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NSW: Q&A Apartment fire door regulations – Compliance, Access

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We’ve received the following questions from lot owners specifically concerning fire door regulations in NSW. Is the installation of security and screen doors is permitted? Do I need approval from the owners corporation to change my front door lock?

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Question: We have a small storeroom which is 1.5 metres square. Does this need a fire door? The building is eight floors high. The storeroom opens onto a wide internal roadway.

Answer: There are likely 50+ reasons why it might require a fire door, so I recommend they contact their fire contractor.

If it’s completely sealed with masonry and/or fire rated materials from above, below and into any other fire compartment other than the hallway/roadway and does not contain electrical equipment, it probably does not require a fire door.

But … there are likely 50+ reasons why it might require a fire door, so I recommend they contact their fire contractor or engage an expert to assess and provide an accurate opinion.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #671.

Question: Our front door cannot be left unlocked from inside the unit. Is this a fire or safety hazard?

We moved into a unit in a relatively new complex. We can enter and exit the unit freely but cannot leave the door unlocked from the inside. I assume the door is a fire door.

Is this a door handle issue or a fire hazard or other safety concern? I know strata has a responsibility to fix common property, but I have to go through my agent to get the work done, and they are dragging their feet. If I could prove the inability to leave the door unlocked from the inside is a fire hazard, it might prompt the agent to respond faster.

Answer: As long as the fire door closes and latches automatically (and the lock matches the fire door set), the fire guys will be good with it.

Owners and residents may choose (or not choose) to lock themselves inside or outside however they like. As long as the fire door closes and latches automatically (and the lock matches the fire door set), the fire guys will be good with it.

Everyone has a right to secure themselves in their home, so within reason, you may choose to modify the locking setup to suit your needs but, you should do so knowing that the door and lock are common property and, therefore, any modification should be with the permission of the owners corporation.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #657.

Question: Our apartment door no longer automatically closes. Would this be a breach of fire safety?

I live in an apartment on the ground floor next to the main entrance. The closer on the apartment door is missing the bolt and does not automatically close. As the door does not work as it should, would this be considered a breach of fire safety in NSW? We repeatedly asked for this to be fixed. Our strata manager and building manager ignore us.

Answer: The door’s ability to self-close is of key importance to preventing fire from spreading throughout a building.

If the entrance door is a fire door (identified by a fire door tag on the hinge side of the door), not closing is indeed a breach of fire safety in NSW. The door’s ability to self-close is of key importance to preventing fire from spreading throughout a building.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #654.

Question: Are there regulations regarding the combustibility of decorative items in foyers of NSW apartment buildings? Our strata manager has instructed that all decorative items such as tables and paintings must be removed.

I live in an 8-floor apartment building with 3 units per floor.

What are the strata fire regulations regarding decorative items in the foyers of each floor of a NSW apartment building?

We had one or two pictures on the walls, small metal hallway tables with small decorator items such as vases and in the alcove off the foyer on our level there was a round table with a table cloth and a vase with fake flowers.

Our Strata Manager has told us that no decorative items can be placed in common property areas of the building and all items need to be removed. This includes carpet mats in front of apartment doors and the lift door as that could be a “fire hazard”.

Are there regulations regarding the combustibility of decorative items in foyers?

Answer: If the common area is part of the egress pathway and the building reasonably new, likely this is reasonable.

My answer would need to be very contextual to building age, size and specific regulations referenced.

If the building’s AFSS references ‘fire hazard indices’ or similar, then it must have been a condition of building approval and strata is likely correct in removing them.

If the common area is part of the egress pathway and the building reasonably new, then also likely this is reasonable.

Ask your strata manager for clarification of the regulation requiring this and then if not satisfied, resubmit your question stating the exact regulation so we can provide more accurate information.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #632.

Question: A fire door was installed around 25 months ago and is now warped beyond repair. Would it be covered by a warranty?

Are builders warranties strictly adhered to, or is there a fair and reasonable expectation things will last beyond a warranty period as is the case with something like a new fridge?

Our strata had a fire door replaced 25 months ago. The door is now so warped that it impossible to shut over the weekend and needs replacing. We will attempt to get this done by the builder who replaced it. Are the responsible for replacing the door under a warranty period?

Answer: I don’t see it is likely to be covered by warranty.

Sorry to the owners, but I don’t see it is likely to be covered by warranty as it’s outside the 2 years applicable to new construction and (usually) 1 year offered by maintenance installers.

That said – doors do not just magically warp and certainly not over a weekend (unless they were burnt or covered in water).

If the door is in a wet area, is situated close to steam or has ever been wet, the owners should look into ensuring the correct door for the usage is installed.

If the owners believe otherwise, perhaps seek legal advice.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the February 2023 edition of The NSW Strata Magazine.

Question: Do I need approval to change the lock on my fire door? If so, what lock can I use?

We’ve been told the door to our apartment is a fire door and part of the common property. Can I change the lock on the door? Do I need approval to change the lock? What lock can I use so that the door is still fire safe and compliant?

Answer: You must get permission from strata. The lock has to be one that is approved for use with that fire door.

The door is owned by the owners corporation and is common property. It is not owned by the lot owner. We all have a right to secure our own premises. These two things conflict a little, but in simple terms, your door is owned by the strata. If you wish to modify it in any way, you must get permission from strata and that includes changing the lock.

What can you use? The lock has to be one that is approved for use with that fire door. You really need to go back to the door manufacturer and find out what locks have been approved for use on that door or on that tested example.

When doors are originally put to market, they are type tested. The door is fitted with individual locks and closers and all the things that might be attached to a door and then it’s fired up in a furnace and they burn it to see whether it will work. So, if it’s a fire door, the lock must match the door type and model and be tested with that type and model of door.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the December 2022 edition of The NSW Strata Magazine.

Question: Our lift is not working. The fire stairwells have fire doors. Can these doors be left open to allow easy access for residents until the lift is functional again?

Answer: Fire doors cannot be left open as this destroys the compartmentalisation between levels.

Fire doors cannot be left open as this destroys the compartmentalisation between levels. This means that if a fire occurred on level 1, the smoke would fill the stairs, blocking safe egress for all other residents. A highly dangerous situation.

In this situation, we would recommend one of the following:

  1. Have a locksmith temporarily change the doors to non-lockable (they must still close and latch) and the fire rating of the door should not be impacted.

  2. If the building has a smoke detection system fitted, magnetic door holders could be fitted to the doors allowing them to remain open, but close automatically on fire or smoke. This means the doors can remain open whenever you want for egress. The down-side is that it would not be cheap.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the October 2022 edition of The NSW Strata Magazine.

Question: Do we need approval to change the lock on a fire door? This door is the main door to our apartment. What lock can we use?

We have been told the door to our apartment is a fire door and part of the common property. We have a master key system.

Can I change the lock on the door? As the door will not longer be opened by the master key, do I need approval to change the lock? What lock can I use so the door is still fire safe?

Answer: Answer: If you wish to modify the fire door in any way, you must get permission from strata. That includes changing the lock.

The Residential Tenancies Act/Regulation provides the right for lot owners to secure their own premises, but that conflicts with fire door standards. In simple terms, your door is owned by strata, not by you, therefore, if you wish to modify it in any way, you must get permission from strata. That includes changing the lock.

What can you use? The lock has to be one that is approved for use with that fire door.

You really need to go back to the door manufacturer to find out what locks have been approved for use on that door or on that tested example. When doors are originally put to market, they are type tested. The tested doorset is essentially one version of that with specific locks and closers and all the things that might be attached to a door are put on and then it’s fired up in a furnace and burnt to see whether it will work in a fire. This means the lock that you put on, even if it’s approved for a fire door, must match the door type and model you have installed. I know that the Lockwood 001 and 003 series are pretty much approved on every single door set that I’ve ever seen, but you really need to check first.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

TThis post appears in the August 2022 edition of The NSW Strata Magazine.

Question: We have old cabling in our 1930s building. Surely this is a fire risk. How can I get this actioned?

I live in an Art Deco building built in the 1930s. There are 5 units in the Building that have had rewired done in the ceilings. The committee is sitting on the decisions to carry out the rewiring in the remaining 7 units.

Surely this poses a fire safety risk? How can I ensure the repairs are completed as soon as possible?

Answer: Take action via the owners corporation and strata to push the need to finalise this upgrade by making sure everyone understands the dangers of old cabling.

I would love to give you a simple answer to that one. Back in the 1930’s most wiring was copper wrapped in tar and Canvas. Highly flammable stuff wrapped around an electrical wire that is likely to heat up if load is applied to it – particularly in winter! Yes, it probably does pose a safety risk.

