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We all know (or should know!) that the final exit door in a building should open in the direction of escape ie outwards. So far so good.This is in lots of guidance, best practice etc. Can anyone point me to WHERE THIS IS A LEGAL REQUIREMENT or is it just "best practice"?
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This is copied from the legislation, see para d,
Emergency routes and exits
14. (1) Where necessary in order to safeguard the safety of relevant persons, the responsible person must ensure that routes to emergency exits from premises and the exits themselves are kept clear at all times.
(2) The following requirements must be complied with in respect of premises where necessary (whether due to the features of the premises, the activity carried on there, any hazard present or any other relevant circumstances) in order to safeguard the safety of relevant persons—
(a)emergency routes and exits must lead as directly as possible to a place of safety; (b)in the event of danger, it must be possible for persons to evacuate the premises as quickly and as safely as possible; (c)the number, distribution and dimensions of emergency routes and exits must be adequate having regard to the use, equipment and dimensions of the premises and the maximum number of persons who may be present there at any one time; (d)emergency doors must open in the direction of escape; (e)sliding or revolving doors must not be used for exits specifically intended as emergency exits; (f)emergency doors must not be so locked or fastened that they cannot be easily and immediately opened by any person who may require to use them in an emergency; (g)emergency routes and exits must be indicated by signs; and (h)emergency routes and exits requiring illumination must be provided with emergency lighting of adequate intensity in the case of failure of their normal lighting.
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(2) The following requirements must be complied with in respect of premises where necessary ...
The key words are "where necessary" and will be decided during the risk assessment process.
Given the wording in section (d) using "must" there will need to be a very convincing argument as to why any particular door is not outward opening.
I have successfully defended such a decision with an enforcement officer who accepted the special circumstances at the premises.
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Agree with David, Fire Officer has accepted this, where the travel of the door is against the flow of escape due to the low number of likely users in the event of fire.
Pete,
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David there are fire safety officers who use common sense to make decisions, for example in a small occupancy it may be sensible to allow a fire exit door to open inward, however if the level of occupancy increases and the fire risk assessment is not reviewed, revised to alter the fire exit to open in the direction of escape, AND something happens that leads to persons becoming trapped, you would have a real problen convincing a Court that you were right.
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Fully agree, FS101.
And that is a good illustration as to why a fire risk assessment needs to be done by someone who fully understands the subject and is capable of making a decision based on their professional judgement, rather than slavishly following a rule book.
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Some good replies, I am not sure that everyone understand that I was referring to the FINAL exit door only?
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Pikeman wrote:Some good replies, I am not sure that everyone understand that I was referring to the FINAL exit door only? Final exit door is a door for use in an emergency therefore see 'd' in the list I provided.
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All doors should open in the direction of travel, especially where > 60 persons are likely to use them or where rapid escape is necessary (ie a paint shop). BS9999 and Approved Doc B of the building regs refer See this excellent website for further info http://www.firesafe.org....ans-of-escape-from-fire/But BS9999 and most of ADB are not a statutory requirement, and these rules can be broken in extreme circumstances if mitigating measures are adopted. Listed buildings often have challenging inward opening doors as final exits, and English Heritage and their chums are very unhelpful when it comes to improving fire safety!! I am responsible for a listed building with an occupancy of around 2,800. We have 10 outward opening final doors which have been approved by building control & the local fire safety enforcement authority. Each door is connected to an electrically powered rapid opening mechanism, which is linked to the fire alarm. The aim is all doors will open automatically within 20 seconds of an alarm being raised. There is an uninterrupted power supply and a secondary power supply - and if all that fails, there are manual door overrides. This is where the where necessary part of the RRO comes in, as it allows complete flexibility in choosing the right approach to each building on a bespoke, rather than prescriptive manner
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Mssy, I have no wish to start an argument, I am now too old for that having started to pick up my old age pension, but still interested in these threads, however para 14 (1) of the Legislation begins with where necessary but para d does not therefore I would think it is mandatory for exit doors to open in the direction of escape.
