The Department for Levelling Up, Housing & Communities (DLUHC) has published a consultation on proposed amendments to Building Regulations – Approved Document B in England. The consultation seeks views on options in a number of areas but one which will be of most relevance to GAI members is the proposal to remove the national classification system for construction products (BS 476 series) and require all relevant construction products to be tested to the British Standard version of the European Standard.
The rationale from DLUHC for the proposed change is that during the Grenfell Tower Inquiry, the use of the national classification standards for reaction to fire and fire resistance in Approved Document B came under scrutiny, and potential flaws in its use were identified. Also the BS 476 series standards have not been reviewed by the British Standards Institution in detail for some time (over 20 years on average), whereas the European equivalents continue to be updated on a regular basis.
Fire doors have been identified as one of a subset of products which will be greatly impacted by this change and a 12 month transition period has been proposed to allow changes to the new regime to be implemented.
GAI members should note that a change from the current national classification to the European classification system as suggested by the consultation would have major repercussions on the ironmongery and fire door industries and how they operate. It could have the potential repercussion of driving the timber fire door market to a similar model to that of the steel door market whereby fire doorsets under EN 1634 would be the norm rather than timber door assemblies under BS 476 22.
It would also have an impact on:
- Product choice of ironmongery on Fire Doors as EN 1634 standards have much narrower parameters on interchangeability of hardware on fire doors
- Retesting Costs to Industry - A huge amount of test evidence for fire doors is in existence under BS 476 22, rather than the EN 1634 equivalents
- Capacity of Supply of Fire Doors as the vast bulk of internal timber fire doors supplied in UK are tested via BS 476 22
- Impact on Existing Fire Test Assessments to BS 476 22
The consultation can be found HERE and members should refer to section 3 “Removal of national classifications” paragraphs 36 to 46, with fire doors being specifically referred to in paragraphs 43 to 46.
Relevant consultation questions will be questions 13 to 18 inclusive.
In addition, there is a section in the consultation on “Design for sprinkler provision”. This picks up on how and where sprinklers are provided for larger protected areas with more than 10 beds and more than one bed per bedroom where fire doors do not require self-closing devices. The Government is interested in receiving evidence and views on whether allowances such as these should be retained or extended.
Relevant consultation questions will be questions 7 and 8. These should be responded to in respect of whether you feel that self-closing devices should be required on all bedroom doors in care homes and provide reasons and evidence as to why.
Please see link to a GAI survey HERE which contains all these questions and which we have set up to allow you to easily feed your thoughts through to us to allow us to collate these and provide a collective industry response, however we also need industry to respond separately and directly to ensure your voice is heard.
GAI SURVEY - TAKE PART >>
Examples of issues which could be factored in within your response relating to BS 476 are as follows:
- What would the impact be on your business in respect of retesting costs?
- Will your product still need to be tested in UK or will you instead be testing in Europe?
- Will this have a significant impact on your turnover or business model?
- What evidence you can provide if you feel that a transition period of 12 months is insufficient?
- Could this have an impact on the amount of people employed within your business?
In order to assist members with further background GAI will be hosting a live webinar and Q and A session on this topic which will be hosted by GAI Technical Manager Douglas Masterson. Date and timings on this webinar will be announced in due course.
Any questions anyone has in advance can be emailed to [email protected]
GAI Chief Executive Simon Forrester said “This potential change to Approved Document B would have massive repercussions on the ironmongery industry, therefore we need to ensure our members’ voices are clearly heard and would urge all of our members affected to respond to this consultation.”
Please bear in mind that this consultation is purely related to England and that the consultation closes at 11:45 pm on 17 March 2023. Please note that you may wish to wait and take part in the live webinar and Q&A session before responding. We would request that members respond to our survey by 28th February to allow time to collate all responses.