A 215-bedroom hotel does not need to fit intumescent strips and smoke seals to its bedroom fire doors in order to satisfy its legal obligations, the secretary of state has determined.
The determination concludes that in order to satisfy the requirements of the Regulatory Reform (Fire Safety) Order, the responsible person did not have to commit to fitting intumescent strips and seals to the existing bedroom doors, and that it was sufficient to record and justify their absence in the fire risk assessment.
The hotel, built in the 1980s, has 215 guest bedrooms, eight staff bedrooms and accommodation over four floors. All bedrooms open onto protected corridors, providing means of escape in two directions. 167 of the bedroom doors are not fitted with intumescent strips and smoke seals, but these doors complied with the appropriate standard for fire doors at the time of its construction. The hotel has a fire alarm system which includes smoke detectors in each bedroom.
In the determination, the chief fire and rescue adviser concluded:
“Having reviewed the material provided, I consider that, as far as can be ascertained from the submissions, the measures currently in place and the assessment of their effectiveness, are sufficient to adequately protect occupants in the event of a fire and ensure that they are able to evacuate the premises as quickly and as safety as possible.
“There is no evidence to suggest that the margin of risk reduction that would be afforded by the installation of intumescent strips and smoke seals on the bedroom doors leading on to the escape corridors would be justified given the potential expense involved.”
The determination is based entirely on the circumstances of the hotel in question, and the decision was taken after careful consideration of the particular circumstances of the case.
The determination also states:
“The guidance should be applied flexibly and the level of fire protection should be proportionate to the risk posed to the safety of the people on the premises. Although the [Department for Communities and Local Government’s] guidance for sleeping accommodation references Approved Document B, there is no requirement under the Fire Safety Order for a responsible person to comply with provisions relating to new buildings and alterations under the Building Regulations.
“However, article 10 of the Order requires that preventive and protective measures should be implemented on the basis of the principles of prevention set out in Part 3 of Schedule 1 to the Order which includes “adapting to technical progress”. As such, where protective measures, that were not available when the building was built, subsequently become available then consideration should be given to adopting such measures where it is proportionate to do so.
“The provision of smoke seals on fire resisting doors does provide increased protection from the spread of smoke in the early stages of a fire and the provision of intumescent seals have been shown to improve the fire resistance of doors, hence their inclusion in modern fire door design. What needs to be considered in this case is whether it would be proportionate to upgrade the existing doors within a defined timescale or to wait until the doors are replaced when they come to the end of their useful life. This is a judgement that should be based an assessment of the risk from fire, the nature of the existing doors and any other preventative or protective measures in place.”
Read the determination in full
