Agree or Disagree

Are we maintaining Life Safety System in the correct way with AS1851 or should they be maintained to the EP&A as per the installation code requirements in NSW?

This was sent to me from an undisclosed source which will get you thinking,

AS1851 is the Australian Standard for routine service of fire protection systems and equipment. AS1851 is formally recognised and adopted by some jurisdictions in Australia, such as Queensland. Fortunately, the NSW Government did not adopt or recognise AS1851 in the Environmental Planning & Assessment Regulation (EP&A Regs).

 AS1851 outlines how someone should go about undertaking a routine service of a fire safety system. Whereas, in NSW Clause 175 of the EP&A Regs states that an annual fire safety statement must be issued to the effect that each essential fire safety measure in the building has been assessed by a CFSP and as found, when it was assessed, to be capable of performing to a standard no less than that specified in the fire safety schedule. This is a much higher a rigorous benchmark. To provide an analogy, you can service your car in accordance with the manufacturer’s recommendations, but doing so will not provide any guarantee that every facet of the car will perform as intended when you drive it. This is the difference between AS1851 and Clause 175 of the EP&A Regs.

 For a specific example and to provide some context I will highlight one of the differences between AS1851 and Clause 175 of the EP&A Regs. AS1851 requires a CFSP to check and ensure that 20% of all fire dampers in a building are in place, free from obstruction, and capable of operation (so that all dampers have been inspected by the end of the fifth year). Whereas, Clause 175 of the EP&A Regs requires a CFSP to assess/ inspect every fire damper in the building and confirm they are capable of performing to the relevant part of the Building Code of Australia (BCA) and design/ installation standard (eg. E1.8 of the BCA, Spec E1.8 of the BCA, AS1682.1 & AS1682.2). This means the CFSP must assess/ inspect every fire damper in the building and confirming every facet of the fire damper complies with the BCA and design/ installation standard.

 Before the owner (or their agent) issues an annual fire safety statement, they must be satisfied that each fire safety measure has been assessed by a CFSP and was found, when it was assessed, to be capable of performing to a standard no less than that specified in the fire safety schedule for the building.

Engaging a CFSP to carry out a routine service in accordance with AS1851 does not meet the owners’ obligations under Clause 175 of the EP&A Regs nor confirm the fire safety measure is capable of complying with the BCA/ relevant Australian Standards. Unfortunately, this is a common misconception and we continuously come across CFSP’s who do not understand the requirements of the EP&A Regs with regard to annual fire safety statements or try to operate under the Queensland model in New South Wales.

 The responsibility as to who signs off which parts of a building or specific fire safety measures is a private matter between the owners, tenants, CFSP’s, etc. However, no one should be signing an annual fire safety statement relying upon AS1851 routine service reports. Feel free to provide my details to anyone who claims an AS1851 service report can be used in lieu of an assessment by a CFSP for the purposes of issuing an annual fire safety statement.

I would be interested to hear your thoughts, agree/disagree?