We’ve received the following questions from NSW lot owners about apartment fire regulations specifically concerning fire doors and the installation of security and screen doors.
Table of Contents:
- QUESTION: What are the rules about individual unit fire doors where they open to the outside, next to a landing?
- QUESTION: I have security grills in place on my bedroom windows which could not be removed during an emergency. Are there apartment fire regulations to have a quick release system installed to allow for quick exit if needed?
- QUESTION: Is there any requirement to have door closers fitted where the front door of a unit opens to the outside rather than into internal common property where a fire could spread to neighbouring units?
- QUESTION: Our building was built in the 1970s and met all code requirements of the day. Do we need to meet current fire and building codes?
- QUESTION: The magnetic door holder on the front door of an apartment does not comply with the fire code. Why is this and when did the ruling come into effect? It has been installed for 20 years and has never been an issue.
- QUESTION: We need to shave a little off the bottom of our entry fire door to install new floorboards. Is strata responsible for modifying or replacing the fire door, since the front fire door is common property?
- QUESTION: Our 60 year old building is under a fire order. The upgrade requirements appear to comply with a standard for a new building. Does the Fire & Safety Legislation take a more common sense approach to safety in older buildings?
- QUESTION: A chain lock has been on my entry door since I bought the unit 12 years ago. The fire company says that this is apartment fire regulations and my door has to be replaced. Is this true?
- QUESTION: Does the door from the only staircase in our 4 story building to the roof verandah require a fire rating? The verandah is completely outside.
- QUESTION: Our Strata committee is considering a request to decorate the apartment building entry foyer. Are there any specific fire regulations or restrictions we may need to be aware of before proceeding?
- QUESTION: Should the fire doors leading from each hallway into the fire escape stairwell be locked on the fire stairwell side? We have security concerns.
- QUESTION: I’ve been told that a door seal cannot be fitted to the door frame and door on my apartment due to apartment fire safety regulations. Is this correct?
- QUESTION: Can Lot Owners install screen doors to their units and what requirements for apartment fire regulations need to be considered before installation?
- QUESTION: I want to install a security door to replace a screen door facing into an open courtyard. Our strata manager says Fire Regulations may deny us having security doors on our units.
- QUESTION: We wish to install a doggie door in a small floor level window. Is there any mention of doggie doors in the Australian Fire Standards relating to apartment fire regulations?
- QUESTION: What are the rules on fitting a security door to the front entrance door of a unit? Does this breach apartment fire regulations?
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Question: What are the rules about individual unit fire doors where they open to the outside, next to a landing?
What are the rules about individual unit doors where they open to the outside, next to a landing? The stairs are used as access for the unit above. We have a solid core door that has been passed by fire inspection. I am trying to figure out what locks we can and can’t have to comply with fire regulations.
I imagine it may have to comply with fire mitigation door regs.
Answer: If you have solid-core doors that are a Statutory Fire Safety Measure (is listed on your AFSS), then these doors need to be self-closing.
There are many unknowns with the scenario that will mean I can’t provide a definitive answer. However, if you have solid-core doors that are a Statutory Fire Safety Measure (is listed on your AFSS), then these doors need to be self-closing. This means the doors must have a self-closing device (door closer), and mustn’t have any hardware that would prohibit the door from fully closing. This would include:
- deadlocks,
- chains,
- hold-open devices,
- wedges, etc.
If your doors are not listed as a Statutory Fire Safety Measure, then there are no requirements about the hardware.
I recommend asking your Accredited Practitioner (Fire Safety) for advice as to whether the above requirements relate to your doors.
Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109
This post appears in Strata News #452.
Question: I have security grills in place on my bedroom windows which could not be removed during an emergency. Are there fire regulations to have a quick release system installed to allow for quick exit if needed?
I am the owner of a NSW ground floor strata apartment which is being rented. There are strata security grills in place on my bedroom windows but they are extremely difficult to remove and certainly cannot be done in case of emergency (fire).
I would like to know if there are a legal requirement or fire regulations to have a quick release system installed to allow for quick exit in the event of an emergency. If there is a legal requirement does the responsibility fall on me, the owner or the strata corporation?
Answer: These Security grills should meet Australian Standard AS5039 of which having keyless emergency egress is highly recommended.
The security grilles have at some point been installed for the security of residents on the ground floor either by the lot owner or the owners corporation. These Security grills should meet Australian Standard AS5039 of which having keyless emergency egress is highly recommended.
