Regulation 7 Audits
Regulation 7 of the Building Regulations requires that building work is carried out using “adequate and proper materials which are appropriate for the circumstances in which they are used and are applied, used or fixed adequately to perform the function for which they are designed in a workmanlike manner”.
In addition to legislative requirements there are practical and commercial reasons for wanting to ensure that passive fire protection components are delivered at handover in a fully compliant condition:
- Any items not compliant could be condemned at handover or at any time in the future when those responsible for the building assess the building for fire risk. In particular such items that are enclosed within the fabric of the building could prove very costly to remediate even if they can be practicably accessed. There are issues and costs that go beyond the immediate cost of remediation for those organisations and individuals involved with delivering non-compliance.
- It is clearly not acceptable to allow items that are specified, procured and installed solely or mainly for the purpose of providing fire protection to be built into the fabric of the building to an inadequate standard, potentially creating weak spots that could hinder or even add to life safety risk in the event of a fire.
The following items provide a quick guide to some of the issues that typically need to be anticipated and addressed:
Structural Steel Protection Systems:
Board systems, normally used to form a box around the steel section, need to be installed within the parameters of the manufacturer’s fire test otherwise there is no guarantee that they will provide the fire resistance that was specified.
Base coats must be applied evenly onto a compatible primer in good condition to specified loadings within the right time frame and within certain ambient temperature and humidity limits. It is neither easy to check nor rectify if incorrectly applied.
Fire Wall Systems:
Buildings will move in the event of a fire and floor slab deflection can cause stress in partitions. The partition’s structural soffit junction detail must be designed to accommodate anticipated movement. The deflection head detail must be correctly installed. Another common problem is that M&E services breaching dry-lined walls, including electrical sockets, are not adequately addressed to reinstate integrity. A robust method of quality assurance for the fire compliance of dry-lined walls should be created prior to installation, not least to establish which subcontractor is responsible for reinstating the fire integrity of the various breaches and how this is to be achieved.
Fire Resistant Glazing Systems:
Have to be installed as tested, using the correct, supplier specified, compatible components. Any site application that deviates from the fire test, especially those involving the installation of larger panes, must to be re-tested or assessed by an industry recognised competent person. The most common fire resistant glass provides ‘integrity’ but no significant level of ‘insulation’ protection and may not be suitable, for example, to protect a refuge area. Security or safety glass cannot be expected to provide any tested fire performance unless expressly stated.
Fire Resisting Doors:
Research carried out by the British Woodworking Federation and others would suggest that more than 80% of fire doors in the UK will not achieve the fire rating to which they were tested due to poor procurement, installation, inspection, maintenance and management standards. Whether they are assembled on site, where all or several items (door leaf or blank, frame, glazing, hinges and other hardware) are sourced separately or procured as a fire ‘door set’, where everything has been pre-assembled or supplied from one source, a large percentage of doors fail to deliver their intended fire performance and are then maintained in a permanent state of non-compliance thereafter.
Fire stopping and linear gap sealing:
When fire stopping around services a number of factors must be considered including the required level of fire resistance, what services are contained within the aperture, how the fabric of the building will react in a fire, load bearing or impact resistance requirements, thermal movement or other ambient conditions and acoustic or other non-fire factors. Issues are particularly prevalent where different subcontract components meet and no one has been made responsible, and nothing designed, for the interface detail. Robust QA standards are required to ensure products are only be installed as fire tested and systems are not be mixed and matched, especially due to the introduction of additional services which necessitate repairs during the construction and fit-out phases.
Building voids need to be effectively separated at determined locations with cavity barriers to limit the unseen spread of fire and smoke. Barriers for fire and smoke should provide at least 30 minutes fire resistance including insulation and integrity; those just for smoke require integrity only. They must be installed to the manufacturer’s fire tested detail to ensure that thermal movement and other factors, will not compromise effectiveness. Cavity barriers may also be required to provide acoustic barriers and / or air seals.
Ducts and dampers:
In some situations, particularly in escape routes, there can be a requirement to fire rate ductwork to prevent fire from breaking out of or entering ducts in order to maintain required fire integrity or resistance. Dampers should be fixed either within or directly adjacent to fire barriers and be robustly supported, independently of the connecting ductwork, so that in a fire situation they will not distort or collapse but remain as an integral part of the barrier. Adjoining ductwork should also be supported as specified. Where ducts and dampers penetrate drywalls they must be framed with the studwork, lined with plasterboard and effectively sealed as per the board manufacturer’s detail. Fire damper expansion frames may be required when cast into mortar and other substrates. All dampers must be accessible for future maintenance.
Has a plethora of issues including; PVC pipes, that will require an external intumescent ‘collar’ or an internal intumescent ‘wrap’ to plug the void left between the pipe and the structure being breached in a fire situation when the pipe will melt away. A collar need mechanical fixings that have the same rating as the correct rating for the collar. For pipes running up the building collars are normally required to be fitted to the underside; pipe breaching walls require collars fitted to both sides of the wall. Intumescent collars are a commodity product and care should be taken in establishing source and test data to ensure they are proven to meet the required fire capability. With insulated pipes, pipe insulation is typically low density and not fire-tested. Insulation that breaches fire barriers must be wrapped with a pipe sleeve at the fire line of the compartmentation or otherwise have a solution that provides evidence of performance.
Electrical and data cables:
Are often run and installed throughout buildings in densities that cannot be effectively fire sealed. The use of fire tested transit sleeves, pre-installed to cater for such runs, should be seriously considered at the design stage. BS 5839 precludes the use of plastic tie clips, cable ties or trunking where these products are the sole means of cable support. Electrical trunking boxes almost invariably have no external fire rating and should be internally fire stopped with a tested solution.
Fire curtains and shutters:
Care must be taken in ensuring that what is specified and installed provides the fire resistance required; for example if intended to create a 30 minute escape route then fire curtains must possess 30 minute insulation from excessive heat together with hot and cold smoke protection and not just fire integrity. Fire Shutters provide a similar function and are often used to provide 120min fire separation. Both products should only be installed and maintained by 3rd Party accredited installers.