This includes the manufacturing, supplying and installation of fully complaint CE marked fire shutters.
SSS Industrial Doors Ltd were the first manufacturer to be tested to the new regulations BS EN 16034. SSS Industrial Doors are the only member of the Door & Hardware Federation (commonly referred to as the ‘dhf’) who hold additionally tested a fire shutter to both flexible and rigid structures.
WHAT ARE THE NEW FIRE SHUTTER REGULATIONS?
All powered doors must be CE marked as per the machinery directive; this has been mandatory since 1995 and is still a legal requirement! The previous standard BS 476 Part 22 (1987) is now a non-compliant regulation and cannot be CE marked as of the 1st November 2019. This has been replaced by the standard BS EN 16034:2014.
The mandatory changes for fire shutters and the additional requirements due to the Construction Products Regulations (EU) 305/2011. BS EN 16034:2014 is a harmonised European standard, manufacturers of fully compliant fire shutters will be aware of the changes to the manufacturing process which are imposed as per the Extended Application Report (BS EN 15269-10).
Fire shutters must be CE marked. It is illegal to manufacture a fire shutter without a CE mark. It is also illegal for contractors, 3rd Parties such as Landlords or employers to allow the installation for a non-compliant shutter which are not CE marked.
The previous regulation standard BS 476 Part 22 (1987) allowed for a varied interpretation of certain variables to be alter from the original test specimen by the manufacturer. An example of this would be manufacturers previously offered the installation of a fire shutter on either timber (flexible) or masonry (rigid) structures. In contrast to the previous standard, the new regulations BS EN 16034 clearly state if the original test specimen is tested to a rigid structure (steel or masonry) than an additional separate test is required for fixing to flexible structure (timber stud or drywall). As stated in the Extended Application Report BS EN 15269-10 in section J.1.2, the document states that rigid to standard flexible is “not possible without additional testing”.
RIGID STRUCTURE TESTED
On 8th February 2019, the Flame Armour Fire Shutter was tested to EN 1634-1 at WarringtonFire Test Facility. The original specimen was tested to a rigid structure. As a result of this, any fire shutter manufactured at that time could only be installed on masonry or steel structures. The image on the right is a photograph taken of the Flame Armour Fire Shutter being tested to a masonry structure.
FLEXIBLE STRUCTURE TESTED
On 7th July 2020, the Flame Armour Fire Shutter was once again tested to EN 1634-1 at WarringtonFire Test Facility. The fire shutter was manufactured to be an identical copy of the original test specimen. However, the fixing structure was altered so that it would be a flexible structure type. The image on the left is a photograph of the Flame Armour Fire Shutter being tested to a timber stud and fire-resistant plaster board structure.
HOW DOES THE NEW REGULATION IMPACT UPON THE CONSTRUCTION INDUSTRY?
In an ideal world, companies that work within the Construction Industry would be aware of the new regulations which were introduced as of 1st November 2019. Therefore, guidance such as this document would not be necessary. However, unfortunately that is not the case. As a manufacturer who proudly supplies to the trade, it has come to our attention that companies are not aware of the regulation change to BS EN 16034.
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It came to our attention after a new customer contacted us to source a fire shutter supplier who held a valid CE marking certification (BS EN 16034). This customer was unfortunate and was sold a non-complaint fire shutter which was manufactured to BS 476 part 22, as a result the building regulators would not sign off the fire shutter as it is non-complaint and his company had to source a replacement. SSS Industrial Doors Ltd, rectified this issue and supplied a fully CE marked and compliant fire shutter.
Due to the regulation changes, it is sometimes necessary to alter a design or building plan to accommodate these additional requirements set by the new standard BS EN 16034. If a company has not additionally tested a fire shutter to both structural types, then alternations must be made to ensure that the fire shutter is CE marked and compliant with the guidance in the Extended Application Report. Only a fire shutter manufacturer who has tested to the new standard will be aware of these requirements.
