Introduction

Despite major advances in Fire Safety and technology, tragic loss of life in public building continues to reinforce the
message that current systems and process are insufficient to cater for the needs of those they are intended to
protect.
In 1968 the Shelton Hospital fire claimed the lives of 21 residents who were asleep in a locked ward. 4 years later
30 people were killed in the Coldharbour Hospital fire. These terrible events took place many decades ago, but how
far have we moved on?
Inquiries have taken place over the years to investigate the causes of such incidences and how these may be
countered, yet tragic cases such as Grenfell Tower serve as a chilling reminder that for all the advances we have
seen in our lifetimes the failure to establish a holistic approach to Fire Safety standards continues to lead to loss of
life.
In 2019 the Fire Door Inspection Scheme (FDIS), referring to more than 100,000 inspections in over 2700 buildings
across the UK, found that 76% of the Fire Doors it inspected were not fit for purpose.
Specialist Door Solutions supports the view shared by Dame Judith Hackitt in Her Review of Building Regulations
and Fire Safety that a change in culture is required to 1.‘support the delivery of buildings that are safe, both now
and in the future.’ In this paper we will share our insight into the changes required and the role our area of
expertise, Fire Rated Door sets, plays in the wider sphere of passive fire protection.

The Scope of the Review

The review makes several recommendations necessary for improving safety within buildings and highlight the lack
of a coherent and uniform structure of standards, testing and product performance. SDS fully supports the view
that improved regulation and compliance to standards will deliver safer environments within public buildings.
Regarding Fire Safety specifically we recognise the stringent standards required and concur that these are currently
found to be lacking in many of the sites we visit.
SDS would welcome the widening of the framework, mentioned in the report, to include further residential
buildings such as Hospitals. As we primarily supply our products to the healthcare Sector, we recognise the
vulnerability of patients within these buildings who may have limited mobility, sight and, or, hearing. History
reminds us of the risks posed to patients within Hospital environments and the necessity in ensuring standards are
maintained.
The report specifically identifies buildings over 10 Storeys although it also recognises that those under 10 storeys
should be covered by the review where the Fire Safety Order already applies. In terms of consistency we would
like to see a framework which encompasses all such buildings and remove any degree of uncertainty in the context
of Fire Safety obligations.

Specification & Design

A fire door carries several functions. On an aesthetic level it can be an attractive addition to the furniture of the
building. It can set the tone for an environment, whether that be a professional office, a vibrant children’s ward, or
the calming pastel colours of a general hospital. At its core however, it is a life saving device which can be relied
upon to compartmentalise fire and allow for a safer evacuation as well as limiting the spread of fire and damage.
There is a huge caveat to this. A fire door is only as effective as the professionalism of its install and the standard
of maintenance it receives throughout its lifespan. The Grenfell investigation identified many doors which 2.‘could
not function (…) as required’ for a range of reasons, including untested ironmongery and non-compliant glazing.
Grenfell also highlighted that all the entrance doors were non-compliant and none of the doors were in line with
current guidance. There are two points here, firstly that the doors in question should meet the standards required,
a critical element of the design and architectural process. Secondly, that maintenance programmes should be
carried out by qualified professionals who can ensure that original specification is maintained and no additional
materials are added which may compromise the fire resisting qualities of the doors or, for that matter, for existing
elements to be removed. It seems incredible, however there are no current rules for mandatory inspections of fire
doors by a qualified individual, and no requirement to maintain records of maintenance.

How can doors specifically designed to meet Fire Safety Standards fail?

• A lack of understanding of the qualities required at design stage
• Poor quality construction leading to product failure
• Poor standards of install of otherwise compliant door sets
• Inadequate maintenance programmes
• The complexity and weakness of systems designed to ensure compliance

How do we ensure compliance to specification in the future?

