NSW: Q&A Apartment fire door regulations – Compliance, Access

We’ve received the following questions from lot owners specifically concerning fire door regulations in NSW. Is the installation of security and screen doors is permitted? Do I need approval from the owners corporation to change my front door lock?

Table of Contents:

• QUESTION: I am concerned about security in my apartment and would like to install a deadlock on my front door. To comply with fire door safety regulations, do I require approval from the owners corporation?
• QUESTION: Are the doors on an exterior cupboard an isolation switch for the common area power and lights, plus Foxtel and NBN connections required to be fire doors?
• QUESTION: Can a lot owner use the fire stairs and fire isolation area for access to their terrace when carrying out renovation works? This includes access by tradespeople and the removal of building rubble.
• QUESTION: Our building is looking at installing electronic smart locks on all apartment doors. What do we have to be aware of regarding fire safety and access? Are they allowed, and do the locks have to be certified to ensure they comply with fire safety standards?
• QUESTION: Do townhouses need to meet the same fire safety standards as apartment buildings?
• QUESTION: I have an apartment in a resort. My entrance door is fireproof. Do all inside doors (e.g. like a bedroom door) or other doors inside the lot also need to be fireproof?
• QUESTION: How can I determine what fire measures are needed for our small building as per NSW regulations?
• QUESTION: How does a holiday renter know that the door is a fire door and cannot be chocked open if there is no sign?
• QUESTION: Are there new regulations in NSW banning the installation of fabric shades on the exterior of buildings due to risks associated with flammable cladding?
• QUESTION: Residents of a large NSW strata building demanded to know if apartment fire regulations govern whether they could use the fire exit for normal egress?
• QUESTION: Who is responsible for replacing our fire door if it fails a fire audit?
• QUESTION: Is my entry door to my apartment a Fire Door?
• QUESTION: I’m installing a thin metal bar under the entrance door of my Strata Unit to reduce the gap between the door bottom and the floor. Will this comply with the apartment fire door regulation in NSW for a Strata Unit? 
• QUESTION: Why are balcony doors not included in fire orders?
• QUESTION: The original front door on my 1996 unit needs to have an intumescent door seal installed. What are the apartment fire door regulations for the installation of intumescent door seals?
• QUESTION: We are wanting to install a screen door on our front door. Is it necessary to get a BCA Fire Consultant to assess this to get a tick of approval if this door is not a fire door?
• QUESTION: We have had a recent fire inspection. Two unit doors were deemed non-compliant with an expensive replacement cost from an inspector. Can we get a second opinion on whether this replacement is necessary or if the doors comply with fire door regulations for NSW?
• QUESTION: What are the regulations in NSW about individual unit fire doors that 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 for NSW strata 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 regulations and building codes?
• QUESTION: The magnetic door holder on the front door of an apartment does not comply with the fire door regulations for NSW. 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. Do the NSW Fire & Safety Regulations take a more common sense approach to safety in older strata 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 does not comply with NSW apartment fire door 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 NSW fire regulations or restrictions our strata 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 fire door regulations for NSW. Is this correct?
• QUESTION: Can Lot Owners install screen doors to their units and what requirements for NSW apartment fire door 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 door 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 door regulations?

Question: I am concerned about security in my apartment and would like to install a deadlock on my front door. To comply with fire door safety regulations, do I require approval from the owners corporation?

Answer: The front door and the lock are traditionally common property, so you definitely require approval from the owners corporation.

The front door and the lock are traditionally common property, so you definitely require approval from the owners corporation to modify it.

Once approved, if the door is fire rated, you will also need to select a lock that is approved for fitment on that particular model of fire door.

I’d suggest you use the word “deadlatch” in lieu of “deadlock” as whatever locking mechanism you choose, it must not prevent the door from closing & latching automatically. Deadlocks and deadbolts often do not allow this.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the February 2022 edition of The NSW Strata Magazine.