Best practice would see these security bars fitted with a quick release system or easily accessible key opening. This is recommended in the Australian Standard but is not a legislative requirement under building codes or fire and emergency planning.
Windows in a bedroom are not considered a path of travel or a required exit under the BCA (Now NCC Sec D1.2) therefore there are no requirements for windows to provide an ease of access in the event of an emergency.
Under Australian Standard 3745-2010 (Planning for Emergencies in Facilities) Owners Corporations, with the exception of townhouses and standalone houses, is to have direct access to an emergency exit or to a passageway leading to at least two different emergency exits.
The building must ensure that all Fire Safety Installations approved at time of construction (and those fitted after) including fire doors are maintained in accordance with Australian Standard 1851.
Solutions in Engineering
E: [email protected]
P: 1300 136 036
This post appears in Strata News #443.
Question: Is there any requirement to have door closers fitted where the front door of a unit opens to the outside rather than into internal common property where a fire could spread to neighbouring units?
During a recent fire compliance audit, we received a corrective action report indicating that all of our solid core doors now require door closers to be fitted. This has never been reported as a defect until this year. On the report, the defect is described as a ‘non-critical defect’.
I can understand the requirement for door closers to be installed on doors that open into a stairwell / enclosed common property. However, all of the doors in our complex open to the outside, mostly to private courtyards or pathway. We were provided with an extract only from the Australian Standards that refer to fire-resistant door sets, but there is no context supplied regarding internal ‘front doors’ vs external doors. There is no mention of the external facing sliding doors which every unit has, nor did the report mention the rear doors that some units have.
Is there any requirement to have door closers fitted where the front door of a unit opens to the outside rather than into internal common property where a fire could spread to neighbouring units?
Answer: There are no Australian Standards that cover solid-core doors, only fire doors.
If the doors open directly outside, they are unlikely to be fire-rated doors or solid-core doors. There are circumstances when they are required (i.e. proximity to the boundary) and therefore I can’t comment unless I go to the building.
Additionally, there are no Australian Standards that cover solid-core doors, only fire doors.
I would recommend the Owners engage another Company that can provide more accurate information.
Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109
This post appears in Strata News #413.
Question: Our building was built in the 1970s and met all code requirements of the day. Do we need to meet current fire and building codes?
Our Strata is currently investigating fire safety upgrades to meet current fire and building code. Our building, 3 levels including ground which is not habitable, was built in the 1970s or so and met all code requirements of the day. Is this update necessary?
Answer: As the building was built in the 70’s it would come under Ord70. This was the Standard that was adhered to at that time.
As the building was built in the 70’s it would come under Ord70. This was the Standard that was adhered to at that time.
This would mean that all compliance would remain as per the implemented design of the fire systems at that time.
Unless there has been a DA Application put in and accepted and the works have been done, then the systems would need to be bought up to the current Australian Standard and BCA regulations.
Chris Chatham
Linkfire
P: 0476 233 109
E: [email protected]
This post appears in Strata News #413.
Question: The magnetic door holder on the front door of an apartment does not comply with the fire code. Why is this and when did the ruling come into effect? It has been installed for 20 years and has never been an issue.
After the last yearly fire inspection was done it was brought to our attention that the magnetic door holder/wall stopper on the front door of the apartment does not comply with the fire code. It is used to keep the door open so the elderly owner can bring in shopping.
Why is this is? When did this ruling come into effect as she has been in this unit for almost 20 years and it has never been an issue until now?
Answer: Fire Doors have always required to be self-closing and anything stopping the door from closing is defective.
The door in question is required to be a self-closing fire rated door. As there is a device holding the door open (and not allowing it to close) this means the fire door is defective. There is a solution available in this scenario which allows an ‘automatic-closing device’ to be installed to the door. This device is activated by the smoke detectors (and sprinkler system) and releases the door from the open position allowing the door to close.
Fire Doors have always required to be self-closing and anything stopping the door from closing is defective.
The standard which references this is Clause C3.11 of the BCA. Shown below.
- A door required by (0) may be automatic-closing In accordance with the following:
- The automatic-closing operation must be initiated by the activation of a smoke detector, or any other detector deemed suitable in accordance with AS 1670.1 if smoke detectors are unsuitable in the atmosphere, installed In accordance with the relevant provisions of AS 1670.1 and located not more than 1.5 m horizontal distance from the approach side of the doorway.
