BSR Gateways – Challenge and Opportunity for Door Manufacturers
The Building Safety Regulator (BSR), grounded in the rigorous “nothing assumed” safety culture of the HSE, represents a fundamental shift in the construction industry.
This deliberate ‘fresh start’ has certainly been a major cultural shakeup, creating a steep learning curve as both the new regulator and seasoned construction professionals implement the new regime.
The shift represents a challenge and opportunity for doorset manufacturers to embrace their role as compliance partners – not merely product suppliers.
How can the Fire Door industry help unlock stalled building projects, prevent delays to Gateway 2 and 3 sign-off, and get more developers up to speed with new duties, processes and standards?
Here are the specific considerations for fire door manufacturers and suppliers – and a strategy to become their customer’s Number One by accelerating their projects safely through Gateways 2 and 3.
BSR Considerations for Fire Door Manufacturers
The BSR does not just check whether doors are fitted where they should be; it also checks that the statements made by the developer are backed up by the manufacturer/supplier. The Principal Designer has to be able to demonstrate that the manufacturer’s Declaration of Performance (DoP), third-party certification, and the product’s field of application meet the requirements of Building Control.
The Major Shifts 2022-2029
From design meetings to the building site, everything feels different since the BSA came into law. With the transfer of Building Control to a newly formed authority, it’s been more than an update to the rules. The new methodology is a binary “prove it or stop” approach, where nothing starts until everything is agreed.
There have been significant delays in large construction projects caused by the lack of licensed Building Control inspectors – and this is likely to replicate itself in the availability of competence-proven fire-door installers.
Some of the significant changes that are impacting construction product manufacturers now are:
New, super-regulator
The BSR is the sole Building Control Authority for high-risk buildings (HRBs), removing the ability to ‘shop around’. The BSR operates on a zero-tolerance, highly detailed approach, which has caused Gateway delays due to insufficient resources – namely, competent and experienced inspectors.
Removal of BS 476 standard
Nationally-approved BS standards such as BS 476 are being replaced by EN standards, such as BS EN 1634. This will provide a single approval route throughout the GB and EU markets, bringing clarity and consistency. However, it means a huge amount of new test infrastructure and training is required, if all BS476-compliant products are to be re-tested to BS EN 1634.
Detailed Specifics From Design Stage Onwards
It’s no longer good enough for architects to use loose terms, such as “or similar approved” in specifications. Early correspondence between architects/developers and manufacturers is crucial to avoiding delays at later Gateway stages.
Pre-built Modules
The construction industry is moving away from onsite “assemblies” (buying a leaf here, a closer there, and hinges from a third supplier) toward offsite-made BS EN 1634 certified doorsets. In turn, manufacturers of these doorsets are finding that complete fire-rated ironmongery sets, such as door-closer kits, can expedite product development and BSR/Client acceptance. In the same way that doorset manufacturers can offer factory-controlled processes and clear certification, sourcing hardware suites that are similarly verified is becoming the foundation of many approved doorsets.
Legal Clarity on Roles & Responsibilities
The new duty-holder regime puts a strict legal responsibility of the Client, Principal Designer, and Principal Contractor to plan, manage and monitor. This involves earlier requests for product compliance scope (specification stage), monitoring to ensure the delivered and installed product is correct, and managing any necessary changes. The aim is to prevent product substitutes, which can nevertheless arise from supply chain disruptions, or product lines being discontinued. Manufacturers should plan and communicate product updates well in advance. Supply chain compliance, factory control processes, documentation, type testing, and product labelling should be vetted by a third party to provide assurance of compliance.
What’s Next?
The Government are still working through the recommendations of the Grenfell Report, and future updates are expected, including:
Construction Products Reform. New legislation is expected 2027 – 2029 to make the BSR responsible for conformity assessment and certification of fire-rated products such as fire-doors. It is likely that the BSR will require more information than the final test certificate, such as actual results, testing history, and any circumstances that might affect product performance.
Approved Doc B updates. The Government is still working on updates to the Building Regulations Approved Document B (Fire Safety). The revision is due to be implemented by 2029.
- Fire Engineers. It is proposed that registered Fire Engineers are mandated for HRB projects. One of their roles is to consider how vulnerable people are protected during a fire or evacuation. Firedoors are heavy and designed to close quickly and firmly, which can pose issues for people who are less physically able. Working with Fire Engineers, architects, and the BSR, the industry can provide fire doors adaptable to the (potentially unique) needs of buildings and their individual occupiers. Cam action slide-arm closers are often easier to open than scissor arm closers, while specialist electromagnetic closers like the Rutland Responder24 can operate in swing-free or hold-open modes until the fire alarm is activated.
Gateway 3 | Regulation 38 (Handover)
Gateway 3 is designed as a hard stop to ensure that the ‘as-built’ property meets the standards of Building Control and the approved Gate 1 strategy. No residential HRB can be occupied until the BSR has confirmed that the approved Gateway 1 and 2 strategies and specifications have been adhered to. Furthermore, the developer must sign a declaration attesting to the building’s safety and compliance. In addition to clarifying the legality of the build, this formal handover provides the building owner/manager with the information they need to know – the Golden Thread principle.
The principle of maintaining a “Golden Thread” of digital information requires the client to provide a digital record of every detail of the building’s construction. This is updated throughout the entire lifetime of the building by the legally accountable person.
The Golden Thread includes every single fire door. The building’s Principal Accountable Person (PAP) will need:
- Fire Rating Evidence: The specific test report or third-party certification (e.g., Certifire, BM TRADA) relevant to that specific product configuration and its field of application.
- Component List: Exact specs for intumescent strips, smoke seals, closers, and hinges. The developer and the BSR will want to check that these details match the specification signed off at Gateway 2.
- Installation Records: Evidence of who installed it (competence) and photos of the installation (especially hidden elements like the gap between the frame and the wall before architraves are fitted).
- Change records: Where a product, system or installation has differed from the Gateway 2 approval, this change must be justified and recorded in the Golden Thread.
- Condition Tracking: By adding a unique code to each door, the PAP can ensure that inspections and maintenance are ongoing, keeping the Golden Thread updated for each individual building component. Damaged or worn components can then be replaced with the correct part, ensuring the doors remain fit for purpose. Some clients will want to use their own identification system, which might relate to a specific location, e.g., Lvl1-Flat04-Ent, but some door manufacturers supplement this with their own factory-set serial code.
The client must confirm that the fire doors as installed match the fire strategy. While the final client is responsible, their door supplier can be a big help:
- Installation instructions. Provide clear instructions on fitting, especially the maximum allowed gap size between door frame and structural opening, and how this should be filled. These details will have been recorded in the product testing and certification stages and should be adhered to.
- Competency: Remind clients of the need for competent fitters and consider offering training for your product range. Passing on knowledge from the supply chain to the contractor/s is essential, which is why Rutland offer their customers and the wider industry
- Avoid the blame game. Imagine if the strategy required FD30S (smoke sealed) and you shipped FD30 (no smoke seal) in error. The fitter might not notice, leading to Gateway 3 being rejected. Disasters usually arise from a series of errors; make sure they don’t start with you.
Many major projects get held up by the BSR due to a lack of evidence, often because information isn’t passed along the chain in a timely and orderly way. Make sure you, as the door manufacturer, contribute to successful project completion and handover – with early engagement, attention to detail, open collaboration; and cross-checking everything.
Discuss how Rutland can support your compliance and fire door development journey, call us today for guidance and solutions for door hardware fire-rating compliance.
