18 Feb What is a Golden Thread of Information?
A Golden Thread of Information:
The term ‘ a golden thread of information’ was used by Dame Judith Hackitt in her report ‘Building a Safer Future’ (May 2018), which was commissioned by the Government as an independent review of Building Regulations as a result of the Grenfell Tower Fire in June 2017.
The term relates to Digital Record Keeping and her recommendations included that there should be:
- Changes in the control processes and associated record-keeping requirements; so that there would be
- A digital record of fire safety components kept for High Rise Residential Buildings and other high-risk buildings. This was envisaged as:
- A single repository, easily accessed and easily understood, that would emerge during the initial design process through to construction – and be there to deal with any changes and maintenance for the life of the building. Such a record would:
- Ensure accountability for decisions and dis-incentivise corner-cutting for the sake of cost.
A ‘Golden Thread’ of information in relation to fire doors and passive fire protection generally, can be defined as:
An accurate linked record of specifications, fire test evidence, certification and all the information required for traceability to ensure that all items have been installed to comply with Regulation 7 of the Building Regulations and can be maintained to comply with Regulation 38 of the Building Regulations and Articles 17 and 38 of the Fire Safety Order.
So, looking at it as a compliance process, what this means is a joined up electronic ‘paper trail’ to ensure that every door and other fire component is SPECIFIED, PROCURED, INSTALLED., MANAGED and MAINTAINED correctly:
I mentioned above, Articles 17 and 38 of the Fire Safety Order and these need to be understood; being prime reasons for a golden thread of information being required:
Article 17 states that:
“Where necessary in order to safeguard the safety of relevant persons the responsible person must ensure that the premises and any facilities, equipment and devices provided in respect of the premises under this Order….. are subject to a suitable system of maintenance and are maintained in an efficient state, in efficient working order and in good repair.”
And Article 38 relates to the Maintenance of measures provided for protection of fire-fighters; stating that:
“Where necessary in order to safeguard the safety of fire-fighters in the event of a fire, the responsible person must ensure that the premises and any facilities, equipment and devices provided in respect of the premises for the use by or protection of fire-fighters under this Order or under any other enactment, including any enactment repealed or revoked by this Order, are subject to a suitable system of maintenance and are maintained in an efficient state, in efficient working order and in good repair.”
A key aspect of making this happen is to comply with Regulation 7 of the Building Regulations, which was also mentioned in the definition above. The key statements are:
“Building work shall be carried out with adequate and proper materials which are appropriate for the circumstances in which they are used”
“The person carrying out the work should show the workmanship will provide the appropriate level of protection and performance”
Regulation 7 is a legal requirement and ensuring that the right materials are used and installed correctly are obviously very important for structural fire protection components intended to protect lives.
That’s the requirement, so what can go wrong?
Fire doors are both familiar objects and at the same time quite complicated – there’s a lot to potentially go wrong and much of this is in terms of the different components of fire doors being compatible and evidence of them being fire tested and installed as a complete DOORSET.
This isn’t a new problem, for example non-compliant fire door installation issues at blocks of flats in Stoke on Trent received media coverage in 2013, but perhaps the full extent of the problem has only been understood and appreciated by a wide audience ‘post Grenfell’.
However, non-compliance issues continue. I do a lot of work with hospital Trusts and here are a selection of photos showing examples with recently installed doors in hospitals that I’ve surveyed within the last 12 months:
Please see below a close up photo of the bottom of a double door. You can see that that the gap at the threshold is both excessive and uneven – you might also notice that the door leaves are not of exactly the same shade of blue, which suggests that they weren’t intended to be matching leaves when they were manufactured:
The next image shows an excessive gap at the bottom of the door frame, which may have occurred due to the doorset having been incorrectly measured:
What is beyond doubt in the next image is that the wrong length of screws were used to fix the door frame to the substrate:
In another hospital, as shown in the next image, we found lock casings that hadn’t been correctly sleeved with intumescent protection. You can probably ascertain that what has been used, incorrectly, are the intumescent pads that should go behind hinges:
The door in the following image was required to have smoke seal capability, which requires a maximum threshold gap of 3mm, but the gap on this and the majority of other doors in the building were found to be in excess of 15mm:
The next 2 photos were taken at another hospital. The one below shows a 60-minute door that had an intumescent grille fitted but the core hasn’t been framed to protect it:
And the one below shows doors opening out onto a busy corridor with no vision panels:
These final 2 photos are examples of poor product selection; the one immediately below showing MDF frames having been fitted on a busy hospital corridor, which didn’t have the impact resistance to stop them from cracking on being hit by service trolleys:
In this last image you can hopefully see that the knuckles are distorting out of line and are leaking oil, which indicates the hinge is being put under distress by the weight of the door. We tried to investigate the cause as they were marked to show that they were the fire rated hinges of the right size; however, we discovered that they had no fire test evidence and were not CE registered – our conclusion was that they were counterfeit and that the CE marking was related to them being ‘Chinese Export’:
Also you might have noticed that the intumescent strips have been fitted in the wrong sequence – it should be the strip with the smoke seal that isn’t in line with the hinge so that the smoke seal will be unbroken by the hinge to maintain the seal for the full length of the door.
