Safe Entrance/Exit Doors – Myth or Reality?

Summary

In the UK entrance/exit doors are mostly fitted with the traditional letterplate for mail deliveries. This creates a problem since the letterplate is an opening element and it will undermine the vital specifications of the door, including security, fire resistance and environmental. In addition, such doors can be in breach of the mandatory legislation.

The unprotected letterplate is often fitted to entrance/exit door even in the premises where by law the door must be fire resisting (protected): arson proof or fire door depending on the risk of fire.

The problem would not go if the letterplate is ’fire rated’. This is because the ’fire rated’ letterplates are tested with the flap specifically closed off. Therefore such test results do not reflect the real situation on site where the flap can be opened by anyone, anytime.

For most doors there can be a low cost solution by fitting the correctly specified secure eco-letter box behind the letterplate.

Fire Resistant Entrance/Exit Doors in the UK – Myth or Reality?

Introduction

In the UK entrance/exit doors are mostly fitted with the traditional letterplate for mail deliveries. This can create a problem since the letterplate is an opening element and it will undermine the vital specifications of the door, including security, fire resistance and environmental.

The large majority of domestic arson involves the use of the letterplate aperture. In 2007 the police service reported that 95% of domestic arsons involve accelerants introduced through the letterplate. Secured By Design Police initiative New Homes 2010 document ^[1] identified arson, whereby the arsonist pours accelerant or pushes a firework through the letter plate aperture, as one of three distinct crime risks associated with letterplates.

More recently the risk of fire starting through the entrance/exit door fitted letterplate, especially by pouring in an inflammable liquid, was highlighted in the ASFP Guide document for Fire Risk Assessors ^[2] (paragraph 3.3) and in the Guidance document on fire safety for blocks of flats ^[3] (paragraph 43.2).

In premises, which are covered by a number of mandatory legislations, including Construction Products Regulation (CPR) (from 1 July 2013), The Regulatory Reform (Fire Safety) Order (RRO) ^[4]  (from 1 October 2006), Building Regulations Part B, E and L, the Housing Act 2004, The Housing Health, Safety Rating System (HHSRS), Health and Safety at Work Act 1974 (HSWA), The Climate Change Act 2008 and more, entrance/exit doors with the unprotected or under-protected letterplate will not be in compliance with the legislation.

If this conflict is not properly addressed the consequences can be disastrous. Although arson is generally perceived to be a threat to property rather than to life, over 60 people die each year as a result of fires that are deliberately lit in buildings and in addition, over 2000 people are injured in such fires ^[5].

Final Exits Doors Security and Fire Safety

Protecting the letterplate always makes good sense. For ‘responsible person’ in the premises, which are covered by the mandatory legislation, preventing arson is a legal requirement. This is covered for Fire Risk Assessment purposes by BAFE Scheme and a number of Guidance documents.

In the case of an accident, the  ‘responsible person’ is risking hefty fines or even imprisonment. The insurance company can refuse the payout if it turns out that the mandatory legislation requirement was not met.

Under Article 14 of the RRO it is mandatory that the entire escape route up to and including the final exit from a building must remain unobstructed at all times. This is also the requirement of the Building Regulations ^[6].

Since a fire starting in the exit door area would effectively cut off the main escape route, in the premises covered by these laws, doors used as the final point of exit should be fire resisting (protected): arson proof or fire doors depending on which areas are at risk of fire.  

If only the internal of the premises is subject to the risk of fire, as it happens in premises with entrance/exit doors facing the road, making the entrance/exit door arson proof should be enough.

However, if risk of fire is applicable to the areas located on both sides of the door, such as the entrance/exit doors of flats that are facing the common areas (like in blocks of flats and houses in multiple occupation), then entrance/exit doors must be fire doors. This is essential for the ‘compartmentation of flats’ – limiting the spread of fire and smoke in case of a fire that may originate in the flats or in the common areas.

A ‘responsible person’ can keep the letterplate in the entrance/exit escape door for undisrupted mail deliveries only if he takes measures to protect the letterplate against internal and/or external spread of fire (and smoke) – any letter boxes that are fitted should be of a protected type.^[3]

And yet, the unprotected letterplate is often fitted to the entrance/exit doors where by law, doors must be fire resisting, which puts lives and property at risk. Hundreds of thousands of people living in high-rise flats and maisonettes are in potential danger.

The problem would not go away if the letterplate is ’fire rated’. This is because the ’fire rated’ letterplates are currently tested with the flap specifically closed off. Therefore such test results do not reflect the real situation on site where the flap can be opened by anyone, anytime.

