We’ve recently received the following questions from NSW lot owners about apartment fire regulations. Peter Berney, Solutions in Engineering and Vincent Graham, Project Guides have provided the following response.
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.
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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.
This post appears in Strata News #299.
Vincent Graham
Project Guides
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
P: 0476 233 109
E: [email protected]
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.
Read next:
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.
Visit our Maintenance and Common Property OR FactSheets: NSW Strata Legislation pages.
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Have a question or something to add to the article? Leave a comment below.
Hi Vince, Theodore, & all,
In NSW the EP&A Regs require that all essential services are maintained such that performance is not degraded to less than that specified in the installation standard. The age of the building is irrelevant to that requirement, so these doors need to be assessed and serviced. Whilst a number of other States (QLD, SA, VIC) nominate the current maintenance standards (AS1851-2012, AS2293.2-1995, etc. NSW simply requires maintenance to provide minimum performance and in many cases this is actually more onerous than that of the maintenance standards.
1. every building should comply with the codes and standards in effect at the time of built/completion date. (there are some exceptions of course, like accessibility codes, … )
2. otherwise not a single building would ever get compliant!!
3. having said that if you modify, renovate, change, … anything, you must comply with the current codes and standards.
4. your best friend is a building certifier , private certifier whom will check, survey, your building and recommend any non compliant issues and upgrades necessary
5. seeking a second opinion always helps as in my experience certifiers tend to “translate” codes and standards differently
In NSW the pre-BCA constructed buildings were covered under Ordinance 70 and the BCA Part D requirements were simply an evolution of this. SDU entry from corridors has always forbidden screen doors for such SDU’s in NSW and there is no legislation in NSW calling for the application of AS1851. The legislation instead, requires maintenance to ensure that the performance of those particular services identified in the fire safety schedule, perform at not less than the performance requirements required by the original code and standards. This can sometimes be more onerous than AS1851-2012, but AS1851 is viewed as MINIMUM best practice.
For older SDU’s having solid core doors, these are usually cedar in the older units and they actually perform quite well in a fire test with FRL -/30/30.
The Local Council Building Fire Surveyor can issue a fire upgrade on any building where they have cause to believe that the building is deficient and this is usually triggered by a concern raised by an occupant or visitor, or after a NSWFR response.
Any owners corporation who endorses a lot owner to add inappropriate hardware to any SDU are taking upon the committee, responsibility for any non-compliance. In NSW the penalty for non-compliance is 300 penalty units / incident which is currently about $13,000 and this cost would be in addition to correction costs. So something to think about.
Hi Theodore,
It may have been a fire door, however, given the age of the door and the fact it isn’t tagged, there will be no way to determine if it is a fire door (other than to test it which will damage the door) and therefore if you want it certified, it will need to be replaced.
Additionally, the door of this age will likely have an asbestos core, so it might be best to have it removed if it is dilapidated.
Regarding whether you need to replace it, this comes down to the AFSS requirements in the EPA Regs. As the building was built in 1974, you may have no requirement to issue an AFSS so there may be no requirement to maintain the ‘Essential Services’ in your building. This isn’t to say that you shouldn’t.
If you have a Fire Safety Schedule and are issuing an AFSS, then yes you will need to maintain Fire Doors.
I would recommend seeking assistance by a Building Surveyor to provide site specific information that you can use to plan any works.
If your building is in Sydney, let me know and I can help out.
Cheers
Vince
Hi Ian,
Some correct points, however some incorrect points made above. Clause D2.21 doesn’t relate to SOU doors – this is for doors in the path of egress, which doesn’t include SOU doors.
SDU I think you mean SOU (sole occupancy unit)?
Other than that, yes always get approval for any changes to your SOU Fire Door.
Our building apartment was built in 1974. there are no fire rated tags on the spine of the entrance doors or garage internal doors. Does this mean these doors are not fire rated. do we need to upgrade to fire rated doors or are we exempt due to its age.
I would suggest that the advice above is somewhat deficient and the adviser appears to have limited understanding of the regulations.
Just to put a few things in perspective. The door to your apartment (SDU) is not yours but is common property as are your balcony doors and windows etc..
You cannot add any hardware or fitments without approval of the owners corp (additional lock, fitting a door chain, removal of door closer, etc).
If your door opens onto any passage used for emergency exit (common corridor or passage) – you must not prop it or chock it open nor inhibit the door from closing in any way (such as stop the closer operation) as this would allow breach of fire compartmentation. You cannot add any other door to the entry door portal as this would not allow the required single handed, single action exit through that door (BCA D2.21). If you do do these things then you are in breach of the Environmental Planning & Assessment Regulations Div.7 which carries significant penalties (of currently $13k/incident).
If we see evidence of screen doors or dead/barrelbolt multiple locksets, we cannot (nor can any CFSP) endorse for the AFSS.
I would suggest that any exit door which can be keylocked from the inside, should always retain the key when the room/apartment is occupied. If there is a fire or emergency, you don’t want to have to search for a key.
Hi Nikki
My question was more in relation to what are the fire safety requirements on a building that was built in the early 1970’s, in terms of unit doors, fire extinguishers , smoke alarms etc?. What are the legal requirements for an Owners Corporation? Or is this still a grey area?
Thanks
Nick
Hi Nick
The following reply from Peter Berney:
This issue is that in 1970 the requirements were very much driven by the local council rather than any form or national regulation. The owners best stop initially is the local council as any improvement system is still driven by the local council.
