Life safety in the BCA
The Need
The safety of building occupants is of paramount importance to fire services and building regulators. AFAC has concerns regarding the ongoing attempts to limit fire safety and fire suppression provisions in the Building Code of Australia (BCA) and the implications this has for fire service operations and firefighter safety.
AFAC has been concerned for some time with the underlying regulatory principles of the BCA. The current approach to building regulation is flawed in that it has unwittingly supported the emergence of a culture in which the safe evacuation of building occupants is regarded as the sole objective, leaving responding fire fighters, the environment, critical infrastructure, building stock more generally, and in some cases, the safety of the community, unnecessarily exposed.
Key points on firefighter life safety in the BCA
- Fire fighters are not considered occupants of a building under the provisions of the BCA. AFAC has consistently sought to have firefighters regarded as occupants of a building whilst engaged in search, rescue and fire fighting operations. This is necessary because OHS legislation is clear on the fire ground being a work place and fire service Acts are clear about firefighting taking all practicable steps to save life and property .
- A fundamental objective of building regulations should be to establish a requirement that buildings are constructed in a manner that will provide the fire services with an opportunity to safely contain a fire to the fire compartment of origin.
- AFAC would like to see increased harmonization between Federal and State regulatory building requirements and regulatory systems. A key focus for the Australian Building Codes Board (ABCB) should be a consistent role for the fire services in the building regulatory process throughout the construction and building-in-use cycle.
- Despite AFAC’s continuous representation on Australian Building Codes Board (ABCB) sub-committees and working parties, together with the strong relationship that AFAC has forged with the ABCB, AFAC has been overlooked as a key stakeholder on several reviews carried out in the building regulatory arena. AFAC members believe that this omission sends a particularly negative message in terms of the value being placed on the safety of the community.
- AFAC believes a national repository of fire-related data is needed for access by key stakeholders. The national repository would support the development of evidence-based changes to “deemed to satisfy” provisions and validation of performance solutions within the BCA. AFAC has offered to work with relevant authorities to develop this data base.
- AFAC has a number of concerns in the Consultation Regulatory Impact Statement (RIS) with the suggestion that Concealed Space Protection changes as proposed by the Consultation RIS. We challenge the validity of the data in the Consultation RIS which suggests that changes in concealed space protection will result in an aggregate cost increase.
- Any suggestion, implied or otherwise that AFAC supports the proposal by way of reference to participation in the Reference Group is not correct. AFAC has sought an appropriate statement that AFAC, although participating in the reference group does not endorse the reference document or the proposed BCA amendments.
- AFAC considers that in the absence of evidence to the contrary, the control of fire should be deemed as equivalent to providing the necessary minimum life safety requirements of the BCA. On this basis the bulk of AS 2118- 2006, including Sections 5 and 11, should be adopted in the ABCB Reference Document. AFAC accepts there is scope for rationalization in relation to minimum water supply duration as already negotiated.
Benefits and Strategic Alignment
AFAC has been concerned for some time regarding the underlying regulatory principles of the BCA. An analysis of the current regulatory framework has identified several key factors contributing to their cause:- Conflict with the statutory obligations of the fire services
- The need to better understand and react to “community expectations” and to ensure the objectives of the regulatory framework are aligned to those of the community
- Inconsistent integration of the fire service role into the building regulatory system
- Lack of effectively resourced research agenda to collect and analyse fire-related data to support evidence-based policy development
- Lack of fire service representation on key decision making bodies.
Proposal
To overcome this current conflict in purpose, AFAC members strongly support the extension of the ABCB mission and BCA objectives to encompass elements such as property and environmental protection. The AFAC response to the intergovernmental review articulates AFAC’s position on these critical issues and in conclusion, makes the following recommendations:1.That the mission of the ABCB and the objectives of the BCA are expanded as a matter of good public policy to encompass:
- property protection
- environment protection
- firefighter safety
- community resilience, and
- precautionary principles (moving from examples of market failure to considerations of future impacts), to the extent necessary to meet community expectations.
- environmental protection
- property protection
- sustainability (community and business)
- life safety
- firefighter safety
- security
- terrorism
- arson
- climate change
3. That a fundamental objective of the building regulations is to establish a requirement that buildings are constructed in a manner that will provide the fire services with an opportunity to safely contain a fire to the fire compartment of origin.
4. That the economic indicators that currently underpin the regulatory framework incorporate a further requirement, “Total Cost of Fire”, when considering economic impacts of regulatory change. Accordingly, the full range of direct and indirect socio-economic consequences of fire must be considered when assessing fire cost.
5. That the achievement of increased harmonisation between Federal and State regulatory building requirements and regulatory systems becomes a key focus for the ABCB, through the implementation of a national framework that incorporates a consistent role for the fire services in the building regulatory process throughout the construction and building-in-use cycle.
Consultation
Fire Services and the Australian Building Code Board have formed a working group to progress this projectGovernance
This work will be managed by the AFAC Community Safety Manager and members of the Community Safety GroupFor more information on this project please contact Rob Llewellyn, AFAC Manager Community Safety.
