Industry Services
Industry Services
Tomos Jones
Hazlin of Ludlow
Upcoming changes to Approved Document B mark a major shift in fire door testing. In this article, Tomos Jones reflects on what the transition may mean for timber door manufacturers across the UK.
On 2 September 2024 the UK Government announced changes to Approved Document B coming into effect from 2029, introducing notable implications for timber fire doors.
The main changes are:
Under these new terms, for an item to be classified it must have a classification report which can either be produced from a single test or multiple tests. If a limited expansion of scope is required a single test can have the DIAP rules applied from EN 1634. If multiple tests are required to expand the scope, then the EXAP rules are needed from EN 15269-3 (for timber hinged doors).
The purpose of EXAPs is to provide an open system that manufacturers can use to reduce the amount of testing that is needed. The intention is to get a good expansion of scope on their products as well as give confidence to necessary individuals that the goods they are receiving are backed by the appropriate level of confidence. The EXAP rules were written collaboratively by the CEN committee based on expert judgement and experience across Europe. Additionally, as this standard is applicable throughout Europe it opens opportunity beyond the UK. Significantly, these rules are not backed by reference to applicable tabled test evidence (intended to be addressed by the Commission).
The EXAPs, in theory, allow a more transparent system with a clear, understandable path to the desired results. These rules enable certain variations—such as size, glazing, and finish— within defined parameters. However, as door and test complexity increases, applying the EXAPs can become more challenging, and certain limitations have emerged in practice. The EXAPs also struggle to cover all design variations, particularly in cases where there is no specified rule. Subsequently these cases must be tested.
Since these rules are written by the CEN committee it is difficult for the UK to change these to better reflect the rules that are more relevant for our industry. As these are an EU standard it requires revision and consent on a scale that would take years for even only minor changes to be made if at all.
While the EXAP rules were intended to be accessible without specialist interpretation, in practice they often require expert input due to their technical complexity. Additionally certain aspects of the EXAP rules can be open to interpretation this means that there could be differences between EXAP reports from different approved bodies.
The EXAPs struggle when combining the rules of smoke and fire. This leads to contradicting rules that require expert interpretation between the documents. Other significant properties, such as acoustic performance, are given scant attention.
They also struggle to reduce the testing required for specialist doors. In fact, they require multiple tests to ensure that the products are covered by the necessary rules. In doing so, they increase the complexity of the document leading to high costs and longer lead times. This long lead time means that new and innovative products may find themselves taking years to come through to market as the cost and time to review these documents will hold them back.
At Hazlin we have spent the past 12 months developing a testing strategy and over that time have encountered some significant problems that will need to be overcome:
Before the Approved Document B changes, there was already a problem in the number of sufficiently qualified individuals who could write relevant reports for timber fire doors. Transitioning to the new standards will require time and investment in training—both for the current workforce and new entrants to the industry. As such, the market may struggle to meet the demand for the increase in testing and report writing required. It’s apparent that the magnitude of the task before the approved assessing bodies is a major one.
Third Party Product and Process Certification (TPPPC) has been an important aspect of the timber fire door industry. It has taken many years, but this is now a vital aspect to ensure that there is confidence in the industry. With the changes, coming through questions remain about how TPPPC schemes will evolve to fit the new classification framework, and which ones will evolve to handle classification. Additionally, the schemes that have worked well thus far are based on the current BS 476-22 fire resistance test which would need to be updated to correlate to the proposed EN 13501 system.
Third Party Product and Process Certification (TPPPC) has been an important aspect of the timber fire door industry. It has taken many years, but this is now a vital aspect to ensure that there is confidence in the industry. With the changes, coming through questions remain about how TPPPC schemes will evolve to fit the new classification framework, and which ones will evolve to handle classification. Additionally, the schemes that have worked well thus far are based on the current BS 476-22 fire resistance test which would need to be updated to correlate to the proposed EN 13501 system.
We are now four years away from the 2029 transition date and I believe these changes present a tight timeline for full industry preparedness, particularly with concurrent revisions to other standards. Especially with multiple other standards being reviewed concurrently which will have profound consequences for the industry.
The Architectural Specialist Door Manufacturers Association (ASDMA) has been working with relevant parties to highlight these problems and ensure that the specialist door industry’s concerns are heard. Recently they have proposed a UK Assessment Framework standard BS 8623, based upon the defunct Passive Fire Protection Forum (PFPF) rules. This is a positive way forward for the specialist door industry as it enables the flexibility needed in the sector. But time is pressing on, and there is little time for the market to be sufficiently prepared for the 2029 deadline.