- Where any other required suitable fire alarm system, including a sprinkler system (other than a FPAA101D system) complying with Specification E1.5, is installed in the building, activation of the system must also initiate the automatic-closing operation.
Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109
This post appears in Strata News #407.
Question: We need to shave a little off the bottom of our entry fire door to install new floorboards. Is strata responsible for modifying or replacing the fire door, since the front fire door is common property?
I am installing floorboards in my apartment which will raise the existing floor levels, consequently, I may need to sand a few millimetres off the bottom of the entry fire door into my unit to ensure the door opens smoothly.
Is strata responsible for modifying or replacing the fire door, keeping in mind the front fire door is common property.
Answer: The Owners Corporation is not responsible to modify the front door to accommodate your renovation works.
We confirm that you are correct. The fire door is common property, however, the Owners Corporation is not responsible to modify the front door to accommodate your renovation works.
Further, you are obliged to preserve the fire safety of the building, so you should check whether the “shortened” door might compromise fire safety/meets BCA requirements.
Also, please ensure you have the proper authorisations of the Owners Corporation before you commence installation of your flooring.
Leanne Habib
Premium Strata
P: 02 9281 6440
E: [email protected]
You can connect with Leanne & Premium Strata on Facebook, Twitter & LinkedIn.
This post appears in Strata News #385.
Question: Our 60 year old building is under a fire order. The upgrade requirements appear to comply with a standard for a new building. Does the Fire & Safety Legislation take a more common sense approach to safety in older buildings?
I am the building manager of a 60-year-old, 28 unit residential block in Manly NSW.
We are under a fire order. The upgrade requirements appear to comply with a standard for a new building.
Is there a Fire & Safety Legislation that takes a more common sense approach to safety in these older buildings? Can you provide some examples of items on a Fire Order for older buildings that can normally be challenged? The building is well maintained. We have a fire company doing regular inspections & reports.
An example on the fire order; we have been asked to replace the fire doors in the internal fire stairs. The handles don’t comply. The handles are a push-down lever-type but don’t have a curve on the end that helps prevent the hand sliding off the handle.
Answer: A Fire Order does allow for a bit of flexibility and we are able to negotiate with Council on some items.
Yes, a Fire Order does allow for a bit of flexibility and we are able to negotiate with Council on some items.
The examples vary significantly and each building has different characteristics that will need to be determined to present an argument to Council./p>
Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109
This post appears in Strata News #380.
Question: A chain lock has been on my entry door since I bought the unit 12 years ago. The fire company says that this is apartment fire regulations and my door has to be replaced. Is this true?
Answer: No additions to or adjustments are allowed to be made to a fire rated door.
Based on the information supplied I assume your unit door is a “fire rated door”.
To check, there will be a Tag on the inside spine of the door. If the tag has been painted over, it should still be obvious to the hand when you touch it.
If it is a fire rated door then technically your fire company/contractor is correct in that no additions to or adjustments are allowed to be made to a fire rated door. This is so the integrity of the door is not breached and that it can still perform its intended function of stopping a fire spreading either out of or into your unit.
Other items that would negate the effectiveness of the fire rated door include peep holes or a door closer being fitted.
Peter Berney
National Business Development Manager
Solutions in Engineering
T: 1300 136 036
E: [email protected]
This post appears in Strata News #378.
Question: Does the door from the only staircase in our 4 story building to the roof verandah require a fire rating? The verandah is completely outside.
My building is fixing its rooftop verandah at the top of a 4 story building (3 stories of units and ground-level parking).
I was wondering if the door from the only staircase in the building to the roof verandah must have a fire rating? What are the fire regulations when the verandah is completely outside.
Answer: The construction is unlikely to be required to be fire rated – except lower down where it bounds a unit.
This is a challenging one to answer as there are a LOT of variables applicable: age, defined height, construction type of the roof & stair, distance to property boundary, fire order or fire engineering report conditions and fire-source-features on roof level.
As it is 3-4 storey building with a single stair, we would assume it to be defined as a non-fire-isolated stair, not a ‘fire stair’ as you would find in a taller building.
As it is not technically a fire stair, the construction is unlikely to be required to be fire rated – except lower down where it bounds a unit.
