The Intumescent Fire Seals Association responds with opinion about the DCLG Determination on the need for intumescent seals on hotel doors

Was the Department for Communities and Local Government (DCLG) Determination on the need for intumescent seals on hotel doors an ‘open and shut’ case?

 The Intumescent Fire Seals Association is, of course, disappointed by the recent publication of a Determination on the suitability and sufficiency of a fire risk assessment in a hotel in respect of the adequacy of the existing bedroom doors.

The determination concluded that a new Fire Risk Assessment (FRA) should be prepared for a hotel where no intumescent seals were fitted to the existing bedroom doors but, on this occasion, the absence of the seals should be recorded and justified. This would apparently contradict the world-wide trend to fit such seals where legislators and researchers have recognised the assurances that such seals are able to provide in the event of a fire incident, ensuring that a small fire never has free rein over a property jeopardising the lives of many, rather than the few. Sadly, the conclusion from the Determination relies heavily on poorly interpreted history and statistics.

Intumescent Seal

 The ‘Responsible Person’ is of the opinion that as the hotel had received a fire certificate under the 1971 Fire Precautions Act with doors installed that did not have fire seals fitted, this indicated that such doors were deemed to be suitable for purpose at that time and should continue to be so.

In 1971, the principle of heat activated intumescent seals had not been invented (the technology of intumescent was in its infancy) and the test method for evaluating fire doors was seriously in error.
The test used to evaluate the life safety potential of a fire door was operated at a negative pressure which ‘sucked’ air into the protected space (the bedroom) from outside (thereby drawing fresh cold air into that space), rather than forcing the fire gases out of the room, due to the inevitable pressure generated by the fire gases forcing flames and hot gases out into the common corridors.

Since the 1970’s, every fire resistance test standard in the world has removed the negative pressure test in favour of a test that mimics the reality of a real-life fire, which is based upon the International Standard (ISO) procedure. How can a hotel in the UK depend upon 41 year old technology to protect its residents on the say-so of a ‘responsible’ person’s opinion? How did the responsible person identify a ‘competent’ person who would share those views? We can only hope that the competent person is well insured and can sleep with a clean conscience.

There have been many changes in hotel furnishings and construction since 1971. Furniture has been increasingly replaced by flat packs and manufactured from wood based composites and bathrooms have increasingly replaced by ‘gap’ pods, both having increased heat release and potentially greater smoke production.

The burnt out remains of the Penhallow hotel

Unsurprisingly, the responsible person proposed that only 1 death per year has occurred in a hotel since 2002 and inferred there was no problem. Isn’t that about the time we started to fit intumescent seals onto hotel doors in earnest? Is that pure coincidence? Fortunately, statistics show that our commercial environment is fairly safe with respect to fire due to the technology that has been introduced, but that must not lead to complacency.

A fire safe environment relies on the interaction of many technologies, not just one and we will rue the day when we put our life in the hands of any one of them. It’s amazing how quickly the image of the Penhallow Hotel fades from the front page of our national press, such that it is no longer remembered by those responsible for our safety.

For more information about IFSA visit www.ifsa.org.uk


Background information about IFSA

IFSA was founded in 1982 and has established itself as one of the leading trade associations for companies engaging in the science and application of intumescent based passive fire protection systems.

The association’s objectives are to:

• To promote the life safety benefits associated with intumescent fire and smoke seals.
• To promote research and development into extending the benefits of intumescent based fire and fire and smoke seals
• To participate in the development of test procedures for fire protection products in BSI, CEN and ISO that are relevant, repeatable and reproducible.
• To ensure that information on the science and application of intumescent based passive fire protection materials is made available to both professionals and the general public.

To ensure objectives are fulfilled IFSA has representation on all the main fire standard committees and is a regular advisor and commentator on proposed fire related legislation matters. The association has close links with the fire community, including legislators, test labatories, insurers, certification/approval organisations and other trade associations.





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