From a fire safety perspective, there is nothing in the fire safety inspections or legislation that says anyone should be inspecting or enforcing it. The requirement to do it is the owners corporation’s choice.

The only other enforcement angle for that is via Council or the fire brigade, putting a fire order on the building, which will get enforced. Though, the blowback for what else they may require you to do may not be pleasant. This is because the Council’s job in New South Wales under the legislation is to bring every building up to a current level of life safety, which is a pretty broad statement. This essentially means if they end up in your building and give you a fire order, you may end up with lots more fire protection systems than was required or installed in your building in the 1930s. This is obviously a great thing for safety and peace-of-mind, but often comes with a substantial financial burden.

I would suggest that your action should be via the owners corporation and strata to push the need to finalise this upgrade by making sure everyone understands the dangers of old cabling. There’s quite a lot of information on the internet regarding old cables and the risks associated with them.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the July 2022 edition of The NSW Strata Magazine.

Question: Residents in my building continually wedge a fire exit door open so they can re-enter the building. What are the regulations?

I live in a residential apartment building that was originally a retirement home. There is a fire exit door on my level. Residents continually wedge the door open so they can re-enter as it is locked from the outside.

The exit leads to an outdoor stairway onto the carpark and has a security camera and intercom installed by the original owners. The door has also been fitted with some type of magnetic release mechanism with a switch next to the door. None of these functions are operational.

I proposed we provide a key to the door and repair the security camera. This will prevent the current security and fire safety hazards, while allowing residents access to the building. What are the regulations for this situation?

Answer: Fire exit doors are required to be unlocked in the direction of travel – e.g. anyone can escape the building safely, but the residents are free to chock it open.

The first thing to note here is the difference between a “fire door” and a “fire exit door”.

If it is a fire exit door, the key requirement is being unlocked in the direction of travel – e.g. anyone can escape the building safely, but the residents are free to chock it open. Security concerns are unrelated to fire and should be dealt with via strata.

If it is a fire door (has a metal tag stating this on the edge of door & frame), the key requirements are being fire rated, automatically closing and latching to prevent fire spreading through the opening and it may not be chocked open (unless you have magnetic hold-open devices fitted that release upon fire alarm).

This is quite hard to answer definitively without the exact location and context, but hope this helps!

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #574.

Question: Our fire doors have been identified as containing asbestos. Who enforces remediation?

In our strata complex, we had an asbestos incident with our fire doors. They tested positive for asbestos. We’ve found enforcement a problem. Safe Work New South Wales were only interested while the tradesperson was there. As it is no longer classed as a workforce, they are not concerned about remediation.

We found that the Environmental Protection Authority (EPA) was only interested in any public property areas and Council was only interested in council areas. How is it possible to enforce remediation?

Answer: Engage a hygienist to formulate a remediation action plan.

If you engage a hygienist they normally formulate a remediation action plan and the safe removal of asbestos and identify the areas. The hygienist will recommend whether air monitoring is required. Once they have provided identification and a scope of work to have the asbestos removed, they also need to notified SafeWork New South Wales.

Once the remediation works are complete, it needs to be signed off by that hygienist to confirm it is safe and asbestos has been removed. The hygienist will confirm it is safe to reoccupy.

Ryan Richards
Sedgwick
E: [email protected]
P: 1300 735 720

This post appears in the April 2022 edition of The NSW Strata Magazine.

Question: I am concerned about security in my apartment and would like to install a deadlock on my front door. To comply with fire door safety regulations, do I require approval from the owners corporation?

Answer: The front door and the lock are traditionally common property, so you definitely require approval from the owners corporation.

The front door and the lock are traditionally common property, so you definitely require approval from the owners corporation to modify it.

Once approved, if the door is fire rated, you will also need to select a lock that is approved for fitment on that particular model of fire door.

I’d suggest you use the word “deadlatch” in lieu of “deadlock” as whatever locking mechanism you choose, it must not prevent the door from closing & latching automatically. Deadlocks and deadbolts often do not allow this.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the February 2022 edition of The NSW Strata Magazine.

Question: Are the doors on an exterior cupboard an isolation switch for the common area power and lights, plus Foxtel and NBN connections required to be fire doors?

We are a small strata with 3 units. On the exterior of the building is a cupboard containing an isolation switch for the common area power and lights, plus Foxtel and NBN connections. The main switchboard and meters for the units are located elsewhere.

Are the doors on this cupboard required to be fire doors?

Answer: There is no need to protect the outside world from the switchboard risk.

The main switchboard if outside are unlikely to need to be fire doors as there is no need to protect the outside world from the switchboard risk.

It is only inside switchboards & even then, only if in a path of travel or in their own room where they are likely to require fire rating with such a small block.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #531.

Question: Can a lot owner use the fire stairs and fire isolation area for access to their terrace when carrying out renovation works? This includes access by tradespeople and the removal of building rubble.

Answer: As long as the fire stair is not obstructed and the fire doors are not chocked open

As long as the fire stair is not obstructed and the fire doors remain closed (not chocked open) when not transiting through them, I don’t see any issue from a fire safety perspective.

I think the person who should be asked is the strata manager and conditions placed on the fire stair’s use and terms put in place if there is any damage & clean-up required.

This advice is on the assumption that construction work is permitted under legislation and the public health orders in-place at the time.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the October 2021 edition of The NSW Strata Magazine.

Question: Our building is looking at installing electronic smart locks on all apartment doors. What do we have to be aware of regarding fire safety and access? Are they allowed, and do the locks have to be certified to ensure they comply with fire safety standards?

Answer: All fire doors, including their hardware (e.g. closer & locks) must be type tested

Electronic smart locks are not precluded from being used on fire doors to apartments; however, all fire doors, including their hardware (e.g. closer & locks) must be type tested. This means – during the approval process for any door, it gets burnt in a testing facility’s furnace to check the fire resistance level of the fire door meets a particular Fire Resistance Level or FRL.

The owners should first check with the manufacturer of the door (look for a phone number on the door tag) whether there is an electronic smart lock approved for that door type and size.

If the manufacturer does not have this on file or is uncontactable, the Australian Standard for Fire Door installation – AS1905.1-2005 states: “A different lockset shall only be substituted for the lockset on the tested specimen if it has been subjected to the fire resistance test on a doorset of similar construction, or if the essential latching components from the same manufacturer are substituted by those constructed from materials of greater or equal melting point”.

Hence, if you can get a certificate from the lock manufacturer stating the lock has been tested successfully on a similarly rated fire door (FRL -/60/30 is the term to look for), you could use them on the apartment doors.

We highly recommend you show the documentation and gain advice from your Accredited Practitioner (Fire Safety) prior to undertaking the works.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the September 2021 edition of The NSW Strata Magazine.

Question: Do townhouses need to meet the same fire safety standards as apartment buildings?

I’m looking at purchasing a townhouse which is under a strata scheme. The building was built in 1994. 

Do townhouses need to meet the same fire safety standards as apartment buildings with regards to fire safety doors, fire hydrants etc.? 

Would a building built in 1994 generally meet the fire safety standards? I know older buildings tend to have issues.

Answer: Townhouses are a different classification to an apartment buildings

Every multi-occupancy building post-1988 should require an annual fire safety statement. Every residential occupancy should have a working smoke alarm.

Townhouses are a different classification to an apartment; require fire safety systems, but generally require less than an apartment building.

It is impossible to state whether a townhouse generally meets the fire safety standards without having inspected it, but further to the above, the fire safety systems are generally fewer than the equivalent apartment building & therefore there is less to go wrong. That said, due to the lesser requirements, there is lesser chance the systems in a townhouse have been maintained.

To summarise – how long is a piece of string?

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the August 2021 edition of The NSW Strata Magazine.

Question: I have an apartment in a resort. My entrance door is fireproof. Do all inside doors (e.g. like a bedroom door) or other doors inside the lot also need to be fireproof? 

Answer: The only doors for an apartment that need to be fire rated are the ones between the apartment & common areas.

The only doors for an apartment that need to be fire rated are the ones between the apartment & common areas (&/or doors between apartments if it’s a resort with that setup).

Doors inside the apartment do not require fire rating as they are deemed to be within the same fire compartment.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #495.

Question: How can I determine what fire measures are needed for our small building as per the NSW fire regulations?

I am the strata treasurer. We are undergoing a fire safety inspection in Newcastle NSW on a 2 level complex with 6 units. We have a car park underneath plus 2 units and 4 units directly above.

