Removal of BS 476: Are we awake to the implications?

This question about removing BS 476 from certification, could it be a simple digital 'select all' and 'replace' exercise?

In my opinion we've been handed an excellent opportunity to wake up, stand up and speak up.

Simple, easy digital 'select all' and 'replace'?!

I've been left with an uneasy feeling after our latest webinar.

I'll admit I wasn't fully awake last week when the inquiry was made, something like this...

"In regards to certification, surely in the digital age in which we live, can't we simply 'select all' [BS 476] and 'replace' [with BS EN 1634]." The inquiry ended with a pause, ...then, "Probably.? Probably.."

What if the civil servants and policy makers are thinking this is a simple, easy digital 'select all' and 'replace'!

If this is the case, our responses to this consultation are even more critical.

It matters to everyone who has anything to do with fire safety, whether you just sniff a construction product at specification stage, through to full-on installation of fire safety critical products, such as fire doors. It's important we all respond.

If the industry had fully tested to EN 1634, then we're talking updating just the physical documents such as Approved Doc B (ADB) which is fairly easy.

Not so easy though when we're talking 'Certification';- 'Fire Test reports';- 'Fire Engineering Assessments' and 'Field of Application' reports. That's not as easy.

It's not possible to simply elevate BS 476 to BS EN 1634

With certification it's not possible to elevate BS 476 to BS EN 1634. It doesn't work like that.

On a side, Chris Waterman is very active in fire safety, in particular ensuring that people can evacuate buildings safely. He is an advisor to MP's and Peers who have a particular interest in fire safety. During our webinar, Chris showed us his pair of 'fire safety tinted' glasses, which he uses when looking at this issue, and strongly believes anyone having anything to do with fire safety should do the same.

One profound statement was when Chris stated was, "If you haven't got decent fire doors then you're no where".

Chris is well known for his involvement and interest in following the Building Safety Bill and Fire Safety Bill through parliament. He has now published his 'Plain Guide to the Fire Safety Act' which focuses on the legislation and the explanatory notes..

He is working on a companion volume that will contain graphs, charts, mind maps and diagrams for the visual learner.

Back on subject:- "how feasible in this digital age we live could there be a quick way to replace BS 476 in certification with EN 1634?"

"Definitely not possible", is the answer.??As I've said, we cannot elevate BS 476 testing to EN 1634-1.?

Will need completely new testing

This means that each application of fire safety construction product that's been tested to BS 476 standard will need completely new testing to the European EN 1634 standard.

Is BS 476 actually going to be any safer?

We asked: is BS 476 actually going to be any safer? Jerry Quayle made it quite clear that in countries where EN 1634 is used, their death rate is higher than ours where we have used the BS 476 standard. He did make a caveat that there could be various influencing factors on this, and stats were challenged in the Q&A session, but it does make you think, why are we doing this?

Jerry says BS476 in various guises is used around the world...it's a line in the sand, just as much is EN 1634 is a line in the sand....if you're measuring different things, items perform in a different way. He also pointed out that the testing furnace is far more rigorous in his opinion that real life situations.

Retesting, that's a lot of money, when just one fire testing phase can cost tens of thousands, plus the admin logistics and manufacturing costs that go along with it.

Removing BS 476 from ADB

So are there disadvantages of removing BS 476 from ADB?

According to Russell Day of Association of Composite Door Manufacturers , the first disadvantage of removing BS 476 from ADB is cost. Russell made it clear, the ￡9m forecast does seem very low when you look at the whole of the product range rather than just fire doors.

One of Russell's members has just spent over ￡500,000 testing their range of fire doorsets to EN 1634.

BS 476 testing has shown a significant reduction of deaths in the UK

His concern is that, as an industry, we have over 40 years of BS 476 test data in test results. This could well be thrown in the bin, even though we have seen that BS 476 testing has shown a significant reduction of deaths in the UK.

It appears that an attempt to remove BS 476 class 'O' could be the one reason for the government wanting to remove the national classes. Who knows, but if so it's in effect throwing the baby out with the bath water.