There is a cost to this, over and above non-compliance; because if doors aren’t right at installation or use inferior components then they will need more maintenance and will fail quicker, which will convert into higher subsequent costs.
For passive fire protection in general and firestopping in particular, the activity is currently largely unregulated in that anyone with a white van and a pad saw is able to install it (often very badly).The following image potentially shows the correct base product choice but poor workmanship:
Finding something to this standard in an occupied building indicates a lack of competence throughout the whole supply chain, which often starts at the procurement if not the design stage.
One common issue is the misunderstanding and limitations of so-called ‘fire foam’ and the fact that it does not intumesce (but it does what it says on the tin!).
Urethane foam, whatever colour it comes in, tends to have a very narrow window of use based on test evidence, to such an extent that some organisations have completely banned it from being in their buildings, not least because of environmental issues:
As a minimum, its use needs to be policed to ensure it complies with fire test evidence because as with all structural components it is often hidden away in the fabric of the building and can be difficult and expensive to put right if used inappropriately.
The answer to “what’s wrong with the image below?” is just about everything. The fire blanket hasn’t been sealed around the ductwork correctly; the fire damper and the ductwork hasn’t been supported. But the worst thing of all is that it wasn’t designed or procured properly and no one in the supply chain, especially those responsible for signing off the building, had the inclination or the expertise to flag it up as a non-compliance issue:
It is where different services and subcontract packages interface that problems often occur, typically due to not having identified who is going to do the work – if it hasn’t been priced or specified it will often be left by everyone ‘to others’ or done badly. This was in the roof void of a mental healthcare building that I inspected several years ago. The building had been occupied for more than 2 years.
To an untrained eye the image below might look just about ok, but an experienced inspector should notice the lack of pressure exerting (black, graphite) mastic around the cables and the absence of identification labels, which would normally be expected if the work was being QA / 3rd Party audited:
But the biggest issue is that it hasn’t been mechanically fixed. If you look at the seal below, which was in the same building, the problem will be more evident:
The image below is of a compliant seal and you can hopefully see the difference:
It’s important to appreciate that there isn’t a ‘one type suits all’ firestopping solution. As shown in this image from firestopping manufacturer FSi, the materials used vary depending on the location, size of required seal, what services breach the penetration, the fire rating required, if there are air sealing or acoustic requirements and any other considerations such as moisture and movement:
Manufacturers test their products for all of these factors and then create and supply ‘detail drawings’ to reflect how they’ve been tested and how they should be installed to replicate and achieve the required fire rating.
In turn, firestopping companies need to record what has been installed in what location and who has installed it to provide adequate quality assurance and a complete electronic record of what has been sealed:
Fundamentally there is a strong case for 3rd Party certification, so that both fire door and passive fire protection installations are independently audited:
This level of digital recording required by 3rd Party schemes will assist in Regulation 38 compliance, which requires passing on the right fire safety details.
Under Regulation 38 of the Building Regulations for England and Wales a package of fire safety information must be provided to the Responsible Person at the completion of a project or when the building or extension is first occupied. The ‘as built’ information should include all fire safety design measures in appropriate detail and accuracy to assist the Responsible Person in operating and maintaining the building safely.
Having the right standard of fire door inspection is also crucial. It Is now being more widely understood that 3 generic types of inspections are required depending on the age and status of the doors:
TYPE 1: A prescriptive one, including invasive elements, that would typically take place soon after the doors have been installed
TYPE 2: A robust but potentially pragmatic and flexible one, carried out on existing fire doors in occupied buildings where there is no evidence of performance and where no, or little, fire door information exists
TYPE 3: Undertaken on fire doors that have already been Type 1 or Type 2 inspected, where the doors are known to meet / have met the standard of fire compliance required and where a paper trail exists
Of course the right standard is dependent on the inspections being carried by people who are competent to do so.
Once ‘Type 1’ or ‘Type 2’ inspections have taken place on doors it Is important to understand how frequently they need to be ‘Type 3’ inspected in terms of maintaining compliance – and this needs to be decided by those responsible for a building, taking into account such factors as their location and level of criticality, their usage and to what extent they might be subjected to impact damage. The matrix below might be a useful guide in determining the frequency of inspection in addition to BS 9999, which gives specific guidance on fire door inspection and maintenance:
It needs to be borne in mind that a building may contain a range of types and styles of fire doors and it needs to be ensured that they are ALL being competently managed and maintained.
This particularly applies to Final Exit Doors; a type of fire door that often gets overlooked. But in a fire evacuation scenario they could be the most critical doors in a building – you need to ensure they function correctly before you have a fire incident:
Last but not least you probably need to be aware that C.E. marking, that has become increasingly applicable to fire doors and passive fire protection products in recent years, is now being changed over to a UKCA standard going forward.