How can I determine what fire measures are needed for our small building as per the NSW fire regulations?

We have fire shutters that a new fire group have said are faulty and we have had secondary advice from a fire shutter contractor who stated that it would cost $2K just to do an inspection not including any additional costs for any repairs. We are seeking 2 other quotes from other contractors.

I can’t find any information on the NSW planning website regarding what is required for our type of strata building.

Do you have any suggestions or possibly a checklist?

Answer: The closest thing to a list is the schedule of Essential Fire Safety Measures contained within the building’s Annual Fire Safety Statement (AFSS).

There is no checklist for each property type. The “list” is set by the Building code of Australia at the time of construction and put in place by the certifier, so most buildings are different.

The closest thing to a list is the schedule of Essential Fire Safety Measures contained within the building’s Annual Fire Safety Statement (AFSS).

If the AFSS says you need fire shutters, then you must maintain them on your building. If it doesn’t list them, the answer may be different.

Fire Shutters are often proprietary equipment tested for the application. Most often you have to go back to the manufacturer or design documentation to determine their performance requirements.

Aside from the inspection itself, the research & therefore PI risk in deciding to endorse (sign-off) performance annually can be extensive.

Suggest asking the fire contractor for evidence outlining why the shutters are faulty plus how and what they used as guidelines to assess performance. If they provide this, their opinion should likely be relied upon.

If the contractor cannot provide the workings of how they made the performance assessment, then the owners would be best engaging an alternate contractor – preferably the manufacturer or specialist in those specific shutters.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the July 2021 edition of The NSW Strata Magazine.

Question: How does a holiday renter know that the door is a fire door and cannot be chocked open if there is no sign?

For a lot that has an entry door being a prescribed fire door, and being a lot that is short-term rented, are there NSW apartment fire door regulations requiring a sign to be attached to the inside of that door letting occupiers know it is a fire door and fire doors cannot be chocked open? 

The penalty for a chocked open fire door is a penalty imposed upon the owner of the door which means the owners corporation cops the fine as it is the owner of the door. 

How does a holiday renter know that the door is a fire door and cannot be chocked open if there is no sign?

Answer: The requirement for signage of fire doors is found in the Building Code of Australia

The requirement for signage of fire doors is found in the Building Code of Australia as follows:

 D2.23  Signs on doors

  1. A sign, to alert persons that the operation of certain doors must not be impaired, must be installed where it can readily be seen on, or adjacent to—
  1. a required—

    (A) fire door providing direct access to a fire-isolated exit, except a door providing direct egress from a sole- occupancy unit in a Class 2 or 3 building or Class 4 part of a building; and

    (B) smoke door,

    on the side of the door that faces a person seeking egress and, if the door is fitted with a device for holding it in the open position, on either the wall adjacent to the doorway or both sides of the door; and

  2. a—

    (A) fire door forming part of a horizontal exit; and

    (B) smoke door that swings in both directions; and

    (C) door leading from a fire isolated exit to a road or open space, on each side of the door.

The requirement does not extend to sole-occupancy unit doors, however the requirement to ensure that the operation of said door remains in place. There is no reason why signage cannot be erected or stickers applied as a best practice measure should the Owners Corporation so decide either on the doors or in the corridors or lobbies or at the top or bottom of the main stairs.

Fire and Rescue NSW have created this fire safety brochure: Fire and Rescue NSW: Fire Safety in High-Rise Buildings Perhaps this could be prominently displayed at the building or circulated to occupiers or be part of the information supplied to holiday renters.

We understand the following as per the Building Code of Australia

A6.0 Determining a building classification

  1. The classification of a building or part of a building is determined by the purpose for which it is designed, constructed or adapted to be used.

A6.2 Class 2 buildings

  1. A Class 2 building is a building containing two or more sole-occupancy units.

  2. Each sole-occupancy unit in a Class 2 building is a separate dwelling.

A6.3 Class 3 buildings

A Class 3 building is a residential building providing long-term or transient accommodation for a number of unrelated persons, including the following:

  1. A boarding house, guest house, hostel, lodging house or backpacker accommodation.

  2. A residential part of a hotel or motel.

  3. A residential part of a school.

  4. Accommodation for the aged, children, or people with disability.

  5. A residential part of a health-care building which accommodates members of staff.

  6. A residential part of a detention centre.

  7. A residential care building.

If the building is classified as a 2 building, which I assume it is then the fire door signage requirements are as previously stated. If it is argued that the dwelling is actually being used for another purpose, this does not reclassify the building. However even if were established that a change of use had occurred, the change would most likely be to a Class 3 which also does not require fire door signage as per BCA Volume One D2.23.

It makes absolute sense to put a sign on the back of the door, however, this will be at the discretion of the Owners and the Owners Corporation given the above.

QIA Group
E: [email protected]
P: 1300 309 201

This post appears in the June 2021 edition of The NSW Strata Magazine.

Question: Are there new fire regulations banning the installation of fabric shades on the exterior of buildings due to risks associated with flammable cladding?

We wish to install a fabric shade on our second storey balcony to block the afternoon sun. We have no flammable cladding on our building. I’ve been told there are recent fire regulations in NSW banning the installation of fabric shades in relation to cladding fires.  

Is this law real? If yes, does it apply to all buildings or just those with flammable cladding?

Answer: This is a little technical because it pertains more to changes to Building Code and Act requirements. In any event, we suggest you obtain the services of a Building Certifier who can certify that the structure meets the legislative requirements and or whether such certification is necessary.

QIA Group
E: [email protected]
P: 1300 309 201

This post appears in Strata News #480.

Question: Residents of a large strata building demanded to know if fire regulations govern whether they could use the fire exit for normal egress?

I manage a large strata complex in Sydney. Residents have been using the fire stairs on their floor to walk down to exit on the ground floor, instead of waiting for the lift.

Is this permitted under apartment fire exit regulations? My concern is that the fire exit doors are being used much more than they normally would be in emergencies only, and sometimes residents keep the fire door on the ground floor slightly open which is also a security breach.

The residents demanded to know what apartment fire door regulations governed whether they could use the fire exit for normal egress.

Answer: There isn’t a requirement that restricts the use of the stairs for emergency only. However, the big issue with your question is that people are wedging open the fire doors (I assume to sneak back up the stairs).

There isn’t a requirement that restricts the use of the stairs for emergency only. However, the big issue with your question is that people are wedging open the fire doors (I assume to sneak back up the stairs). Yes, this may be a security problem but it also creates a HUGE fire risk.

A fire door is designed and installed to close automatically to prevent the spread of smoke and fire into an area. Fire doors must always be closed unless they are held open by a device that is connected to a system that allows for the door to close automatically in the event of fire / smoke being detected.

Part of the testing of a fire door is that the closer is in place and that the fire door automatically closes and latches. In this case, having these doors held open would allow smoke and fire to enter the stairwell which is designated for emergency egress.

Chris Chatham
Linkfire
E: [email protected]
P: 1300 669 439

This post appears in Strata News #477.

Question: Who is responsible for replacing our fire door if it fails a fire audit?

The entry door to our apartment is a fire door. I don’t believe it is compliant with fire door regulations for NSW. The gaps around the doors are too wide / there is a peephole.

Who is responsible for replacing this if it fails a fire audit? The strata of the owner?

Answer: Apartment fire doors are the property of the strata plan.

Apartment fire doors are the property of the strata plan. While lot owners have a right to secure their property (fit locks, etc), they cannot do so if it impacts compliance of the fire door.

Non-compliance as identified in inspection, testing or audit, unless caused by the lot owner (e.g. fitting non-compliant locks or plastic peepholes) is strata’s responsibility.

Expand on the specific subject matter:

  • Gaps in accordance with AS1905.1 are generally average of <3mm between door & frame on sides & head & <10mm at bottom (this can vary based on door brand, core & tested sample)

  • Peepholes can be compliant or non-compliant. Depends on the model & what has been tested with that door model. Generally – 10mm or less penetration & metal construction is often acceptable.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #474.

Question: Is my entry door to my apartment a Fire Door?

Is my entry door to my apartment a Fire Door?

If YES, to comply with NSW fire door regulations, how often does my apartment entry door require inspection?

Can I fit a hold open device to my door closer on my entry door?

Answer: The apartment entry door should be a fire door

This is a difficult question to answer without any photos or physical reference, but the apartment entry door should be a fire door, yes! Albeit the question says “Is my entry door to my apartment a Fire Door ?” as opposed to ‘should it be a fire door’ but, yes, it should be a fire rated door for at least one hour.

