Type 3 - Ongoing, Functional Fire Door Inspections _2023-03-08

PAUL BRAY Have you got a template or an agenda for what we should be looking at for this meeting today or have you got any preconceived ideas about what you might want to achieve through this?

JOE STOTT I haven’t, no. I missed the first round of these things so I'm playing catch up here. I’m an architect, so I'm not sure how much I can really contribute to. I'm interested in this because we have  a surveying team in-house who are busy scanning or identifying fire doors. ’m not quite sure how they want to go about that, so I'm here to kind of hopefully learn something from you guys.

PAUL BRAY I think it's probably important to understand each other's roles in what we might bring or might learn from being in the group because we could be teaching each other stuff that we already know, or we might not be taking advantage of other people's knowledge base. So I think the number of people in the group, Hello, Richard joined us there.

RICHARD I read through your notes from last time and you had a very good chat and it seemed to be very productive, but it didn’t actually get onto the document, which is what I want to do today.

PAUL BRAY I’d like to, if I can, try and steer this. RICHARD I’m very happy for you to do that. PAUL BRAY Because I feel, and this is why I want to understand what everybody’s bringing to this section, because my organisation and team have done a lot of work on this, so I feel that I may have something I would class as best practice. So, I can share you everything that we’ve done already, because I think we’re quite well advanced, but I want to understand what everybody else is going to bring to this group so that I’m not dominating the way forward. Because if you let me, I will.

RICHARD That’s fine, mate. Firstly, let’s remember we’re framing it around the existing document, I know you’ve got a lot of notes onto that, Paul. I suggest that we actually use your copy that you put your notes on. PAUL BRAY I only went through a bit on Section 3, I think. RICHARD Yeah, but it’s a start. PAUL BRAY Yeah, we can do that, but can we first have an intro about who’s who in this group.

NICK TAYLOR I come from a background of door manufacture and studied fire safety and currently do fire door inspections and compliance within the company I work for.

LAURA SMITH 'm a strategic player safety manager for a housing association in the North East and I've been working in the fire industry for about 15 years now.

PAUL BRAY I’m fire safety manager for Plymouth Community Homes, I’ve been doing that for 4 years now. Before that I was head of fire safety for Devon and Somerset Fire and Rescue service for seven years. And before that, I've been in fire safety since 1998. So I've been doing it a little while and we've been doing, since I've joined social housing, it’s all about fire doors.

RICHARD I’ll share the document. Paul, you’ve added a lot of notes to this, which I think are valid. We’ve got to be a bit careful because the point about this is that it’s simple, it’s concise and it’s all there in, not exactly layman’s language, but there’s no complications. You’ve put in there, Paul, about minimum requirements for inspectors of doors.

PAUL BRAY Yeah, that’s taken from the guidance. I can’t remember if I’ve taken it from the guidance in the purpose built block of flat guidance or some other guidance. So, the information is already out there, and this is what we talked about in the last group meeting was that we should be very cautious about over complicating this process, because this is a low-level check on an existing door. It is not a Type 1 or Type 2 check that we discussed in the previous document. And this is to be carried out by people who have been given basic training in what to look for in a door. We already do this with our staff. The whole of our staff in PCH, any of our repair operatives going inside a flat have to carry out a check on the fire alarm and they have to do a basic check on the fire doors, looking for self-closers, intumescent strips damage, gaps etc and if it doesn’t meet that criteria they report that. We’ve got a tablet process that allows that to all happen, so it automatically creates a repair which then goes to our specialist fire door team that will cary out the repair. If a carpenter is already on-site they can carry out minor repairs. So, there’s a whole process wrapped up in doing this, reports back to a spreadsheet, a template, so we’re able to keep a key handle on what’s occurring on our flat front doors.

We’ve recently introduced an asset tagging process for our communal doors, because there’s a requirement under the new regulations for buildings over 18 metres to have their communal doors checked every three months. So, you don’t want to necessarily resource a specialist team to do that because of the massive cost implication.

RICHARD I’m thinking a lot of what you’re saying there in not necessarily for this group, it’s more about the methodology and about the whole inspection regime which would be more pertinent to group 4.

