Fire Door Inspections: AS 1851: Costly Maintenance

Essential Property Services reports that the costs associated with fire door inspections and maintaining fire doors continually grate on property owners and managers, as they are reminded constantly by most maintenance contractors that remedial works are necessary, mandatory, and under AS 1851: 2005 "Maintenance of Fire Protection Systems and Equipment" attract penalties for non compliance, and thus reinforce the need for frequency of fire door inspections and maintenance by competent and qualified assessors.

This fire door inspections article is not to advocate non compliance with "specified" statutory fire door inspections requirements (AS 1851), or to advocate a reduction in maintenance costs or fire door inspections that reduces the safe operation of fire doors in an emergency where State legislation allows the owner/ occupier to determine the extent of fire door inspections and maintenance on fire doors to be performed outside of those nominated in AS 1851. The purpose of this article is for owners and managers to be informed on the parameters of the legislation and AS 1851 which allows them to implement a safe fire door inspections and smoke door inspections maintenance regime.

Fire door inspections legislation in three States is discussed, with Queensland and New South Wales discussed briefly, and the more involved Victoria fire door inspections legislation discussed at length.

New South Wales: Fire Door Inspections

Maintenance of essential fire safety measures (fire doors) has been regulated to differing degrees by evolving legislation over the years, commencing with Ordinance 70 in the early 1970′s, through to the current maintenance regimes under the Environmental Planning and Assessment Act 1979 and Environmental Planning and Assessment Regulation 2000 (EPAR), which have not nominated AS 1851 which includes fire door inspections.

Essential fire safety measures such as fire doors must be able to continue to perform to the relevant regulations and Australian Standard requirements to which it was designed and installed. The owner may decide to utilise AS 1851: 2005 "Maintenance of fire protection systems and equipment" (see Victoria for further comments as the benchmark for fire door inspections regime). It is mandatory however, that the fire doors are maintained to facilitate their compliance with the relevant performance standard at all times, and not AS 1851, maintenance must include fire door inspections.

Queensland: Fire Door Inspections

The Queensland Fire and Rescue Service require fire doors to be maintained (including fire door inspections) by the occupier under Section 54 of the Building Fire Safety Regulations 2008 (BFSR). This means that if a "fire safety installation" such as a fire door is installed in a building, then the applicable Australian Standard must be adhered to (in our example AS 1851: 2005 "Maintenance of fire protection systems and equipment" will apply). Fire door inspections are to be performed by an appropriately qualified person registered to inspect fire doors, at regularities specified in the QDC - MP6.1 Schedule 1 and not the regime specified in AS 1851-2005.

Victoria: Fire Door Inspections

Part 12 of the Building Regulations 2006 and AS 1851: 2005 "Fire protection systems and equipment services" covers fire door maintenance and fire door inspections in Victoria. Part 12 contains two Divisions, Division 1 - Maintenance of Essential Safety Measures is broken down into three subdivisions. Subdivision 1 applies when fire doors are contained in a building built after July 1994 or an existing building where the fire doors have been altered under a building permit. Subdivision 2 applies to fire doors in buildings that existed prior to 1994 and have not been altered.

Part 12 makes it mandatory on the property owner to ensure that fire doors comply with either AS 1851 or are maintained in a state which allows the fire door to fulfill its purpose. While the objectives and intent of both Subdivisions 1 and 2 (buildings) relative to fire doors may be the same, Subdivision 1 is prescriptive and refers to AS 1851 (which contains fire door inspections provisions) as applied by the relevant building surveyor, whilst Subdivision 2 nominates a performance standard.

For new buildings or buildings having recent alterations (Subdivision 1 or combined Subdivisions 1 and 2 buildings), the building surveyor must determine the extent of fire door inspections required for fire doors (usually nominating AS 1851) and place the fire door inspections requirements in writing to the owner upon completion of the building works, in the form of an Occupancy Permit, Maintenance Schedule or Certificate of Final Inspection - Maintenance Determination.

The current benchmark AS 1851 stipulates quarterly fire door inspections. We strongly recommend property managers request the building surveyor to nominate four fire door inspections per year in high use fire doors, and lower number of fire door inspections where the frequency of use of the fire door is low, (for example: a hospital, nightclub, shopping centre, etc. may warrant a higher number of inspections). The building surveyor can modify the number of fire door inspections under AS 1851.

If required to use the previous benchmark AS 1851:7, as is stipulated on an Occupancy Permit or Maintenance Determination, twelve fire door inspections per year (eleven Type 1 and one Type 2) will be required.

For existing buildings (Subdivision 2) the owner has an obligation to ensure that the fire doors will function adequately in the event of an emergency. Building Regulations 2006 does not compel existing fire doors to comply with the current Australian Standard for maintenance under Subdivision 2 of Part 12, that is AS 1851 - 2005. Indeed, even AS 1851 specifies that unless this standard has been invoked by a controlling authority, under legislation it is not applicable. (Refer to Clause 4.3.2 (b)).

Prior to 1994, the fire door inspections and maintenance standard (AS 1851) was not invoked by Victoria's legislation. Consequently for existing buildings, it is the property owner who is required to determine the extent of required of fire door inspections required in the pursuit of ensuring the fire doors are maintained adequately. The fire door maintenance standard (AS 1851) can be used as a guide.

We do not believe that it is the intent of the Building Regulations 2006 for "essential safety measures" known as fire doors in existing buildings (Subdivision 2) to strictly comply with all new Australian Standards created after the building was constructed, e.g. AS 1851. It may well be for certain installations, like emergency lights and exit signs, that some essential safety measures should comply with the current standard, but not fire doors (as the Standard stipulates).

Essential Property Services staff are finding after fire door inspections that a significant number of fire doors should never have been tagged (that is, where the installer certifies fire door installation in accordance with the installation Standard AS 1905.1 - 2005), due to defects at installation stage, but are required to be maintained with the current fire door maintenance standard - AS 1851 (sometimes the contractor represents the same company who installed the fire door). This situation should be considered intolerable, especially when the defects to the fire door are minor and can be very costly to repair under AS 1851 stemming from fire door inspections.

Many fire doors that are installed in sprinkler protected buildings deserve consideration, especially when they were installed in a period when no fire door inspections maintenance legislation existed (e.g. AS 1851). Minor defects that some contractors say are acceptable in a non sprinkler protected building are called up as maintenance items by other contractors in sprinkler protected buildings, and in such case a judgment call should be made by "appropriately qualified" inspectors/ person as to the extent of remedial works required on the fire door relative to AS 1851.