Providing that the door does not open closer than 1.5m to the boundary of the property and there are no fire source features within 1.5 metres of the door itself, it seems unlikely that this door is required to be a fire door.
Happy to answer more accurately if more information about the situation were provided.
This post appears in Strata News #376.
Rob Broadhead
2020 Fire Protection
P: 1300 340 210
E: [email protected]
Question: Our Strata committee is considering a request to decorate the apartment building entry foyer. Are there any specific fire regulations or restrictions we may need to be aware of before proceeding?
I live in a new apartment building with 7 floors and 30 lots in NSW.
A suggestion has been forwarded to our building Strata committee to decorate the building entry foyer. Suggestions include wallpaper, hanging pictures, adding furniture items, etc.
The foyer has entry doors from 2 fire exit stairwells, bike storage, garage access doors, a fire control panel, a powder room access, along with the Main Street entry door.
Are you able to advise any specific regulations or restrictions we may need to be aware of before proceeding with this proposed aesthetic improvement?
Answer: Points to consider are the “Paths of Travel to Exits” regulations from BCA D16.
Points to consider are the “Paths of Travel to Exits” regulations from BCA D16.
Paths of Travel to Exits are to provide an unobstructed pathway for occupants travelling to an Exit.
To provide a passage to an exit that is of a width and height as specified by the Building Code of Australia.
To ensure that Paths of Travel to Exits are operational and effective, they must not be obstructed or altered in any way.
It is the responsibility of the owner to ensure that Paths of Travel to Exits are maintained in and efficient condition and kept functional at all times.
So what does this mean.
It is allowable to have pictures, plants and minimal furniture in the foyer area, it must not impede on the travel paths to exits.
Consideration must also be given to access to the Fire Indication Panel as this is a Critical Measure within the building, this must not be obstructed in any way.
Consideration must also be given to Wheelchair access.
Chris Chatham
Linkfire
P: 0476 233 109
E: [email protected]
This post appears in Strata News #369.
Question: Should the fire doors leading from each hallway into the fire escape stairwell be locked on the fire stairwell side? We have security concerns.
Our strata complex is 74 lots over 9 floors.
Should the fire doors leading from each hallway into the fire escape stairwell be locked or unlocked on the fire stairwell side? There are differences of opinions due to security concerns.
Locking the fire doors would mean that a person cannot gain access to each level of the building by simply walking up the fire stairwell and into the common areas.
Answer: If the building is over 25m in effective height, there are conditions.
If the building is over 25m in effective height, which a 9 storey building would be (3m per floor x 9 = 27m) then there are conditions. Refer to the below screenshot of Clause D2.22 of the BCA2019, which provides some exemptions.
D2.22 Re-entry from fire-isolated exits
- Doors of a fire-isolated exit must not be locked from the inside as follows:
- In a Class 9a health-care building.
- In a Class 9c building.
- In a fire-isolated exit serving any storey above an effective height of 25 m, throughout the exit.
- The requirements of Open link in same page(a) do not apply to a door fitted with a fail-safe device that automatically unlocks the door upon the activation of a fire alarm and—
- on at least every fourth storey, the doors are not able to be locked and a sign is fixed on such doors stating that re-entry is available; or
- an intercommunication system, or an audible or visual alarm system, operated from within the enclosure is provided near the doors and a sign is fixed adjacent to such doors explaining its purpose and method of operation.
All doors leading to the fire stairs needs to be always openable.
Clause D2.22 relates to the doors from inside the fire-isolated stairs to the common area. The purpose of having the doors unlocked is if people cannot travel the whole way down the stairs, they are able to go into the common areas.
Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109
This post appears in Strata News #360.
Question: I’ve been told that a door seal cannot be fitted to the door frame and door on my apartment due to apartment fire safety regulations. Is this correct?
I live in a unit established in 2020. The front door and door frame are missing proper rubber and sound/air proof sealing. The gap underneath the door is significant.
A building company has inspected the issue and said a seal cannot be installed to the door frame and the door due to apartment fire safety regulations. I’ve previously lived in an apartment where the was developed in 2015 and both the door and frame were sealed! This stopped all sound coming from the lift lobby/corridor. Can someone advise please?
Answer: Smoke seals could be installed to the door if they have an adhesive backing.
Smoke seals could be installed to the door if they have an adhesive backing (no screwing into the door or frame). Just make sure the installation of the smoke seals still allow the door to fully close correctly.