According to AS1851 testing standard in section 12, Fire Doors are required to be tested every 6 months. However in the case of a Sole Occupancy Unit / Apartment Door it is only done annually at LinkFIRE as access often proves difficult more frequently than this.

Oftentimes, the onus is put on to the occupier to ensure any changes, deterioration or damage is reported back to the Owners Corporation Manager.

You can only install a hold open device if it is an automatic fail safe device (closes in the event of power loss or an alarm signal etc.).

Chris Chatham
Linkfire
E: [email protected]
P: 1300 669 439

This post appears in the May 2021 edition of The NSW Strata Magazine.

Question: I’m installing a thin metal bar under the entrance door of my Strata Unit to reduce the gap between the door bottom and the floor. Will this comply with the apartment fire door regulations in NSW for a Strata Unit?

Answer: The owners may consider some sort of tested fire door seal as an alternative.

Being there is little context to this, we’ve chosen to answer based on Australian Standard for Fire Doors (simplified description): AS1905.1-2005 – specifically clause 5.5.2 – excerpt below.

If the gap between the bottom of the door and the concrete under the carpet does not exceed 25mm; it is possible that a metal bar affixing the carpet to the floor will reduce the gap. The maximum gap between the metal bar and bottom of the door is generally 10mm or less.

FYI – Being that a metal strip could cause a trip hazard if being used for the purposes of reducing this gap, the owners may consider some sort of tested fire door seal as an alternative.

Note: there are many possible variances to the above as some fire doors are type-tested & approved with alternate dimensions to those in the standard.

5.5.2 Sill and floor finish

Clearances between the bottom of all door leafs and the floor shall be as follows (see Figures 1.4.1 and 5.5.2):

  1. Between the leaf and the top of any floor covering—not less than 3 mm and not more than 10 mm.

  2. Between the leaf and the top of the non-combustible sill—

    1. not more than 10 mm where there is no combustible floor covering; and

    2. not more than 25 mm where there is a combustible floor covering present.

NOTE: When the installed doorset is inspected for compliance with Item (ii), the clearance should not exceed 25 mm for the purpose of certification unless an appropriate note is made in the evidence of compliance (see Clause 6.3).

C5.5.2 In essence the maximum gap between the bottom of the door leaf and the adjacent floor covering is 10 mm. The 25 mm dimension is provided to limit the thickness of carpets and underlays to a maximum thickness of 15 mm in total. The intention of this Standard is to not allow a 25 mm gap under a door unless carpet is in the process of being installed. This is a temporary measure allowing for certification of the doorset, provided that a note is put in the evidence of compliance schedule and is checked at the first maintenance inspection regime.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in the May 2021 edition of The NSW Strata Magazine.

Question: Why are balcony doors not included in fire orders?

Answer: A balcony door generally has nothing to do with fire safety as it’s not separating fire compartments or providing emergency egress, hence, would not be included in a fire order.

A balcony door generally has nothing to do with fire safety as it’s not separating fire compartments or providing emergency egress, hence, would not be included in a fire order.

Not to say there can’t be a unique situation that might require a fire rated balcony door or egress, but I’ve not seen one in the 29 odd years I’ve been in fire protection.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #468.

Question: The original front door on my 1996 unit needs to have an intumescent door seal installed. What are the NSW fire door regulations for the installation of intumescent door seals?

I have been told I have to have an intumescent door seal installed on the front door of my unit, opening into the communal internal hall area. The door has remained the same since the unit was completed in 1996 but the fire services have decided this is now an issue.

What are the NSW fire door regulations for the installation of intumescent door seals? Is there are legal requirement for how big the gap between door and frame is allowed to be? Has this suddenly changed? Why has the door been acceptable for over 20 years and now suddenly there is a problem? Who is responsible for the costs associated with the installation of the door seal?

Answer: For fire doors, generally an intumescent seal would only need to be installed as a rectification measure if the clearances between the door leaf and frame exceed the maximum tolerances permitted under AS 1905.1.

Assuming the door is a fire door, generally, an intumescent seal would only need to be installed as a rectification measure if the clearances between the door leaf and frame exceed the maximum tolerances permitted under AS 1905.1. However, it is also worth noting that in some cases fire doors may be permitted to have clearances that exceed the tolerances outlined in AS 1905.1 if the doorsets have been tested with larger clearances and obtained approval. If that is the case, then the door manufacturer would have relevant test certificates to substantiate this. In the majority of cases though, the tolerances as listed in AS 1905.1 are applicable.

The clearances permitted by AS 1905.1 are 3mm at the top and sides of the door, and a maximum of 10mm at the bottom. This has remained the same between AS 1905.1-1990, AS/NZS 1905.1-1997, AS 1905.1-2005 and AS 1905.1-2015.

Obviously, we could not make any comment on why excessive gaps may or may not have been identified by service providers previously as we do not know the site or the circumstances.

Chris Chatham
Linkfire
E: [email protected]
P: 1300 669 439

This post appears in Strata News #463.

Question: We are wanting to install a screen door on our front door. Is it necessary to get a BCA Fire Consultant to assess this to get a tick of approval if this door is not a fire door?

We live in a strata complex of 12. This includes 10 apartments and 2 townhomes. Our lot is one of the townhomes with street frontage and direct access to our front door. This is a non fireproof front door. We also have internal access through a fire door to our garage.

We are wanting to install a screen door on the front door. We have been directed by our strata management to find a Fire Consultant to assess this to get a tick of approval. After doing a bit of googling I am wondering if this is necessary as it’s not a fire door? I’m getting a little confused!

Answer: If the door is classed as a designated exit or forming part of a Path of Travel – this would mean that the door needs to be able to freely open to allow egress without the need for keys etc.

The door is not a fire door, so it should be fine to put a screen door on.

The only potential issue would be if the door is classed as a designated exit or forming part of a Path of Travel – this would mean that the door needs to be able to freely open to allow egress without the need for keys etc. It can still be key locked from the front.

Chris Chatham
Linkfire
E: [email protected]
P: 1300 669 439

This post appears in Strata News #458.

Question: We have had a recent fire inspection. Two unit doors were deemed non-compliant with an expensive replacement cost from an inspector. Can we get a second opinion on whether this replacement is necessary or if the doors comply with fire door regulations for NSW?

We have had a recent fire inspection. Two unit doors were deemed non-compliant with an expensive replacement cost. 

Checking with the company suggested the doors did not have compliance tags even though they are likely to be the same doors as all other 8 units. 

Can we get a second opinion on whether this replacement is necessary or if the doors comply with fire door regulations for NSW? We are trying to avoid a $5000 cost for two doors in the statement process.

Answer: To certify whether a door is compliant, it must have a door tag.

To certify whether a door is compliant, it must have a door tag. Therefore, in order to find a Contractor who will certify the door, you will need to find a contractor who will install a door tag. Is there an option to go back to the original installer to re-certify? If not, it will be extremely difficult to find anyone to legally sign off on the door.

I would recommend two things:

  1. Organise a second quote to install a fire door. The cost for a new door with hardware and painting should be approximately $1,500 + GST. Seems like the incumbent contractor is charging you a high cost for your two doors.

  2. I would recommend having the doors that are tagged to be fixed to the door (not glued on). If your door tags are glued on, they will eventually fall and will be lost and you will continually find you need to replace your doors.

Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109

This post appears in the March 2021 edition of The NSW Strata Magazine.

Question: What are the regulations in NSW about individual unit fire doors that open to the outside, next to a landing?

What are the regulations in NSW about individual unit doors where they open to the outside, next to a landing? The stairs are used as access for the unit above. We have a solid core door that has been passed by fire inspection. I am trying to figure out what locks we can and can’t have to comply with apartment fire door regulations.

I imagine it may have to comply with fire mitigation door regulations.

Answer: If you have solid-core doors that are a Statutory Fire Safety Measure (is listed on your AFSS), then these doors need to be self-closing.

There are many unknowns with the scenario that will mean I can’t provide a definitive answer. However, if you have solid-core doors that are a Statutory Fire Safety Measure (is listed on your AFSS), then these doors need to be self-closing. This means the doors must have a self-closing device (door closer), and mustn’t have any hardware that would prohibit the door from fully closing. This would include:

  • deadlocks,

  • chains,

  • hold-open devices,

  • wedges, etc.

If your doors are not listed as a Statutory Fire Safety Measure, then there are no requirements about the hardware.

I recommend asking your Accredited Practitioner (Fire Safety) for advice as to whether the above requirements relate to your doors.

Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109

This post appears in Strata News #452.

