NSW: Q&A Apartment fire regulations – Fire Doors, Screen Doors, Access

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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.

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
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

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 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.

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 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 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?

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 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.

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.”

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.

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• QLD: Q&A Fire Audit and Fire Door Compliance

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