The Effects of AS1851-2012 Changes Taking Effect on 13 February 2025

Introduction

The Australian Standard AS1851-2012, which sets out the requirements for the routine service of fire protection systems and equipment, plays a vital role in ensuring fire safety across various industries and buildings in Australia. On 13 February 2025, AS1851-12 will take effect, that aim to improve compliance, maintenance practices, and overall safety. These changes reflect ongoing efforts to adapt to evolving fire safety needs and ensure that fire protection systems function reliably in emergencies.

This article will explore the key impacts of these changes and what stakeholders—such as building owners, facility managers, and fire protection service providers—need to know as they prepare for this shift.

In New South Wales, the Environmental Planning and Assessment (Development Certification and Fire Safety) Regulation 2021, specifically Section 81, outlines the obligations of building owners regarding the maintenance of essential fire safety measures. According to this regulation, building owners are responsible for maintaining fire safety systems to specific standards:

  1. For fire safety measures listed in a fire safety schedule—maintenance must be done to the standards specified in that schedule.

  2. For fire safety measures not listed in a fire safety schedule (referred to as original measures)—maintenance must be performed to the standards originally designed and implemented for those systems.

While the regulation clearly states the need to maintain these systems, AS1851, the Australian Standard for the routine service of fire protection systems and equipment, is notably absent from the legislation. This has led to a situation where some fire maintenance companies are not adhering to AS1851 when providing their services, instead following whatever standard they state in their quotations to clients.

Now the Environmental Planning and Assessment (Development Certificate and Fire Safety) Amendment (Fire Safety) Regulations 2022

[22] Section 81A

Insert after section 81—

81A. Essential fire safety measures to be inspected, tested and serviced

(1) The owner of a building must ensure that the maintenance activities for each. essential fire safety

measure for the building are undertaken in accordance. with—

(a) if a performance solution approved for building work addresses the  maintenance activity—

the performance solution, or

(b) AS 1851—2012, if the maintenance activity—

(i) is not addressed by a performance solution approved for building work, and

  (ii) is addressed by AS 1851—2012.

Maximum penalty—

(a) for a corporation—600 penalty units, or

  (b) for an individual—300 penalty units

(2). The owner of a building must—

(a) keep the records required by AS 1851—2012, or the approved performance solution, on site at

the building for at least 7 years, and

(b) make the records available for inspection by the Fire Commissioner or the relevant council.

Maximum penalty—

(a) for a corporation—300 penalty units, or

(b) for an individual—150 penalty units.

(3) In this section—

AS 1851—2012 means AS 1851—2012, Routine service of fire protection systems and equipment

as in force from time to time. maintenance activities means the following—

(a) inspection,

(b) testing,

(c) servicing.

Stricter Compliance and Documentation Requirements

One of the most noticeable effects of the AS1851-2012 is the stricter focus on compliance and documentation. Building owners and facility managers will be required to maintain detailed records of all fire system inspections, testing, and maintenance activities. The new regulations emphasize transparency and accountability, requiring that all reports be readily available for auditors, fire authorities, and insurers.

Under these changes, failure to keep accurate records or complete routine servicing within specified timeframes could result in more severe penalties, including fines or legal action. This puts added pressure on building operators to remain diligent in their fire safety practices, as any gaps in documentation could result in compliance breaches.

More Frequent and Thorough Testing Protocols

AS1851-2012 standard will introduce more stringent testing intervals and methods for fire protection systems, ensuring that all components are thoroughly inspected and maintained. The changes are designed to address weaknesses in the current service schedules, especially in critical systems that are prone to wear and tear or could fail in an emergency.

  • Sprinkler Systems: Fire sprinkler systems will now require more frequent inspections, with enhanced testing protocols to ensure components like valves, pumps, and piping remain in working order.

  • Fire Detection and Alarm Systems: Smoke detectors, heat detectors, and fire alarm systems will undergo more rigorous testing procedures, ensuring they are properly calibrated and ready to detect fires promptly.

  • Portable Fire Equipment: Portable fire extinguishers, hose reels, and fire blankets will also be subject to more frequent checks, ensuring they remain accessible and functional in the event of an emergency.

These more frequent and thorough testing protocols are designed to minimize the risk of equipment failure, helping to ensure that fire protection systems are always ready to respond to a fire.

Digital Record-Keeping

Digital platforms will allow for automated reminders for upcoming inspections, instant logging of maintenance activities, and quick access to historical records for audits or reviews. The transition to digital record-keeping should also help streamline communication between service providers, building owners, and regulatory authorities, making the entire process more efficient and transparent. This does not eliminate the requirement for logbook on site.

Increased Costs for Maintenance and Upgrades

The changes to AS1851-2012 will likely result in increased costs for building owners and facility managers, as the standards require more frequent testing, detailed reporting, and in some cases, system upgrades. Fire protection service providers will also need to adapt by investing in new tools, training, and digital systems to comply with the updated requirements.

While these additional costs may seem burdensome, they are intended to ensure that fire protection systems remain reliable and effective, reducing the risk of catastrophic fires and potential legal liabilities. By catching faults or deficiencies early, the revised standards aim to prevent costly repairs or system failures down the line, ultimately saving money in the long term.

