team puts this together. It comes up with lots of different doors, even our leasehold doors are in there, and that's where we have the inconsistencies around some of the checks being out of date, because our leasehold team have a real job trying to get through the door, so we can't check them. There are about 700 leasehold doors in our scheme. The Red List of the doors are the ones that are due to be checked within the next or are coming up for a check or might be coming out of date. We've got all sorts of other types of properties in there. And this is a list that we're working on to improve, because there are obviously areas which can be captured better. It’s used as a tool for ensuring that we are at least keeping an eye on what’s being done. 

JIM HANNON What about residents' engagement?  I mean from the client people that are on this call. Is there an active way of getting that information? Do you pursue that? 

PAUL BRAY I think we’ve upped our game, but before that we always gave them a handbook telling then what the fire doors were all about. But the new regulations came out on the 23rd of January that was a requirement then to give information to all the residents about their fire doors and how to look after them. And in that was information about reporting faults. So that's correspondence that we're still putting out now. The challenge that I’ve got with some of it is interpreting when doors need to be inspected. Because the guidance in the regulation says buildings over 11 metres, once a year for front doors, every three months for communal doors, but it's ambiguous with below that. You look at British standards and other guidance says all doors should be checked at least every 12 months, London Fire Brigade says every six months, so where do you get your balance on that? And I'm having departments come to me and say, oh, we're gonna check our leasehold doors in buildings under 11 metres, a policy that suits us because we haven’t got the resources. I say that’s not acceptable; I need it done at least every 12 months for flat front doors. 

The government could have helped us by making it mandatory, and they haven't. They've said 11 metres is where it's mandatory. Under that it’s, even 11 metres is best endeavours, under that it just says you should do this, you should check this. And that’s a bit frustrating from my point of view because Jim and Steve both talked about the loophole, this is the loophole that responsible people will have for not doing it every 12 months. Some residents engage with us, others don’t. So it’s really difficult because you’ll get leaseholders that sublet, so you can’t get in touch with the leaseholders, they might not even live in this country. So how do you get into check the door if you're supposed to communicate with them? Ongoing challenge.

LAURA SMITH From a tenant engagement point of view, we've done a leaflet, but we've been doing that for years. We’ve held drop-in sessions, we've been out to each of the blocks of our high-rise buildings and we've held sessions within the blocks, so residents engage. We’ve updated our website; we've advertised it on social media as well because a lot of our residents use social media. For our leaseholds, we’ve dropped letters at the leaseholds and we've also emailed them as well. So that accounts for anyone that's overseas. And I know what you’re saying, Paul, about it only saying 11 metres over. We've took the policy that for any building under 11 metres, all doors will be checked once a year, namely because the communal doors, it's literally only probably one or two communal doors that are opened probably once every six months, so they're really not seeing that much activity, those doors. So, we took the policy of all doors will have a functional check once every 12 months. 

I think in regard to the NHS document, it's advertising a functional fire door check, which is what we're doing in line with the regulations set out in the fire safety regs. But one of the things it doesn't advertise in the document is checks by fire risk assessors. So even though we do a functional check with our competent staff from our repairs and maintenance team, our fire risk assessors will also do a sample check of flat entrance doors during the fire risk assessment and a check of the communal doors as well. And that layer of checking isn’t within this document.  And I think the whole idea of what the government is trying to introduce since Grenfell is having these multifaceted layers of checks to ensure that if there is, heaven forbid, ever a fire within the building, you can demonstrate your layered approach to reducing the risk within that building. Now we're adopting that through the functional checks, our fire risk assessments and now our ongoing maintenance. And also when we're introducing new doors, the checks that go on with there, and where we've got any notional fire doors, we're doing a notional fire door assessment as well, which I think is similar to this type 1, 2 and 3. But obviously it's not including that fire risk assessment approach within there which I think, as a housing association, should be introduced. And I feel that's what Paul was trying to sort of suggest as well. There needs to be the fire risk assessment check, but housing associations also need to take on the responsibility for that ongoing functionality of the door.

PAUL BRAY I agree with that. The problem you get as a fire risk assessor, because I so that as well, I’m an accredited fire risk assessor with the IFE, so I have to do fire risk assessments. I concentrate on a high-rise block. We try to sample about 10% of the flat front doors, but you won't get people opening the door to you so you can't check the door. So, you're walking around looking for a resident walking in and out. Oh, can I check your door? The other issue that was identified recently, Covid is one, that's stopped a lot of that, but also persons that may have a behavioural issue that you need to be aware of before you carry out your…needs to be taken account for health and safety reasons, so it become more and more difficult to do the actual checks on the flat front doors when you do your fire risk assessment. And that's why this document that we use for the spreadsheets and getting the operatives to go in and do that, that completes that element of the check. So, doors that don't get checked every 12 months that get identified on that spreadsheet, we make a point of going to visit as part of a scheduled visit then. So, we close that loophole or that weakness that we've got in our system.