Question: Are the doors on an exterior cupboard an isolation switch for the common area power and lights, plus Foxtel and NBN connections required to be fire doors?

We are a small strata with 3 units. On the exterior of the building is a cupboard containing an isolation switch for the common area power and lights, plus Foxtel and NBN connections. The main switchboard and meters for the units are located elsewhere.

Are the doors on this cupboard required to be fire doors?

Answer: There is no need to protect the outside world from the switchboard risk.

The main switchboard if outside are unlikely to need to be fire doors as there is no need to protect the outside world from the switchboard risk.

It is only inside switchboards & even then, only if in a path of travel or in their own room where they are likely to require fire rating with such a small block.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #531.

Question: Can a lot owner use the fire stairs and fire isolation area for access to their terrace when carrying out renovation works? This includes access by tradespeople and the removal of building rubble.

Answer: As long as the fire stair is not obstructed and the fire doors are not chocked open

As long as the fire stair is not obstructed and the fire doors remain closed (not chocked open) when not transiting through them, I don’t see any issue from a fire safety perspective.

I think the person who should be asked is the strata manager and conditions placed on the fire stair’s use and terms put in place if there is any damage & clean-up required.

This advice is on the assumption that construction work is permitted under legislation and the public health orders in-place at the time.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the October 2021 edition of The NSW Strata Magazine.

Question: Our building is looking at installing electronic smart locks on all apartment doors. What do we have to be aware of regarding fire safety and access? Are they allowed, and do the locks have to be certified to ensure they comply with fire safety standards?

Answer: All fire doors, including their hardware (e.g. closer & locks) must be type tested

Electronic smart locks are not precluded from being used on fire doors to apartments; however, all fire doors, including their hardware (e.g. closer & locks) must be type tested. This means – during the approval process for any door, it gets burnt in a testing facility’s furnace to check the fire resistance level of the fire door meets a particular Fire Resistance Level or FRL.

The owners should first check with the manufacturer of the door (look for a phone number on the door tag) whether there is an electronic smart lock approved for that door type and size.

If the manufacturer does not have this on file or is uncontactable, the Australian Standard for Fire Door installation – AS1905.1-2005 states: “A different lockset shall only be substituted for the lockset on the tested specimen if it has been subjected to the fire resistance test on a doorset of similar construction, or if the essential latching components from the same manufacturer are substituted by those constructed from materials of greater or equal melting point”.

Hence, if you can get a certificate from the lock manufacturer stating the lock has been tested successfully on a similarly rated fire door (FRL -/60/30 is the term to look for), you could use them on the apartment doors.

We highly recommend you show the documentation and gain advice from your Accredited Practitioner (Fire Safety) prior to undertaking the works.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the September 2021 edition of The NSW Strata Magazine.

Question: Do townhouses need to meet the same fire safety standards as apartment buildings?

I’m looking at purchasing a townhouse which is under a strata scheme. The building was built in 1994. 

Do townhouses need to meet the same fire safety standards as apartment buildings with regards to fire safety doors, fire hydrants etc.? 

Would a building built in 1994 generally meet the fire safety standards? I know older buildings tend to have issues.

Answer: Townhouses are a different classification to an apartment buildings

Every multi-occupancy building post-1988 should require an annual fire safety statement. Every residential occupancy should have a working smoke alarm.

Townhouses are a different classification to an apartment; require fire safety systems, but generally require less than an apartment building.

It is impossible to state whether a townhouse generally meets the fire safety standards without having inspected it, but further to the above, the fire safety systems are generally fewer than the equivalent apartment building & therefore there is less to go wrong. That said, due to the lesser requirements, there is lesser chance the systems in a townhouse have been maintained.

To summarise – how long is a piece of string?

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the August 2021 edition of The NSW Strata Magazine.

Question: I have an apartment in a resort. My entrance door is fireproof. Do all inside doors (e.g. like a bedroom door) or other doors inside the lot also need to be fireproof? 

