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Maintenance of fire doors that don't need to be.
Rank: Super forum user
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This is causing me no end of constant agro so your input would be much appreciated.
The company I work for is constantly expanding and taking on buildings as warehouses with trade counters. Location is based on catchment and so they may be new or old but they are all relatively small, simple buildings. I am constantly coming across fire doors that have been installed simply because a heavy industrial door is required as opposed to any requirement from a fire perspective.
My worry is that a partially educated FSO will come along and give me a kicking for not maintaining them if they are not perfect (and they rarely are). Is there anything I can do to make it clear that although it "looks like a duck", the quack doesn't work and any type of aquatic bird will suffice.
Incidentally, I would find it easier if they just restored/replaced/maintained them but I have to justify why someone else should spend the money.
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Rank: Forum user
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cover it in your fire risk assessment - add an annex to it - explaining the situation
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Rank: Forum user
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I've had a similar issue. I decided to identify what was a fire door and what wasn't in the fire risk assessment and use this to prove to FSO/Fire Brigade that there is no need for PPM.
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Rank: Super forum user
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Thanks both, I was starting to lean towards that idea.
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Rank: Super forum user
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If they were bona fide fire doors then they will/should have 'Fire Door - Keep Shut' or 'Fire Door - Keep Locked' signs on them. If they don't have the signs then it could be argued that they are just 'normal' doors. So to justify your use of fire doors as normal access doors just take the fire safety signs off and then maintain them or classify them as 'normal' doors, which happen to have good fire integrity. You just have to make sure that all the 'proper' fire doors are suitably signed.
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Rank: Super forum user
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chas wrote:If they were bona fide fire doors then they will/should have 'Fire Door - Keep Shut' or 'Fire Door - Keep Locked' signs on them. If they don't have the signs then it could be argued that they are just 'normal' doors. So to justify your use of fire doors as normal access doors just take the fire safety signs off and then maintain them or classify them as 'normal' doors, which happen to have good fire integrity. You just have to make sure that all the 'proper' fire doors are suitably signed.
That's fine chas but an FSO will spot the three unevenly spaced hinges, guauge the thickness of the door, whip out a make-up mirror, scan the top of the door, spot the label and then proceed to tell you it's a fire door! (not to mention the substantial door jamb, the rebate for the seal or the colour coded stud)
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Rank: Super forum user
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I spotted this on Wikipedia about the Fire Safety order
“The answer to this was to change to a logical 'assessment' based methodology whereby all risks are identified, assessed, appropriate action determined and the implementation of the solution recorded. There would be no minimum requirement, which would allow the use of any product or equipment deemed necessary by the assessor and which best met the requirements for the risk, allowing less measures in some cases and requiring more for others.
This 'assessment' approach would allow the unification of legislation but only under one condition. The burden of proof for compliance would have to be moved to a person at the premises in question to ensure continual monitoring of risks.
No longer would responsibility rest with a local fire authority to issue fire certificates, indeed any previously issued are now void.
It is the job of who the RRFSO identifies as being the 'responsible person' to prove that they have provided adequate and reasonable safety precautions specific to their premises.”
Which means in a nutshell that it is the responsibility of the Responsible person to decide what is and is not a fire door not the FSO whose job is just to check that it was working.
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Rank: Super forum user
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A Kurdziel wrote:
Which means in a nutshell that it is the responsibility of the Responsible person to decide what is and is not a fire door not the FSO whose job is just to check that it was working.
That may well be the aim of the RRO, but that is not how it's being Policed.
The free, open risk based approach as envisaged by the politicians needed a change in attitude and extra training for fire service inspecting Officers (IO). This (in many cases) did not happen.
I was there during the change and had to find my own training (often free seminars by private companies) backed up by self study in my own time to augment the pathetic training provided by my former employers
New IOs were thrown a book of guides and mentored by dinosaurs from the prescriptive fire precautions act era. The result is that the guides have been interpreted as the minimum standard and often no flexibility is possible. The squeeze on fire service budgets will make things worse.
I am being a little hard on my former colleagues as many are very capable. But some are bordering on useless and carry out audits with their guides held to their chests like a child and it's comfort blanket. Even more useless can be their managers. In my experience I had many who had no fire safety experience and were promoted into post, only to be guided by... yes you've guessed it.... the old dinosaurs from the FPA era.