The currently certified ‘fire rated’ letterplates are tested in a closed position so they may meet the UK Standards and Regulations BS 476:1987 Pt. 20/22, BS 476:1983 Pt. 31.1 (British Standard) and BS EN 1634-3: 2004 (European Normative standard) on the surface and they are allowed in fire rated doorsets. However, the letterplate is an opening element of a door and in open position it has no fire, arson, intruder, crime or vandalism resistance. Those who are using this loop hole in the legislation are putting lives at risk. BM TRADA says: ‘A letter plate will only have a fire resistance integrity when in the closed position. If the letter plate is open it would instantly fail integrity by the 25mm gap gauge criteria.’

Fire Risk Assessment

Preventing arson is one of the key issues faced by the property managers/owners when trying to implement the RRO. The issue of arson is covered by BAFE Scheme for Fire Risk Assessment ^[7].

The Fire Safety Order states clearly that when carrying out the fire risk assessment the ‘responsible person’ must consider the possibility of a malicious fire or arson attack. The first thing to do is to identify fire hazards: source of ignition, source of fuel, source of oxygen. Arson attack through the letter box is a source of ignition and source of fuel. As such it must be identified at steps one and two of the fire risk assessment.  An excessive air flow through an open letterplate leads to an additional source of oxygen and increased risk to the premises in case of fire. The open letterplate allows a direct passage for hot gasses and flames.

The Home Office says: ‘The diverse motives of arsonists, vandals and criminals mean that no home or business is immune from an attack’. Therefore, more often than not the risk posed by a letterplate (letter box) has to be addressed. In case of under specifying the fire risks and a serious fire accident taking place the consequences can be devastating for everyone affected, including the ‘responsible person’ and the fire risk assessor.

Among the non-domestic premises that are most at risk of the letter box arson are small businesses, such as offices, shops and pubs, and common areas of flats and houses in multiple occupation. The high risk premises are mostly those premises that have sleeping accommodation like hotels, hostels, residential homes and like premises.

Yet this is often overlooked and sometimes there is even confusion over the scope of the fire safety legislation: whether the risk of a letterplate (letter box) in the entrance door is within the scope of the RRO.

The situation is exacerbated by the absence of a sound UK standard that would address the vital for the UK issue of a letterplate and letter box performance against arson.

Loopholes in the Legislation

Doors are covered by the new CPR and must meet seven basic requirements, including Safety in case of fire and Energy economy and heat retention. Under CPR manufacturers need to declare the conformity of their door product to these essential characteristics in a Declaration of Performance, which is the key concept in the CPR intended to provide transparency.

However, the current practice, which is followed by many manufacturers, allows declaring all or some of these essential characteristics as ‘No Performance Declared’. The reason may be that their doors will not be in compliance. There is a growing concern in the industry about this loophole in CPR legislation that manufacturers may take.

Note 21.18.1 of SBD^[1]  says that the police service is currently exploring the creation of a new attack test standard/guide for letterplates and letter boxes with partner organisations with similar interests and that the SBD requirement will be updated upon completion of a standard/guide. Apparently this was implemented in 2012 when the Door & Hardware Federation (DHF) in association with SBD issued a new Technical Specifications for letterboxes – TS008:2012 and TS009:2012.^[8]

On the positive side the new Technical Specifications for letterboxes included for the first time an attempt to assess a letter and mail box product against a potential arson attack. However the value of the included tests for letter and mail box resistance against arson is limited since the tests method is based on pouring of an unsubstantiated and surprisingly small volume 100ml of petrol. This is a serious subject but there is a funny side to it: in Russia 100ml would certainly make sense as it is the usual minimum drinking volume of vodka…

Clearly testing with this small volume does not address the risk of the real world accidents where litres of diverse inflammables can be poured in. The letter and mail box products tested in this way would not be suitable for fire doors and would not be in compliance with RRO and Building Regulations, since low-security letter box product or low-security fire door is nonsense. Imagine what would happen if a low-security letter box product is fitted to a fire rated door. There is no debate on the fact that you either get a fire rated door or you don’t.

Specifying secure letter box

Although original entrance/exit doors often need upgrading for compliance with the legislation, eliminating the letterplate would be inappropriate in most cases. Apart from the certain heritage issue here, it may mean replacing the whole door, nuisance with getting to mail, letting warm air out through the open door, frustration with the mailbox locks and keys that tend to get lost. Plus the outdoors fitted mail box is a well-known target for vandalism and mail theft.