Question: I have security grills in place on my bedroom windows that could not be removed during an emergency. Are there fire door regulations to have a quick release system installed to allow for a quick exit if needed?

I am the owner of a NSW ground floor strata apartment which is being rented. There are strata security grills in place on my bedroom windows but they are extremely difficult to remove and certainly cannot be done in case of emergency (fire).

I would like to know if there are legal requirements or fire door regulations to have a quick release system installed to allow for quick exit in the event of an emergency. If there is a legal requirement does the responsibility fall on me, the owner or the strata corporation?

Answer: These Security grills should meet Australian Standard AS5039 of which having keyless emergency egress is highly recommended.

The security grilles have at some point been installed for the security of residents on the ground floor either by the lot owner or the owners corporation. These Security grills should meet Australian Standard AS5039 of which having keyless emergency egress is highly recommended.

Best practice would see these security bars fitted with a quick release system or easily accessible key opening. This is recommended in the Australian Standard but is not a legislative requirement under building codes or fire and emergency planning.

Windows in a bedroom are not considered a path of travel or a required exit under the BCA (Now NCC Sec D1.2) therefore there are no requirements for windows to provide an ease of access in the event of an emergency.

Under Australian Standard 3745-2010 (Planning for Emergencies in Facilities) Owners Corporations, with the exception of townhouses and standalone houses, is to have direct access to an emergency exit or to a passageway leading to at least two different emergency exits.

The building must ensure that all Fire Safety Installations approved at time of construction (and those fitted after) including fire doors are maintained in accordance with Australian Standard 1851.

Peter Berney
Solutions in Engineering
E: [email protected]
P: 1300 136 036

This post appears in Strata News #443.

Question: Is there any requirement to have door closers fitted where the front door of a unit opens to the outside rather than into internal common property where a fire could spread to neighbouring units?

During a recent fire compliance audit, we received a corrective action report indicating that all of our solid core doors now require door closers to be fitted. This has never been reported as a defect until this year. On the report, the defect is described as a ‘non-critical defect’.

I can understand the requirement for door closers to be installed on doors that open into a stairwell / enclosed common property. However, all of the doors in our complex open to the outside, mostly to private courtyards or pathway. We were provided with an extract only from the Australian Standards that refer to fire-resistant door sets, but there is no context supplied regarding internal ‘front doors’ vs external doors. There is no mention of the external facing sliding doors which every unit has, nor did the report mention the rear doors that some units have.

Is there any requirement to have door closers fitted where the front door of a unit opens to the outside rather than into internal common property where a fire could spread to neighbouring units?

Answer: There are no Australian Standards that cover solid-core doors, only fire doors.

If the doors open directly outside, they are unlikely to be fire-rated doors or solid-core doors. There are circumstances when they are required (i.e. proximity to the boundary) and therefore I can’t comment unless I go to the building.

Additionally, there are no Australian Standards that cover solid-core doors, only fire doors.

I would recommend the Owners engage another Company that can provide more accurate information.

Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109

This post appears in Strata News #413.

Question: Our building was built in the 1970s and met all code requirements of the day. Do we need to meet current fire regulations and building codes?

Our Strata is currently investigating fire safety upgrades to meet current NSW fire regulations and building code. Our building, 3 levels including ground which is not habitable, was built in the 1970s or so and met all code requirements of the day. Is this update necessary?

Answer: As the building was built in the 70’s it would come under Ord70. This was the Standard that was adhered to at that time.

As the building was built in the 70’s it would come under Ord70. This was the Standard that was adhered to at that time.

This would mean that all compliance would remain as per the implemented design of the fire systems at that time.

Unless there has been a DA Application put in and accepted and the works have been done, then the systems would need to be bought up to the current Australian Standard and BCA regulations.

Chris Chatham
Linkfire
E: [email protected]
P: 1300 669 439

This post appears in Strata News #413.

Question: The magnetic door holder on the front door of an apartment does not comply with the fire door regulations for NSW. Why is this and when did the ruling come into effect? It has been installed for 20 years and has never been an issue.

After the last yearly fire inspection was done it was brought to our attention that the magnetic door holder/wall stopper on the front door of the apartment does not comply with fire door regulations for NSW. It is used to keep the door open so the elderly owner can bring in shopping.

Why is this is? When did this ruling come into effect as she has been in this unit for almost 20 years and it has never been an issue until now?

Answer: Fire Doors have always required to be self-closing and anything stopping the door from closing is defective.

The door in question is required to be a self-closing fire rated door. As there is a device holding the door open (and not allowing it to close) this means the fire door is defective. There is a solution available in this scenario which allows an ‘automatic-closing device’ to be installed to the door. This device is activated by the smoke detectors (and sprinkler system) and releases the door from the open position allowing the door to close.

Fire Doors have always required to be self-closing and anything stopping the door from closing is defective.

The standard which references this is Clause C3.11 of the BCA. Shown below.

  1. A door required by (0) may be automatic-closing In accordance with the following:

    1. The automatic-closing operation must be initiated by the activation of a smoke detector, or any other detector deemed suitable in accordance with AS 1670.1 if smoke detectors are unsuitable in the atmosphere, installed In accordance with the relevant provisions of AS 1670.1 and located not more than 1.5 m horizontal distance from the approach side of the doorway.

    2. Where any other required suitable fire alarm system, including a sprinkler system (other than a FPAA101D system) complying with Specification E1.5, is installed in the building, activation of the system must also initiate the automatic-closing operation.

Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109

This post appears in Strata News #407.

Question: We need to shave a little off the bottom of our entry fire door to install new floorboards. Is strata responsible for modifying or replacing the fire door, since the front fire door is common property?

I am installing floorboards in my apartment which will raise the existing floor levels, consequently, I may need to sand a few millimetres off the bottom of the entry fire door into my unit to ensure the door opens smoothly.

Is strata responsible for modifying or replacing the fire door, keeping in mind the front fire door is common property.

Answer: The Owners Corporation is not responsible to modify the front door to accommodate your renovation works.

We confirm that you are correct. The fire door is common property, however, the Owners Corporation is not responsible to modify the front door to accommodate your renovation works.

Further, you are obliged to preserve the fire safety of the building, so you should check whether the “shortened” door might compromise fire safety/meets BCA requirements.

Also, please ensure you have the proper authorisations of the Owners Corporation before you commence installation of your flooring.

Leanne Habib
Premium Strata
E: [email protected]
P: 02 9281 6440

This post appears in Strata News #385.

Question: Our 60 year old building is under a fire order. The upgrade requirements appear to comply with a standard for a new building. Do the NSW Fire & Safety Regulations take a more common sense approach to safety in older strata buildings?

I am the building manager of a 60-year-old, 28 unit residential block in Manly NSW.

We are under a fire order. The upgrade requirements appear to comply with a standard for a new building.

Are there NSW Fire & Safety Regulations that take a more common sense approach to safety in these older buildings? Can you provide some examples of items on a Fire Order for older buildings that can normally be challenged? The building is well maintained. We have a fire company doing regular inspections & reports.

An example on the fire order; we have been asked to replace the fire doors in the internal fire stairs. The handles don’t comply. The handles are a push-down lever-type but don’t have a curve on the end that helps prevent the hand sliding off the handle.

Answer: A Fire Order does allow for a bit of flexibility and we are able to negotiate with Council on some items.

Yes, a Fire Order does allow for a bit of flexibility and we are able to negotiate with Council on some items.

The examples vary significantly and each building has different characteristics that will need to be determined to present an argument to Council./p>

Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109

This post appears in Strata News #380.

Question: A chain lock has been on my entry door since I bought the unit 12 years ago. The fire company says that this does not comply with NSW fire door regulations and my door has to be replaced. Is this true?

Answer: No additions to or adjustments are allowed to be made to a fire rated door.

Based on the information supplied I assume your unit door is a “fire rated door”.

To check, there will be a Tag on the inside spine of the door. If the tag has been painted over, it should still be obvious to the hand when you touch it.

If it is a fire rated door then technically your fire company/contractor is correct in that no additions to or adjustments are allowed to be made to a fire rated door. This is so the integrity of the door is not breached and that it can still perform its intended function of stopping a fire spreading either out of or into your unit.

Other items that would negate the effectiveness of the fire rated door include peep holes or a door closer being fitted.

Peter Berney
Solutions in Engineering
E: [email protected]
P: 1300 136 036

This post appears in Strata News #378.

Question: Does the door from the only staircase in our 4 story building to the roof verandah require a fire rating? The verandah is completely outside.