Our building was built in the early 1970’s and we are a self-managed Strata Corporation, as such we have tried to engaged the services of a ”Fire safety Company”, who could not advise specifically what we needed or did not need to be compliant to the NSW Environmental Planning & Assessment Regulation 2000 Part 9, regarding the initial Fire Safety Installation Certificate and the Annual Fire Safety Certificate each year after.
I was advised by them to call my local Council to get further information about our building fire safety requirements. The council had no information on this whatsoever and advised they had no staff that specifically looked after this area (Fire Safety). They then referred me to another website.
The questions remain is do we as a Strata Corporation have to do something or not regarding the initial Fire Safety Installation Certificate & Annual Fire Safety Certificate given our building was built in the early 1970’s? and if so what are the scope of works required?
Thanks
Nick
Hi Nick,
We have received the following response from Peter Berney, Solutions in Engineering:
Firstly there is no simple short answer to this question, and I hope to not bore too many with this response.
When looking at screen doors the strata needs to consider the need or desire for them and if there are not better ways to achieve the same result. This decision ideally should be made in advance of an owner making a request as this will ensure uniformity through the building.
Most owners will want screen doors for either improved airflow or improved security or both.
When considering this the strata needs to take into account the following issues both positive and negative.
· If the unit entry door is fire rated the strata must consult with their fire door maintenance company. The reason for this will be evident from the point below.
· The overall ‘look’ of the property if screen doors are installed particularly if some owners have them installed and some don’t. Consider that the Strata may need to specify the type and colour of the door to gain some uniformity.
· Who is paying for the door and any ongoing maintenance considering it is being installed on common property but is for the sole benefit of a single unit?
· Safety to others in the building having due regard for the width and shape of the corridor or walkway at all unit entries, not just the unit making the request. Can others pass safety past this door if it is left open particularly in the event of an emergency? Remember that at least some screen door closers can be set to hold open, others could fail and not self-close or the closer not be installed or be removed. As the door is fitted to the outside on the door frame the handle will protrude into the corridor and may cause a safety issue even if the door is correctly closed.
· Emergency services may have increased difficulty accessing the unit in the event of an emergency.
· Noise both from the door opening and closing and noise radiating onto the common property if the entry door is held open.
· Cooking odours, or smoke from cooking radiating onto common property affecting the comfort of others or triggering common property smoke detection equipment. Depending upon the fire detection equipment installed at the building it could result in unnecessary brigade callouts, and increased costs for owners, occupiers and Strata.
· If the door is needed for security, is it a type that offers better security than the existing entry door? Generally better security comes at a higher cost.
· Can the existing door be fitted with an additional lock to improve its security? In this the Strata will need to consider if the existing entry door contains Asbestos, and that the correct type of lock is fitted by the correctly licensed tradesperson if the door is fire rated.
· Can the Strata reasonably improve security into the building or site so that all occupiers receive the benefit over the entire building?
· If the door is fire rated having a screen door is an inducement to wedge or hold open the fire door. If this occurs an offence has been committed, and should a fire start in the area smoke, heat or fire could spread through this doorway. Fire doors can only be held open with an approved device which will not be possible in some buildings and will come at a high cost in one where it is possible.
· If the door is fire rated so is the door frame. Penetrating the frame for hinges and locks, adding door jams or seals, etc has the potential to affect the certification of the opening and may make it non-compliant.
· If the frame is fire rated only correctly licensed tradespersons can do alterations. The Strata must ensure that the tradesperson is correctly licensed and insured to work on fire rated installations.
From this most will have gathered that it is a difficult if not impossible process and in most cases, this is so. However, it may well be feasible and beneficial in some strata particularly low rise townhouse developments where most doors are not fire rated and the unit opens directly onto an open space.
Are all units required to have a fire door? our block is a 1960’s and only have ordinary wood doors that actually do not fit correctly, our body corp[orate are very loath to spend any money on anything if they can avoid it. Is the fire door the owners or strata’s responsibility?
Hi Beverley
Thanks for the question. We have received the following comment back from Peter Berney, Solutions In Engineering:
The requirements or otherwise of fire doors is clear. They must be maintained as approved at the time the building was passed for occupation. Either at the time of construction or renovation, unless the council has issued an improvement order at a later date.
In this case, if the building was approved without fire doors and no council improvement order exists, there is no requirement for them to be installed now. We would however strongly recommend that the existing doors fit and operate correctly. If any need to be replaced they must be replaced like for like.
Entry doors are generally the responsibility of the Strata as they are considered an essential part of the building.
Our building in Sydney dates from 1964, and our fire review in 2007 required every fire door to the units to have the closers. Civil Fire are very assiduous in ensuring all the closers work as directed in order to issue the annual certicate!
My building dates from 1972. Are the doors to each Unit, which are fire rated, obliged to have automatic door closers on them?
Hi Owen
We have received the following reply back from Peter Berney, Solutions In Engineering:
Yes they need to be self closing as detailed in AS 1851 Section 12 Table 12.4.3.1.
” I can’t think of any legitimate reason to fit a security door in front of a fire door….””
Really? How about security? Not being allowed to improve the locks etc. on a fire door (most entrance fire doors belong to the Strata) means that the only way to get additional security is to install a security door. Of course, this may or may not be objected to by the fire officer, but no legitimate reason? I don’t think so.
Tony Page