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ASFP Guide to Inspecting Passive Fire Protection for Fire Risk Assessors (2012): 'If the door has a letterplate, consideration should be given to fitting a device, which can help prevent arson attack e.g. by items or flammable liquid being passed through the door.' 

Arson Control Forum Annual Report Sept 2008 - Sept 2009: 'Arson is the number one cause of fire in the UK.'

Fire Protection Association: 'An assessment of the likelihood and the consequences of an arson attack should form a critical part of the fire risk assessment exercise.'

GOV.UK Guidance Fire safety risk assessment: 5-step checklist (2006): ‘Have you protected your premises from accidental fire or arson?’

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Fire Risk Assessment

Since the introduction of the new Fire Safety Law, The Regulatory Reform (Fire Safety) Order 2005 (RRO), owners and managers of non-domestic premises are personally responsible for the fire safety of their premises.

They are legally obliged to carry out the fire risk assessment of their premises and take measures to protect them from the known fire risks. They cannot delegate this responsibility down to the employees.

In the case of an accident, there would be no excuse for the owners/managers if they cannot produce evidence to show that they have exercised due diligence in fulfilling their duty. They are risking hefty fines, difficulty with the renewal of the insurance or even imprisonment. The court will have little sympathy. The insurance company can refuse the payout if it turns out that the mandatory legislation requirement was not met by the business.

Businesses are discovering - to their considerable cost - that it is not injury, but the risk posed if there was to be a fire, which is triggering prosecution under the RRO.


Final Exits Doors Security and Fire Safety

Under Article 14 of the RRO and Building Regulations Part B, the entire escape route up to and including the final exit from a building must remain unobstructed at all times. Escape routes in a building should be designed so that people can escape quickly enough to ensure they are not placed in any danger from fire.

The final exit doors have two vital functions in the event of a fire: when closed they form a barrier to fire spread, and when open they provide a means of escape. The fire started in the exit door area (for example, as it happens in the case of letterbox arson), would effectively cut off the main escape route from the premises. For these reasons, in the premises covered by the mandatory RRO and Building Regulations, doors used as the final point of exit should be fire-resisting (protected): arson proof or fire-rated doors.

If only the interior of the premises is subject to the risk of fire, as is the case with premises with entrance/exit doors facing the road, making the entrance/exit door arson proof should be sufficient to achieve compliance with the legislation. If the risk of fire is applicable to the areas located on both sides of the door, such as the entrance/exit doors of flats that are facing the common areas in blocks of flats and in HMOs, then the entry/exit door must be a fire-rated door.

Fire risk from the unprotected or under-protected letter plate

In the UK entry/exit doors that serve as final exits in domestic premises and non-domestic premises are often fitted with a letter plate.

The unprotected or under-protected letter plate will undermine the effectiveness of an escape door that should be fire-resisting. This is because the letter plate can be open for whatever reason: accidental or malicious. For example, it is often opened by a newspaper or mail items, and there is a possibility of a malicious fire or arson attack through the letter plate.

In premises the oxygen source will be the air in the building. Where only normal natural domestic ventilation is provided, the risk of fire in the premises will generally be normal. However, excessive airflow through an open letter plate and draughts add to normal natural domestic ventilation. This leads to an additional source of oxygen and increased risk to the premises in case of fire. Also, in the case of fire (not necessarily arson), the open letter plate allows a direct passage for hot gases and flames. It will contribute to the stack effect and this will increase the spread of smoke.

Such final exit door on exit route would be incompatible with the RRO and Building Regulations. 


Letterbox arson 

The risk of a fire starting through the entrance/exit door fitted letter plate (letterbox), particularly by pouring inflammable liquids, is well known and recognised by the insurance industry, the Fire Brigade, the Police service, the Master Locksmiths Association, and others, and it was highlighted in the ASFP Guide to Inspecting Passive Fire Protection for Fire Risk Assessors (paragraph 3.3) and in the Guidance document on fire safety for blocks of flats (paragraph 43.2). 

Arson attack through the letterbox is a source of ignition and source of fuel. As such it must be identified at steps one and two of the fire risk assessment.

Among the non-domestic premises that most at risk of the letterbox arson are small businesses, such as offices, shops and pubs, and common areas of flats and HMO's (Houses in Multiple Occupation).

The high-risk premises are mostly those premises that have sleeping accommodation like hotels, hostels, residential homes and like premises.  

Source - The Home Office:

The diverse motives of arsonists, vandals and criminals mean that no home or business is immune from an arson attack

All properties, be they residential, commercial, or industrial, are potential targets for crime and vandalism attacks and deliberate fire-raising. Preventing arson is one of the key issues faced by the property managers/owners when trying to implement the RRO.

The issue of arson is covered by BAFE Scheme: SP205 Version 2: December 2012 for Fire Risk Assessment.

Says Sergeant Phil Butler of the West Midlands Arson Task Force: "If you're doing a fire risk assessment, and half of all fires are arson, then if you're not dealing with arson in the assessment you've only done half the job. It is part and parcel of the assessment".

Therefore, when carrying out the fire risk assessment, the 'responsible person' must not overlook the letter plate fitted in the front door and consider its fire risk if he does not want to end up with a court judgement against him.

In the premises covered by the legislation, the responsible person can keep the letter plate in the entrance/exit escape door for undisrupted mail deliveries only if he takes measures to protect the letter plate against internal or both internal and external spread of fire (and smoke) depending on the risk of fire.

Protecting the letter plate is a practical, not moral choice for the owners and managers

However, often this issue is not properly understood or overlooked by the fire risk assessors or 'responsible persons'.