Table of Contents
1. Third-party certification
The merits of various standards are irrelevant if we have no assurance at the highest level i.e. from Notified Bodies, that the product arriving on site is the same as the one fire tested. The only product standards with valid third-party certification currently available in the UK are:
- For vertical fire curtains – BS EN 16034
- For horizontal fire curtains – ISO 21524
- For concertina fire curtains – BS EN 16034
Note – product standards comprise a collection of applicable product tests (such as the fire test, BS EN 1634-1, and the smoke test BS EN 1634-3) so a product standard gives a more holistic assessment of how a product may perform in real applications that a single product test.
BS 8524-1 does not have valid third-party certification. Anyone that says it does and shows us a certificate with a 2026 date on it is being misleading. The Notified Bodies who issued the original certificate will confirm this.
With regards to ISO 9001, this does not ensure the product being supplied to site is manufactured the same as the fire tested specimen.
a) Our field evidence shows this (see example in our post, Will this fire curtain work in a fire?1*) and,
b) If ISO 9001 did ensure the product being supplied to site was manufactured the same as the fire tested specimen:
i. Paul Morrell would not be advocating for life safety products such as fire curtains (“anything that could cause harm to the public”) to submit to the highest level (System 1+) of Assessment and Verification of Constancy of Performance (AVCP)
ii. Notified Bodies and their third-party certification schemes would not be necessary. This is a multi-hundred-million-pound industry that reduces risk for the consumer and insurers.
iii. ‘Assessment and Verification of Constancy of Performance’ (AVCP) in life-safety product standards would be effectively redundant, making the standards easier to adhere to (a lot less demanding) – not good for safety.
*In the above post you will see an example of a fire curtain that is not manufactured as it was fire tested. This is from a manufacturer that has the old BS 8524 certification and ISO 9001. The product has been supplied to the customer with missing and/ or removed retention fasteners. It would offer little to no protection in a fire. This is a five-storey care home and each of the five floors are the same. The retention fasteners are prone to frequent jamming especially on horizontal fire curtains where the weight of the fabric pulls the fasteners into the guide aperture causing it to jam. In this example it would appear that when the fabric has been replaced the manufacturer has supplied it with less retention fasteners (or they have been removed) to seek to overcome the jamming. This means it is no longer as it was fire tested and it would not work in a fire. This is one of the more blatant deviations from the fire tested design. Other deviations, just as fatally consequential in a fire, are less easy to see and what we see on a weekly basis on site underlines the paramount importance of independent regular Factory Production Control (FPC) that occurs when maintaining valid third-party certification.
There is more about mitigating risk for construction products in the ‘Morrell Day’ report2.
Using a life-safety product without valid third-party certification when there is a third-party certified alternative is an unnecessary risk and it is unlikely that anyone recommending it would indemnify the consequences. To advocate it is contrary to the direction of travel that the Morrell Day report and the Building Safety Act is taking the industry in. We have many photos of products that have been installed differently to how they were tested showing they would offer no protection in a fire. Read our brief article including example scenarios as to why deviations can occur, How valid third-party certification reduces your risk to close to zero3.
Whilst ASFP are not an independent authority (they are a trade body that, amongst other work, represent their members), they also strongly advocated for valid third-party product certification for the ten years that BS 8524-1 had it; for example, see them talking with a BS 8524 fire curtain manufacturer in this 2-minute clip4, “…you need to be third-party approved…and go through rigorous testing and auditing…and that provides that competency… the golden thread, evidencing product’s compliance…”. We agree with what is being said in this clip about evidencing and proving a product’s compliance virtue of valid third-party product certification. Since 9th June 2023 this auditing and third-party approval is no longer available with BS 8524-1 to evidence the products compliance. Additionally, there are valid, comprehensive alternative product standards such as BS EN 16034 for vertical fire curtains (including concertinas) and ISO 21524 for horizontal fire curtains.
As such, with there being no valid third-party certification for BS 8524-1, and with there being valid, comprehensive, alternative current product standards that are more widely recognised than BS 8524-1 ever was, from the perspective of the timeless risk-based principle of independent third-party auditing that the industry unanimously agrees is critical for safety, no one should be advocating for the current use of BS 8524-1.
2. Current standards and regulations
Whilst there may be some contrary opinions about the applicability of BS EN 16034 to fire curtains, and whilst standards may change in the future, we all have to go by the current standards and the current regulations, otherwise we would have no standards and no regulations; everyone would just do what they thought was best in their own eyes.
The current situation is that BS EN 16034 was harmonised on 1st November 2019. In the foreword of BS EN 16034 it states that conflicting national standards have to be withdrawn. Subsequently BS 8524-1 lost all support from Notified Bodies. Warringtonfire and IFCC both pulled out of supporting BS 8524-1, not a decision they would have made lightly after setting the schemes up and getting them accredited by UKAS at the cost of hundreds of thousands. If one Notified Body pulled out, it could be a coincidence and the remaining Notified Body would have the market to themselves, but they have both pulled out.
In Oct 2018 (during the coexistence period), ASFP and others in the UK pushed back on BS EN 16034 applying to fire curtains. The Steering Group responsible (GNB-CPR-SG06) confirmed in response that it does indeed apply. We have to respect this as we are signed up to the Construction Products Regulations 2013.
3. Pros and cons
Whilst there are significant risks involved in using non-third-party certified fire curtains, we cannot see any improvement for the safety of the people or the asset in using fire curtains that were historically tested to BS 8524-1. See more in point ‘4’.
The main point for a fire curtain product is, Is the product fire tested? And preferably, Is it fire tested to the European fire test (EN 1634-1)?
