4 February 2019

MHCLG Consultation on Assessments in Lieu of Tests (AILOTs) and GRP Composite Material Doors

Dear valued customer, 

The MHCLG published the Government Response to the Consultation on Amendments to Statutory Guidance on Assessments in Lieu of Tests in Approved Document B on 18 December 2018. A copy of the document can be found here.

The document provides feedback on the consultation paper issued by the Government, which set out proposed amendments to guidance on AILOTs in ADB, in line with Dame Judith Hackitt’s recommendation, to restrict the use of assessments in lieu of tests.

The Government’s response to the consultation is set out in Section 4 of the document and clause 71 (copied in italics below) states that assessments should not be used to justify the performance of Glass Reinforced Plastic (GRP) composite material fire doors.

71. The Government has also made clear in advice issued in the Summer that assessments should not be used to justify the performance of Glass Reinforced Plastic (GRP) composite material fire doors – standards clearly say that tests should be carried out. Since then, the industry has removed from the market doors which it could not demonstrate met the required fire test standards. The industry has committed to only reintroducing GRP composite fire doors to the market where full test evidence is available. This has had an impact on the number of AILOTS undertaken for GRP composite fire doors.

As of 18 December 2018, therefore, Warringtonfire (WF) and BM TRADA (BMT) will no longer be producing AILOTs for GRP composite material door designs and will not revalidate or update existing AILOTs for this type of door construction.

Until further notice, WF and BMT will be following the advice from the Government that only relevant British Standard (BS) or European Normative (EN) fire test evidence is acceptable for demonstrating the fire resistance performance of GRP composite material fire doors.

To clarify, our understanding from the paper issued by the Government is that the ban on AILOTs applies only to GRP composite material fire doors. Therefore, it is expected that AILOTs can still be used to support the fire resistance of doorsets that do not contain GRP composite materials.

As you know WF and BMT recognise the importance of assessments for the composite door industry, and are seeking urgent clarification from MHCLG on this issue, particularly in relation to the impact of removing AILOTs that are used within third party certification schemes.

However, until we receive clarification from MHCLG on how we can move forward with AILOTs on GRP composite material fire doors we are advising our customers that hold third party certification under Q-Mark and Certifire of the following:
 

1. Assessments on GRP Composite Material fire doors can no longer be listed on the manufacturer’s scope of certification.

2. Manufacturers can continue to manufacture GRP composite material fire doors under third party certification but only if the designs are the same as the supporting test evidence (no variations permitted at all i.e. size, shape, design, specifications, hardware etc.) and the test evidence is listed on the manufacturers scope of certification

3. Only doors that are identical as the relevant tested design, as detailed in the test evidence listed on the manufacturers scope of certification, can be labelled or plugged according to the requirements of the relevant third party certification scheme, as appropriate

4. Manufacturers under Q-Mark and Certifire will need to request having GRP Composite Material fire door assessments removed from their scope of certification and supply the test evidence that they would like to have listed on their scope

We acknowledge the impact of restricting the use of AILOTs on the composite door industry and have made the case to MHCLG on the importance of AILOTs (including assessments with greatly reduced scope) through the Association of Composite Door Manufacturers (ACDM) but MHCLG have made their position clear and we are presented with little choice but to cease producing assessments, and allowing assessments as suitable supporting documents for manufacturing GRP composite material fire doors under our third party certification schemes, until we receive further clarification.

One possible option that exists for GRP composite material doors that have been tested to the BS EN 1634-1 test standard is to have a classification report written that includes a direct field of application using the rules in BS EN 1634-1. The rules are limited but do allow smaller and bigger doors to be constructed (subject to tested performance) and providing the door leaves are constructed using the same specification (other than the leaf dimensions).  Should you take this route, the classification report would also need to be included within your scope of certification for it to be compliant with Q-Mark or Certifire certification schemes.

In the Government response to the consultation on AILOTs and in the proposed amendments to Approved Document B there is a steer towards the use of Extended Application (EXAP) standards for extending the scope of application of construction products, where an EXAP standard exists. Unfortunately the EXAP standard for composite fire doors has not yet been finalised and we are therefore unable to look at the EXAP route until the standard is ready.  

We will keep you updated on any developments regarding AILOTs and composite door designs as soon as we have had feedback from MHCLG.

We have written to the MHCLG and ACDM explaining our position and have offered assistance in trying to resolve this issue.

Please feel free to contact us on any of the issues raised in this communication and we will do our best to assist.

Kind regards, 

Karen Prendergast - Divisional Director Certification