Answer: The only doors for an apartment that need to be fire rated are the ones between the apartment & common areas.

The only doors for an apartment that need to be fire rated are the ones between the apartment & common areas (&/or doors between apartments if it’s a resort with that setup).

Doors inside the apartment do not require fire rating as they are deemed to be within the same fire compartment.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #495.

Question: How can I determine what fire measures are needed for our small building as per the NSW fire regulations?

I am the strata treasurer. We are undergoing a fire safety inspection in Newcastle NSW on a 2 level complex with 6 units. We have a car park underneath plus 2 units and 4 units directly above.

How can I determine what fire measures are needed for our small building as per the NSW fire regulations?

We have fire shutters that a new fire group have said are faulty and we have had secondary advice from a fire shutter contractor who stated that it would cost $2K just to do an inspection not including any additional costs for any repairs. We are seeking 2 other quotes from other contractors.

I can’t find any information on the NSW planning website regarding what is required for our type of strata building.

Do you have any suggestions or possibly a checklist?

Answer: The closest thing to a list is the schedule of Essential Fire Safety Measures contained within the building’s Annual Fire Safety Statement (AFSS).

There is no checklist for each property type. The “list” is set by the Building code of Australia at the time of construction and put in place by the certifier, so most buildings are different.

The closest thing to a list is the schedule of Essential Fire Safety Measures contained within the building’s Annual Fire Safety Statement (AFSS).

If the AFSS says you need fire shutters, then you must maintain them on your building. If it doesn’t list them, the answer may be different.

Fire Shutters are often proprietary equipment tested for the application. Most often you have to go back to the manufacturer or design documentation to determine their performance requirements.

Aside from the inspection itself, the research & therefore PI risk in deciding to endorse (sign-off) performance annually can be extensive.

Suggest asking the fire contractor for evidence outlining why the shutters are faulty plus how and what they used as guidelines to assess performance. If they provide this, their opinion should likely be relied upon.

If the contractor cannot provide the workings of how they made the performance assessment, then the owners would be best engaging an alternate contractor – preferably the manufacturer or specialist in those specific shutters.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the July 2021 edition of The NSW Strata Magazine.

Question: How does a holiday renter know that the door is a fire door and cannot be chocked open if there is no sign?

For a lot that has an entry door being a prescribed fire door, and being a lot that is short-term rented, are there NSW apartment fire door regulations requiring a sign to be attached to the inside of that door letting occupiers know it is a fire door and fire doors cannot be chocked open? 

The penalty for a chocked open fire door is a penalty imposed upon the owner of the door which means the owners corporation cops the fine as it is the owner of the door. 

How does a holiday renter know that the door is a fire door and cannot be chocked open if there is no sign?

Answer: The requirement for signage of fire doors is found in the Building Code of Australia

The requirement for signage of fire doors is found in the Building Code of Australia as follows:

 D2.23  Signs on doors

1. A sign, to alert persons that the operation of certain doors must not be impaired, must be installed where it can readily be seen on, or adjacent to—

1. a required—
   
   (A) fire door providing direct access to a fire-isolated exit, except a door providing direct egress from a sole- occupancy unit in a Class 2 or 3 building or Class 4 part of a building; and

   (B) smoke door,

   on the side of the door that faces a person seeking egress and, if the door is fitted with a device for holding it in the open position, on either the wall adjacent to the doorway or both sides of the door; and

2. a—
   
   (A) fire door forming part of a horizontal exit; and

   (B) smoke door that swings in both directions; and

   (C) door leading from a fire isolated exit to a road or open space, on each side of the door.

The requirement does not extend to sole-occupancy unit doors, however the requirement to ensure that the operation of said door remains in place. There is no reason why signage cannot be erected or stickers applied as a best practice measure should the Owners Corporation so decide either on the doors or in the corridors or lobbies or at the top or bottom of the main stairs.