Architects, building contractors and construction companies might not be aware of the regulation changes. Therefore, you must ensure that the fire shutter is CE marked to BS EN 16034:2014.
WHO IS RESPONSIBLE FOR ENSURING THE REGULATIONS ARE FOLLOWED?
A fire shutter must be CE marked as per the Construction Products Regulations (EU) 305/2011, it is illegal to manufacture and sell a fire shutter to the previous standard BS 476 Part 22. Any contractor or company that knowingly manufacture, install, or supply a fire shutter that is not CE marked would be breaking the law and subject to the penalties for selling a faulty unfit for purpose product. These fire shutters would not be correctly manufactured, or CE marked correctly and therefore are endangering life as a fire shutter is a life safety critical product.
Any company that decides to not adhere to the new legislation and standards, by omission or otherwise would be directly violating the law. Failure to comply to the new standard BS EN 16034 and correctly CE Mark a fire shutter could result in penalties for the manufacturers, such as:
▪ Imprisonment.
▪ Product removed from the UK Marketplace
▪ A fine of £5000.
▪ Enforcement notice.
For contractors, it is imperative that they ensure that their manufacturer provides legitimate documentation that states that their fire shutters are legally safe and comply with current regulations. A contractor that omits to requesting documentation from the manufacturer could be liable for any damages caused by installing a non-CE Marked product within the UK Marketplace.
HOW CAN I IDENTIFY A FULLY COMPLIANT FIRE SHUTTER MANUFACTURER?
Any manufacturer of fully compliant fire shutters will be able to supply a certificate of conformity which is evidence that the fire shutter has been tested and is CE marked. The certificate will be provided by a notified body, such as WarringtonFire. The certificate will clearly state the manufacturer and will also provide a certification reference number and manufacturing plant number, these are essential for traceability purposes.
The certificate of constancy of performance will provide the essential characteristics for the fire shutter. These characteristics provide the information of the performance of the original test specimen. Failure to provide a certificate which states BS EN 16034 is evidence of a non-compliant fire shutter.
Separate testing data is required for CE marking to flexible (timber stud) and rigid (steel or masonry) structures. This additional test data is mandatory for the manufacturer to CE mark a fire shutter. If a manufacturer has only tested one structural type, then they can only supply and CE mark a fire shutter to that structure. SSS Industrial Doors Ltd have successfully tested both structures types.
WHAT ARE IMPLICATIONS OF BREXIT AND UKCA MARKING OF FIRE SHUTTERS?
With the challenges posed by Brexit, there will be a migration from CE marking to the United Kingdom Conformity Assessed (UKCA) marking. This will come into effect on the 1st January 2021 and there will be a transition period were both CE and UKCA marking will be compliant within the UK marketplace. UKCA marking will as be a direct replacement of CE marking within the United Kingdom.
The government guidance currently states that "all existing harmonised European standards will become UK designated standards". This includes fire shutters regulations such as BS EN 16034 and the Extended Application BS EN 15269-10 which will become UK designated standards. This will not impact the manufacturing or installation of fire shutters which are currently CE marked to BS EN 16034. As notified bodies, such as WarringtonFire, will be able to transfer companies’ current certification to confirm with the new regulations.
The following information and guidance regarding UKCA marking can be referenced to directly from the United Kingdom Governments website. In relation to the transferring of current fire shutter certification, which will conform to the new UKCA marking. SSS Industrial Doors Ltd have in writing from the notified body WarringtonFire, which states that the transferal of currently held certification is possible, and if desired, companies can apply to start this process now. However, further clarification will be provided later.
BIBLOGRAPHY
For more information please visit the following links:
DHF Changes to CE marking fire and smoke resisting industrial doors
Construction Products Regulation (EU) 305/2011
Supply of Machinery Safety Regulations 2008 Health and Safety at Work act 1974
Regulatory Reform (fire safety) Order 2005
BS EN 13241:2003 +A2:2016
BS EN 16034:2014
BS EN 1634-1:2014 +A1:2018
DHF TS 012 2019
Approved Document B
