IFSA Response to DLUC Consultation on Amendments to ADB – Proposals to Remove BS476 Tests from Regulations

The UK Government proposes to substantially amend Approved Document B from a fire safety perspective, specifically by removing the national classification system for construction products and requiring relevant testing to the British Standard version of the European Standard. The effect will be to remove all BS 476 tests, including fire resistance, from National Regulations.

IFSA believes that this could have hugely detrimental consequences for those companies that have already registered their product ranges to existing BS 476 standards, necessitating a very time consuming and costly revalidation to the European standards.

The fundamental basis of our concerns is the removal from Approved Document B of the national classifications for fire resistance, with a 12 months transition period, which we believe would be too short a time to allow the industry to adapt to the changes.

Some companies have accumulated test evidence against British Standards over decades and if this were rendered unusable by the changes then significant re-investment in testing would be required to permit those scopes to be maintained. The number of Fire Resistance tests required would increase dramatically following the amendment, and since it can take up to 6 months to book a fire resistance test (or longer for some types of test), and fire resistance test reports taking up to a further 6 months before they are issued then 12 months would be insufficient time given the volume of tests required.

For many products the European Classification route to market is not in place, and for some bespoke systems, e.g. architectural and specialist door assemblies, this route is unlikely to ever be in place.

National classification is the requirement for a level of fire resistance, for example, 30 minutes integrity performance, which can be achieved by means of test or Technical Assessment in accordance with the Passive Fire Protection Forum (PFPF): ‘Guide to Undertaking Technical Assessments of Fire Performance of Construction Products Based on Fire Test Evidence, 2021, Industry Standard Procedure’.

It is IFSA’s view that if the proposed amendment to Approved Document B proceeds then :

  • a transition period of 10 years would be a reasonable time frame in order to allow for the increased quantity of testing required
  • the requirement for additional tests would be a significant investment in testing, and while this may be a manageable cost for a large business, it may well an unsustainable expense for small or medium enterprises.
  • relying entirely on the European classification would not allow the types of bespoke designs currently produced by British architects to be used in prestigious buildings in the UK, as it is not designed to be used for Technical Assessments; if these were no longer permitted the UK bespoke fire door industry would largely disappear
  • the existing performance related route should be maintained and that the wording chosen should allow for the continued use of Technical Assessments in accordance with the PFPF Guide based upon fire resistance periods

IFSA has submitted this view as part of the consultation process.

For further information in relation to IFSA’s activities please contact the association (email: contactus@ifsa.org.uk; website: www.ifsa.org.uk).

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