My building is fixing its rooftop verandah at the top of a 4 story building (3 stories of units and ground-level parking).

I was wondering if the door from the only staircase in the building to the roof verandah must have a fire rating? What are the fire regulations when the verandah is completely outside.

Answer: The construction is unlikely to be required to be fire rated – except lower down where it bounds a unit.

This is a challenging one to answer as there are a LOT of variables applicable: age, defined height, construction type of the roof & stair, distance to property boundary, fire order or fire engineering report conditions and fire-source-features on roof level.

As it is 3-4 storey building with a single stair, we would assume it to be defined as a non-fire-isolated stair, not a ‘fire stair’ as you would find in a taller building.

As it is not technically a fire stair, the construction is unlikely to be required to be fire rated – except lower down where it bounds a unit.

Providing that the door does not open closer than 1.5m to the boundary of the property and there are no fire source features within 1.5 metres of the door itself, it seems unlikely that this door is required to be a fire door.

Happy to answer more accurately if more information about the situation were provided.

Rob Broadhead
2020 Fire Protection
E: [email protected]
P: 1300 340 210

This post appears in Strata News #376.

Question: Our Strata committee is considering a request to decorate the apartment building entry foyer. Are there any specific fire regulations or restrictions we may need to be aware of before proceeding?

I live in a new apartment building with 7 floors and 30 lots in NSW.

A suggestion has been forwarded to our building Strata committee to decorate the building entry foyer. Suggestions include wallpaper, hanging pictures, adding furniture items, etc.

The foyer has entry doors from 2 fire exit stairwells, bike storage, garage access doors, a fire control panel, a powder room access, along with the Main Street entry door.

Are you able to advise any specific fire regulations or restrictions we may need to be aware of before proceeding with this proposed aesthetic improvement?

Answer: Points to consider are the “Paths of Travel to Exits” regulations from BCA D16.

Points to consider are the “Paths of Travel to Exits” regulations from BCA D16.

Paths of Travel to Exits are to provide an unobstructed pathway for occupants travelling to an Exit.

To provide a passage to an exit that is of a width and height as specified by the Building Code of Australia.

To ensure that Paths of Travel to Exits are operational and effective, they must not be obstructed or altered in any way.

It is the responsibility of the owner to ensure that Paths of Travel to Exits are maintained in and efficient condition and kept functional at all times.

So what does this mean.

It is allowable to have pictures, plants and minimal furniture in the foyer area, it must not impede on the travel paths to exits.

Consideration must also be given to access to the Fire Indication Panel as this is a Critical Measure within the building, this must not be obstructed in any way.

Consideration must also be given to Wheelchair access.

Chris Chatham
Linkfire
E: [email protected]
P: 1300 669 439

This post appears in Strata News #369.

Question: Should the fire doors leading from each hallway into the fire escape stairwell be locked on the fire stairwell side? We have security concerns.

Our strata complex is 74 lots over 9 floors.

Should the fire doors leading from each hallway into the fire escape stairwell be locked or unlocked on the fire stairwell side? There are differences of opinions due to security concerns.

Locking the fire doors would mean that a person cannot gain access to each level of the building by simply walking up the fire stairwell and into the common areas.

Answer: If the building is over 25m in effective height, there are conditions.

If the building is over 25m in effective height, which a 9 storey building would be (3m per floor x 9 = 27m) then there are conditions. Refer to the below of Clause D2.22 of the BCA2019, which provides some exemptions.

D2.22 Re-entry from fire-isolated exits

  1. Doors of a fire-isolated exit must not be locked from the inside as follows:

    1. In a Class 9a health-care building.

    2. In a Class 9c building.

    3. In a fire-isolated exit serving any storey above an effective height of 25 m, throughout the exit.

  2. The requirements of Open link in same page(a) do not apply to a door fitted with a fail-safe device that automatically unlocks the door upon the activation of a fire alarm and—

    1. on at least every fourth storey, the doors are not able to be locked and a sign is fixed on such doors stating that re-entry is available; or

    2. an intercommunication system, or an audible or visual alarm system, operated from within the enclosure is provided near the doors and a sign is fixed adjacent to such doors explaining its purpose and method of operation.

All doors leading to the fire stairs needs to be always openable.

Clause D2.22 relates to the doors from inside the fire-isolated stairs to the common area. The purpose of having the doors unlocked is if people cannot travel the whole way down the stairs, they are able to go into the common areas.

Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109

This post appears in Strata News #360.

Question: I’ve been told that a door seal cannot be fitted to the door frame and door on my apartment due to fire door regulations for NSW. Is this correct?

I live in a unit established in 2020. The front door and door frame are missing proper rubber and sound/air proof sealing. The gap underneath the door is significant.

A building company has inspected the issue and said a seal cannot be installed to the door frame and the door due to apartment fire door regulations. I’ve previously lived in an apartment where the was developed in 2015 and both the door and frame were sealed! This stopped all sound coming from the lift lobby/corridor. Can someone advise please if this does or does not comply with NSW fire door regulations?

Answer: Smoke seals could be installed to the door if they have an adhesive backing.

Smoke seals could be installed to the door if they have an adhesive backing (no screwing into the door or frame). Just make sure the installation of the smoke seals still allow the door to fully close correctly.

The gap under the door should be no greater than 10mm.

Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109

This post appears in Strata News #352.

Question: Can Lot Owners install screen doors to their units and what requirements for NSW apartment fire door regulations need to be considered before installation?

Our fire inspection services company has decided the screen doors on the front doors of units don’t comply with NSW apartment fire door regulations. They have stated this is because when the screen doors are open, they restrict egress from units and stairs.

The screen doors were installed over 10 years ago. What legislation does this come under as my Lot Owners are not happy.

Answer: If the screen doors reduce the width of the path of travel to less than 1m, this would be a building defect.

  1. What type of screen door (if any)?

    Fire and Rescue New South Wales (FRNSW) released a guideline in 2010 Guide Sheet No. 7: Security in Apartment Complexes relating to screen
    doors. The apartment fire regulation recommendations in this paper are as follows:

    It is recommended against the fitting of security doors and security screen doors. Where occupants desire
    additional security, FRNSW recommends the following:

    • The screen door must not be fitted with any special locking device that will render the door difficult to open by FRNSW and other emergency service personnel;

    • The screen door must not compromise the integrity of the SOU’s fire rated door, including the door jamb (question 2 below);

    • The screen door must be fitted in a manner which will not impact on safe entry/egress for the occupants (question 3 below);

    • Each screen door must be fitted with a self-closing device to ensure the door always returns to a closed position and cannot be held open.

  2. How is the screen door installed?

    Typically screen doors are fixed to the door frame on both sides (hinge side requires fixing and the door strike requires a latch). Fire rated doors include the door frame and there are specific requirements about the frame construction. Unfortunately, there are no test results with screens attached to the frame and therefore to attach the screens to the fire rated frames would result in the fire rated door being defective under AS1905.1-2015.

    A solution that may be acceptable would be to fix the screen around the frame to the wall. This typically requires approval from the Building Owners as it changes the appearance of the building. Your Strata Manager will advise further.

  3. Does this screen door impede on egress?

    Clause D1.6 of the NCC2016 relates to dimensions of exits and paths of travel to exits. The common areas of buildings are classified as a path of travel. For residential buildings, the path of travel to an exit must not be less than 1m.

    If the screen doors reduce the width of the path of travel to less than 1m, this would be a building defect.

  4. Other concerns

    A typical concern with the installation of screen doors is that it increases the chances that the fire doors are propped open using a wedge-like device and therefore not allowing the door to close. This is not a building defect but it is an issue that should be discussed if screens are installed.

NB: This document only relates to the building requirements.

Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109

This post appears in Strata News #347.

Question: I want to install a security door to replace a screen door facing into an open courtyard. Our strata manager says fire door regulations may deny us having security doors on our units.

Answer: If you are replacing an existing screen door, it would indicate there are no issues with this location.

It sounds like the screen door opens directly outside, which could mean there is no requirement for Fire Doors or the screen door would fall in the path of egress.

Additionally, if you are replacing an existing screen door, that would also indicate there are no issues with this location.

Without going to the building, I can’t be certain, however, it doesn’t appear to be any issues on the installation of a screen door to a door leading directly outside.

Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109

This post appears in Strata News #299.

Question: We wish to install a doggie door in a small floor level window. Is there any mention of doggie doors in the Australian Fire Standards relating to fire regulations?

My daughter owns a ground floor unit in a pet friendly apartment block and wishes to install a doggie door in a small floor level window.

She has been given starts approval on the basis that it doesn’t breach any Australian Fire Standards.