PAUL BRAY There was there was a conversation with George about whether I wanted to be in Group 3 or 4, but I also feel it's important that we get this right at Group 3 because if we're not doing this right at a national level, there'll be so many different versions of it going around.

RICHARD Absolutely. But what I’m thinking is if we overcomplicate Group 3 by including stuff that would actually be covered by Group 4 then we’re overcomplicating it. PAUL BRAY Well, this group can be done in half an hour then, really, because you just put that in. What I’ve set, minimum requirements for the inspections of fire doors. In the last meeting we talked around what we felt we needed to…

RICHARD OK, so let’s go through the document. 3.2 there are a number of factors that will help determine a satisfactory standard, a suitable system, and the frequency of inspection, not least the usage and importance of the doors in terms of overall fire containment. Do you agree with that?

LAURA SMITH If we step away from this just being for residential, if you look at it for all fire doors, that's the approach that I adopted when I worked with in the NHS. Because obviously if you look at the usage of doors within the NHS, you've got a whole range of doors and obviously if you look at that then within a high rise block of flats you could have covered doors that only get opened once a year. They’re just not high frequency use, whereas if you think of your lobby doors are high frequency use, they'll be getting a lot more battering than a riser door, which will only get opened when someone goes in to look at that riser. So if you look at it from that point of view, some doors will naturally last longer than others because they're just simply not undergoing wear and tear. And then also if you think doors on communal areas, I’ve found from my personal experience, doors in communal areas, if someone's got a pram or something like that, they don't care about the door, they'll just ram into those things. That’s why I would tend to agree with that statement. There are factors that affect the longevity.

PAUL BRAY Yeah, absolutely. It'd be difficult to put a time scale to it, but you still have to have what minimum inspection regime would it require. So either every 12 months minimum, where you putting a report together or where the statutory requirements are for 3 monthly inspections that you've got a system in place that adequately records that. But yeah, I agree.

RICHARD Again, Paul, I totally agree with you, but I think that would be on Group 4’s plan, this is how you’re doing the actual inspection, not about what the regimen is. So, BS99 whatever gives the following specific guidelines for guidance for routine fire door inspection maintenance. Well, if that's the specific guidance, it's the specific guidance. I don't think we are going to argue with that, unless there's anything we want to add if it needs clarifying.

NICK TAYLOR The need, potentially, for more that what that says. I'm not sure on the actual wording, just off the top of my head, but I think it's quite limited in the fact that it says, I believe it guides you to inspect twice a year. Are we happy that that single statement suits all buildings?

PAUL BRAY I do think that that can be a bit onerous depending on the types of, especially with regards to residential buildings and blocks of flats, trying to gain access to residents more than once a year is more than hard enough. If you make it a statutory requirement, or the government haven't made it statutory requirement, and that's where I would say we need to be guided by what statutory, so what do we have to do, and then what do we do as considered best practise. The phrase they use in the regulations is best endeavours. And the words in there means that it should be, it doesn’t say it must be so it still isn’t the best practice.

RICHARD I don’t think that should be with us. Anyway, I think alphadi should be inspected every six months. It’s not a function, that’s for Group 4. We don’t decide, it’s not for us to decide when they should be inspected. What we’re doing is what is the inspection.

LAURA SMITH I would suggest the wording old fire doors should be routinely inspected rather than stay in a period. If you say routinely inspected. If you're then inspected, your doors, say every year, but you're continually finding a large number of defects, it should then be down as part of your management system that you might want to increase that frequency. So you're ensuring that your data is more compliant. So instead of giving a frequency period there, I would just

use the word routinely. And then at least it can covers the bits that you need to be checking and then the route. What that routine would look like would be down to Section 4.

RICHARD But if we don’t determine when it’s done, we just determine what’s done. LAURA Yes, so if you do change the word to routine. RICHARD So whether it’s routine or what…that’s for them to say, not for us to say. Yeah, but Laura, that’s not function. LAURA Or periodically, cause periodically could mean anything, you could say 1 week periodically, and then your frequency would be determined by Section 4. RICHARD That's not a function, that's Group 4 to do, it's Group 4 to determine that we're just determining what happens when you're doing an inspection. What are we doing? That's what we're doing and I can't highlight this and I don't really know why.