Alignment with Best Practices

The AS1851-2012 also bring NSW fire safety regulations more in line with all other states. This alignment is especially beneficial for businesses operating across multiple states, as it simplifies compliance by standardising fire protection maintenance protocols. The updated guidelines reflect international trends in fire safety, incorporating lessons learned from state incidents and ensuring that Australian buildings meet high standards for fire protection.

Implications for Fire Protection Service Providers

The fire protection industry will feel the impact of the AS1851-2012 changes in several ways. Service providers will need to adjust their testing procedures and workflows to comply with the more stringent requirements. Technicians may require additional training to handle the updated protocols and advanced equipment needed to meet the higher standards.

Furthermore, service providers will likely need to invest in system to meet the new record-keeping requirements. This could involve upgrading existing systems or adopting new platforms to ensure they can accurately track and report on all maintenance activities. As the demand for high-quality, compliant fire protection services grows, companies that adapt quickly will have a competitive edge in the market.

Enhanced Safety and Risk Mitigation

The ultimate goal of the AS1851-2012 changes is to improve fire safety outcomes and reduce risks associated with fire system failures. By increasing the frequency and thoroughness of testing, the revised standards ensure that any potential faults or deficiencies in fire protection systems are identified and addressed promptly.

This proactive approach to fire safety helps to minimise the chances of fire incidents escalating due to faulty equipment or insufficient maintenance. For building owners, adhering to the updated standards not only ensures compliance but also enhances the safety of occupants and assets, potentially reducing insurance premiums and liability risks.

AS1851 Maintenance: Not Sufficient for Annual Fire Safety Statements Alone

While AS1851 provides a crucial framework for the routine maintenance of fire protection systems, it is important to note that AS1851 maintenance alone is not sufficient to endorse the performance of fire safety measures on the Annual Fire Safety Statement (AFSS). Under New South Wales regulations, the Environmental Planning and Assessment (Development Certification and Fire Safety) Regulation 2021, an Accredited Practitioner (Fire Safety) is required to inspect and assess the building’s essential fire safety measures before endorsing the AFSS.

Why AS1851 Maintenance Alone is Not Enough

AS1851 outlines the procedures and frequencies for maintaining various fire safety systems, such as fire alarms, sprinklers, etc. However, simply following AS1851 does not fulfill all the requirements for ensuring that a building's fire safety measures are compliant with legislation. Here’s why:

  1. Annual Fire Safety Statement Requirements: The Annual Fire Safety Statement is a mandatory document that confirms all essential fire safety measures in a building are functioning to the required standards. It requires two critical elements:

    • Performance Assessment: An Accredited Practitioner (Fire Safety) must assess the functionality and performance of each essential fire safety measure, ensuring it operates as originally intended or to the level specified in the fire safety schedule.

    • Maintenance Confirmation: Building owners must confirm that these measures have been maintained in accordance with relevant standards, such as AS1851.

    AS1851 only addresses the second requirement—routine maintenance. The performance assessment, however, requires an Accredited Practitioner to inspect and certify that the systems are effective and compliant, and you can not have performance without compliance.

  2. Independent Verification by an Accredited Practitioner: An Accredited Practitioner (Fire Safety) is a certified individual or entity who is authorised to assess fire safety measures independently. They verify whether the fire systems, after being maintained, meet the performance requirements as outlined in the fire safety schedule and building codes. This verification process ensures that the systems are not only maintained but also perform as required during emergencies.

    Therefore, even if maintenance has been carried out to AS1851 standards, it is still necessary for an Accredited Practitioner to inspect and certify the building's fire safety measures annually. The practitioner provides an unbiased assessment and ensures that systems have not degraded over time or due to other factors, which could affect their performance.

The Role of Building Owners and Facility Managers

As a building owner or facility manager, are responsible for ensuring that both the routine maintenance and the annual assessment of fire safety systems are completed. Following AS1851 is essential, but to fully comply with the law and submit a valid Annual Fire Safety Statement, you must also engage an Accredited Practitioner (Fire Safety) to perform the required assessments.

This dual process ensures that:

  • Systems are properly maintained throughout the year as per AS1851.

  • The performance of systems is independently verified and assessed to meet legal and safety standards.

Conclusion

The changes to AS1851- 2012, which take effect on 13 February 2025, will have a significant impact on fire protection practices across New South Wales. With stricter compliance requirements, enhanced testing protocols, building owners, facility managers, and fire protection service providers must prepare for a more rigorous approach to fire system maintenance.

Although these changes may introduce additional costs and operational challenges, they are ultimately aimed at improving fire safety and reducing the risks associated with fire system failures. By staying informed and proactive about these changes, businesses can ensure they remain compliant and continue to protect their buildings and occupants effectively.

In summary, while AS1851 is critical for maintaining fire protection systems, it alone is not enough to satisfy the requirements of the Annual Fire Safety Statement. To comply with New South Wales fire safety regulations, an Accredited Practitioner (Fire Safety) must inspect and assess each essential fire safety measure to confirm its performance. Building owners should ensure they follow both routine maintenance and engage accredited professionals to meet their legal obligations and ensure the safety of building occupants.

Jody Aldag