I think they are worried that they may not comply with the standards if a number of upper level apartments were to be given the same approval.

Is there any mention of doggie doors in the Australian Fire Standards relating to fire regulations?

Answer: We would need to outline the location of the doggie door.

In order to answer this, they will need to outline the location of the doggie door.

If the doggie door was leading directly outside, this may be ok, however, some issues may arise.

However, if the location was internal and the doggie door was to be installed in a wall that separates the unit from the common areas, these walls are required to be fire-rated and therefore the location of the doggie door is not permitted.

I would recommend discussing the location with a Building Consultant so the Owners can be confident that any installation complies.

This post appears in Strata News #282.

Vincent Graham
Project Guides
E: [email protected]
P: 0476 233 109

These articles are not intended to be personal advice and you should not rely on it as a substitute for any form of advice.

Question: What are the NSW fire door regulations on fitting a security door to the front entrance door of a unit? Does this breach apartment fire door regulations?

What are the NSW fire door regulations on fitting a security door to the entrance door of a unit? Does this breach apartment fire door regulations?

A while ago in our NSW strata building, another owner and I got permission to fit security mesh doors to our balconies. However, the other lot owner also had one fitted to their entrance door which was not part of the permission.

The fire safety inspector objected but somehow this owner (who happens to be on the committee) and the Strata Manager, buried the issue. That Strata Manager has now left. My query is whether screen doors comply with apartment fire door regulations in NSW?

In case of a fire, doesn’t that hamper firefighters entering the unit? Will that affect the insurance of the building in any way?

Answer: The NSW Fire Brigade recommend against security doors being fitted and for good reason as they would hamper the fire and rescue services.

The NSW Fire Brigade recommend against security doors being fitted and for good reason as they would hamper the fire and rescue services. Also the ‘ideal’ of compartmentalisation would be lost as the fire could either start in the unit and then easily spread as it’s not being contained within the unit it started and/or enter the unit because the fire door may not be shut resulting in what could have been a preventable disaster. I can’t think of any legitimate reason to fit a security door in front of a fire door, other than to allow ventilation meaning the fire door is open meaning it is now rendered ineffective.

However in saying that and with the EP&A Regs 2000 Division 7 in mind, I do not know of any specific regulation that states unit security doors are not to be installed and I do not know if this would affect the building insurance but if this was my scheme that is the first question I’d be asking the insurers before fitting any door in front of a fire door.

Please see this FactSheet from NSW Fire and Rescue: Safe living in high rise buildings:

“The front door of your apartment should be a certified fire resistant door. Making alterations to the front door can make it unsafe in the event of a fire. Check with your building management before making alterations.”

Peter Berney
Solutions in Engineering
E: [email protected]
P: 1300 136 036

This post appears in Strata News #173.

This article is not intended to be personal advice and you should not rely on it as a substitute for any form of advice.

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Comments

  1. Edward says

    Hi Rob

    What year was the laws introduced for Fire Doors & what does it cover
    is it the
    1st the Lock
    2nd the Hinges
    3rd the Door Closuers
    4th the Frame work around the doors

    Reply

  2. Linda Kwok says

    we are currently renovated a small block of six units which is built around 1970.
    only two levels in front and three levels at the back and which is two garages on the ground level
    what is the doors requirement for this kind of property regarding fire regulation ?
    best regard
    linda

    Reply

  3. Beni Lajara says

    Hi, my door was just replaced apparently due to non-compliance. Strata says the cost is not covered by strata because “ The unit is part of the common property. But somehow, someone repaired the timber unit door; repair/installed personal dead lock on the timber door in last 20 to 30 years ago without the approval by the Owners Corporation.”
    I just bought the unit last year and nothing in any of the documents say the door is not part of strata or that it’s non compliant.
    Is it really not covered by strata?

    Thanks

    Reply

  4. Mathew says

    I am a quadriplegic, living in ground floor apartment, recently had automatic door opening system placed on my apartment door due to inability to open the heavy fire door by hand, however the rubber seal on door frame is restricting the automatic door opening system from functioning. Door gets stuck when complex door (Glass Door) is left open creating a vacuum stopping my door opening, I have asked Strata nd building manager if seal can be removed but they never respond.

    Reply

  5. peter Cavanagh says

    Fire doors have a compliance plate on the inner edge, many are not fire doors but just smoke doors.

    Reply

  6. Missy says

    I have been told I have to have an intumescent door seal installed on the front door of my unit that opens into the communal internal hall area. The door has remained the same since the unit was completed in 1996 but the fire services have only just recently decided this is now an issue. They seem to go from one issue to another issue each year in order to drum up business for themselves.
    What are the legal requirements for the installation of intumescent door seals? Is there are legal requirement for how big the gap between door and frame is allowed to be? Has this suddenly changed? Why if the door was OK for over 20 years is there suddenly a problem? Who is responsible for the costs associated with the installation of the door seal? Thanks

    Reply

  7. George Galea says

    Notwithstanding all this talk of whether security screens can or cannot be fitted to fire doorsets it has been settled by a Fire Certifier.. Screens can be fitted. Notwithstanding the building was constructed in 1974 and is in Queensland the determining factor on the fitting of screens is not determined by state legislation but by Australian Standards., and these standards apply nation wide. Hence, as a screen has been deemed ok for Qld they must be ok for all states.. And to add insult to all these writings the screen is screwed into a tagged fire door frame, has a keyed lock and has no self closer. The fire doorset gained a certificate notwithstanding all these assumed defects!

    Reply

  8. Arthur says

    Hi, I live in a unit established in 2020. The front door fame is missing proper rubber, sound/air proof sealing. So does the door and the gap under is significant. I raised the issue with the agency (it is a rental property) and they have sent a building company representative to look into defects listed. He said that seal cannot be installed to the door frame and the door due to fire safety regulations. Previously i lived in a new building developed in 2015 and both the door and frame were sealed! I loved it as there was absolutely no sound coming from the lift lobby/corridor. Can someone advise please?

    Reply

  9. ndibs says

    Hi Vince, Theodore, & all,

    In NSW the EP&A Regs require that all essential services are maintained such that performance is not degraded to less than that specified in the installation standard. The age of the building is irrelevant to that requirement, so these doors need to be assessed and serviced. Whilst a number of other States (QLD, SA, VIC) nominate the current maintenance standards (AS1851-2012, AS2293.2-1995, etc. NSW simply requires maintenance to provide minimum performance and in many cases this is actually more onerous than that of the maintenance standards.

    Reply

  10. matty V says

    1. every building should comply with the codes and standards in effect at the time of built/completion date. (there are some exceptions of course, like accessibility codes, … )
    2. otherwise not a single building would ever get compliant!!
    3. having said that if you modify, renovate, change, … anything, you must comply with the current codes and standards.
    4. your best friend is a building certifier , private certifier whom will check, survey, your building and recommend any non compliant issues and upgrades necessary
    5. seeking a second opinion always helps as in my experience certifiers tend to “translate” codes and standards differently

    Reply

  11. ndibs says

    In NSW the pre-BCA constructed buildings were covered under Ordinance 70 and the BCA Part D requirements were simply an evolution of this. SDU entry from corridors has always forbidden screen doors for such SDU’s in NSW and there is no legislation in NSW calling for the application of AS1851. The legislation instead, requires maintenance to ensure that the performance of those particular services identified in the fire safety schedule, perform at not less than the performance requirements required by the original code and standards. This can sometimes be more onerous than AS1851-2012, but AS1851 is viewed as MINIMUM best practice.
    For older SDU’s having solid core doors, these are usually cedar in the older units and they actually perform quite well in a fire test with FRL -/30/30.
    The Local Council Building Fire Surveyor can issue a fire upgrade on any building where they have cause to believe that the building is deficient and this is usually triggered by a concern raised by an occupant or visitor, or after a NSWFR response.
    Any owners corporation who endorses a lot owner to add inappropriate hardware to any SDU are taking upon the committee, responsibility for any non-compliance. In NSW the penalty for non-compliance is 300 penalty units / incident which is currently about $13,000 and this cost would be in addition to correction costs. So something to think about.

    Reply

  12. Vincent Graham says

    Hi Theodore,

    It may have been a fire door, however, given the age of the door and the fact it isn’t tagged, there will be no way to determine if it is a fire door (other than to test it which will damage the door) and therefore if you want it certified, it will need to be replaced.

    Additionally, the door of this age will likely have an asbestos core, so it might be best to have it removed if it is dilapidated.

