The UK Government has unveiled plans to significantly revise Approved Document B, impacting fire safety standards. The proposed changes involve eliminating the national classification system for construction products and mandating compliance with the British Standard version of the European Standard tests.
As a result, this move would effectively remove all BS 476 tests, including those for fire resistance, from National Regulations.
Implications for Existing Standards
The International Fire Sprinkler Association (IFSA) warns that such amendments could have severe repercussions for companies whose products are currently compliant with BS 476 standards. These companies may face extensive, costly revalidation processes to align with European standards.
Industry Concerns
IFSA argues that this timeframe is inadequate for the industry to adjust to the new requirements
The core issue lies in the proposed removal of national fire resistance classifications from Approved Document B, coupled with a 12-month transition period. IFSA argues that this timeframe is inadequate for the industry to adjust to the new requirements.
With many firms having built up decades of testing evidence under British Standards, the amendments would necessitate considerable reinvestment to preserve their product scopes.
The increase in required Fire Resistance tests represents another challenge. Given that scheduling a test can take up to six months, and with additional time needed for issuing reports, the proposed 12-month transition is viewed as impractical given the anticipated volume of tests.
IFSA's Perspective
IFSA highlights the lack of a European Classification route for many products, particularly bespoke systems like architectural and specialist door assemblies. The organization recommends a transition period of 10 years to accommodate the heightened testing demands effectively.
According to IFSA, larger businesses may bear the cost of additional testing, but for small and medium enterprises, this could result in unsustainable financial burdens. Furthermore, the exclusive reliance on European classifications could limit the use of bespoke designs in UK buildings. The absence of Technical Assessments could lead to the decline of the UK's bespoke fire door industry.
IFSA advocates maintaining the current performance-related route, allowing Technical Assessments as per the PFPF Guide, based on established fire resistance periods. These concerns have been formally submitted by IFSA as part of the consultation process.
The UK Government proposes to substantially amend Approved Document B from a fire safety perspective, specifically by removing the national classification system for construction products and requiring relevant testing to the British Standard version of the European Standard. The effect will be to remove all BS 476 tests, including fire resistance, from National Regulations.
IFSA believes that this could have hugely detrimental consequences for those companies that have already registered their product ranges to existing BS 476 standards, necessitating a very time-consuming and costly revalidation to the European standards.
Fundamental basis of the concerns
The fundamental basis of the concerns is the removal from Approved Document B of the national classifications for fire resistance, with a 12-month transition period, which IFSA believes would be too short a time to allow the industry to adapt to the changes.
Some companies have accumulated test evidence against British Standards over decades, and if this were rendered unusable by the changes, then significant re-investment in testing would be required to permit those scopes to be maintained.
The number of Fire Resistance tests required would increase dramatically following the amendment, and since it can take up to 6 months to book a fire resistance test (or longer for some types of test), and fire resistance test reports taking up to a further 6 months before they are issued then 12 months would be insufficient time given the volume of tests required.
IFSA’s views
For many products the European Classification route to market is not in place, and for some bespoke systems, e.g. architectural and specialist door assemblies, this route is unlikely to ever be in place.
It is IFSA’s view that if the proposed amendment to Approved Document B proceeds then:
- A transition period of 10 years would be a reasonable time frame in order to allow for the increased quantity of testing required
- The requirement for additional tests would be a significant investment in testing, and while this may be a manageable cost for a large business, it may well an unsustainable expense for small or medium enterprises.
- Relying entirely on the European classification would not allow the types of bespoke designs currently produced by British architects to be used in prestigious buildings in the UK, as it is not designed to be used for Technical Assessments; if these were no longer permitted the UK bespoke fire door industry would largely disappear
- The existing performance related route should be maintained and that the wording chosen should allow for the continued use of Technical Assessments in accordance with the PFPF Guide based upon fire resistance periods
IFSA has submitted this view as part of the consultation process.
