Building Regs / FENSA required or not for THESE french doors?

[eBatch]

Considering having French doors and side panels replaced (each side panel is, as near as dammit, same size as one of the French doors). Plan is to have these made of wood with argon filled toughened DG and to leave the existing overall frame in place. So the existing main frame and the vertical bars between doors and each side panel would stay.

Question is does this need building regs approval?

For example, back of FENSA certificates has a section entitled "Does not fall into remit of FENSA" which includes "Repairs (Frame not included)". I've even had quote where has actually been stated that what we propose does not need building regs approval or FENSA cert as the frame not being replaced.

Any views on this? Are the rules sufficiently open to interpretation (e.g. as to what is a repair rather than replacement) mean approval not needed?

 

[joe-90]

FENSA is really for plastic windows that have no structural integrity.

 

[^woody^]

That's not a repair, it's a replacement and therefore controlled work.

 

[^woody^]

FENSA is really for plastic windows that have no structural integrity.

What about plastic windows with structural integrity?

 

[Brad Ninch]

Had this experience a couple of years ago and regulations are quite clear - if the frame remains in place FENSA certification is not required.

 

[eBatch]

Had this experience a couple of years ago and regulations are quite clear - if the frame remains in place FENSA certification is not required.

Thanks for that, but does the question remain as to whether it still falls within remit of building regs (even if not FENSA)?

In any event, could you expand on your experience at all please?

 

[Brad Ninch]

Hi - have a look at Building Regulations Approved Document K 2013. You can download this from lots of places including the Planning Portal. Ignore the first few pages numbered i) to vii) and look at Page 1 under the paragraph Application 0.2. It says "Regulation 3 defines building work" and then goes on at "b) the replacement of glazing whilst retaining an existing frame (e.g.as a repair) is not building work, but the supply of glazing may be subject to consumer protection legislation." The answer to your question is therefore simple. What you are proposing is not "building work" and therefore not covered by the Building Regulations. When we had similar work done we asked the glazing supplier if they would issue a FENSA certificate and they said that the supply was not covered by the FENSA protocols. They did however - and rightly - agree that we should use toughened glass (as we had asked for) and I guess that that that reflects the reference in the paragraph b) to the fact that the supply of glazing "may be covered by consumer protection legislation". I hope this helps.

 

[^woody^]

Hi - have a look at Building Regulations Approved Document K 2013

Window replacement and the involvement of FENSA derives from Parl L not K.

Part L defines what is a controlled fitting in this context. Only a repair of part of the fitting would not be controlled work. Any substantive replacement is effectively replacement, and thus controlled.

There is nothing to state that leaving the frame in is not controlled work. That is a misinterpretation of the example given in Part L of replacing glass and leaving the frame

 

[Chud]

That's not a repair, it's a replacement and therefore controlled work.

What if you accidentally put a hammer through the existing glass first

 

[Brad Ninch]

Interesting perspective about Part L. I absolutely agree that replacement windows and doors are covered by Part L and FENSA requirements but the replacement of glazing within a retained frame is not mentioned (as far as I can see) anywhere in Part L but is explicitly provided for in Part K. It is quite possible that some Building Control Officers will ask for applications covering replacement glazing in a retained frame but my contention is that they are doing so outside the legal framework of the Building Regulations. If I have missed a clause in Part L that covers replacement glazing in a retained frame (as is cited in Part K) I would be glad to have it pointed out.

 

[freddiemercurystwin]

Requirements for the renovation or replacement of thermal elements – Regulation 23
(1) Where the renovation of an individual thermal element—
(a) constitutes a major renovation; or
(b) amounts to the renovation of more than 50% of the element’s surface area; the renovation must be carried out so as to ensure that the whole of the element complies with paragraph L1(a)(i) of Schedule 1, in so far as that is technically, functionally and economically feasible.
(2) Where the whole or any part of an individual element is proposed to be replaced and the replacement—
(a) constitutes a major renovation; or
(b) (in the case of part replacement) amounts to the
replacement of more than 50% of the thermal element’s surface
area; the whole of the thermal element must be replaced so as to
ensure that it complies with paragraph L1(a)(i) of Schedule 1,
in so far as that is technically, functionally and economically feasible.

 

[^woody^]

Look in L2b. I don't recall the exact clause, but the criteria for doors and windows is specifically stated.

 

[Brad Ninch]

I note the quotation from Regulation 23 but of course this does not apply to windows and doors as windows and doors are explicitly excluded from the definition of "thermal elements" under Regulation 2(3). Part L2B does indeed cover the replacement complete windows and doors but I still cannot track down any reference (such as there is in Part K) to part replacement within a retained frame. I remain to be persuaded by a specific reference to a specific clause in the absence of which the poser of the original question can surely proceed without seeking authority approval.

 

[Brad Ninch]

In the hope of putting this to bed and giving the poser of the original question and other contributors some comfort, please see paragraph 4.23 of Approved Document L2B which says, "4.23 In the context of this approved document the application of the term controlled fitting to a window roof window, rooflight or door refers to a whole unit i.e. including the frame. Consequently replacing the glazing whilst retaining the existing frame is not providing a controlled fitting and so such work is not notifiable and does not have to meet Part L standards, although where practical it would be sensible to do so. Similar arguments apply to a new door in an existing frame." Best of luck.

 

[eBatch]

That's brilliant. Nice to see some concise and to the point discussion quoting the various regs (rather than unsubstantiated shooting from the hip that seems to be the case in so many of the threads on the forums on this site).