Surface downlights - do they need to be fire rated ?

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My son's bathroom has surface mounted downlights set into a lowered, suspended ceiling. It's a flat with another flat above.

The downlights at present are fire rated so the whole unit has to be removed to change the bulb. This damages the ceiling each time a bulb has to be replaced.

As it's a suspended ceiling which doesn't affect the integrity of the main ceiling fire break, could you tell me if the lights need to be fire rated or could they be replaced with normal downlights for which the bulbs could be replaced without removing the whole unit please ?
 
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As most electricians, I am not a fire prevention officer, I may from time to time assist one walking around with a smoke generator, but it is well over my remit to work out how fast a fire will spread, and using plastic bulbs instead of glass in down lighters must clearly affect their fire rating, but never seen on marked glass bulbs only.

So we air on the safe side, and likely fit hoods, and fire rated fittings when really not required, but once fitted it is a brave man who will decide it was never required.

Look at GX53, surface mounted, with renewable bulbs.
 
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these are fire rated replaceable bulb GU10 downlights
NOT a recommendation , as not used, just an example
my son-in-law was thinking of using in a shower room
IP65 , so zone1,2,3 , how high is the false ceiling ?
 
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