The gap under the door should be no greater than 10mm.
Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109
This post appears in Strata News #352.
Question: Can Lot Owners install screen doors to their units and what requirements for apartment fire regulations need to be considered before installation?
Our fire inspection services company has decided the screen doors on the front doors of units don’t comply with apartment fire regulations. They have stated this is because when the screen doors are open, they restrict egress from units and stairs.
The screen doors were installed over 10 years ago. What legislation does this come under as my Lot Owners are not happy.
Answer: If the screen doors reduce the width of the path of travel to less than 1m, this would be a building defect.
-
What type of screen door (if any)?
Fire and Rescue New South Wales (FRNSW) released a guideline in 2010 Guide Sheet No. 7: Security in Apartment Complexes relating to screen
doors. The recommendations in this paper are as follows:It is recommended against the fitting of security doors and security screen doors. Where occupants desire
additional security, FRNSW recommends the following:- The screen door must not be fitted with any special locking device that will render the door difficult to open by FRNSW and other emergency service personnel;
- The screen door must not compromise the integrity of the SOU’s fire rated door, including the door jamb (question 2 below);
- The screen door must be fitted in a manner which will not impact on safe entry/egress for the occupants (question 3 below);
- Each screen door must be fitted with a self-closing device to ensure the door always returns to a closed position and cannot be held open.
-
How is the screen door installed?
Typically screen doors are fixed to the door frame on both sides (hinge side requires fixing and the door
strike requires a latch). Fire rated doors include the door frame and there are specific requirements about
the frame construction. Unfortunately, there are no test results with screens attached to the frame and
therefore to attach the screens to the fire rated frames would result in the fire rated door being defective
under AS1905.1-2015.A solution that may be acceptable would be to fix the screen around the frame to the wall. This typically
requires approval from the Building Owners as it changes the appearance of the building. Your Strata
Manager will advise further. -
Does this screen door impede on egress?
Clause D1.6 of the NCC2016 relates to dimensions of exits and paths of travel to exits. The common areas of buildings are classified as a path of travel. For residential buildings, the path of travel to an exit must not be less than 1m.
If the screen doors reduce the width of the path of travel to less than 1m, this would be a building defect.
-
Other concerns
A typical concern with the installation of screen doors is that it increases the chances that the fire doors
are propped open using a wedge-like device and therefore not allowing the door to close. This is not a
building defect but it is an issue that should be discussed if screens are installed.
NB: This document only relates to the building requirements.
Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109
This post appears in Strata News #347.
Question: I want to install a security door to replace a screen door facing into an open courtyard. Our strata manager says Fire Regulations may deny us having security doors on our units.
Answer: If you are replacing an existing screen door, it would indicate there are no issues with this location.
It sounds like the screen door opens directly outside, which could mean there is no requirement for Fire Doors or the screen door would fall in the path of egress.
Additionally, if you are replacing an existing screen door, that would also indicate there are no issues with this location.
Without going to the building, I can’t be certain, however, it doesn’t appear to be any issues on the installation of a screen door to a door leading directly outside.
Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109
This post appears in Strata News #299.
Question: We wish to install a doggie door in a small floor level window. Is there any mention of doggie doors in the Australian Fire Standards relating to apartment fire regulations?
She has been given starts approval on the basis that it doesn’t breach any Australian Fire Standards.
I think they are worried that they may not comply with the standards if a number of upper level apartments were to be given the same approval.
Is there any mention of doggie doors in the Australian Fire Standards relating to apartment fire regulations?
Answer: We would need to outline the location of the doggie door.
In order to answer this, they will need to outline the location of the doggie door.
If the doggie door was leading directly outside, this may be ok, however, some issues may arise.
However, if the location was internal and the doggie door was to be installed in a wall that separates the unit from the common areas, these walls are required to be fire-rated and therefore the location of the doggie door is not permitted.
I would recommend discussing the location with a Building Consultant so the Owners can be confident that any installation complies.
This post appears in Strata News #282.
Vincent Graham
Project Guides
E: [email protected]projectguides.com.au
P: 0476 233 109
These articles are not intended to be personal advice and you should not rely on it as a substitute for any form of advice.
Question: What are the rules on fitting a security door to the front entrance door of a unit? Does this breach apartment fire regulations?
What are the rules on fitting a security door to the entrance door of a unit? Does this breach apartment fire regulations?