NICK TAYLOR You're questioning whether the time frame is important for this section. RICHARD Yeah, because our Section is what is being done in this Type 3 inspection. Group 4 are sorting out the methodology, the plan of what happens. They’re the group that say it could be 6 months, or whatever. Or it could be that they’re just putting out a template for a plan rather than filling out that template because it will vary between buildings. But what I’m saying is that’s them, let’s not overcomplicate ours because we’re just talking about what happens in the inspection. As I say, I’m trying to highlight this, but it won’t highlight. OK, so Page 50, criticality: how important the fire door is to the occupant, should be considered in line with any PEEPS and other fire safety factors relevant to the building.

JOE STOTT I find that kind of strange to say, are there other unimportant fire doors?

PAUL BRAY I think it relates back to the healthcare application as much as anything because you're not likely to have PEEPS, at this moment in time the way the legislation is, there’s no requirement for PEEPS for people in general use housing, you may have it in sheltered schemes. Where we're applying this, to some extent it's a rhetorical question, maybe, because the door is always important, no matter the occupants. The door is a critical element of the compartmentation of the building, so is it a relevant question. If you’re looking at hospitals and care premises where you're working on progressive horizontal evacuation, that might be where it's critical, or you've got preference where you've got refugees. So it depends on what type of building you're applying this to.

So again, you might say that that there could be added to Part 4, if it’s going to be the building type, the door may have a more critical value within the fire strategy because in general it needs to stay put. The most important fire door is the front door to the flat because it stops the fire from getting out into the areas because everybody is going to stay in their flat. In a sheltered scheme it might be slightly different, residential care will definitely be different because you’re working on fire compartments to evacuate vulnerable persons to await further evacuation or to make sure they’re in a safe place.

RICHARD I agree. So, are we saying that 3.6 is not really us, it should be group 4?

LAURA SMITH When you look at the wider NHS document, after that sentence there they go in to describe the dependency of your patients within NHS. So I think by cutting out all of that, that doesn’t make sense within this document. Whereas if you were to put that in an NHS setting, it makes perfect sense why they would mention that, but if you apply that to blocks of flats it doesn’t. I think the critically of the door is what is the function of that door. Is it a staircase door, is it a flat entrance door - what is the purpose of that door. Whereas they’re akin in this to the dependency of the patients which makes sense in a healthcare situation.

RICHARD Yeah, I think you’re right. So you’re saying we don’t dump that 3.6, we re-write it?

LAURA SMITH Yeah. Because within your block of flats certain fire doors have a higher criticality than other fire doors. If it was a 30 minute fire door to an electrical cupboard. I'm not saying it's not important. However, if that was your door to you're single staircase and you lose your doors to your single staircase, your staircase is gone and you're kind of hoping and praying that nothing happens. There will be a natural hierarchy to your compartmentation within your block, protecting your means of escape being, predominantly, number one, and if you have a single staircase that will be the thing that you really need, you can’t afford to go wrong. If you start having your single staircase go wrong, you then have a look at other measures that you need to do within the building.

PAUL BRAY Do we feel that it’s needed to be in that Section? is it just a reminder that doors are important/

RICHARD Yeah, I see what you’re saying, because in reality 3.6, there isn’t a Section 3.6. There’s the introductory sentence and there’s nothing else, because, as Laura said, they’ve cut it out because it was about health. So maybe it’s a question of actually we don’t need 3.6 at all.

PAUL BRAY It’s an overarching statement about doors being critical to the safety of the occupants. We don’t need it there. It could be at the opening to the document.

RICHARD Yeah, it’s just a generalisation. Right, frequency of use. So, Laura, this would actually go after that sentence in what you were saying, wasn't it?

LAURA SMITH Yeah. So I think what this document's doing is something similar that we did in the NHS. You look at the criticality of the door and then you would look at the frequency of the use of the door. If you look at this from a residential set and what they're trying to say here is the criticality, which they cut out all of that section, and then what the saying is, right, if you look at the frequency of the use, is that a high use door, medium use or low use door. And then when you apply those two factors together that would give you your matrix for your testing. So it's whether we adopt that approach for a residential premises in which we would need to look at what's your criticality of that door, what would your frequency of use for the doors be, and then that gives you your matrix again.

