Implementing compliance: Paints & coatings

Implementing compliance: Paints & coatings

There has been an increased awareness regarding the impacts for fires, both in the finance industry as well as within governments. This is leading to newer regulations and evolving conformity regimes. Developers are now asking contractors about evidence of fire safety. With changing supply chains due to realignments of global relationships, specific queries are being fielded by manufacturers and traders of building materials about traceability of materials. Continuing the series about ‘implementation’ of passive fire protection, abhishek chhabra, business development manager, thomas bell-wright consultants, takes a deep dive into interior finishing and structural fire protection as two different applications of passive fire protection, but with some common pitfalls.

Recently the general command of civil defense in the uae issued a memo urging industry partners to adhere to the “uae fire and life safety code of practice” and to adhere to the requirements of the circular issued in june 2023 which brings about some amends to how fire-stopping is to be implemented and inspected. These were further to workshops discussing improvement of internal firestopping in buildings undertaken in the last 12 months in the uae. This is a clear sign of how government bodies are getting more involved in, and having a closer watch on, ensuring fire safety regulatory frameworks.


These are omnipresent whenever there is anything being built. Everywhere from manufacturing locations to construction sites, and our offices and homes too. Drums or powders with mixers are often a result of a lot of precise research and development to create optimum performance as well as look and feel. Often the manufacturing locations producing these chemicals operate under strict health and safety conditions as the simple-looking experiments in beakers, petri dishes and test tubes potentially become high-hazard processes when the volumes of these ingredients become huge. What looks like a tiny hiss in a beaker is potentially a large explosion inside a factory.

While there is a massive spread of performance and behaviour of paints and coatings; there are a couple of similarities among all of them. While they could be used to control the reaction to fire behaviour on one side or to enhance the fire resistance capability of structural elements and other systems; their production and the form in which they are available and transported are often very similar. But there is a key aspect related to using these which is often insufficiently understood. And this has to do with how these paints and coating actually do their jobs. If you consider image 1, you can probably grasp that application methodology and the processes by which the chemicals create a hold on the surface can vary a lot. These are complex actions, requiring a lot of precision and control in terms of the environment where the coating is applied as well as, of course, how it is done. This leads to a key variable which is the state and type of substrate on to which the paints and coatings are applied. And, of course, the knowledge and precision expected of the applicators.

To add more context image 2 points to a list of properties which actually help bring about the function which provides for the passive fire protection (often related to fire resistance).

The post-pandemic world and changed geo-political environment has left the manufacturing industry work hard to adapt. There is a dire need to look for new raw material suppliers as well as train new staff members who undertake roles which were undertaken by others or scenarios where technology is forcing adaptation. For businesses to maintain repeatability of supply of materials requires effort and sometimes more money. In instances where no one is watching or assuring the repeatability of production, it is easier to let things slide till something drastic happens. Image 3 gives an indicator of the volumes of imports which helps us understand how much of this product is moving in the world.


The buyer of a paint or a coating material is often a subcontractor who will deliver something in between what he has been contracted to do and what is being checked by a competent authority. If the contract is not a high stake project it may not lay emphasis on who is taking the liabilities in case of nonperformance and what those liabilities could be! The assurance of performance of a paint or a coating lies in ensuring the repeatability of manufacturing and following the application process which is proven to bring out the marketed results. Whether they are used to control the reaction to fire behavior of finishing materials indoors or outdoors, or used to enhance the fire resistance capability of structural elements and other systems; the application rigor needed to deliver what is showcased in image 1 needs supervision of some sort. Let’s take a look at specific stakeholders to understand where does the control lie and where can more care be taken to ensure there are no slippages.


Whatever the type of construction; it would involve a structure to be protected by fire and it would have interior and exterior finishing done. In certain instances, the extent could be minimal but a mechanism of assurance needs to be in place. Correct implementation starts with the ‘owner’ realising that a risk of fire exists, special attention needs to be given to ensuring it does not spread in the interior/ exterior and that the structure needs a protection measure. The owner may not always be fully aware as the potentially affected entity due to a fire could be the ‘insurer’ or ‘occupier’. This is not a desirable situation but is very prevalent.


The changing supply chains, transport as well and storage have a direct impact on the assurance of promised performance. A relatable example is comparing the effort required to bring about repeatability between cooking a dish of any cuisine versus fixing together and modular furniture pieces. Getting the repeatability in the taste of a dish requires a slightly more rigorous process.


The owners should keep in mind that the probabilities of fires are higher than what they used to be. Combined with the changing landscape of materials and manpower, there needs to exist a more robust framework to check and assure these two aspects bring about increased assurance. Relying on the minimum regulations set by the local government or jurisdiction (which might not be updated) may not be sufficient.

The fulfilment in case of an incidence from the local jurisdiction would have limitations. This is less likely to cover the liability on reputation and commercial losses for the property owner. Hence it is recommended to use best known practices as compared with minimum local requirements. Knowing there are more combustible materials indoors, the total fire load inside buildings is higher than what it used to be a decade or two ago and this is a matter of concern and must be factored in.