Fire and Rescue NSW have created this fire safety brochure: Fire and Rescue NSW: Fire Safety in High-Rise Buildings Perhaps this could be prominently displayed at the building or circulated to occupiers or be part of the information supplied to holiday renters.

We understand the following as per the Building Code of Australia

A6.0 Determining a building classification

1. The classification of a building or part of a building is determined by the purpose for which it is designed, constructed or adapted to be used.

A6.2 Class 2 buildings

1. A Class 2 building is a building containing two or more sole-occupancy units.
2. Each sole-occupancy unit in a Class 2 building is a separate dwelling.

A6.3 Class 3 buildings

A Class 3 building is a residential building providing long-term or transient accommodation for a number of unrelated persons, including the following:

1. A boarding house, guest house, hostel, lodging house or backpacker accommodation.
2. A residential part of a hotel or motel.
3. A residential part of a school.
4. Accommodation for the aged, children, or people with disability.
5. A residential part of a health-care building which accommodates members of staff.
6. A residential part of a detention centre.
7. A residential care building.

If the building is classified as a 2 building, which I assume it is then the fire door signage requirements are as previously stated. If it is argued that the dwelling is actually being used for another purpose, this does not reclassify the building. However even if were established that a change of use had occurred, the change would most likely be to a Class 3 which also does not require fire door signage as per BCA Volume One D2.23.

It makes absolute sense to put a sign on the back of the door, however, this will be at the discretion of the Owners and the Owners Corporation given the above.

QIA Group
E: [email protected]
P: 1300 309 201

This post appears in the June 2021 edition of The NSW Strata Magazine.

Question: Are there new fire regulations banning the installation of fabric shades on the exterior of buildings due to risks associated with flammable cladding?

We wish to install a fabric shade on our second storey balcony to block the afternoon sun. We have no flammable cladding on our building. I’ve been told there are recent fire regulations in NSW banning the installation of fabric shades in relation to cladding fires.  

Is this law real? If yes, does it apply to all buildings or just those with flammable cladding?

Answer: This is a little technical because it pertains more to changes to Building Code and Act requirements. In any event, we suggest you obtain the services of a Building Certifier who can certify that the structure meets the legislative requirements and or whether such certification is necessary.

QIA Group
E: [email protected]
P: 1300 309 201

This post appears in Strata News #480.

Question: Residents of a large strata building demanded to know if fire regulations govern whether they could use the fire exit for normal egress?

I manage a large strata complex in Sydney. Residents have been using the fire stairs on their floor to walk down to exit on the ground floor, instead of waiting for the lift.

Is this permitted under apartment fire exit regulations? My concern is that the fire exit doors are being used much more than they normally would be in emergencies only, and sometimes residents keep the fire door on the ground floor slightly open which is also a security breach.

The residents demanded to know what apartment fire door regulations governed whether they could use the fire exit for normal egress.

Answer: There isn’t a requirement that restricts the use of the stairs for emergency only. However, the big issue with your question is that people are wedging open the fire doors (I assume to sneak back up the stairs).

There isn’t a requirement that restricts the use of the stairs for emergency only. However, the big issue with your question is that people are wedging open the fire doors (I assume to sneak back up the stairs). Yes, this may be a security problem but it also creates a HUGE fire risk.

A fire door is designed and installed to close automatically to prevent the spread of smoke and fire into an area. Fire doors must always be closed unless they are held open by a device that is connected to a system that allows for the door to close automatically in the event of fire / smoke being detected.

Part of the testing of a fire door is that the closer is in place and that the fire door automatically closes and latches. In this case, having these doors held open would allow smoke and fire to enter the stairwell which is designated for emergency egress.

Chris Chatham
Linkfire
E: [email protected]
P: 1300 669 439

This post appears in Strata News #477.

Question: Who is responsible for replacing our fire door if it fails a fire audit?