JOE STOTT In terms of the criticality, is this important for life safety, or asset safety? PAUL BRAY It’s life safety, it will always be life safety. JOE STOTT But then in terms of life safety are we saying there are, depending on the exact usage, different levels of criticality within that? PAUL BRAY I think it’s saying how likely it is to be damaged with overuse. So if you’re opening and closing a door on a regular basis it’s likely to take more wear and tear, therefore you should have a more frequent inspection regime. As Laura said, you’ll get a riser cover door that may not be open from one month to the next, and when it is open it’s only open for a short period, it’s not put under any undue stress. You’ll have other corridor doors, especially these days with mobility scooters and e-scooters going through buildings, they don’t open the door, they bash through to door.

NICK TAYLOR The concern for me on this one, it probably should be considered that it talks about looking at some doors daily. Now, that’s not going to be practical for most social housing situations, fine if you’ve got supported living and things like that. That’s going to be a challenge to achieve and we shouldn’t probably be trying to recommend something that’s going to be very costly and almost impossible for most of the larger landlords.

PAUL BRAY This is where it goes back to the point of what Richard was saying earlier. We edge into Part 4 where we’re giving guidance on the way to do it. In our sheltered schemes we have staff on-site, we train them how to report damage, and there are caretakers on-site, so if they find damage they report it. That’s your daily inspection, it’s not a tick box, oh, I’ve inspected it, it’s you are asking people to be eyes and ears.

NICK TAYLOR It’s definitely achievable where you have staff, but where yo haven’t got staff you’ve got an issue because you won’t be able to comply with that statement.

PAUL BRAY No, and I would never recommend a daily. What you’re saying is if you spot damage, report it, it’s about everybody having eyes and ears and the facility to report damage.

RICHARD Can I just say that Group 4, in their output, have very clearly not just staff any staff within the building, but staff who pass through the building, to have basic training on the kind of things to look for so that if they spot something they know that it’s worth reporting. So they’re kind of covering that, which is where I think it needs to be covered, in Group 4. I know that because I wrote it. I find this document a little bit confusing, actually, because I understood it that there were the three types of inspections, and if you’re doing Group 3 and type 3 inspection, this tells you what to do. But somebody who’s doing a type 3 inspection wouldn’t be deciding on how often they’er going to do it, would they?

LAURA SMITH No. I think what this is trying to do is get you to sort of look at your doors and look at when it needs to be done, because if you go a little bit further on it develops that matrix which then says a 12-month door, 6-month door, 3-monthly check or a monthly check. So I think what it’s trying to do is categorise your doors for the frequency of the inspections, looking at the criticality of the door and the frequency of use of the door, which is not what I was interpreting it as. To me, the Type 3 inspection was going to be your regular checks of that door and what would need to be checked as part of that door. But this seems to be categorising doors as to the frequency of when they need to be checked.

RICHARD Yeah, exactly, it’s not just about the door type, is it? It’s gone into other realms.

PAUL BRAY Yeah, and it talks about the dependency which is a hospital-based thing. So when we were the matrix you’d have to change that for the type of property. It might be supported living, it might be care home. And that would then lead you to, in that matrix, if you scroll down the page it shows you the matrix.

LAURA SMITH (referring to the matrix). To me this is very healthcare-based and if we were to do this Section the same it would need a complete rewrite because that’s looking at the dependency of you patients. So the worked example makes sense, if you’ve got an ITU and it’s a high use door, obviously that's more critical and you would need to be checking those on a monthly basis, which makes sense. But if you think about in a residential block of flats, it's never going to hit these usage rates at all. There's no door on a block of flats that's going to be opened 100 times a day unless you've got very popular residents who have got people coming and going all the time, but it's never going to be opened at that frequency. So we’d have to do a complete rewrite and rework out that matrix and we’re saying would be a high-sue door and a low-use door.

NICK TAYLOR Is it worth doing a quick recap on what we’re actually trying to achieve because it does seem that this Section is a bit off…

RICHARD I’m very confused, I have to say. Obviously, you appreciate I read through this very quickly just before the meeting, so I’ve not really thought about it. Group 4’s work is obviously totally different. But what I’m finding is that I’m not really sure what we’re supposed to be doing. I don’t think it’s very clear, because my understanding of it was completely wrong, and it seems from what you guys are saying…I think when we finish this we need to actually get some clarity with Alan and ask him that question. My initial reaction was to take anything out about frequency because that would be covered in the plan in Group 4, but it seems there wasn’t just the odd mention about frequency, there’s pages about it. So, it’s obviously not supposed to be taken out. But that being the case, I’m just a bit confused.