Having said that your post is very interesting and does show what measures can be achieved if you really want to, you do mention outward opening doors?
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FireSafety101 wrote:Mssy, I have no wish to start an argument, I am now too old for that having started to pick up my old age pension, but still interested in these threads, however para 14 (1) of the Legislation begins with where necessary but para d does not therefore I would think it is mandatory for exit doors to open in the direction of escape. Dear FS101, debate is healthy, arguments are not and I am always willing to debate and have my opinions questioned. Meanwhile, you really do need to book a visit to Specsavers (although Boots can do a good deal!!) Paragraph d that you refer to is actually Article 14(2)(d), which when you read the article and subsequent list, does indeed mention 'where necessary', as follows (my CAPITALS)
(2) The following requirements must be complied with in respect of premises WHERE NECESSARY (whether due to the features of the premises, the activity carried on there, any hazard present or any other relevant circumstances) in order to safeguard the safety of relevant persons— (a)emergency routes and exits must lead as directly as possible to a place of safety; (b)in the event of danger, it must be possible for persons to evacuate the premises as quickly and as safely as possible; (c)the number, distribution and dimensions of emergency routes and exits must be adequate having regard to the use, equipment and dimensions of the premises and the maximum number of persons who may be present there at any one time; (d)EMERGENCY DOORS MUST OPEN IN DIRECTION OF ESCAPE;
You owe me a pint I reckon :)
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Bob on Mssy,
I know of a few premises where it is accepted that final exit doors do not open in the direction of travel, one a large relatively new public building where the exits (large steel doors) lead onto busy public walkways - liable to collide with pedestrians when opened in a hurry and another in a care home (low numbers of likely users), both with the approval of the Enforcement Authority - The Local Fire Brigade and CQC for the care home.
Pete,
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I have been involved in the setting up of a number of residential care homes (low occupancy, refit of large houses) and it is generally accepted that emergency exit doors will open inwards. We even have one or two which are sliding doors (even though I do not agree with it) which have been accepted as there was no alternative means available. Compensatory measures have been taken with this approach and all enforcement authorities are satisfied with this. Albeit in Ireland of course, but seeing as we generally just cut and paste UK legislation it is probably similar :) Kevin
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ha ha ha - where X or current Fire Officers collide (im guessing here of course but there are enough clues)
Fire safety your round mate?
Im getting this all the time with many debates - I have a well established PAP for safety and I entered one for fire safety and get two FO's is a debate it is great.......... But what you learn is immense.....
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What! myround not without a fight (I mean argument/debate of course) ha ha.
The Oxford English online dictionery states :
Necessary - needed to be done, achieved or present. Essential.
What part of that definition allows it not to be done.
Whose round is it now ?
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Add "where" to "neccessary" and it becomes a sentence with a different meaning.
To the pub with you immediately, wallet in hand, haha!
Pete,
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I have to let you know I have deep pockets and very short arms ha ha
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Re doors opening out onto the pavement, I have been involved in recommending lobbying arrangements to get the doors away from the pavement.
It works if you have the want to get it done but understand it is difficult with expensive doors and listed buildings.
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FireSafety101 wrote:I have to let you know I have deep pockets and very short arms ha ha Don't worry about that as I have been on a manual handling course today and will simply hold you upside down and shake the money out of your pockets :) PeterL has it spot on: Definition of the phrase is "Where it needs to be done" the doors should open outwards etc etc. The use of the English language ain't good in the Fire Safety Order and can be confusing, but nonetheless, I still want my beer! For DP who was having fun watching us 'X fire officers collide', that wasn't the case at all. I believe being fire safety professionals, of course we were saying the same thing; its just FS101 was using his words in a different order :) Is it Friday yet?
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ok then for the sake of consistency of the debate lets apply 'interpretation' - drink up?
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I have agreed for messy and I to meet and I will purchase the first round, as long as he gets the second.
If there are any third parties at the meeting it WILL become a party and who knows what topics will be on the agenda then.
In the meantime final exit doors WILL open in the direction of travel "where necessary".
Thank you and goodnight.
