Seven 'reasons' cited for using BS 8524.
Are they valid?
References to ‘BS 8524’ are referring to BS 8524-1:2013
Notified Bodies have withdrawn from BS 8524 which means there is no valid third-party certification. BS 8524 is also not harmonised meaning that it has no legal compliance with the Construction Products Regulations. So, are there any valid reasons to keep using BS 8524?
BS 8524 does not have valid third-party certification and should not be used until it has valid third-party certification again.
No fire industry professional would advocate using a life-safety product without valid third-party certification, unless:
- There is no alternative, or
- They have a vested interest to say otherwise
In terms of life-safety advice, we can disregard what is said to suit commercial and vested interests. In terms of an alternative, there is one: BS EN 16034 (for horizontal fire curtains, use ISO 21524).
BS EN 16034 is current, it is valid, it has third-party certification, it is comprehensive, and it is harmonised. And it is legally required.
You can read an in-depth technical comparison here.
Will BS 8524 achieve valid third-party certification again? We are told it will. But when? No one can say. There is an indefinite and lengthy process before it may be available again.
Is anyone still using BS 8524? Some
are have done.
Here are the seven most common ‘reasons’ for continuing to use BS 8524:
- “BS 8524 is better”
- Additional tests in BS 8524,
- Reference to retail premises in BS EN 16034
- BSi’s National foreword on BS EN 16034
- BS 8524-2 still has third-party approval
- Manufacturer’s claims
- BS 9999 refers to BS 8524
“BS 8524 is better”
This reason is simplistic and doesn’t stand up to scrutiny for two main reasons:
Reason 1: Some BS 8524 certified products are poor; some customers are taking them out and replacing them due to recurring issues, https://bit.ly/gsfcsurvey
Reason 2: There are pros and cons for BS 8524, with more downsides than upsides.
For an in-depth appraisal of BS 8524 and how it compares technically with the European Standard equivalent, BS EN 16034, you can read our comprehensive white paper.
In our opinion, the best active fire curtains on the market are not BS 8524.
The reasons why BS 8524 is not the best on the market:
- BS 8524 is an old standard that needs improving,
- BS 8524 doesn’t offer legal compliance with the CPR,
- BS 8524 doesn’t have valid third-party certification.
See the tangible proof of what is better and why in a less than 2 minute video.
Additional tests in BS 8524
You don’t need BS 8524 to have the additional tests. The following table highlights the most significant technical similarities and differences between BS EN 16034 and BS 8524.
Technical Comparison: BS 8524 + BS EN 16034
What are the additional tests that are beneficial?
BS 8524 has three additional tests:
- The ‘Gravity fail-safe requirement’
- The ‘Short circuit tests’
- The ‘Controlled descent speed’.
These tests can and should be taken independently.
What are all the ‘✗’s in the comparison table?
- Allows BS 476 testing
- Allows ‘likelihood’ fire performance evaluations
- Has superfluous or arguably dangerous tests:
- Hot motor test;
- Pressure-sensitive protective equipment;
- Ancillary equipment testing;
- Heat test for switches; and
- Reaction-to-fire test;
- Has no legal compliance with the CPR (CE/ UKCA marking);
- Lacks traceability and transparency of paperwork i.e.no public details on:
- product dimensions tested and certified, nor fixings used;
- materials or components tested; and
- orientation tested (it is 50/50 it is the right way round)
For an in-depth appraisal of BS 8524 and how it compares technically with the European Standard equivalent, BS EN 16034, you can read our white paper – a technical comparison of BS EN 16034 and BS 8524.
Reference to retail premises in BS EN 16034
BS EN 16034 does reference retail premises. It also refers to a whole load more applications. In fact, reading the full scope of BS EN 16034 shows it covers all applications where a person could be under the fire curtain. This includes all vertical fire curtains.
Read the ‘nut-and-bolt’ answer to this, including other FAQs, in our white paper.
BSi’s National foreword on BS EN 16034
The National foreword is not part of the harmonised standard i.e., it’s the British Standards Institute pointing to a British Standard (understandably), but, with a critical caveat.
The National foreword refers readers to BS 8524 in connection with ‘operation deployment speeds’ and ‘initiation devices or warning devices’. ‘Operation deployment speeds’ are not unique to BS 8524 e.g., the test is also used in ISO 21524 and EN 12101-1.
BS 8524’s ‘initiation devices or warning devices, etc.’ tests are cold laboratory tests. The value of the laboratory tests is debatable as the components are already CE marked.
BS 8524-2 still has third-party approval
BS 8524-2 is a code of practice for installation and servicing. Whilst it is commendable to have a code of practice for installation, there are three things:
- If it looks right and it works right when it is fitted, it likely is right. If it works right on each of your weekly tests, it is fitted right.
- If it doesn’t work right when it is fitted it likely isn’t right – regardless of the code of practice paperwork. And/or if it gives you problems on the weekly tests, it isn’t right, regardless of the code of practice paperwork.
- There is no product to fit. Having BS 8524-2 without BS 8524-1 is a bit like knowing how to drive a manual car when we’re all driving autos.
Some examples of manufacturer’s claims and the analysis of them:
- “The ASFP are helping find a new Notified Body; two are already creating their BS 8524 schemes and one is awaiting approval from UKAS. We have started the certification process with them”
Are these Notified Bodies creating a scheme for the old BS 8524 or the new? The new BS 8524 hasn’t even been finalised and published yet and won’t be until late 2023 at the earliest. It is unlikely that a Notified Body would go too far in creating a scheme for a standard that is in the process of being updated. The imminence inferred here seems more hopeful and tactical than realistic.
And will the next version of BS 8524 still refer to BS 476? The Building Safety Act is removing British Standards and Classes including BS 476 in favour of European Standards and Classifications.