NICK TAYLOR I think what Paul was started with explaining how the system's done that he works with, that's how I kind of envisage Section 3 to be.

LAURA SMITH If you keep scrolling down, it does go onto that. It breaks each of the doors down into types, so it goes into heritage doors, roller shutter doors, hygienic doors, which has probably been taken out, steel doors and things like that. But again, I think this entire section would need a complete rewrite, because if you think of the fire doors you’re likely to see in a residential block of flats, you're more likely to have composite doors, timber doors, all of which have slightly different requirements for inspection.

PAUL BRAY And this is where I was wanting to add my comments onto this group, because going back to the beginning, I thought it was simple. We developed our own fire door check form and the questions on it are very simple. The name of the person doing it, reference to the door (if its got that), what the property is, where the door is located. Is the door closer fitted? Yes or no. Does it work? Yes or no. Is the door closer shutting without resistance? Yes or no. There’s a requirement to check it from two different angles, but you add that to the training. What type of door is it? Is there a smoke seal present? Is a repair required? You can add additional information and then a photo if necessary. That’s as simple as it gets. If you do it more differently than that, you can add one or two to suit your organisation’s needs, but that’s basically what you’re looking for in a door. I think we’ve added is there glass damage, you need to include that because the glass is critical to the fire installation or integrity of the door. And is there any other damage? That’s why you have the comments field in there.

Because you can’t plan for every eventuality, but you can cover that through making sure that there is ability for somebody to add a comment on it. And we go back to the very beginning of this, we’ve got to keep it simple, and if the whole process for this is to provide a template for somebody to do the checks, let’s come up with that template and put that forward as best practice.

LAURA SMITH That template has already been established within the government guidance though, hasn’t it? Because we’ve done our own questions and we’ve made sure we clearly link it back to the government guidance where it says you must check X, you must check Y, and as long as we can always establish it back to there. And when you go through that point for point, it does fully check the entire door.

PAUL BRAY Yeah, exactly, and there is guidance from the door trade around what we should be looking for in a door. i think if you’re not careful, the pendulum can go in any direction, it’s trying to  find whether you’re doing too little or too much. And don't make it, at this level, so onerous that anybody with a bit of common sense can't do it. You shouldn't be bringing in specialist people to do this job because it will become too onerous to achieve for the general landlord or housing provider.

RICHARD Absolutely. Which is why we've gotta keep what we're doing here as simple and straightforward as possible.

NICK TAYLOR The problem with going into a building at the minute that's not had a Type 1 or Type 2 survey completed is that then if you've got someone who's not trained…so it's got to follow on from the Type one and Type 2.

RICHARD Absolutely. If they’ve not had a type 1 or type 2, they cannot have a type 3. We're gonna have to go back into the main meeting. So what I'm going to do, if you agree, is I'm going to ask for a bit of clarification on those points that we've raised. If I forget one, jump in. At that point, when we know what we’re actually doing, we can make a plan as to how we’re going to do that. These half an hour meetings just aren’t long enough for what we’re looking at doing.

PAUL BRAY I’d be interested, as you’re social housing, what procedures you follow and what you’ve got to assist your staff in carrying out these checks, because there’s a massive amount of duplication of effort if we’re not careful. i think we’re trying to promote a simplified process. And if you’re using what the government say, let’s put that into a document where we say this is what is considered the beset practice. Because we’re all interpreting what the government says and there may be omissions.

RICHARD The thing is, as you say, there are a lot of initiatives doing some guidance, but they’re all slightly different and what we've done with in in other in another piece of guidance we've put out, we put it all together and so t's been all-encompassing, along with the experience of just a lot of people. So, we’ll go back to the meeting now, get a bit more clarity from Alan, then I’ll email you all and we’ll have a meeting with us lot, and anybody else who’s in Group 3. We’ll have a proper lengthly meeting and get something hammered out.