Fire doors containing asbestos-impacted fire-retardant boards

Fire-retardant boards (FRBs) distributed in Aotearoa New Zealand and imported from Australia and from China between 2021 and 2025, have tested positive as containing asbestos. This product has been used to manufacture fire doors.

Building owners who have been supplied with fire doors that may be affected need to understand and comply with the requirements of the Building Act 2004, the New Zealand Building Code, the Health and Safety at Work Act 2015 and Health and Safety at Work (Asbestos) Regulations 2016.

Please also refer to

Imports and Exports (Asbestos-containing Products) Prohibition Order 2016 (LI 2016/218) - legislation.govt.nz

The following information will help building owners understand how to comply with the requirements of the Building Act, if the building contains potentially affected fire doors.

Responsibilities under the Building Act 2004

Under the Building Act, section 14B Responsibility of owner states that an owner is responsible for:

• (a) obtaining any necessary consents, approvals, and certificates
• (b) ensuring the building work carried out by the owner complies with the building consent or, if there is no building consent, with the Building Code
• (c) maintaining the building and meeting Building Warrant of Fitness obligations for specified systems (such as fire doors and passive fire separations)
• (d) ensuring compliance with any notices to fix.

Responsibilities under the Building Act - legislation.govt.nz

Aotearoa New Zealand-based manufacturers and importers need to make particular information about the building products they supply publicly available.

This includes information about the scope and limitations of use for the product, how it is expected to contribute to relevant Building Code clauses, and any design, installation, and maintenance requirements.

Building product information requirements.

Affected parties should have received notification from their supplier about the voluntary recall of fire doors containing potentially affected fire-retardant boards.

The voluntary recall applies to doors that have not yet been installed or are only partially installed. Doors that are already fully installed and in use are not subject to recall.

Contact your supplier if you have any concerns. Supplier information will be visible as a sticker or tag on the door.

Warnings or bans under section 26 of the Building Act 2004

Under the Health and Safety at Work (Asbestos) Regulations 2016, it is prohibited to carry out any work that involves manufacturing, supplying, transporting, storing, removing, using, installing, handling, treating, disposing of, or disturbing asbestos.

MBIE considers this prohibition sufficient grounds for those with responsibilities under the Building Act 2004 to take appropriate action in their specific circumstances.

As of today, MBIE has not issued a warning or declared a ban under Section 26 of the Building Act. This is because such actions are considered measures of last resort and there are specific legal provisions already in place (through the regulations). However, MBIE may review this position at any time if it determines that the level of risk has changed.

Buildings with doors that contain potentially affected fire-retardant board

If you have received notification from your supplier, follow their instructions along with the advice from WorkSafe.

All potentially affected fire doors will need to be identified by those who manage or control the property to comply with the Health and Safety at Work (Asbestos) Regulations 2016. This includes:

• adopting a blanket asbestos presence presumption for risk management purposes
• adding the doors to any existing asbestos management plan or implement a new asbestos management plan in relation to the doors
• keeping the asbestos management plan up to date, making careful note of where the doors are located and their condition.

Further installation of the affected fire doors, including hardware fitting, is strictly prohibited under Regulation 7 of the Health and Safety at Work (Asbestos) Regulations 2016.

All regulatory requirements for handling asbestos apply when removing the affected doors.

For more information on safe practices for identifying, installing and disposal of asbestos, health advice, WorkSafe’s position on further testing, and frequently asked questions read fire safety doors response.

Fire safety doors response - worksafe.govt.nz

Building owners who have potentially affected fire doors could be in one of the following stages of their build:

• doors supplied and uninstalled
• doors supplied, installed, with further invasive work such as hardware install pending
• doors supplied, fully installed and fire tags issued.

Doors supplied and uninstalled

If you have been supplied with potentially affected fire doors that have not been installed:

• affected doors must be quarantined and disposed of as asbestos waste. This will need to be done in line with your asbestos management plan
• a licensed asbestos removal specialist must carry out the work if 5 or more doors are to be removed cumulatively across your building/building site.