    Regarding whether you need to replace it, this comes down to the AFSS requirements in the EPA Regs. As the building was built in 1974, you may have no requirement to issue an AFSS so there may be no requirement to maintain the ‘Essential Services’ in your building. This isn’t to say that you shouldn’t.

    If you have a Fire Safety Schedule and are issuing an AFSS, then yes you will need to maintain Fire Doors.

    I would recommend seeking assistance by a Building Surveyor to provide site specific information that you can use to plan any works.

    If your building is in Sydney, let me know and I can help out.

    Cheers

    Vince

    Reply

  13. Vincent Graham says

    Hi Ian,

    Some correct points, however some incorrect points made above. Clause D2.21 doesn’t relate to SOU doors – this is for doors in the path of egress, which doesn’t include SOU doors.

    SDU I think you mean SOU (sole occupancy unit)?

    Other than that, yes always get approval for any changes to your SOU Fire Door.

    Reply

  14. Theodore Velentzas says

    Our building apartment was built in 1974. there are no fire rated tags on the spine of the entrance doors or garage internal doors. Does this mean these doors are not fire rated. do we need to upgrade to fire rated doors or are we exempt due to its age.

    Reply

  15. Ian Childs says

    I would suggest that the advice above is somewhat deficient and the adviser appears to have limited understanding of the regulations.

    Just to put a few things in perspective. The door to your apartment (SDU) is not yours but is common property as are your balcony doors and windows etc..
    You cannot add any hardware or fitments without approval of the owners corp (additional lock, fitting a door chain, removal of door closer, etc).

    If your door opens onto any passage used for emergency exit (common corridor or passage) – you must not prop it or chock it open nor inhibit the door from closing in any way (such as stop the closer operation) as this would allow breach of fire compartmentation. You cannot add any other door to the entry door portal as this would not allow the required single handed, single action exit through that door (BCA D2.21). If you do do these things then you are in breach of the Environmental Planning & Assessment Regulations Div.7 which carries significant penalties (of currently $13k/incident).

    If we see evidence of screen doors or dead/barrelbolt multiple locksets, we cannot (nor can any CFSP) endorse for the AFSS.

    I would suggest that any exit door which can be keylocked from the inside, should always retain the key when the room/apartment is occupied. If there is a fire or emergency, you don’t want to have to search for a key.

    Reply

  16. Nick Daniels says

    Hi Nikki

    My question was more in relation to what are the fire safety requirements on a building that was built in the early 1970’s, in terms of unit doors, fire extinguishers , smoke alarms etc?. What are the legal requirements for an Owners Corporation? Or is this still a grey area?

    Thanks
    Nick

    Reply

    • Nikki Jovicic says

      Hi Nick

      The following reply from Peter Berney:

      This issue is that in 1970 the requirements were very much driven by the local council rather than any form or national regulation. The owners best stop initially is the local council as any improvement system is still driven by the local council.

      Reply

  17. Nick Daniels says

    Our building was built in the early 1970’s and we are a self-managed Strata Corporation, as such we have tried to engaged the services of a ”Fire safety Company”, who could not advise specifically what we needed or did not need to be compliant to the NSW Environmental Planning & Assessment Regulation 2000 Part 9, regarding the initial Fire Safety Installation Certificate and the Annual Fire Safety Certificate each year after.

    I was advised by them to call my local Council to get further information about our building fire safety requirements. The council had no information on this whatsoever and advised they had no staff that specifically looked after this area (Fire Safety). They then referred me to another website.

    The questions remain is do we as a Strata Corporation have to do something or not regarding the initial Fire Safety Installation Certificate & Annual Fire Safety Certificate given our building was built in the early 1970’s? and if so what are the scope of works required?

    Thanks
    Nick

    Reply

    • Nikki Jovicic says

      Hi Nick,

      We have received the following response from Peter Berney, Solutions in Engineering:

      Firstly there is no simple short answer to this question, and I hope to not bore too many with this response.

      When looking at screen doors the strata needs to consider the need or desire for them and if there are not better ways to achieve the same result. This decision ideally should be made in advance of an owner making a request as this will ensure uniformity through the building.

      Most owners will want screen doors for either improved airflow or improved security or both.

      When considering this the strata needs to take into account the following issues both positive and negative.

      · If the unit entry door is fire rated the strata must consult with their fire door maintenance company. The reason for this will be evident from the point below.

      · The overall ‘look’ of the property if screen doors are installed particularly if some owners have them installed and some don’t. Consider that the Strata may need to specify the type and colour of the door to gain some uniformity.

      · Who is paying for the door and any ongoing maintenance considering it is being installed on common property but is for the sole benefit of a single unit?

      · Safety to others in the building having due regard for the width and shape of the corridor or walkway at all unit entries, not just the unit making the request. Can others pass safety past this door if it is left open particularly in the event of an emergency? Remember that at least some screen door closers can be set to hold open, others could fail and not self-close or the closer not be installed or be removed. As the door is fitted to the outside on the door frame the handle will protrude into the corridor and may cause a safety issue even if the door is correctly closed.

      · Emergency services may have increased difficulty accessing the unit in the event of an emergency.

      · Noise both from the door opening and closing and noise radiating onto the common property if the entry door is held open.

      · Cooking odours, or smoke from cooking radiating onto common property affecting the comfort of others or triggering common property smoke detection equipment. Depending upon the fire detection equipment installed at the building it could result in unnecessary brigade callouts, and increased costs for owners, occupiers and Strata.

      · If the door is needed for security, is it a type that offers better security than the existing entry door? Generally better security comes at a higher cost.

      · Can the existing door be fitted with an additional lock to improve its security? In this the Strata will need to consider if the existing entry door contains Asbestos, and that the correct type of lock is fitted by the correctly licensed tradesperson if the door is fire rated.

      · Can the Strata reasonably improve security into the building or site so that all occupiers receive the benefit over the entire building?

      · If the door is fire rated having a screen door is an inducement to wedge or hold open the fire door. If this occurs an offence has been committed, and should a fire start in the area smoke, heat or fire could spread through this doorway. Fire doors can only be held open with an approved device which will not be possible in some buildings and will come at a high cost in one where it is possible.

      · If the door is fire rated so is the door frame. Penetrating the frame for hinges and locks, adding door jams or seals, etc has the potential to affect the certification of the opening and may make it non-compliant.

      · If the frame is fire rated only correctly licensed tradespersons can do alterations. The Strata must ensure that the tradesperson is correctly licensed and insured to work on fire rated installations.

      From this most will have gathered that it is a difficult if not impossible process and in most cases, this is so. However, it may well be feasible and beneficial in some strata particularly low rise townhouse developments where most doors are not fire rated and the unit opens directly onto an open space.

      Reply

  18. Beverly Stanborough says

    Are all units required to have a fire door? our block is a 1960’s and only have ordinary wood doors that actually do not fit correctly, our body corp[orate are very loath to spend any money on anything if they can avoid it. Is the fire door the owners or strata’s responsibility?

    Reply

    • Nikki Jovicic says

      Hi Beverley

      Thanks for the question. We have received the following comment back from Peter Berney, Solutions In Engineering:

      The requirements or otherwise of fire doors is clear. They must be maintained as approved at the time the building was passed for occupation. Either at the time of construction or renovation, unless the council has issued an improvement order at a later date.

      In this case, if the building was approved without fire doors and no council improvement order exists, there is no requirement for them to be installed now. We would however strongly recommend that the existing doors fit and operate correctly. If any need to be replaced they must be replaced like for like.

      Entry doors are generally the responsibility of the Strata as they are considered an essential part of the building.

      Reply

  19. Tony Page says

    Our building in Sydney dates from 1964, and our fire review in 2007 required every fire door to the units to have the closers. Civil Fire are very assiduous in ensuring all the closers work as directed in order to issue the annual certicate!

    Reply

  20. Owen says

    My building dates from 1972. Are the doors to each Unit, which are fire rated, obliged to have automatic door closers on them?

    Reply

    • Nikki Jovicic says

      Hi Owen

      We have received the following reply back from Peter Berney, Solutions In Engineering:

      Yes they need to be self closing as detailed in AS 1851 Section 12 Table 12.4.3.1.

      Reply

  21. Tony Page says

    ” I can’t think of any legitimate reason to fit a security door in front of a fire door….””

    Really? How about security? Not being allowed to improve the locks etc. on a fire door (most entrance fire doors belong to the Strata) means that the only way to get additional security is to install a security door. Of course, this may or may not be objected to by the fire officer, but no legitimate reason? I don’t think so.

    Tony Page

    Reply

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