Fire Doors

Essential Property Services advises that the costs associated with fire doors inspection and maintenance of fire doors continually grates on building managers, as they are constantly reminded by most contractors that remedial works are mandatory, and under the fire doors Australian Standard AS 1851 “Maintenance of Fire Protection Systems and Equipment” attract penalties for non-compliance, and thus reinforce the need for frequency of fire doors inspection and maintenance by competent, qualified assessors.

This fire doors inspection article is not advocating non-compliance with “specified” statutory fire doors inspection requirements or to suggest a reduction in maintenance costs or fire doors inspection that reduces the safe operation of fire doors where State legislation allows the manager to determine the extent of fire doors inspection and maintenance on fire doors to be performed outside of those nominated in AS 1851. This article is for managers to be informed on the parameters of the legislation and AS 1851 which allows them to implement a safe fire doors inspection maintenance regime.

Fire doors inspection legislation in three States is discussed, with Queensland and New South Wales discussed briefly, and the more involved Victoria fire doors inspection legislation discussed at length.

Victoria – Fire Doors Inspection

Part 12 of the Building Regulations and AS 1851 “Fire protection systems and equipment services” covers fire doors maintenance and fire doors inspection in Victoria. Part 12 contains two Divisions, Division 1 – Maintenance of Essential Safety Measures is broken down into three subdivisions. Subdivision 1 applies when fire doors are contained in a building built after July 1994 or an existing building where the fire doors have been altered under a building permit. Subdivision 2 applies to fire doors in buildings that existed prior to 1994 and have not been altered.

Part 12 makes it mandatory on the building owner to ensure that fire doors comply with either AS 1851 or are maintained in a state which allows the fire doors to fulfil their purpose. While the objectives and intent of both Subdivisions 1 and 2 relative to fire doors may be the same, Subdivision 1 is prescriptive and refers to AS 1851 (which contains fire doors inspection provisions), whilst Subdivision 2 nominates a performance standard.

New South Wales: Fire Doors Inspection

Maintenance of essential fire safety measures (fire doors) has been regulated to varying degrees by changing legislation over many years, starting with Ordinance 70, through to the current maintenance regimes under the Environmental Planning and Assessment Act and Environmental Planning and Assessment Regulation, which have not nominated AS 1851 which includes fire doors inspection.

Essential safety measures such as fire doors must be able to continue to perform to the relevant regulations and Standard requirements to which it was designed and installed. The manager may decide to utilise AS 1851 “Maintenance of fire protection systems and equipment” (see Victoria for further comments as the benchmark for fire doors inspection regime). It is mandatory however, that the fire doors are maintained to facilitate their compliance with the relevant performance standard at all times, and not AS 1851, maintenance must include fire doors inspection.

Queensland: Fire Door Inspections

The QFRS require fire doors to be maintained (including fire doors inspection) by the occupier under the Building Fire Safety Regulation (BFSR). This means that if a “fire safety installation” such as fire doors installed in a building, then the applicable Standard must be adhered to (in our example AS 1851 “Maintenance of fire protection systems and equipment” will apply). Fire doors inspection is to be performed by an appropriately registered person to inspect fire doors, at regularities specified in the QDC – MP6.1 Schedule 1 and not the regime specified in AS 1851-2005.

Fire Doors: Existing Buildings

For existing buildings (Subdivision 2) the building owner has an obligation to ensure that the fire doors will function adequately in the event of an emergency. Building Regulations does not compel existing fire doors to comply with the current Standard for maintenance under Subdivision 2 of Part 12, that is AS 1851. Indeed, even AS 1851 specifies that unless this standard has been invoked by a controlling authority, under legislation it is not applicable.

Prior to 1994, the fire doors inspection and maintenance standard was not invoked by legislation. Consequently for existing buildings, it is the building owner who is required to determine the extent of required of fire doors inspection required in the pursuit of ensuring the fire doors are maintained adequately. The fire doors maintenance standard can be used as a guide.

We do not believe that it is the intent of the Building Regulations for “essential safety measures” known as fire doors in existing buildings to strictly comply with all new Standards created after the building was constructed, e.g. AS 1851. It may well be for certain installations, like emergency lights, that some essential safety measures should comply with the current standard, but not fire doors (as the Standard states).

Fire Doors: New Buildings

New buildings or buildings having recent alterations (Subdivision 1 or combined Subdivisions 1 and 2 buildings), the building certifier must determine the extent of fire doors inspection required for fire doors and place the fire doors inspection requirements in writing to the building owner upon completion of the building works, in the form of an Occupancy Permit, Maintenance Schedule or Certificate of Final Inspection.

The current benchmark AS 1851 stipulates quarterly fire doors inspection. We recommend building managers request the building certifier to nominate four fire doors inspection per year in high use fire doors, and lower number of fire doors inspection where the frequency of use of the fire doors is low, (for example: a hospital, shopping centre, etc. may warrant a higher number of inspections). The building certifier can modify the number of fire doors inspection under AS 1851.

If required to use the previous benchmark AS 1851:7, as is stipulated on an Occupancy Permit or Maintenance Determination, twelve fire doors inspection per year (eleven Type 1 and one Type 2) will be necessary.

Fire Doors: Installation

Essential Property Services staff are finding after fire doors inspection that a number of fire doors should never have been tagged (that is, where the installer certifies fire doors installation in accordance with the installation AS 1905.1 – 2005), due to defects at installation stage, but are required to be maintained with the current fire doors maintenance standard – AS 1851 (sometimes the contractor represents the same company who installed the fire doors). This situation should be considered unacceptable, especially when the defects to fire doors are minor and can be very costly to repair under AS 1851 stemming from fire doors inspection.

Fire Doors: Sprinkler Protection

Many fire doors that are installed in buildings protected by sprinklers deserve consideration, especially when they were installed in a period when no fire doors inspection maintenance regulations existed. Minor defects that some contractors say are acceptable in a non-sprinkler protected building are called up as maintenance items by other contractors in sprinkler protected buildings, and in such case a judgment call should be made by “appropriately qualified” inspectors as to the extent of remedial works required on fire doors relative to AS 1851.