S/Smurf. Just record your findings, remove the fire door signs and keep your fingers crossed that an IO as lovely as me turns up nest time!!
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Rank: Super forum user
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Smurf, why not make a single line drawing, not to scale, showing the fr walls and doors, (if any) and file it with the fra, that way you will have something to show the keen fire safety officer (nothing wrong with being keen) that the walls and therefore the doors are not fire resisting.
Another way would be to attach a simple label to each door stating "not a fire resisting door".
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Rank: Super forum user
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@ Chris,
I include fire strategy drawings with all of my FRA's now but won't draw in fire compartmentalisation (how many points is that worth in Scrabble*?) unless I can back it up.
*Other spelling games are available
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Rank: Super forum user
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At least 29 plus the points for the letters already on the board that you join on to plus 150 for using all of your 20 tiles. I think you've won this one :-))
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Rank: Super forum user
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Messy,
While I agree entirely with your analysis of how fire officers deal with the FSO, we've found that you can win an argument with them, provided you quote chapter and verse from the order and the guidance. Most recently we had a fire officer trying to insist that we had to open doors to check if there was a fire behind them; we asked her if fire crew would do that without wearing BA and PPE, she said no, so we said our (unprotected) care workers wouldn't either. She didn't like it, but has had to concede the point,
John
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Rank: Super forum user
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I think that as H&S professionals we should challenge rubbish enforcement. Just because an enforcement officer (FSO, HSE or EHO) says black is white does not make it so. The point of being a professional is that you make your own case and present it. Ideally you should be able to create a dialogue with the enforcement person but sometimes you just have to stand up to them say things like “if you think I am wrong issue me a notice and we can discuss this in court/ employment tribunal”
Speaking of legal challenges, does anybody think that the Regulatory Reform (Fire Safety) Order has increased the burden on businesses? If it has and you can prove it then the order is not working. The order was created under the Regulatory Reform Act 2001, who’s aim is ‘removing or reducing the regulatory burdens’ which means that it better but no laxer than that the older FPA etc. If FSO are imposing additional duties which did not exists under the older legislation then those duties can be challenged. I love to have a go at this but I can’t as I work for the government and they’d lock me in the Tower if I tried to.
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Rank: Super forum user
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jwk wrote:Messy,
While I agree entirely with your analysis of how fire officers deal with the FSO, we've found that you can win an argument with them, provided you quote chapter and verse from the order and the guidance. Most recently we had a fire officer trying to insist that we had to open doors to check if there was a fire behind them; we asked her if fire crew would do that without wearing BA and PPE, she said no, so we said our (unprotected) care workers wouldn't either. She didn't like it, but has had to concede the point,
John
John- Nicely done mate. As A Kurdziel says, it really is worth standing up to poor decisions.
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Rank: Forum user
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A Kurdziel wrote:I think that as H&S professionals we should challenge rubbish enforcement. Just because an enforcement officer (FSO, HSE or EHO) says black is white does not make it so. The point of being a professional is that you make your own case and present it. Ideally you should be able to create a dialogue with the enforcement person but sometimes you just have to stand up to them say things like “if you think I am wrong issue me a notice and we can discuss this in court/ employment tribunal”
Speaking of legal challenges, does anybody think that the Regulatory Reform (Fire Safety) Order has increased the burden on businesses? If it has and you can prove it then the order is not working. The order was created under the Regulatory Reform Act 2001, who’s aim is ‘removing or reducing the regulatory burdens’ which means that it better but no laxer than that the older FPA etc. If FSO are imposing additional duties which did not exists under the older legislation then those duties can be challenged. I love to have a go at this but I can’t as I work for the government and they’d lock me in the Tower if I tried to.
Excellent post.
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Rank: Forum user
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I think it has been pretty much covered but would boil down to ensuring the doors are not identified as fire doors on the fire risk assessments and any floor plans i.e. fire or general emergency/evacuation plans.
Ensure it is covered and justified within the fire risk assessment as well and then make whoever looks after the maintenance aware of this i.e. if a door is damaged and ever replaced there is no need to replace with a fire door.
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Maintenance of fire doors that don't need to be.
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