2. “The date of our BS 8524 certificate is 2026”
This is misleading. On 23rd June 2022, IFCC (the last Notified Body to support BS 8524) announced, “With regret IFCC announces its withdrawal from the provision of the Product Certification Scheme for Active Fire Curtain Barrier Assemblies, SDP11-02 [the IFCC scheme name for BS 8524 third-party certification]. The recent retirement of critical staff combined with an organisational restructure has left the business technically unable to deliver this scheme.”
The full statement can be found here.
On the 9th June 2022 IFCC had written to manufacturers saying, “we will maintain the certification if requested for a period of 12 months from the date of this letter”, meaning the last BS 8524 third-party certification expired on 9th June 2023.
To imply the third-party certificate is valid beyond 9th June 2023 is misleading. It isn’t valid.
Independent Factory Production Control audits and inspections, and independent UKAS-accredited process assessments are the fundamental value of third-party certification. Without them, a certificate has no more value than the paper it is written on.
3. “We have ISO 9001 approval for manufacturing”
This doesn’t ensure anything with regard to the specifications and design and how a specific product is made. It just means you have a documented process for making things.
4. “A number of regulatory bodies deem our approach ok”
What have they deemed ok and are they happy to indemnify any adverse outcomes of BS 8524 fire curtains not being manufactured as they were independently tested and certified? Or is it just ‘table talk’?
5. “We are providing a managed, ethical, professional approach to this situation”
To quote the UK ‘Head of Fire’ from one of the largest contractors in the world, “If I made something, I’d say it was perfect, wouldn’t I?”
You cannot ‘hang your hat’ on something a commercially driven manufacturer says. Think of Kingspan. One of the biggest. You can read more about Kingspan here.
Independent assessment and periodic Factory Production Control audits by a UKAS-accredited Notified Body are invaluable for ensuring the product sold is identical to the product tested.
BS 9999 refers to BS 8524
Is it valid to say “BS 9999 refers to BS 8524” as a reason to keep using BS 8524-1? Or is BS 9999 out of date?
Since BS 9999 was published in 2017:
- BS EN 16034 was harmonised (1st Nov 2019); and
- Notified Body support for BS 8524 was withdrawn (9th June 2023)
Richard Millet, KC to the Grenfell Inquiry, referred to ‘dangerously out of date’ guidance as contributory to the tragedy: “Behind all of these discrete factors there lay… an overreliance… on guidance, some of which, including the statutory guidance, was ambiguous, dangerously out of date, and much of which was created by non-governmental bodies and influenced by commercial interests”. Overarching Statements and Module 7 Closing Statements, 10th November 2022.
Timeline of events
2017: Since BS 9999 was published in 2017.
1st November 2019: BS EN 16034 was harmonised meaning all vertical fire curtains must legally be CE marked to it as required by the Construction Products Regulations.
9th June 2023: Notified Body support for BS 8524 was withdrawn meaning no valid third-party certification is available for BS 8524.
We can see BS 9999 is an example of dangerously out-of-date guidance.
An important note to consider:
If BS 8524 achieves third-party certification again, BS 9999 will need to be revised to include the legal requirement to CE mark all vertical fire curtains to BS EN 16034 as required by the Construction Products Regulations, or it will remain dangerously out of date. You can see why here.
These seven ‘reasons’ given for using BS 8524 are reminiscent of how we’ve hung onto BS 476. We know BS 476 is inferior to its European counterparts. We’ve known this for 20 years. But some in the UK have pushed to keep it because of the testing and certification work required for manufacturers to switch. Only now is The Building Safety Act finally removing BS 476 from use. Please note: BS 8524 has 30 references to BS 476 in it.
See more about BS 476 being removed here.
BSI tell us:
“standards aren’t the same as regulations and following a standard doesn’t guarantee that you’re within the relevant laws”
“Compliance with a British Standard cannot confer immunity from legal obligations”
The seven ‘reasons’ you may hear to justify BS 8524 do not stand up to scrutiny. They only hold-up on the basis of commercial or vested interest.
- There is an alternative.
- It is current and valid.
- It is third-party certified.
- It is harmonised.
- It has a CE marking scheme covering vertical fire curtains.
- It is comprehensive.
- It covers the best design of fire curtain.
It is BS EN 16034.
The facts around fire curtain regulations and product standards:
Regulations (legal): It is a legal requirement to CE mark all vertical fire curtains to BS EN 16034 since 1st November 2019. Read more in our comprehensive white paper, including FAQs on the subject.
Product standards with third-party certification: The only product standards with valid third-party certification are:
- Vertical fire curtains – BS EN 16034
- Horizontal fire curtains – ISO 21524
- Concertina fire curtains – BS EN 16034
BS 8524 does not have valid third-party certification.
NB. ref BS 8524 achieving valid third-party certification again.
We are told it will*. But when? No one can say.
No one would indemnify you against a date when third-party certification will be available again for BS 8524. Why YOU provide the indemnity?
There is an indefinite and lengthy process before valid third-party certification for BS 8524 may be available again:
- BS 8524 needs revising
- Notified Bodies then need to create a scheme that can be assessed and accredited by UKAS or equivalent
- We (manufacturers) then need to pass the new tests in BS 8524 including the European Standards fire test
- Then certification, audits, lots of paperwork, and Factory Production Control needs to be completed
*If BS 476, and/ or the superfluous or even dangerous tests are still in BS 8524, we would recommend staying away from it
Until these updates, do not use BS 8524, at least until it has valid third-party certification again. Even then, insist on legal compliance with the CPR. And choose the best design. In the meantime, insist on valid third-party certification, insist on legal compliance with the CPR, (and choose the best design).