The entry door to our apartment is a fire door. I don’t believe it is compliant with fire door regulations for NSW. The gaps around the doors are too wide / there is a peephole.

Who is responsible for replacing this if it fails a fire audit? The strata of the owner?

Answer: Apartment fire doors are the property of the strata plan.

Apartment fire doors are the property of the strata plan. While lot owners have a right to secure their property (fit locks, etc), they cannot do so if it impacts compliance of the fire door.

Non-compliance as identified in inspection, testing or audit, unless caused by the lot owner (e.g. fitting non-compliant locks or plastic peepholes) is strata’s responsibility.

Expand on the specific subject matter:

• Gaps in accordance with AS1905.1 are generally average of <3mm between door & frame on sides & head & <10mm at bottom (this can vary based on door brand, core & tested sample)
• Peepholes can be compliant or non-compliant. Depends on the model & what has been tested with that door model. Generally – 10mm or less penetration & metal construction is often acceptable.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #474.

Question: Is my entry door to my apartment a Fire Door?

Is my entry door to my apartment a Fire Door?

If YES, to comply with NSW fire door regulations, how often does my apartment entry door require inspection?

Can I fit a hold open device to my door closer on my entry door?

Answer: The apartment entry door should be a fire door

This is a difficult question to answer without any photos or physical reference, but the apartment entry door should be a fire door, yes! Albeit the question says “Is my entry door to my apartment a Fire Door ?” as opposed to ‘should it be a fire door’ but, yes, it should be a fire rated door for at least one hour.

According to AS1851 testing standard in section 12, Fire Doors are required to be tested every 6 months. However in the case of a Sole Occupancy Unit / Apartment Door it is only done annually at LinkFIRE as access often proves difficult more frequently than this.

Oftentimes, the onus is put on to the occupier to ensure any changes, deterioration or damage is reported back to the Owners Corporation Manager.

You can only install a hold open device if it is an automatic fail safe device (closes in the event of power loss or an alarm signal etc.).

Chris Chatham
Linkfire
E: [email protected]
P: 1300 669 439

This post appears in the May 2021 edition of The NSW Strata Magazine.

Question: I’m installing a thin metal bar under the entrance door of my Strata Unit to reduce the gap between the door bottom and the floor. Will this comply with the apartment fire door regulations in NSW for a Strata Unit?

Answer: The owners may consider some sort of tested fire door seal as an alternative.

Being there is little context to this, we’ve chosen to answer based on Australian Standard for Fire Doors (simplified description): AS1905.1-2005 – specifically clause 5.5.2 – excerpt below.

If the gap between the bottom of the door and the concrete under the carpet does not exceed 25mm; it is possible that a metal bar affixing the carpet to the floor will reduce the gap. The maximum gap between the metal bar and bottom of the door is generally 10mm or less.

FYI – Being that a metal strip could cause a trip hazard if being used for the purposes of reducing this gap, the owners may consider some sort of tested fire door seal as an alternative.

Note: there are many possible variances to the above as some fire doors are type-tested & approved with alternate dimensions to those in the standard.

5.5.2 Sill and floor finish

Clearances between the bottom of all door leafs and the floor shall be as follows (see Figures 1.4.1 and 5.5.2):

1. Between the leaf and the top of any floor covering—not less than 3 mm and not more than 10 mm.
2. Between the leaf and the top of the non-combustible sill—
   
   1. not more than 10 mm where there is no combustible floor covering; and
   2. not more than 25 mm where there is a combustible floor covering present.

NOTE: When the installed doorset is inspected for compliance with Item (ii), the clearance should not exceed 25 mm for the purpose of certification unless an appropriate note is made in the evidence of compliance (see Clause 6.3).