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mssy wrote: For DP who was having fun watching us 'X fire officers collide', that wasn't the case at all. I believe being fire safety professionals, of course we were saying the same thing; its just FS101 was using his words in a different order :)
Is it Friday yet?
Yes it is now Friday :o) mssy, your comment above brought to my mind Eric Morecambe and Andre Previn or was it Andrew Preview? :o))
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I now believe that I have the answer which supports my original thought. That is, "where necessary". I note that it does not say "shall".
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I know one thing the final exits in my local don't open in the direction of travel and i'm sure I have been impared in my ability or want to escape when leaving on occassion, haha!!!
Pete,
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Pikeman wrote:I now believe that I have the answer which supports my original thought. That is, "where necessary". I note that it does not say "shall". It does say "Must" in the same sentence and I think is taken to have the same meaning as "shall", which does not help in understanding. I'm sure they knew what they were on about when it was written. Where would our fun be if it all made sense. Chris
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As indicated in some ACoPs, I tend to regard both 'must' and 'shall' as mandatory (though in this case because they say 'where necessary' that allows for some interpretation and differing opinion).
If I read guidance that says 'should' I tend to think of it as not mandatory, but suggested best practice, and in court you might have to explain when/why you didn't use the suggested best practice.
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Where necessary.... must be outward opening.
Clear now?
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On another note....
Last year the council built a ground level 6 bedded care facility to be predominately used with wheelchair users and to be registered as a HMO. I was instructed to complete the first initial FRA and to advise on signage and fire fighting equipment. All the final exits opened inwards which was ludicrous because of the wheelchair users. My concerns were raised with the council and the Fire and Rescue Service quoting section 13 of The Fire Safety (Scotland) Act 2006. My advice was ignored and the Fire officer granted the HMO licence, despite me mentioning RosePark to him.
Note, All of my FRA's, documentation and communication is securely stored and evidenced just in case.
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Toe, thanks for that.
So you see everyone, those two little words that so many of you point out mean that fire doors don't necessarity have to open in the direction of escape, have the potential to allow individuals to create conditions that can cause fatalities.
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David Bannister wrote:Where necessary.... must be outward opening.
Clear now? David, yes, but in premises with just say 7 able-bodied employees the manager can decide 'not necessary' and keep his inward-opening doors.
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Yes John and it also looks like in premises where there are mostly disabled wheelchair users the Manager can decide to have his doors opening in.
Give an inch and take a mile ?
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Decisions on vital safety features of buildings (and legistave requirements) should not normally be made by managers. They should be made by fire safety professionals/engineers. This is one reason why healthcare premises get annual inspection's from the Fire and Rescue Services, etc... To ensure compliance with the Law.
I guess this thread is more about the wording and interpretation on the law than anything else, and this is how I see it.
Ideally final exits should open in the direction of flow, which can easily be achieved in new builds, however, if the door opens onto a public pathway or a roadway or the building is old or is a listed building or the building has low occupancy with fully abled bodies then it may not be a reasonable request to change these to opening outward.
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Toe. Did the occupiers or fire service give you any justification for choosing not to run with your advice?
I really can't see huge costs involved, but there again, I am unsighted re the design of the building.
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"Decisions on vital safety features of buildings (and legistave requirements) should not normally be made by managers. They should be made by fire safety professionals/engineers."
Fair point Toe, I can recall 3 companies who had inward opening fire doors at a main reception and which were signed off by the Council Fire Officer. They would be considered as fire safety professionals.
Regards
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mssy
Not officially. I was told that the building had been passed at the design stage and authorised to be built in that way, and that the path round the perimeter of the building would have to be made wider to make the landing area bigger at the door exits. Ok the building has a sprinkler system fitted but the fire inspector didn't even want to see the FRA that I completed and issued the licence with no extinguishers or signage within the premises at that time.
I was involved at the finished stage of the building, the residents were due to move into an already delayed build (pleasures to get them out of a hospital setting) - I suspect this was the main factor not to change the doors.
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Pressures not pleasures- Dohhhhh
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