A while ago in our NSW strata building, another owner and I got permission to fit security mesh doors to our balconies. However, the other lot owner also had one fitted to their entrance door which was not part of the permission.
The fire safety inspector objected but somehow this owner (who happens to be on the committee) and the Strata Manager, buried the issue. That Strata Manager has now left. My query is whether that’s legitimate in NSW?
In case of a fire, doesn’t that hamper firefighters entering the unit? Will that affect the insurance of the building in any way?
Answer: The NSW Fire Brigade recommend against security doors being fitted and for good reason as they would hamper the fire and rescue services.
However in saying that and with the EP&A Regs 2000 Division 7 in mind, I do not know of any specific regulation that states unit security doors are not to be installed and I do not know if this would affect the building insurance but if this was my scheme that is the first question I’d be asking the insurers before fitting any door in front of a fire door.
Please see this FactSheet from NSW Fire and Rescue: Safe living in high rise buildings:
“The front door of your apartment should be a certified fire resistant door. Making alterations to the front door can make it unsafe in the event of a fire. Check with your building management before making alterations.”
This post appears in Strata News #173.
Peter Berney
National Business Development Manager
Solutions in Engineering
T: 1300 136 036
E: [email protected]
This article is not intended to be personal advice and you should not rely on it as a substitute for any form of advice.
Have a question or something to add to the article? Leave a comment below.
Read next:
- NSW: Annual Fire Safety Statements: What Are They Good For? Sometimes, Absolutely Nothing!
- QLD: Q&A Fire Audit and Fire Door Compliance
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Notwithstanding all this talk of whether security screens can or cannot be fitted to fire doorsets it has been settled by a Fire Certifier.. Screens can be fitted. Notwithstanding the building was constructed in 1974 and is in Queensland the determining factor on the fitting of screens is not determined by state legislation but by Australian Standards., and these standards apply nation wide. Hence, as a screen has been deemed ok for Qld they must be ok for all states.. And to add insult to all these writings the screen is screwed into a tagged fire door frame, has a keyed lock and has no self closer. The fire doorset gained a certificate notwithstanding all these assumed defects!
Hi, I live in a unit established in 2020. The front door fame is missing proper rubber, sound/air proof sealing. So does the door and the gap under is significant. I raised the issue with the agency (it is a rental property) and they have sent a building company representative to look into defects listed. He said that seal cannot be installed to the door frame and the door due to fire safety regulations. Previously i lived in a new building developed in 2015 and both the door and frame were sealed! I loved it as there was absolutely no sound coming from the lift lobby/corridor. Can someone advise please?
Hi Arthur
We have responded to this question in the article above.
Hi Vince, Theodore, & all,
In NSW the EP&A Regs require that all essential services are maintained such that performance is not degraded to less than that specified in the installation standard. The age of the building is irrelevant to that requirement, so these doors need to be assessed and serviced. Whilst a number of other States (QLD, SA, VIC) nominate the current maintenance standards (AS1851-2012, AS2293.2-1995, etc. NSW simply requires maintenance to provide minimum performance and in many cases this is actually more onerous than that of the maintenance standards.
1. every building should comply with the codes and standards in effect at the time of built/completion date. (there are some exceptions of course, like accessibility codes, … )
2. otherwise not a single building would ever get compliant!!
3. having said that if you modify, renovate, change, … anything, you must comply with the current codes and standards.
4. your best friend is a building certifier , private certifier whom will check, survey, your building and recommend any non compliant issues and upgrades necessary
5. seeking a second opinion always helps as in my experience certifiers tend to “translate” codes and standards differently
In NSW the pre-BCA constructed buildings were covered under Ordinance 70 and the BCA Part D requirements were simply an evolution of this. SDU entry from corridors has always forbidden screen doors for such SDU’s in NSW and there is no legislation in NSW calling for the application of AS1851. The legislation instead, requires maintenance to ensure that the performance of those particular services identified in the fire safety schedule, perform at not less than the performance requirements required by the original code and standards. This can sometimes be more onerous than AS1851-2012, but AS1851 is viewed as MINIMUM best practice.
For older SDU’s having solid core doors, these are usually cedar in the older units and they actually perform quite well in a fire test with FRL -/30/30.
