Operational Musings on new Fire Door Guidance by Neil Yeomans

Change 1: Logistics

"I like that the guidance advises checkers to assume doors are compliant if a detailed FRA has already confirmed their “standard-of-day” performance. It mirrors asbestos surveys, where material sampling feeds into an annual visual re-inspection programme. In practice, this places FRAs in the same role asbestos specialists occupy: Asbestos specialists take samples of materials to confirm what sort (if any) asbestos is present and then they provide key information to help manage the risks. In fire door land, that equates to confirming that the most common door-set in a block met the standards of its era and remains safe for current use.

My Musings on the Operational Impact of Change 1:

FRAers are going to have to seek documentation to show the doors installed were up to muster when installed - many FRAers already do this, but I think this guidance now makes this step vital to the overall system.

The bad news is that I suspect the vast majority of doors in this country won't have that data.

Housing providers have fire doors that pre-date the concept of a CAFM system!

Essentially, information management in those days was purchasing some carbon paper! If you're too young to know what carbon paper is; imagine a bit of kit that copied everything you wrote down; exactly how you wrote it down, including the spelling mistakes!

This lack of available information, I feel, will lead to destructive sampling of fire doors becoming routine rather than occasional. One departure from my asbestos analogy is that testing a fire door is far more invasive than taking an asbestos core, so I suspect FRA firms will either start offering “door-testing” services where they offer to facilitate door laboratory testing or we’ll see a surge in 'fire-door survey required' actions and leave it at the feet of the housing provider to confirm the situation.

And yes, the notional-versus-certificated door debate looms large again.

Thought 2: Effort transfer

FRAs are likely to be quite demanding on the information they require to carry confirm if fire doors are suitable. Therefore the management of the information is going to be a serious challenge across all teams.

Crucially, safety teams rarely handle door replacements themselves - (it's always my preference they do as otherwise it creates a box ticking culture, but alas, I'm in the minority on this matter). Repairs and investment teams often take the lead, so managing information across silos becomes a logistics challenge that will need to be addressed.

I suspect the way this will manifest is that FRAers will request information, and the poor soul that runs the FRA programme will spend hours trawling work orders for door repairs and replacements to see what happened in a particular building. Even in the event they find a works order with enough description to lead them to the team responsible for managing the work, I fear they'll find the repairs and planned teams may not have saved the information quite how the FRAer needs it. Or they may not have saved anything at all...

Either way, the people running the FRA programme are likely to have a difficult task in this data mining, so make sure if you see them and they're looking stressed and forlorn; give them some support.

My message to development, repairs and planned-improvement teams: start logging key fire-door data—make, model, certification status, installation date—in your asset management system now. The HACT website’s UKHDS parameters under “fire doors” are a great reference. Speak to your safety teams - remember; you are just as responsible for making sure fire safety is maintained.

Thought 3: The impact of time

Capturing every detail of doors that are installed today is a challenge in and of itself. Just imagine managing that for tens of thousands of doors that have information all over the place from the last 60 years. Now imagine managing all of that for the life cycle of a fire door into the future. Past, present and future data management represents a huge challenge when FRAers are going to need this information kept and presented to them.

During the 30-40 year life cycle of a fire door (or longer!) we'll see new;

• FRA contractors,
• Fire-door contractors,
• IT systems,
• Mergers and acquisitions etc.
• Panic installs after a downgrade or legal notice

All of these, and more, will expose the data to risk of translation error, loss or corruption.

Without a digital overhaul, we'll be stuck in the same old cycle of sending out another surveyor to collect the information we already held. All of that undermines the thrust of the new guidance, as it'll be the poor tenants and leaseholders paying for those additional surveys.

However, all is not lost; this challenge has already been overcome in your asbestos registers. So, my advice; if you're managing fire doors, take some time to shadow your counterpart who manages the asbestos register and see how they do things - you may find that the IT kit already exists for what you're after, if just needs to be replicated for fire doors.

Thought 4: Contradiction

A logistical contradiction also caught my eye. The guidance states:

“With appropriate instruction, caretakers, managing agents, housing officers and maintenance personnel should be able to do them … as the checks are only visual and do not involve, for example, use of tools.”

Then it adds:

“To check flat entrance doors, you will need access to each flat … Arrangements should be made with residents in advance … You could consider offering a range of times, so that residents can be present.”

Expecting already-over-stretched housing officers to organise no-access programmes and potentially build legal cases against uncooperative residents shows a misunderstanding of how time-intensive access becomes.

For what it’s worth, even with gas safety, the compilation of a robust case against the resident is a significant amount of work.

To me, it feels like this new guidance is likely to reduce fire door inspection companies from doing annual and quarterly door checks, and it then feels likely that housing providers will directly employ staff to manage the programme, much the same way as gas safety manages its workload. It's one of the very few ways I can see that'll provide the labour required.

I'm afraid the bad news there for customers is that those staff are likely to get the majority of their wages paid for from the management fees, which are again, additional to rent...

In essence, what I'm saying is that the guidance underestimates both the current workload of existing staff and the logistical effort required to do this work in the first place.

Anyway, I hope those musings help give some reassurance that the guidance represents progress in that clarity of the different pieces of law are now crystal clear.

And I also hope that I've suggested some solutions; the most important of which is; you may not need to re-invent the wheel here. Your asbestos team may have done some of the heavy lifting, so take a look at the asbestos management plan and shadow the team for a bit."

Neil Yeomans

Head of Education & Building Safety

Totus Digital