Doors supplied, installed, and further invasive work pending

If you have been supplied with potentially affected fire doors, and they are partially installed:

• further installation of these fire doors, including hardware fitting, is strictly prohibited under Regulation 7 of the Health and Safety at Work (Asbestos) Regulations 2016
  
  Regulation 7 of the Health and Safety at Work (Asbestos) Regulations 2016 - legislation.govt.nz
• affected doors must be quarantined and disposed of as asbestos waste. This will need to be done in line with your asbestos management plan
• a licensed asbestos removal specialist must carry out the work if 5 or more doors are to be removed cumulatively across your building/building site.

These doors are likely to be present on construction projects where building work is ongoing, and that are subject to a building consent.

If the affected doors are removed and replaced with a door with exactly the same specification, that is the same make (manufacturer) and model (the specific product line or type), there will be no requirement to update the building consent.

Where doors are replaced with a door that is different to the one specified in the building consent, and noted in the draft compliance schedule, a variation to the building consent will be needed.

More information on product substitution

Contact your building consent authority for their interpretation and requirements.

Doors supplied, fully installed with fire tags issued

If you have been supplied with potentially affected fire doors, and they are fully installed with fire tags issued, consider the following:

• the initial building project may be complete, and the Code Compliance Certificate and Compliance Schedule issued
• the building may also be occupied.

In these situations, replacing affected doors will result in a new building project, and may require a building consent.

The new door set must meet or exceed the original fire rating and comply with relevant Building Code clauses.

You must use a building product that is suitable for the intended fire rating and installation context.

Buildings that are used by the public may also require a Certificate of Public Use until the Code Compliance Certificate for the door replacement has been issued.

Options for building owners

Building owners with potentially affected fire doors have three options.

Like-for-like replacement

Replace the affected fire door(s) with a new door of the same make, model and fire-resistance rating.

This work may be exempt under Schedule 1 of the Building Act, Exemption 1. General repair, maintenance, and replacement provided:

• it is a like-for-like replacement
• the replacement does not alter the fire safety system or structural elements.

When replacing an installed fire door there are some key things to consider:

• the replacement fire door and all associated work must comply with the Building Code
• asbestos management and removal must comply with the Health and Safety at Work (Asbestos) Regulations 2016.

Replacement with a different door (affecting the door set)

In this situation the affected fire door(s) are replaced with a different make or model, or the replacement changes the door set or fire separation.

Replacing a fire-rated door with a different make/model is a significant change that requires building consent, compliance with the Building Code, proper asbestos management, and updating of your BWOF and compliance schedule.

You must use a building product that is suitable for the intended fire rating and installation context.

The new door set must meet or exceed the original fire rating and comply with relevant Building Code Clauses.

If the fire door is not the same specification or the replacement of a fire door involves adjustment of the door frame or alterations to the surrounding fire separation, this would not fall under the exemptions in Schedule 1 of the Building Act 2004.

Asbestos management and removal must comply with the Health and Safety at Work (Asbestos) Regulations 2016.

Always consult your local council and WorkSafe New Zealand for guidance.

Speak to your local council to discuss the extent of the intended building work to confirm if a building consent is needed.

Door(s) remain in place

All potentially affected fire doors will need to be treated by those who manage or control the property to:

• add the doors to any existing asbestos management plan or implement a new asbestos management plan in relation to the doors
• keep your asbestos management plan up to date
• make careful note of where the doors are located and their condition
• follow the advice of your supplier and WorkSafe about how to comply with the Health and Safety at Work Act 2015 and the Health and Safety at Work (Asbestos) Regulations 2016.

The building consent and Code Compliance Certificate (CCC) must accurately reflect the products installed.

Making changes to your plans has information on building consent amendments and minor variations

Where CCC has already been issued and the affected door is part of a specified system listed in the compliance schedule, the compliance schedule should be updated to reflect any changes to the inspection, maintenance, or replacement protocols for the specified system that are required due to the presence of asbestos.

Building owners should check with the council to discuss what is required to amend the building consent and compliance schedule.

Information on amending compliance schedules

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