The Local Council Building Fire Surveyor can issue a fire upgrade on any building where they have cause to believe that the building is deficient and this is usually triggered by a concern raised by an occupant or visitor, or after a NSWFR response.
Any owners corporation who endorses a lot owner to add inappropriate hardware to any SDU are taking upon the committee, responsibility for any non-compliance. In NSW the penalty for non-compliance is 300 penalty units / incident which is currently about $13,000 and this cost would be in addition to correction costs. So something to think about.
Hi Theodore,
It may have been a fire door, however, given the age of the door and the fact it isn’t tagged, there will be no way to determine if it is a fire door (other than to test it which will damage the door) and therefore if you want it certified, it will need to be replaced.
Additionally, the door of this age will likely have an asbestos core, so it might be best to have it removed if it is dilapidated.
Regarding whether you need to replace it, this comes down to the AFSS requirements in the EPA Regs. As the building was built in 1974, you may have no requirement to issue an AFSS so there may be no requirement to maintain the ‘Essential Services’ in your building. This isn’t to say that you shouldn’t.
If you have a Fire Safety Schedule and are issuing an AFSS, then yes you will need to maintain Fire Doors.
I would recommend seeking assistance by a Building Surveyor to provide site specific information that you can use to plan any works.
If your building is in Sydney, let me know and I can help out.
Cheers
Vince
Hi Ian,
Some correct points, however some incorrect points made above. Clause D2.21 doesn’t relate to SOU doors – this is for doors in the path of egress, which doesn’t include SOU doors.
SDU I think you mean SOU (sole occupancy unit)?
Other than that, yes always get approval for any changes to your SOU Fire Door.
Our building apartment was built in 1974. there are no fire rated tags on the spine of the entrance doors or garage internal doors. Does this mean these doors are not fire rated. do we need to upgrade to fire rated doors or are we exempt due to its age.
I would suggest that the advice above is somewhat deficient and the adviser appears to have limited understanding of the regulations.
Just to put a few things in perspective. The door to your apartment (SDU) is not yours but is common property as are your balcony doors and windows etc..
You cannot add any hardware or fitments without approval of the owners corp (additional lock, fitting a door chain, removal of door closer, etc).
If your door opens onto any passage used for emergency exit (common corridor or passage) – you must not prop it or chock it open nor inhibit the door from closing in any way (such as stop the closer operation) as this would allow breach of fire compartmentation. You cannot add any other door to the entry door portal as this would not allow the required single handed, single action exit through that door (BCA D2.21). If you do do these things then you are in breach of the Environmental Planning & Assessment Regulations Div.7 which carries significant penalties (of currently $13k/incident).
If we see evidence of screen doors or dead/barrelbolt multiple locksets, we cannot (nor can any CFSP) endorse for the AFSS.
I would suggest that any exit door which can be keylocked from the inside, should always retain the key when the room/apartment is occupied. If there is a fire or emergency, you don’t want to have to search for a key.
Hi Nikki
My question was more in relation to what are the fire safety requirements on a building that was built in the early 1970’s, in terms of unit doors, fire extinguishers , smoke alarms etc?. What are the legal requirements for an Owners Corporation? Or is this still a grey area?
Thanks
Nick
Hi Nick
The following reply from Peter Berney:
This issue is that in 1970 the requirements were very much driven by the local council rather than any form or national regulation. The owners best stop initially is the local council as any improvement system is still driven by the local council.
Our building was built in the early 1970’s and we are a self-managed Strata Corporation, as such we have tried to engaged the services of a ”Fire safety Company”, who could not advise specifically what we needed or did not need to be compliant to the NSW Environmental Planning & Assessment Regulation 2000 Part 9, regarding the initial Fire Safety Installation Certificate and the Annual Fire Safety Certificate each year after.
I was advised by them to call my local Council to get further information about our building fire safety requirements. The council had no information on this whatsoever and advised they had no staff that specifically looked after this area (Fire Safety). They then referred me to another website.
The questions remain is do we as a Strata Corporation have to do something or not regarding the initial Fire Safety Installation Certificate & Annual Fire Safety Certificate given our building was built in the early 1970’s? and if so what are the scope of works required?
Thanks
Nick
Hi Nick,
We have received the following response from Peter Berney, Solutions in Engineering:
Firstly there is no simple short answer to this question, and I hope to not bore too many with this response.
