Advice for Fire Safety Professionals

Heritage and building regulations

If the Fire and Rescue Service (FRS) issue an enforcement notice under the Regulatory Reform (Fire Safety) Order 2005, as amended (referred to here as the Fire Safety Order 2005), they are required to consult the Local Planning Authority Conservation Officer under the provisions of Article 30.5(e). Fire and Rescue Services and Fire Risk Assessors working in listed buildings should advise the property owner or Responsible Person that Listed Building Consent may be required before any interventions are put in place.

Both the Building Regulations 2010 and the fire safety guides published in support of the Fire Safety Order 2005 include provisions to look at fire safety interventions with a degree of flexibility. For example, the current Building Regulations Approved Document B (Fire Safety) includes the following paragraph:

0.17 - Where Part B applies to existing buildings, particularly buildings of special architectural or historic interest for which the guidance in this document might prove too restrictive, some variation of the provisions in this document may be appropriate. In such cases, it is appropriate to assess the hazard and risk in the particular case and consider a range of fire safety features in that context.

The term 'buildings of special architectural or historic interest' is used to refer to listed buildings and may include other existing heritage buildings.

In addition the fire safety guides provide an Appendix C which encourages a balance between ensuring that there are sufficient fire safety measures for the protection of people and the preservation of the protected heritage value of the building.

It should be remembered that all parts of a listed building are covered by the listing, not just what is recorded on the National Heritage List for England entry. If works are proposed, then Listed Building Consent may be required before the works commence. Check with the Local Planning Authority Conservation Officer.

Fire strategy

For larger or more complex heritage buildings, consideration should be given to preparing a fire strategy to establish and record the overall approach to fire safety for the building. It could then provide the basis for subsequent fire risk assessments and enable previously assessed and justified fire safety measures to be taken into account, provided that the building, its use and the relevant fire safety measures have not materially changed and continue to be adequately maintained.

The fire strategy should include passive and active fire protection measures. Historic Environment Scotland's publication Fire Safety Management in Traditional Buildings (2010) Part 2 recommends different passive and active measures that could be applied to traditional buildings.

The fire strategy should ideally include plans of the building marked up to show these measures.

During the creation of the fire strategy plan each door should be assessed to determine if it is required to be a fire door or a smoke stop door, or if there is no requirement for it to be either. The historical and architectural significance of the door should be assessed along with the likely fire resistance. The possibility for upgrade should also be examined.

The following could be used to assess the building:

• Where a building was previously subject to a fire certificate, the certificate and any associated plans, specifications or other supporting documents may provide useful information on the fire safety measures and assumptions previously applied to the building. Where available, these should be considered when preparing or reviewing the fire strategy, but their continued suitability should be verified against the building as it exists and is used today and against current fire safety requirements. For heritage buildings, these documents may also help identify the basis on which existing features, such as historic doors, compartmentation or means of escape, were previously considered acceptable.
• The relevant Fire Safety Order article 50 guides.
• BS 9999:2017 – Fire safety in the design, management, and use of buildings. Code of practice.
• BS 9991:2024 – Fire safety in design, management and use of residential buildings. Code of practice.
• Fire safety: Approved document B.
• A fire engineered solution based on the principles in BS 7974:2019 – Application of fire safety engineering principles to the design of buildings. Code of practice.

Fire doors

The most common fire safety enquiry received by Historic England is where owners and occupiers have been told to replace their doors with fire doors that have a current test certificate.

After the Grenfell fire in 2017, the government has updated fire legislation, resulting in the Fire Safety (England) Regulations 2022. In the accompanying fire door guidance, which has been designated as an Article 50 guide, HM Government states:

For avoidance of doubt, the purpose of these Regulations is not to ensure that existing flat entrance doors satisfy the current standards for flat entrance doors in new blocks of flats, as imposed under the Building Regulations. The purpose of the Fire Safety (England) Regulations is to implement the recommendations of the Public Inquiry into the Grenfell Tower fire, which, quite correctly, emphasised the importance that flat entrance doors must be effectively self-closing.

In short, it is expected that, in the majority of circumstances, a door that satisfied the standards for a fire-resisting flat entrance door at the time the block was built, or the door was manufactured, will continue to provide adequate protection for means of escape in common parts of the block, provided the door is undamaged and that gaps between the door and the frame are not too large (see 6.7 a-g). The absence of intumescent strips and smoke seals, and the absence of any form of certification for the door, does not imply that the door is unfit for purpose.

While the above regulations are primarily designed to consider doors in blocks of flats, it is recommended that they are considered before any alteration or replacement is proposed to heritage doors.

Listed Building Consent for the replacement of doors in listed buildings will probably be required. The possibility of refusal of listed building consent,and therefore the need for alternative solutions, should be considered.

Where a fire strategy exists, the fire resistance of doors required to be fire doors will have been assessed for the building, and it should not therefore be necessary for a fire risk assessor to reassess these doors, provided that their condition, use and relevant circumstances have not materially changed.

Fire resistance of historic panel doors

Fire doors are installed to reduce the spread of fire and smoke from different compartments in buildings. Historic doors are often relied upon to provide a degree of fire and smoke resistance. However, in some cases, fire safety improvements may be necessary.

The Guide to the Fire Resistance of Historic Timber Panel Doors provides advice on how to decide whether changes are necessary. The guidance looks at:

• escape routes and compartmentation
• factors affecting the performance of fire doors such as construction, distortion and structural stability
• how to determine fire resistance
• upgrading fire doors, including adding self-closing or hold-open devices
• maintenance of doors to improve the performance and fit of doors in the frame.

Upgrading solutions using intumescent paints and varnishes have been omitted from the guide because of the variations that can occur in their application. Manufacturer's literature will need to be consulted if these systems are proposed to ensure the correct application.