To avoid these complications one should look at the attractive alternative. For most doors in these situations the conflict can be easily resolved by simply fitting the correctly specified arson or fire proof secure letter box behind the letterplate. This can be a low cost and cost-effective solution that will transform the insecure external door to be fit for purpose, but ‘buyers beware’. The market is full of inadequate ‘secure’, ‘fire rated’, ‘anti-arson’ and ‘eco’ letter box products, often with little or no substance behind these claims. It is easy to end up with a half-measure at best or a further problem at worst.

The fire resistant letter box products, which can protect from fire and crime, must have enough mechanical strength to withstand a mechanical attack, high temperature or an explosion. To suit fire doors they must be made of metal ^[8], with a melting point greater than 800ºC. For that reason, do not consider mail bags made of cloth or fabric.

When choosing among the metal products, one should be guided by the RRO and good engineering practice, which dictate that priority should always be given to the products, which work by eliminating hazards, especially flammable liquids, rather than focusing on containing all hazards in the letter box and trying to cope after there is a developed problem, such as a fire or an explosion.

Article 10 of the RRO requires that preventive and protective measures should be implemented on the basis of the principles of prevention set out in Part 3 of Schedule 1:

(a) avoiding risks;

(c) combating the risks at source;

(d) adapting to technical progress;

(e) replacing the dangerous by the non-dangerous or less dangerous.

To follow the RRO recommendations, priority should always be given to eliminating hazards, especially flammable and highly flammable liquids, as most deliberate ignition fires were from fires started by liquids. Liquid inflammable is more dangerous than the solid one because it gives out twice as much heat from the same mass and burns twice as fast.

ASFP Guide ^[2] too recommends that if the door has a letterplate, consideration should be given to fitting a device, which can help prevent arson attack e.g. by items or flammable liquid being passed through the door. Clearly, it is preferable to prevent hazards rather than relying on any measures, including fire extinguishers, after a problem, such as fire, have developed. 

Beware of the outdated metal ‘anti-arson’ or ‘fire-proof’ letter box products, which are available on the market with or without a fire extinguisher, which similarly to mail bags essentially rely on the containment of the hazards introduced through the letterplate rather than on the principles of avoiding risks and prevention. 

In reality, when a hazard, especially a liquid accelerant, which was poured in and contained, is ignited, this usually leads to an explosion. The fire or the explosion can cause building excessive internal pressure and explosive ruptures of the sealed container. This will send shrapnel and fire in every direction, at high velocity. Fitting these products indoors behind the letterplate may result in creating a potential “bomb” in the premises.  

Never be guided by the price alone. Look for the now available ^{[9] [10]} cost-effective integrated solution where passive fire protection, high security, draught proofing and insulation are delivered by a single strong steel product suitable for fitting indoors to the letterplate at any level as a letter box and even as an outdoors mailbox, if you wish so. Then it will match the RRO definition of ‘necessary’ and ‘reasonable practical’ actions of the ‘responsible person’ and you will solve the problem cost-effectively.

REFERENCES

• ^[1] SBD_New_Homes_2010. ACPO SBD 16/12/09.
• ^[2] ASFP Guide to Inspecting Passive Fire Protection for Fire Risk Assessors. Association for Specialist Fire Protection 2012.
• ^[3] Fire safety in purpose-built blocks of flats. Local Government Group, July 2011.
• ^[4] The Regulatory Reform (Fire Safety) Order 2005. Crown copyright.
• ^[5] The Prevention and Control of Arson 3^rd Edition. The Fire Protection Association.
• ^[6] Building Regulations 2010 Part B (Fire Safety)
• ^[7] BAFE Scheme: SP205 Version 2: December 2012 for Fire Risk Assessment.
• ^[8] TS008:2012 ENHANCED SECURITY AND GENERAL REQUIREMENTS FOR LETTER PLATE ASSEMBLIES AND SLIDE  THROUGH BOXES and TS009:2012 ENHANCED SECURITY AND GENERAL REQUIREMENTS FOR LETTER BOX ASSEMBLIES THAT ARE FREE STANDING OR SURFACE MOUNTED AND WHERE MAIL IS RETRIEVED FROM THE SAME SIDE AS DELIVERY. Copyright DHF.
• ^[8]Fire Safety Order Guides published by CLG (Communities and Local Government) in 2006. Crown copyright.
• ^[9] Safety first at the front door. Eureka Magazine 08 August 2007. Findlay Media copyright.
• ^[10]  http://www.secureletterbox.com – PowerPrize Limited 2006-2014.

For more information please visit www.secureletterbox.com

Published June 2014