When looking at screen doors the strata needs to consider the need or desire for them and if there are not better ways to achieve the same result. This decision ideally should be made in advance of an owner making a request as this will ensure uniformity through the building.
Most owners will want screen doors for either improved airflow or improved security or both.
When considering this the strata needs to take into account the following issues both positive and negative.
· If the unit entry door is fire rated the strata must consult with their fire door maintenance company. The reason for this will be evident from the point below.
· The overall ‘look’ of the property if screen doors are installed particularly if some owners have them installed and some don’t. Consider that the Strata may need to specify the type and colour of the door to gain some uniformity.
· Who is paying for the door and any ongoing maintenance considering it is being installed on common property but is for the sole benefit of a single unit?
· Safety to others in the building having due regard for the width and shape of the corridor or walkway at all unit entries, not just the unit making the request. Can others pass safety past this door if it is left open particularly in the event of an emergency? Remember that at least some screen door closers can be set to hold open, others could fail and not self-close or the closer not be installed or be removed. As the door is fitted to the outside on the door frame the handle will protrude into the corridor and may cause a safety issue even if the door is correctly closed.
· Emergency services may have increased difficulty accessing the unit in the event of an emergency.
· Noise both from the door opening and closing and noise radiating onto the common property if the entry door is held open.
· Cooking odours, or smoke from cooking radiating onto common property affecting the comfort of others or triggering common property smoke detection equipment. Depending upon the fire detection equipment installed at the building it could result in unnecessary brigade callouts, and increased costs for owners, occupiers and Strata.
· If the door is needed for security, is it a type that offers better security than the existing entry door? Generally better security comes at a higher cost.
· Can the existing door be fitted with an additional lock to improve its security? In this the Strata will need to consider if the existing entry door contains Asbestos, and that the correct type of lock is fitted by the correctly licensed tradesperson if the door is fire rated.
· Can the Strata reasonably improve security into the building or site so that all occupiers receive the benefit over the entire building?
· If the door is fire rated having a screen door is an inducement to wedge or hold open the fire door. If this occurs an offence has been committed, and should a fire start in the area smoke, heat or fire could spread through this doorway. Fire doors can only be held open with an approved device which will not be possible in some buildings and will come at a high cost in one where it is possible.
· If the door is fire rated so is the door frame. Penetrating the frame for hinges and locks, adding door jams or seals, etc has the potential to affect the certification of the opening and may make it non-compliant.
· If the frame is fire rated only correctly licensed tradespersons can do alterations. The Strata must ensure that the tradesperson is correctly licensed and insured to work on fire rated installations.
From this most will have gathered that it is a difficult if not impossible process and in most cases, this is so. However, it may well be feasible and beneficial in some strata particularly low rise townhouse developments where most doors are not fire rated and the unit opens directly onto an open space.
Are all units required to have a fire door? our block is a 1960’s and only have ordinary wood doors that actually do not fit correctly, our body corp[orate are very loath to spend any money on anything if they can avoid it. Is the fire door the owners or strata’s responsibility?
Hi Beverley
Thanks for the question. We have received the following comment back from Peter Berney, Solutions In Engineering:
The requirements or otherwise of fire doors is clear. They must be maintained as approved at the time the building was passed for occupation. Either at the time of construction or renovation, unless the council has issued an improvement order at a later date.
In this case, if the building was approved without fire doors and no council improvement order exists, there is no requirement for them to be installed now. We would however strongly recommend that the existing doors fit and operate correctly. If any need to be replaced they must be replaced like for like.
Entry doors are generally the responsibility of the Strata as they are considered an essential part of the building.
Our building in Sydney dates from 1964, and our fire review in 2007 required every fire door to the units to have the closers. Civil Fire are very assiduous in ensuring all the closers work as directed in order to issue the annual certicate!
My building dates from 1972. Are the doors to each Unit, which are fire rated, obliged to have automatic door closers on them?
Hi Owen
We have received the following reply back from Peter Berney, Solutions In Engineering:
Yes they need to be self closing as detailed in AS 1851 Section 12 Table 12.4.3.1.
” I can’t think of any legitimate reason to fit a security door in front of a fire door….””
Really? How about security? Not being allowed to improve the locks etc. on a fire door (most entrance fire doors belong to the Strata) means that the only way to get additional security is to install a security door. Of course, this may or may not be objected to by the fire officer, but no legitimate reason? I don’t think so.
Tony Page