The reputation of a business is directly linked with increasing their clients as well as liability. A wrong decision or overlooking a matter that is critical to a contract (promise of deliverables) will eventually lead to an instance which will lead to reputation loss and eventually loss of business. Whether the matter is related to understanding the newer methods of creating a buildings structure (structural consultant) or understanding the interiors, compartmentations and the fire risks and potential routes of spread of fire; a specialism is needed. Depending on the scale of the project/ building getting this competence has been becoming more and more critical. Here are some suggestions.

  • If the project is large make sure the structural consultant
    is contracted to design and build in correct structural fire
    protection. What is in contracts is implementable and is either
    backed by a law or a commercial clause.
  • Ensure an updated understanding within the architect
    / designer or fit-out specialist about the reaction to fire
    properties and fire load calculation of interiors.
  • Contracts: Define, limit and link your liability using assurance
    mechanisms of certification and listing and appropriate
    standards and codes.
  • The scope of a specialist consultant could be both maker and
    checker. If so, make sure the teams are equipped with the (as
    sometimes needed) accreditation or at least training.
  • In some jurisdictions/ codes like the UAE Fire & Life Safety
    Code and Saudi Building Code have some scope calling for third
    party accreditation to authorise auditing.


The contractor does what the contract says. And if the contract does not say much then a lot of things could fall into default options. Hence it is important to define important aspects in the contract. Below are some points to note.

  • Be careful, aware and keep track, of local minimum
    requirements that could be handed over as per a legal
    requirement in the jurisdiction where work is being performed.
  • As an example, Decree 213 in UAE empowers the UAE fire &
    Life safety code of practice. This code has a chapter (18) on
    the responsibilities of stakeholders.
  • In case a contractor is not being allowed to fulfill their
    obligations technically or commercially, then they need to
    back out of the contractual document and pass it on to
    someone else.
  • Often, though not always, the contractor gets an approved
    drawing which needs to be built. Changing anything here or
    initiating any change brings the ownership of the efficacy of
    the design back to the changer/ contractor. In case these are
    not documented, these can become liability.
  • A key worry for contractors is to maintain the workmanship.
    This should be addressed using regular training and audits.
  • To safeguard the interests, third party independent Inspection
    bodies are used. Sometimes, these are contracted by the main
    contractors or consultants. But in case such inspection bodies
    are reporting back to the sub-contractor themselves then there
    is conflict of interest.
  • Care must be taken to choose a qualified inspection body.


Sometimes the supplier ends up taking on more liability than needed. Often tempted by the order (value). This is dangerous as there are limits to what the material supplier has visibility of. Specifically, on how the material could be used. Below are some of the key points of note for sellers and buyers of paints and coatings.

  • A manufacturer or seller of material can only provide assurance
    of the fire performance of the material alone with a defined
    substrate and application methodology. This should be
    correctly documented and contracted.
  • As an example, a flame retardant which provides a Class A (As
    per American methods) or Class A2(As per European norms)
    would be on a given substrate (Even types of wood are defined)
    and give number of coats. This should be defined and declared
    correctly to minimize taking on blanket liabilities.
  • In a fast-paced trade environment, keeping the raw material
    suppliers and manufacturing processes the same is not that
    easy. This is a challenge for manufacturers, but should be
    known to buyers correctly as well.
  • Trained applicators need to be used is often known, but
    seldom contracted in. Defining their expected qualifications or
    liabilities helps.
  • To safeguard the interests, third party independent conformity
    assessment bodies are used. They independently audit the
    processes and supply chain control mechanisms along with
    regularly assessing samples of the products to check for their



Image 6 provides a graphical representation of the key considerations for the implementation of fire safety for coatings & paints. The image adds references of international standards which can be used by regulators as well as contracts to bring about parity of performance of third-party assurance providers.

The main risk when it comes to paints and coatings is a mismatch of two key aspects:

  • What is expected to be supplied to the site and what actually
    reaches it? The solution is the correct use of Testing and certification
    & Listing.
  • The mismatch between how the coating was done for the test
    whose results are being relied upon and how the coating is
    being done at the site. The solution is attaching liability to this
    assessment and using third-party inspection to define and
    divide this liability.


To deliver a coating system correctly will always have several stakeholders. In order for the solution to perform as committed, specifically on the fire safety side, it is imperative that there is an alignment of expectation of performance and clearly contracted responsibilities. Correctly worded and referenced standards provide the tools to complete assurance and quantifying liability. The aim is to deter actions that are (now) known to create (fire) risky situations which needed to be avoided.

  • Understand the limitations of test reports. Test reports only
    prove capability of someone being able to produce a sample
    for a test. Test reports alone are not proof of what will be
  • Understand the tools of certification and listing that provide
    traceability check on materials. Use this knowledge in
    specifications and decisions: Pre-tender & Post tender.