C5.5.2 In essence the maximum gap between the bottom of the door leaf and the adjacent floor covering is 10 mm. The 25 mm dimension is provided to limit the thickness of carpets and underlays to a maximum thickness of 15 mm in total. The intention of this Standard is to not allow a 25 mm gap under a door unless carpet is in the process of being installed. This is a temporary measure allowing for certification of the doorset, provided that a note is put in the evidence of compliance schedule and is checked at the first maintenance inspection regime.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the May 2021 edition of The NSW Strata Magazine.

Question: Why are balcony doors not included in fire orders?

Answer: A balcony door generally has nothing to do with fire safety as it’s not separating fire compartments or providing emergency egress, hence, would not be included in a fire order.

A balcony door generally has nothing to do with fire safety as it’s not separating fire compartments or providing emergency egress, hence, would not be included in a fire order.

Not to say there can’t be a unique situation that might require a fire rated balcony door or egress, but I’ve not seen one in the 29 odd years I’ve been in fire protection.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #468.

Question: The original front door on my 1996 unit needs to have an intumescent door seal installed. What are the NSW fire door regulations for the installation of intumescent door seals?

I have been told I have to have an intumescent door seal installed on the front door of my unit, opening into the communal internal hall area. The door has remained the same since the unit was completed in 1996 but the fire services have decided this is now an issue.

What are the NSW fire door regulations for the installation of intumescent door seals? Is there are legal requirement for how big the gap between door and frame is allowed to be? Has this suddenly changed? Why has the door been acceptable for over 20 years and now suddenly there is a problem? Who is responsible for the costs associated with the installation of the door seal?

Answer: For fire doors, generally an intumescent seal would only need to be installed as a rectification measure if the clearances between the door leaf and frame exceed the maximum tolerances permitted under AS 1905.1.

Assuming the door is a fire door, generally, an intumescent seal would only need to be installed as a rectification measure if the clearances between the door leaf and frame exceed the maximum tolerances permitted under AS 1905.1. However, it is also worth noting that in some cases fire doors may be permitted to have clearances that exceed the tolerances outlined in AS 1905.1 if the doorsets have been tested with larger clearances and obtained approval. If that is the case, then the door manufacturer would have relevant test certificates to substantiate this. In the majority of cases though, the tolerances as listed in AS 1905.1 are applicable.

The clearances permitted by AS 1905.1 are 3mm at the top and sides of the door, and a maximum of 10mm at the bottom. This has remained the same between AS 1905.1-1990, AS/NZS 1905.1-1997, AS 1905.1-2005 and AS 1905.1-2015.

Obviously, we could not make any comment on why excessive gaps may or may not have been identified by service providers previously as we do not know the site or the circumstances.

Chris Chatham
Linkfire
E: [email protected]
P: 1300 669 439

This post appears in Strata News #463.

Question: We are wanting to install a screen door on our front door. Is it necessary to get a BCA Fire Consultant to assess this to get a tick of approval if this door is not a fire door?

We live in a strata complex of 12. This includes 10 apartments and 2 townhomes. Our lot is one of the townhomes with street frontage and direct access to our front door. This is a non fireproof front door. We also have internal access through a fire door to our garage.

We are wanting to install a screen door on the front door. We have been directed by our strata management to find a Fire Consultant to assess this to get a tick of approval. After doing a bit of googling I am wondering if this is necessary as it’s not a fire door? I’m getting a little confused!

Answer: If the door is classed as a designated exit or forming part of a Path of Travel – this would mean that the door needs to be able to freely open to allow egress without the need for keys etc.

The door is not a fire door, so it should be fine to put a screen door on.

The only potential issue would be if the door is classed as a designated exit or forming part of a Path of Travel – this would mean that the door needs to be able to freely open to allow egress without the need for keys etc. It can still be key locked from the front.

Chris Chatham
Linkfire
E: [email protected]
P: 1300 669 439

This post appears in Strata News #458.

Question: We have had a recent fire inspection. Two unit doors were deemed non-compliant with an expensive replacement cost from an inspector. Can we get a second opinion on whether this replacement is necessary or if the doors comply with fire door regulations for NSW?

