DHF's statement on standards for fire curtains

The question of the appropriate standards for fire curtains has recently been the subject of comment from manufacturers and trade bodies.  This statement is the position of the Door & Hardware Federation, which has several manufacturers and suppliers of fire curtains among its members.

Under the UK Construction Products Regulations 2013 (as amended), once a product standard is ‘harmonised’ under these Regulations (which are generally referred to as the ‘CPR’), manufacturers have a legal obligation to apply the CE marking in accordance with that standard when placing relevant products on the UK or EU market. (They may also choose to apply the UKCA mark against the UK-‘designated’ version of the standard – a post-Brexit idea that is now receding but still available to use as an alternative to CE marking, but which is valid only within Great Britain).

With regard to fire curtains, the European standard EN 13241, in conjunction with EN 16034, are harmonised standards (valid since 2016) that include fire curtains with side guides. The convenor of the CEN committee responsible for standards for industrial doors, commercial doors, garage doors and gates[1] has confirmed that the standards’ scopes include fire curtains.

BSI is a long-standing member of CEN and remained a member of CEN after Brexit.  This means that BSI has to adopt all EN standards and withdraw conflicting national standards. BSI (or any other CEN member) cannot independently decide which standards to publish. To do so would be contrary to the CEN rules.  The BSI’s own ‘standard for standards’, BS 0, contains similar requirements.

In this respect, the scope of BS 8524-1 does conflict with the scope of EN 13241 in that they both cover fire curtains and have a similar range of performance characteristics. Hence, according to CEN rules, BS 8524-1 should be withdrawn, or substantially revised.  If a revised BS 8524-1 were to be published, it would have to exclude the requirements covered by EN 13241, EN 16034 and their normative references.  A revised BS 8524 could, however, retain any useful elements that are not already covered by the EN standards.  This type of relationship already exists, for example, with the lock standards, EN 12209 and BS 3621.

BS 8524-1 can neither provide compliance with the CPR nor enable conformity marking, legally required by the CPR.  It is also the case that the retention of this standard in its current form is in breach of CEN rules and, presumably, BS 0, as long as BSI remains a member of CEN. This is true both now and when EN 16034 is incorporated into a revision of EN 13241 (which is anticipated).

Our aim here is not to disparage the work done on BS 8524, but to ensure we comply with the legal requirements of the CPR and that BSI can remain within CEN rules.

Readers may be aware of statements suggesting that DHF accepts that there is no ‘clash’ between BS 8524-1 and EN 13241/EN 16034. This is incorrect.  In fact, as we have made clear above, DHF has always maintained that there is ‘conflict’[2] between the current BS 8524-1 and EN 13241/EN 16034. This should be dealt with by withdrawal or substantial modification of BS 8524. 

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[1] CEN/TC 33/WG 5

[2] As defined in BS 0