Automated Doors - What does the law say?
Powered (automatic) gates (barriers and doors) located in ‘workplaces’ are subject to a number of specific legal requirements. These will include requirements for:
- design, manufacture, supply and installation under the Supply of Machinery (Safety) Regulations 2008; and
- inspection and maintenance under the Workplace (Health, Safety and Welfare) Regulations 1992.
There will also be general requirements under the Health and Safety at Work etc. Act 1974 in relation to risks to third parties (non-employees).
Powered (automatic) gates for use on private domestic premises must comply with the Supply of Machinery (Safety) Regulations 2008 when first installed.
Impact of Provision and Use of Work Equipment Regulations (PUWER) on Automated Door Installation and Maintenance
The main requirements are essentially that any risks to people's health and safety arising from the use of work equipment are prevented or controlled by:
- selecting and providing the right equipment for the job;
- ensuring work equipment is safely used by trained people;
- inspecting and maintaining work equipment so it remains safe.
Maintenance work should only be undertaken by those who are competent to do so, who have the necessary knowledge and experience to:
- know what to look at;
- know what to look for;
- know what to do; and
- be aware of, and able to avoid, unnecessary risks to themselves and others.
In some cases, workers undertaking maintenance on certain types of equipment should have specific training which is relevant to that work (e.g. meeting EN16005 or where they may encounter asbestos).
What are the risks with powered (automatic) doors and gates, and how can they be controlled?
In recent years, a number of adults and children have been seriously injured or killed by this type of machinery. The injuries were caused because people have been trapped or crushed by the moving door or gate. All powered doors and gates must be properly designed, installed and maintained to prevent possible injuries.
Powered Gates and Doors:
- Must be properly designed, taking full account of the environment of use, the presence of vulnerable members of the population, and potential foreseeable misuse, as well as intended use;
- Manufactured (including when assembled from components in situ) to the safety standards required by law, regardless of whether for use in connection with work, or located on private domestic premises;
- Supplied with all relevant documentation, particularly the User Instructions for the complete product, and where necessary of component parts;
- Installed safely, and maintained for safety, by competent contractors;
- If part of a workplace, be adequately inspected and maintained for safety;
- If part of premises managed by a work undertaking (including landlords and managing agents of residential complexes), to meet the general duty for the safety of non-employed persons;
- As necessary for on-going safety, regularly checked, which may require specific inspection, testing, and adjustment, so they remain safe; and
- Where found to be dangerous, immediately taken out of use until all of the safety concerns have been adequately addressed.
Products produced for permanent incorporation in building and civil engineering works enforce the provisions of the direct acting EU Regulation 305/2011. Where such products are also machinery (e.g. powered roller shutter doors), they will also have to meet the Machinery Directive 2006/42/EC and the Electromagnetic Compatibility Directive 2014/30/EU (if electrically powered).
Fire Safety and Doors
Most fires are preventable. Those responsible for workplaces and other buildings to which the public have access can avoid them by taking responsibility for and adopting the right behaviours and procedures.
Employers (and/or building owners or occupiers) must carry out a fire safety risk assessment and keep it up to date. This shares the same approach as health and safety risk assessments and can be carried out either as part of an overall risk assessment or as a separate exercise.
Fire Doors are engineered products that provide life and property saving functions in the event of fire. It is important that they are regularly inspected and maintained to permit them to perform at their best on the one and only occasion when they are called upon to do so.
Doorsets fitted with hold open devices or swing free type closers should be closed daily, particularly overnight when there is likely to be low building occupancy. For busy 24/7 buildings (e.g. hospitals), Fire Doors should be closed at least weekly. All Fire Doors should close effectively from any angle of opening, using only the door closer.
- There are a number of reasons why doors may fail to close:
- foreign bodies or other objects may be obstructing the door,
- the smoke seals may be incorrectly fitted or damaged,
- a fitted latch may be malfunctioning or require lubrication,
- the closing device may need adjustment but this must only be done as a last resort and very carefully, to ensure that the door can be opened without undue force.
Intumescent seals should be checked regularly, at intervals not greater than 6 months, and damaged or missing ones replaced. To maintain the designated performance potential, replacement seals should be of the same brand, size and type as the original.
Mechanical items such as hinges, locks, latches, closers, floor springs, etc., are likely to wear over time. Maintenance provisions should comply with the hardware supplier’s recommendations.