Interpretation of terms used in Approved Recommendation UK21/F025: UK23/F001
UK approved recommendation UK23/F001 on testing and certifying hinged B-class fire doors that are not symmetrical. Adopted EU recommendation FIRE-087.
Question
Scenario: An Approved Body receives an application for a Module B certificate for a hinged B-class fire door that is not symmetrical. The manufacturer’s opinion is that the single-sided testing has been carried out towards the inferior (worst case) side, and thus is entitled to be considered as a general application fire door that also is entitled to USCG Approval in compliance with UK Approved Recommendation UK21/F025.
Question: Is there a guideline for the Approved Body to make evaluations about which side is considered to actually be the inferior (worst case) side?
If fire testing against the other side also will be required, then the manufacturer and test lab need to know the acceptable way of carrying out this testing without being in conflict with the Fire Test Procedures, 2010 (FTP Code).
Recommendation
Section 1 – General advice If the manufacturer is able to design the hinged B-class fire door without making it unsymmetrical, this would make it easier for all parties, because this will qualify for both Module B issuance and USCG Approval number, provided the fire testing was successful, and otherwise meeting the conditions in the FTP Code.
Section 2 – The conditions for accepting single-sided fire testing for an Unsymmetrical hinged B-class fire door
• The Approved Body shall request an “Engineering Justification” from the manufacturer.
• The Engineering Justification shall also be backed up with a supporting Assessment by the IMO Recognized fire test lab, to re-confirm the manufacturer’s Engineering Justification.
• If the Approved Body is in doubt as to whether the Engineering Justification and the test lab Assessment affirmatively proves that the single-sided fire testing of the hinged B-class door actually was carried out towards the weakest side, then the Approved Body may contact its notifying authority for making or confirming an evaluation. For a product for which a USCG number has been requested, the notified body shall – in agreement with the manufacturer - also contact the US Coast Guard (Email to: TypeApproval@uscg.mil).
• If the above conditions are not met, then the manufacturer shall be requested to carry out a fire test towards the other side before a Module B certificate can be issued and USCG Approval can be granted.
Section 3 – When fire testing from both sides is required, care should be taken to avoid being in conflict with the FTP Code
The IMO Recognized test lab shall conduct fire testing in compliance with the FTP Code. However, this Code does not clarify how the hinged B-class fire door shall be tested from both sides due to some technicalities. Compared to the construction of the first test specimen (Figure 1, left side), the construction of the second test specimen (Figure 1, right side) is rotated 180 degrees, and then fire tested:
Testing as in Figure 1: This will imply that the construction of the second test specimen will be rotated 180 degrees compared to the first test specimen, and the door blade will open into the heating conditions.
When fire testing from both sides is required, the above test set up of Figure 1 will demonstrate that paragraph 1.2 of the FTP Code, Annex 1, Part 3, Appendix 1 is met (i.e. that the construction has been tested from each side separately), because the construction of the two test specimens will be exactly the same.
Choosing the above test set up will imply that specimen 1 will open away from the heating conditions, while specimen 2 will open into the heating conditions.
The manufacturer shall, before testing of the second specimen, contact the chosen Approved Body to discuss the testing arrangement. Successful testing according to the above figure shall be addressed in the test report, and the test lab shall specify which Approved Body deemed it necessary to make this AdHoc testing with the hinged fire door opening into the furnace.
When the fire door has been tested from both sides, it meets the general application requirements.
If IMO at some point in time should amend the FTP Code to clarify how unsymmetrical hinged B-class fire doors shall be tested, and it is in conflict with this Recommendation, then the amended FTP Code will prevail.
References:
• MSN 1874 as amended
• The Merchant Shipping (Marine Equipment) Regulations 2016 as amended
• Fire Test Procedures, 2010 (FTP Code)
Items affected:
• UK/ 3.16 (Hinged B-class fire doors)
More information
Maritime and Coastguard Agency
Bay 2/21
Spring Place
105 Commercial Road
Southampton
SO15 1EG
Telephone: +44 (0) 203 817 2000
Email: MEQA@mcga.gov.uk
Website: https://www.gov.uk/mca