Several recommendations have been put forward by the Independent Review which seek to reduce or eliminate
the potential for failures.
The creation of a Regulatory Framework for oversight of high-risk residential buildings
A Joint Competent Authority comprising Local Building Control, Fire & Rescue Authorities and the HSE
The report identifies the need for Independent 3rd Party Certification of all HRRBs to ensure compliance of any
installed product to the initial specification.
SDS supports these recommendations and would welcome an increased level of detail regarding the proposals,
their implementation and enforcement. As a company which works closely with 3rd party bodies, we also believe
this would be of great benefit to the JCA in ensuring consistency of enforcement.
Regular review of existing standards is critical to ensuring their suitability for the changing environments we live
and work in. Building design and specification is continually evolving and it is vital that Building Regulations evolve
at an appropriate pace. Currently these are reviewed every five years meaning that changes in materials,
technology and best practice go unnoticed.
Improving communication between the various stakeholders in fire safety is critical to ensuring specifications are
followed. Building Information Modelling (BIM) is becoming more widely utilised and this, combined with data
sharing in relation to product performance, can greatly assist.
As a specialist in Fire Rated Door set manufacture, we believe that door sets should be sold as complete systems.
Where component parts are supplied by different companies there remains an element of uncertainty over their
ability to meet specification and, indeed, it is not possible to certify a door set under 3rd party guidelines, unless
those component parts have been proven under test conditions. As a minimum we would recommend a complete
audit trail for each door set and mandatory maintenance records to record any instance of alterations made.

Changing cultural behaviours

A key component in shifting fire compliance from its current position is understanding and improving the cultures
within organisations that manage it.
The fact that 76% of fire doors inspected in 2019 were found to be non-compliant tells us several things.
Currently compliance is focussed too narrowly on production and install. Manufacturing materials, tolerances and
the training and capability of installers are tested under strict conditions and regularly audited to ensure they
continue to meet the criteria. This however, is where the focus stops, and complacency sets in. Having worked
with numerous healthcare bodies there is a huge variance in maintenance standards and record keeping which
leads to some institutions continually demonstrating strict compliance whilst others reveal clear neglect. Levels of
competence in the maintenance of fire doors is highly inconsistent and reflects the lack of requirement for those
carrying out such maintenance to be qualified to do so. We continue to see examples of doors either propped
open or having dropped to the point they can be ‘jammed’ open with the tell-tale markings on the floor indicating
that this is not a recent occurrence. The addition, or replacement, of door closers and other non-compliant
ironmongery is also a concern and demonstrates the potential for tragedy where the original specification is
deviated from due to lack of understanding, competence, or wilful neglect.

So, what can we do to change this?

The failings in levels of compliance can be attributed, to a large extent, to the wide range of individuals and groups
responsible for maintaining it. The Independent Review seeks to reduce the overlapping nature of responsibilities
by a requirement for a single ‘Duty Holder’. They would have overall responsibility for all aspects of HRRB and
would also require them to share the fire strategy with residents.
Whilst this recommendation is more focussed on residential buildings SDS believes the consolidation of
responsibility within a single Duty Holder would crystalise compliance and, when part of a wider audit/inspection
process, would have a dramatic effect on culture within public buildings. We would also recommend increased
dialogue with staff and residents with a focus on encouraging reporting of defects and the raising and recording of
any concerns.