Why throw everything out?

Russell raised his concern, I can understand why they are trying to remove Class O, but....why throw everything out when all you're trying to remove is one class that was invented by predecessors of DLUHC?

Rutland Door Controls spoke with an intumescent manufacturer last week who values their BS 476 test evidence at ￡5m. Their technical manager fears this will all go in the waste paper basket and he not only doesn't have funds to re-test from scratch, but time is the issue too:- there's no chance they can re-test all this in 12 months.

Major concern from within the industry

Hence the major concerns from within the industry. This change will cost far more than the government's forecast, and will take much more longer to implement.

Richard Kowalski DipGAI, RegAI highlighted to us, the note from the government actually says 476 'and the series', so that's any part within 476, so that includes smoke certification and smoke testing as well.

This means what ever fire safety product from glazing to fire mastic to fire doors will have to be retested.

You can assess EN 1634-1 down to?BS 476, but you can't do it vice versa

He also put into perspective that some of the major UKAS accredited third-party certification fire door schemes are all certificated to BS 476. This is not a 'control F, replace all' exercise.

Richard confirmed that, doing an assessment you can assess EN 1634-1 down to?BS 476, but you can't do it vice versa.

You will see a reduced scope from some suppliers

Another caution from Richard Kowalski was that, this will mean documents have to be re-written in line with EN 1634 and the effect could be that "people may lose product, lose the scope or lose a part of the scope, you will see a reduced scope from some suppliers, until they retest and get that scope back up to what they had under BS 476."

Richard's opinion is to be taken note of when he summarized:- "I'm all for fire safety, fire safety is paramount, I'm an advocate of fire safety, but if we do go through with this change it needs to be implemented correctly. The suggested twelve month period is not possible, at all."

Some feel that five years is required at the minimum for the transition period..."Implementing something like this will absolutely cripple the industry"

He backed up Russell Day of ACDM on the five years by saying:- "You are thinking five years required at the minimum for the transition period. Test houses can only just cope at the minute with their workload, but implementing something like this will absolutely cripple the industry, the test lab industry. There are so many things that are associated with these standards it is quite shocking."

This isn't a 'control F', 'replace all' exercise

So now we now know we can't assess up from BS 476 to BS EN 1634, this isn't a 'control F', 'replace all' exercise. It's a re-testing program on a massive scale. For much of the industry it's a huge cost and needs implemented very wisely if we're to prevent the life-safety industry stalling.

Please respond to the consultation - here's the link below.

P.S. In case you think you're on the wrong link (because I did), it's titled 'Sprinklers in care homes.." and talks about "Staircases in residential buildings.." but you are on the right link, where it says 'Removal of National Classes..' that means removal of BS 476 from Building control Approved Doc B.

Want to be heard, consider answering questions 1 - 3, 13 -18, then question 28:-

Question 1?- What is your name? [Free Text]

Question 2?- What is your email address [Free Text]

Question 3?- Are you responding as an individual or on behalf of an organisation? [Individual/on behalf of an organisation]

If you answered ‘On behalf of an organisation’ please provide us with the name of your organisation [Free Text]

Consultation questions for the removal of national classes

Question 13?– Do you agree that the national classifications for reaction to fire should be removed from Approved Document B? [Agree/Disagree]

Question 14?– Do you agree that the national classifications for fire resistance should be removed from Approved Document B? [Agree/Disagree]

Question 15?– If you disagree, what evidence can you provide that outlines why the national classifications are still required. [Free text]

Question 16?– Do you agree that there should be a transitional period of twelve months? [Agree/Disagree]

Question 17?- If you disagree, how long should the transition period be and what is your evidence to support a longer or shorter transition period? [Free text]

Question 18?– Please outline any concerns you have about the withdrawal of the national classification with regards to fire resistance including potential impacts, such as on the fire door industry. [Free text]

Question 28?– Please provide any additional evidence on costs, risks and benefits which should be considered in an assessment of impacts in the following areas.

b) removing the national classification (BS 476 series) from Approved Document B

Ways to respond

Respond online