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What you need to know about successfully demonstrating damper compliance

Within Europe and the UK, fire dampers are covered by a harmonised product standard, which is EN15650:2010. There has been a requirement for damper manufacturers to comply with this standard since July 2013, when CE marking against the Construction Product Regulation came into effect.  

As we have discussed in other blogs, one of the main requirements of the harmonised product standard is Fire Resistance testing of the dampers against EN1366-2:2015.   

The fire resistance test takes into account the installation method of the damper.  If the installation differs from how the manufacturer tested the damper, then the test results and certification are no longer valid. 

One of the biggest challenges that we see on a day-to-day basis is fire dampers not installed as tested by the manufacturer.  There can be many reasons why the installation method does not match the tested method.  The most common ones include the following: 

  • Installation is not appropriate for the supporting construction (i.e. single boarded wall or shaftwall construction).
  • Incorrect hole size in the supporting construction. 
  • Wrong penetration seal fitted. 

These problems can be eliminated by early engagement with Swegon or whoever is the specified damper manufacturer.  This approach saves not only time but also money. 

The following options are possible solutions when you are facing a non-compliant installation.  A non-compliant installation is a potential safety hazard as there is no way of knowing if it will maintain compartmentation under fire conditions. In the UK, the Authority Having Jurisdiction (AHJ) on the project will have the final decision on which of these alternative approaches are acceptable. 


The Right Way 

The best way to resolve the issue is to change the installation to make it compliant with the manufactures installation method.  Depending on the problem with the installation and when it has been identified, the cost of change can be high. It's far better to do the installation correctly the first time than try to fix it later on.  As stated above, early involvement with the manufacturer will help prevent these issues. 


Testing to EN1366-2 

The next option is to conduct a Fire Test to the damper test standard EN1366-2.  This can be achieved by manufacturer lead testing or customer lead testing. 

Manufacturer Lead Testing

Depending on how the damper is installed, the manufacturer may be interested in conducting the fire tests.  By the manufacturer taking ownership of the testing, they could increase the scope of their certification.  Fire Resistance testing can be expensive and time-consuming, so it might not be an option if there is no value for the manufacturer in conducting the tests. In this situation, you may have to consider a customer lead test. 

Customer Lead Testing

In this scenario, the customer arranges the fire test with the manufacturers support.  The difference with this approach is that it is typically only a test.  The ownership of the test data will belong to the customer rather than the manufacturer. 

A risk with this approach is that because the manufacturer will not have it added to their certification, it is only of any use for the specific project that has had compliance issues.  Any changes to the product in the future would mean that the test is no longer valid going forward. 


A Word of Warning 

Fire Resistance testing is not a given; never assume that it will pass just because you have booked a test.  There may be a good reason why no one has tested the damper in the configuration that has been fitted on-site.  Any test failure will mean that the site installation will have to change.  This could range from replacing the penetration seals to replacing dampers or walls. 


BS476 Test and Assessments 

At the time of writing this blog, the UK government have completed a consultation regarding the removal of national classes from Approved Document B.  Whilst it is currently possible to get a BS476 assessment, depending on the outcome of the consultation, this may change, in the next couple of years. 

BS476 Test 

If the AHJ deems it appropriate, then a BS476 test might be another option.  These tests are less demanding than a test conducted to EN 1366-2 due to the lack of leakage measurements and plate thermocouples.  Since the EN damper test standard has been around since 1999, and BS476-22 has not been updated since 1987, you need to consider if it is appropriate to conduct a test to a standard that is 36 years old! 

BS476 Assessment 

The final option for demonstrating a level of compliance is to get a BS476 assessment.  Before applying for an assessment, you should check with the damper manufacturer.  They may have a global assessment that might be suitable.   They should also know if they have been turned down previously for trying to get an assessment for the same issue. 

Assessments should be completed as defined in the Passive Fire Protection Forum Guide (PFPF Guide).  This guide gives information on the competency requirements of the person conducting the assessment, along with what test evidence would be appropriate.  You should always make sure that if you are choosing to go down this route, the organisation that is completing the assessment is following the PFPF guide. 

As with testing, never assume that an assessment will be granted.  Failing to achieve an assessment will have the same consequence as failing a fire test.  


Conclusion 

The easiest way to demonstrate damper compliance is to use a pre-existing CE installation method from the IO&M/DoP, although the options detailed above can be considered if necessary.

  • The best way to avoid these issues from ever occurring is early engagement with the damper manufacturer.  They can tell you what their certification covers and doesn't cover. 
  • The damper manufacturer should be able to support you when there is an issue; however, the responsibility for deciding on the appropriate solution lies with the AHJ.   
  • Never assume that you are going to pass a test or assessment. 
  • ASFP Advisory Note 17 gives some further information on assessments in lieu of fire testing.