Improving Training and Certification

The key change suggested by the Independent Review is the
3.‘testing of products that are critical to the safety of HRRBs should be subject to independent third-party
certification.’
SDS works closely with 3rd party certification bodies and fully supports this recommendation. Whilst we can be
sure of the quality of production and the suitability of our products for their installed environment the same
cannot be said for their maintenance thereafter.
Management of Fire Safety Systems depends upon those tasked with maintaining them being fully trained and in
possession of such skills relevant to the role. To ensure maintenance and inspection programmes fulfil their
purpose it is vital that training is provided and that 3rd Party bodies can confirm this and correct where failings are
identified. The independent report, when referring to current skill levels, states there is 4.‘a lack of skills,
knowledge and experience and a lack of any formal process for assuring the skills of those engaged at every
stage of the lifecycle of HRRBs’. There are also concerns that whilst individuals may be highly skilled in their own
discipline, they may lack an understanding of how their actions may impact on others who interact with them. The
absence of a single, focussed approach to training and competence was raised in the report, where the range of
different qualifications and disciplines can make their function and accountability difficult to distinguish between.
In contrast to mandatory inspections for electrical appliances there is no such enforcement required for inspection
and maintenance regimes for Fire Doors. As a result, records are often incomplete or non-existent with the result
being findings such as those identified in the 2019 review.
Testing of fire doors is rigorous and extensive, with Best Practice displayed through membership of industry
auditing schemes. Installation of fire rated door sets, likewise, is carried out by skilled professionals who are
audited on a regular basis to ensure competence is maintained. Beyond this point, however, inspections on
installed doors and ongoing performance checks should be compulsory and carried out by 3rd party inspectors to
ensure corners are not cut and failings highlighted where they exist.
SDS believes all components of fire safety systems should be certified. This is over and above the recommendation
of the Independent review which merely recommends a revision to the current British Standards to determine how
and when product assessments should be made. This is, in our view, clearly insufficient and could result in further
confusion and non-compliance.

Consequences for manufacture

As previously stated, the 2019 survey found that the vast majority of Fire Door sets were non-compliant and
unable to carry out their function as passive fire safety devices. The Grenfell Tower – Fire Safety Investigation that
5.‘fire doors containing multiple additional fixtured and fittings, unless expressly constructed and fire tested to
prove their viability (…) pose a serious risk of failure’.
This clearly shows the need to not only certify at production, but also through the installation and maintenance
periods of the product lifespan. If clear on paper this becomes cloudy in practice where coherent systems and rules
are not in place, meaning a product can be radically altered from its original design to the point it may no longer
perform within its designed parameters. To achieve the wider sphere of compliance a greater degree of targeted
regulation is required to keep all stakeholders engaged.

Improving Performance and Quality

In addition to the requirement for third party certification of all fire safety products, the independent review has
called for 6. ‘a more effective testing regime with clearer labelling and product traceability, including a periodic
review process of test methods and the range of standards in order to drive continuous improvement and higher
performance.’
Specialist Door Solutions fully supports this and, as a leading manufacturer of Fire Rated Door sets, we are very
familiar with 3rd party certification and the standards this drives. Through continuous external auditing processes,
we ensure our production methods remain cutting edge and compliant and our products meet the precise
tolerances required to function superbly in fire conditions. We are continually reviewing our product offer,
identifying innovative new features, and testing these to rigorous standards in third party tests which expose our
products to furnace conditions.
We fully support the view that product maintenance should be a central party of building Fire Safety regulations,
and that this should be carried out by qualified professionals rather then general maintenance teams. Just as PAT
testing supports the prevention of fire through electrical faults, so maintenance of fire doors can raise compliance
and help to save lives both through preventing the spread of fire and supporting swift evacuation.
Specialist Door Solutions has over 40 years of experience in the manufacture of Fire Rated Door sets. From our
factory in Bordon, Hampshire we continue to develop new product lines with fully tested and audited components.
We work closely with third party assessment bodies and are proud to supply our NHS with Quality passive fire
safety devices designed to handle the high traffic, high impact environments found in our hospitals.

1. Building a Safer Future – Independent Review of Building Regulations and Fire Safety: Final Report, P.11
2. Grenfell Tower – Fire Safety Investigation, section 2.21.23
3. Building a Safer Future – Independent Review of Building Regulations and Fire Safety: Final Report, P.95
4. Building a Safer Future – Independent Review of Building Regulations and Fire Safety: Final Report, P74
5. Grenfell Tower – Fire Safety Investigation, section 2.29.4
6. Building a Safer Future – Independent Review of Building Regulations and Fire Safety: Final, Ch.7

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