When does an access hatch become a door?

I am interested in other people’s opinion on whether a fire rated access hatch in a fire wall requires a self-closer? I have always treated fire rated access hatches as fire doors therefore requiring self-closers but this has recently been challenged by another engineer. It has been pointed out to me that C/AS2 (2020) only stipulates the self-closing provision for fire and smoke doors but not specifically for fire rated access hatches. There is a definition in C/AS2 (2020) of fire resisting closures which entails fire doors, fire windows and access panels. We all know fire windows are made of fixed glazing so self-closing does not apply. That leaves us with whether the self-closing capability should apply to fire resisting closures or just fire doors. If there was a dispensation for fire rated access panels/hatches, what is the threshold for a fire rated hatch to be deemed as a fire rated door? Is it the size, use or other factors? I also note the fire door standard NZS4520 applies to fire-resistant doorsets. The standard has a definition for a doorset which again does not include access hatches.

Hi Nick
I would have thought the simple definition would apply where a door is a hinged panel and an access panel would be securely (screw) fixed and require a special tool to open or remove it.

Thanks John for your reply. I wonder what is your opinion on whether a fire rated access hatch/panel requires a self-closer then?

Nick I would say that a closer was only required when the opening is a passage for people. An example would be a fire door to a MSB enclosure. A closer would make it very difficult for an electrician to work if the door kept closing against him from behind. In that case the fire door would be locked closed when not open for servicing. An actual access panel couldn’t have a closer if it was screw fixed on 4 sides and fully removed such as a service hatch to a shaft.

Hi Nick
I normally would not require a self closer if the hatch is highly unlikely to be left in an open position. For example I believe that closers on fire rated electrical cupboard doors make the cupboard unserviceable without using wedges. Magnetic hold open devices on electrical cupboard doors is of highly questionable value. It is highly unlikely that electrical cupboard doors are to be left open and are normally secure.
I am not aware of magnetic hold open devices on electrical cupboard doors and wedges defeat the purpose of self closers. So I consider that self closers on electrical cupboards more harmful to achieving fire separation of such cupboards.

Thanks Robert and John for your replies. Really appreciate your inputs.

John - I tend to agree that passage for people is a good deciding factor because it follows the same logic and intent of a proper fire door. This particular access hatch that I am looking at is a hinged hatch which provides access to a crawl space where plant equipment is located.

Robert - How is the term “highly unlikely” defined in this context? Is it the number of times the electrical cupboard doors being left open during a period of time (weeks, months or years) OR the probability of the same doors being left open unattended when it is opened for maintenance at a particular time and a particular date. The former may be deemed as highly unlikely because of the infrequent inspections needed (either quarterly or annual maintenance) but the latter is a different story. 9 out of 10 times have I seen fire rated electrical cupboard doors with signage reading “fire door, please keep closed” being left open unattended because the maintenance contractor is either gone for smoko or picking up parts or just not there. What’s even worse is that most of those fire rated cupboards are located in the safe path.

John and Rob - a follow up question for both of you. If a judge asked you whether you have fulfilled your duty to exercise reasonable skill and care to reduce the risk or likelihood of fire spreading across the fire rated cupboard door, should such door be determined as the cause for a loss in a fire, what would you response be? My response would be yes I have because I have asked for a self-closer. The key word in judge’s question here is “you” the fire engineer, not what you anticipate how others (contractors) would behave during their course of action. If the maintenance contractor wedged the door open, or tampered with the self-closer then they would be liable for the loss. Otherwise, if there was no self-closer both the fire engineer and the contractor could potentially be held liable. The fundamental difference between those two scenarios is whether we are relying on other people’s good will to close the hatch behind them in order to fulfill our duty of care owed to the client.

I would say you could still “swing” if you ask for a closer if a reasonable person could foresee that such a stipulation would result a likelihood of the door being wedged open.
Tell us - how does one work on a switch board in a cupboard without wedging the door open?
One answer is to make all cupboards that require fire separating large enough to work in with the door closed - good luck with that.
Sounds like you are going to be caught what ever your decision is. If you blindly follow the acceptable solution and put door closers on in full knowledge that the only practicable use of the cupboard is to wedge the fire doors open, then I think a judge may also find the fire engineer culpable. Slavish adherence to an inappropriate set of rules won’t protect a professional who has the ability to make appreciations and judgements. I think I prefer the good engineering option - sometimes this coincides with the acceptable solutions which are an attempt to provide a set of rules to cover all situations. The acceptable solutions can generally do a good job but as for any set of general rules there are areas where they are inappropriate.

Thanks again Robert. You have made some very good points there. A large enough MSB room dedicated for all the electrical switchboards and equipment that the electrical engineer wants does sound like a way forward, although finding a way to make sure contractors can still work without wedging the door open is another one.

Also, it does make you think…either decision will get us caught as long as the lawyer is determined to find a “legitimate” reason to do so and arguments can swing both ways.

I think the best way is to document your rationale in your fire report. If the peer reviewer or BCA disagrees then make a statement in your report that the peer reviewer or BCA does not accept the rationale and their acceptable design is this.
Document “Against my recommendation, in order to gain building consent approval, Mr/Mrs/Ms Architect please show this fire rated electrical cupboard door with XXXXXXXX” Let the approving body take the rap.

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Access hatches that serve at required sub-system servicing are okay without a spring loaded hinge.
Access hatches within attics for fire compartmentalisation or smoke, would require self closures devices.

Local experience
2 story residential with an exterior egress system that connected 20 units, caught on fire and on investigation, the attic hatches were deems to have been left open, which caused the building to be a lost, before the fire service could control it.

Further to this topic… have just been told by Auckland Council that switchboards behind fire doors in a safe path are not permitted by C/AS2? thoughts? C/AS2 3.10.1 (f) Exitways shall not be used for: The location of an electrical switchboard or similar

If the switchboard is fire separated from the safe path then technically it is not in the safe path.
Fire rating off a switchboard used to be the “fix” for old existing buildings with switchboards in the fire escape stairs.
Switchboards are good places for fires to start. Consider the failure mechanisms that could result in a switchboard fire compromising the egress stair. Becomes significantly more important it the stair is a single escape stair.
You could choose to force the issue but I suggest you pick your battles. Try not to support bad architectural design.

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Agree wholeheartedly Rob, very important to pick your battles! Definitely a good ‘safety in design’ decision for a new building to take away the risk entirely of doors to switchboards being left open, especially for a SMOE.

I totally agree with Robert.

A switchboard in a safe path is exactly that. Put it into a separate fire cell (door or inspection hatch/whatever) and it is not in the safe path. Compliance to C/AS2 would be achieved…