The European fire test is widely known to be superior (Read, Why scrapping BS476 is good for safety5).
A 60-minute fire curtain tested to BS 476 (as permitted by BS 8524-1) may only achieve 45 minutes (E45) in the European fire test.
4. Is BS 8524-1 more robust than BS EN 16034?
We are called out to failing fire curtains every week and there is nothing consistently rigorous, stringent, or robust about a BS 8524-1 fire curtain. Indeed, some of the worst products on the market are manufactured and were historically tested to BS 8524-1. Probably the most consistent thing with BS 8524-1 fire curtains is the problems and headaches they cause end-users.
This is not to say that BS 8524-1 was a thoroughly bad standard – it certainly wasn’t – but rather, this is to point out that it wasn’t a panacea; bad products passed it and were certified to it.
This also applies to other fire curtains that are not third-party certified to a current product standard and/ or use the old designs.
FYI, we have seen BS 8524-1 fire curtains installed with paint pot lids for packers in the centre of London, showing BS 8524-2 does not guarantee a quality installation. You can read/ watch more about BS 8524 in:
a) BS 8524-1: A conflicting national standard that should be formally withdrawn – and the improvements it needed6
b) Safety is the standard – a detailed look at BS 8524 and why it can no longer be used for fire curtains.7
c) Seven reasons cited for using BS 8524. Are they valid?8
d) The dangers of the hot motor test in BS 8524-1:20139 (the hot motor test is on the list of things to remove should BS 8524-1 reappear in a revised form)
e) Every question answered: Do operable fabric curtains (fire curtains) need to be CE marked?10(e.g. the cycle test is not unique to BS 8524-1)
5. The product options available under BS EN 16034 certification include the best designs on the market.
See Simply put, It is better11 and The quiet transformation happening in the fire curtain industry12.
With BS EN 16034 certified products the industry can now have a design without the headaches:
a) without the jamming that would stop it working in a fire,
b) without the tears and rips that would stop it working in a fire, and
c) without the gaps and billowing at the edges that would stop it working in a fire.
This is better and safer for everyone.
We are happy to chat to any industry professional about the situation and we offer a RIBA accredited CPD which touches on the pros and cons of the various standards alongside applications and design characteristics of fire curtains. For posterity’s sake, we also have a technical comparison of these two standards in this white paper, A technical comparison of BS EN 16034 and BS 852413.
In summary, BS 8524-1 is not a legal requirement, and it brings no safety benefits going by the products that were historically tested to it. BS 8524-1 also restricts the consumer to a narrow band of products that are not the best available, and there is also no independent control of the manufacturing of those products which is highly risky.
1 Devenish, C. (2024) Charles Devenish on LinkedIn: Will this fire curtain work in a fire?, LinkedIn. Available at: https://www.linkedin.com/posts/charles-devenish-333670260_will-this-fire-curtain-work-in-a-fire-feel-activity-7159214384496435200-EX6D/?utm_source=share&utm_medium=member_desktop (Accessed: 09 February 2024).
2 Department for Levelling Up, H. and C. (2023) Independent Review of the construction product testing regime, GOV.UK. Available at: https://www.gov.uk/government/publications/independent-review-of-the-construction-product-testing-regime (Accessed: 09 February 2024).
3 Adexon Team (2023) How valid third-party certification reduces your risk to close to zero, Adexon. Available at: https://www.adexon-uk.com/how-valid-third-party-certification-reduces-your-risk/ (Accessed: 29 August 2023).
4 FIREX 2022 – coopers fire ASFP on importance of third-party approval (no date) ASFP. Available at: https://workdrive.zohopublic.eu/file/5fw9357e691a41e0a4fd08e1f2d8fe11e8eb5 (Accessed: 09 February 2024).
5 Adexon Team (2023) Why scrapping BS476 is good for safety, Adexon. Available at: https://www.adexon-uk.com/video/why-scrapping-bs476-is-good-for-safety/.
6 Adexon Team (2023) BS 8524-1: A conflicting national standard that should be formally withdrawn – and the improvements it needed. Available at: https://www.adexon-uk.com/articles/bs-8524-1-a-conflicting-national-standard/
7 Adexon, T. (2023b) Safety is the standard – a detailed look at BS 8524 and why it can no longer be used for fire curtains. Available at: https://www.adexon-uk.com/whitepaper/safety-is-the-standard/ (Accessed: 09 November 2023).
8 Adexon (2023) Seven ‘reasons’ cited for using BS 8524. Are they valid? Available at: https://lnkd.in/e3E63yhr (Accessed: 09 November 2023).
9 Adexon Team (2023) The dangers of the hot motor test in BS 8524-1:2013, Adexon. Available at: https://www.adexon-uk.com/the-dangers-of-the-hot-motor-test/ (Accessed: 30 August 2023).
10 Adexon Team (2023) Every question answered: Do operable fabric curtains (fire curtains) need to be CE marked?, Adexon. Available at: https://www.adexon-uk.com/white-papers/every-question-answered/ (Accessed: 29 December 2023).
11 Adexon Team (2023) Simply put, it is better, Adexon. Available at: https://www.adexon-uk.com/it-is-better/ (Accessed: 29 August 2023).
12 Adexon Team (2023) The quiet transformation happening in the fire curtain industry (2023) Adexon. Available at: https://www.adexon-uk.com/articles/the-quiet-transformation-happening-in-the-fire-curtain-industry/ (Accessed: 29 December 2023).
13 Adexon Team (2023) A technical comparison of BS EN 16034 and BS 8524, Adexon Resources. Available at: https://www.adexon-uk.com/whitepaper/technical-comparison-of-bsen16034-bs8524/.