We have had a recent fire inspection. Two unit doors were deemed non-compliant with an expensive replacement cost. 

Checking with the company suggested the doors did not have compliance tags even though they are likely to be the same doors as all other 8 units. 

Can we get a second opinion on whether this replacement is necessary or if the doors comply with fire door regulations for NSW? We are trying to avoid a $5000 cost for two doors in the statement process.

Answer: To certify whether a door is compliant, it must have a door tag.

To certify whether a door is compliant, it must have a door tag. Therefore, in order to find a Contractor who will certify the door, you will need to find a contractor who will install a door tag. Is there an option to go back to the original installer to re-certify? If not, it will be extremely difficult to find anyone to legally sign off on the door.

I would recommend two things:

1. Organise a second quote to install a fire door. The cost for a new door with hardware and painting should be approximately $1,500 + GST. Seems like the incumbent contractor is charging you a high cost for your two doors.
2. I would recommend having the doors that are tagged to be fixed to the door (not glued on). If your door tags are glued on, they will eventually fall and will be lost and you will continually find you need to replace your doors.

Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109

This post appears in the March 2021 edition of The NSW Strata Magazine.

Question: What are the regulations in NSW about individual unit fire doors that open to the outside, next to a landing?

What are the regulations in NSW 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 apartment fire door regulations.

I imagine it may have to comply with fire mitigation door regulations.

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 that could not be removed during an emergency. Are there fire door regulations to have a quick release system installed to allow for a 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 legal requirements or fire door 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.

Peter Berney
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 regulations and building codes?

Our Strata is currently investigating fire safety upgrades to meet current NSW fire regulations 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
E: [email protected]
P: 1300 669 439

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 door regulations for NSW. 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 fire door regulations for NSW. 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.

1. A door required by (0) may be automatic-closing In accordance with the following:
   
   1. 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.
   2. 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
E: [email protected]
P: 02 9281 6440

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. Do the NSW Fire & Safety Regulations take a more common sense approach to safety in older strata 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.

Are there NSW Fire & Safety Regulations that take 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 does not comply with NSW fire door 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
Solutions in Engineering
E: [email protected]
P: 1300 136 036

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.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #376.

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 fire 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
E: [email protected]
P: 1300 669 439

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

1. Doors of a fire-isolated exit must not be locked from the inside as follows:
   
   1. In a Class 9a health-care building.
   2. In a Class 9c building.
   3. In a fire-isolated exit serving any storey above an effective height of 25 m, throughout the exit.
2. 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—
   
   1. 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
   2. 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 fire door regulations for NSW. 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 door 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 if this does or does not comply with NSW fire door regulations?

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 NSW apartment fire door 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 NSW apartment fire door 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.

1. 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 apartment fire regulation 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.

2. 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.

3. 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.

4. 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 door 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 fire regulations?

My daughter owns a ground floor unit in a pet friendly apartment block and wishes to install a doggie door in a small floor level window.

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 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]
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 NSW fire door regulations on fitting a security door to the front entrance door of a unit? Does this breach apartment fire door regulations?

What are the NSW fire door regulations on fitting a security door to the entrance door of a unit? Does this breach apartment fire door 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 screen doors comply with apartment fire door regulations 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.

The NSW Fire Brigade recommend against security doors being fitted and for good reason as they would hamper the fire and rescue services. Also the ‘ideal’ of compartmentalisation would be lost as the fire could either start in the unit and then easily spread as it’s not being contained within the unit it started and/or enter the unit because the fire door may not be shut resulting in what could have been a preventable disaster. I can’t think of any legitimate reason to fit a security door in front of a fire door, other than to allow ventilation meaning the fire door is open meaning it is now rendered ineffective.

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.”

Peter Berney
Solutions in Engineering
E: [email protected]
P: 1300 136 036

This post appears in Strata News #173.

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.

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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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