Significant changes have been proposed for Australia’s building code.

The Australian Building Codes Board (ABCB) has released the first stage of the public comment draft for the 2022 update of the National Construction Code (NCC), which is expected to come into force in September next year.

The draft is being released in two stages.

The first stage – which was released last week – contains most of the proposed changes which are expected to be included in NCC 2022.

These include:

• New requirements for accessible housing
• A new minimum level of lead for plumbing products which come into contact with drinking water.
• Egress provisions for early childhood centres and primary schools
• New requirements for bushfire protection for non-residential buildings with vulnerable occupants.
• Quantification of performance requirements in several areas.

A detailed description of these changes can be seen here. A summary is below.

The second stage of consultation is expected to open on July 19. This will deal with proposed changes to energy efficiency and condensation. These are the subject of current project work.

The National Construction Code (NCC) is the primary document in Australia which sets out the technical design and construction provisions for residential and commercial buildings.

Previously updated each year, the Code moved to a three-year updating cycle in 2016.

Current and previous editions of the code can be freely downloaded here.

In addition to the substantiative changes outlined below, the 2022 update of the NCC includes several features in its structure and format which aim to make the code easier to read, understand and apply.

These include a consistent volume structure, a new referencing system and greater web content accessibility. Information is available here.

Key Changes Under Stage 1 Consultation

Important changes contained in Stage 1 of the public comment draft are set out below.

1) New Accessible Housing Provisions

One of the more publicised changes in the NCC 2022 draft involves the insertion of mandatory requirements for accessible housing.

The new provisions are based on requirements which are needed to achieve Silver level certification under the Liveable Housing Design Guidelines.

This follows a decision by a majority of ministers at last month’s Building Ministers Forum to include accessibility requirements as part of the NCC.

Details can be seen here.

The main requirements are:

• A safe, continuous and step free path of travel from the street entrance and / or parking area to a dwelling entrance that is level.
• Internal doors and corridors that facilitate comfortable and unimpeded movement between spaces.
• A toilet on the ground (or entry) level that provides easy access.
• A bathroom that contains a hobless shower recess.
• Reinforced walls around the toilet, shower and bath to support the safe installation of grabrails at a later date.
• Stairways which are designed to reduce the likelihood of injury (such as through provision of continuous handrails) and to enable future adaptation.

The draft changes will apply to Class 1a buildings (detached homes, detached units, townhouses, row houses etc.) and Class 2 sole-occupancy units (apartments) only. Common areas in Class 2 buildings will continue to be covered by current NCC provisions and the Disability (Access to premises — Buildings) Standards 2010.

The draft changes also include a limited set of exemptions from the step-free access path requirement for Class 1a buildings referred to above. The exemptions apply to steep sites, small sites and dwellings where a high floor level is required. They are subject to the limitations set out and explained at clauses H8P1 and H8D2 in NCC Volume Two.

2) Lead in Plumbing Products (Volume 3) (Plumbing Code of Australia)

Next, the public comment draft includes changes to Volume 3 of the NCC (often referred to as the Plumbing Code of Australia) to limit the content of lead in plumbing products which come into contact with drinking water.

Under the changes, the evidence of suitability provisions contained within A5G4 will be amended to require a maximum lead content of 0.25 percent for all new copper alloy products which come into contact with drinking water.

This will apply only to products which come into contact with drinking water. These include fittings, valves, fittings on stainless steel braided hoses, taps, mixers, appliances for the delivery of drinking water, water heaters, water dispensers (boiling and cooling units).

Compliance with this will need to be verified by either a test report from an accredited testing laboratory or a WaterMark certificate.

The changes come in response to concern about potentially unsafe levels of lead in plumbing products.

Where the toxic material leeches from the products into the drinking water, it enters the bloodstream and is distributed to organs such as the brain, kidneys, liver and bones.

At high levels of exposure, consequences can include coma, convulsion and death. Other effects can include reduced intelligence, behavioural changes such as reduced attention span and antisocial behaviour, anaemia, hypertension, renal impairment, immunotoxicity and toxicity to reproductive organs.

Currently, the use of lead in the manufacture of plumbing products is permitted by Australian Standards. The exact allowable lead content of products varies by component, though some products in contact with drinking water can contain up to 6 percent lead as a proportion of raw material.

During a forum with manufacturers, Standards Australia’s technical committees, health professionals and plumbing suppliers and retailers held by the ABCB in 2019, 92 percent agreed that lead content in products which come into contact with drinking water should be reduced.

3) Fire Safety and Evacuation for Early Childhood Centres and Primary Schools in High Rise Buildings (Volume One)

The next area of change relates to deemed to satisfy (DTS) provisions regarding egress in early childhood centres (ECCs) or primary schools which are located in high-rise buildings in the event of fire or other emergency.

In relation to early childhood centres, current NCC DTS provisions address fire related concerns through active and passive measures that suppress the fire’s effects and its ability to spread.

On egress requirements specifically, an amendment to the 2019 edition of the NCC specified that these would be met where the ECC was located within a storey which provided direct access to roads or open space (most likely, by being on the ground floor).

In NCC 2022, the draft Code has gone further and addresses situations where the centres are located on upper floors where direct egress to roads or public space is not available.

This is particularly important considering the growing prevalence of ECCs which are located on higher floors within multi-storey buildings. Within such facilities, the ABCB says there are concerns about unacceptable levels of risk to life as we are dealing with very young children and potentially long travel distances.

The changes aim to address these concerns and to ensure that such facilities can safely be accommodated under DTS provisions.

To achieve this, several DTS provisions have been amended within Volume One of the Code.

The changes will:

• Tighten building classification rules under Part A6 to ensure that early childhood centres are not exempt from additional requirements by virtue of being located on a relatively large floor plan – such as within a large office building.
• Require ECCs to have two fire compartments, two horizontal exits 9m apart, and smoke lobbies in lieu of fire compartments for smaller ECCs (up to 500 m2).
• Require ECCs to have at least two exits.
• When fire-isolated stairways and ramps are required: require ECCs to have fire-isolated exits in all instances where it is located above a storey that provides direct egress to road or open space.
• Require smoke lobbies to be pressurised by a dedicated system if connected to an exit that is pressurised to keep the lobby clear of smoke creep.
• In terms of barriers to prevent falls: insert additional requirements to fire-isolated exits (stairs) serving Class 9b ECC parts in a building to remove the exemption from compliance with Clause D3D27 (previously D2.16) in instances of an open or split stair configuration in a building containing an ECC, a balustrade or barrier that does not permit the passage of a 300 mm sphere.
• Require fire-isolated exits serving ECCs to be provided with re-entry provisions back into the Class 9b ECC storey or part.
• Require sprinklers to be provided not just in the ECC but throughout an entire building that incorporates ECCs above ground floor level, where the ECC is not wholly within a storey that provides direct egress to a road or open space. Additional requirements set out the type of sprinkler system required and specifies that within ECCs, the sprinklers must be fast-response.
• Require all ECCs above ground level not wholly within a storey that provides direct egress to a road or open space to have a smoke detection and alarm system provided throughout the building. This requirement will apply in addition to any other DTS smoke hazard management measures.

In the case of primary schools, meanwhile, a proposed change to clause D2D23 (previously D1.18) has been developed to address a current lack of DTS Provisions which cater for primary schools in high-rise buildings.

The amendment will apply to primary school buildings which are either greater than four storeys in height or which also contain another building class.

In the case of such buildings, the amendment will require that egress be direct to a road or open space. Where this is not possible, performance solutions will need to be applied in the design of such facilities to ensure that relevant performance requirements of the NCC are satisfied.

4) Bushfire Protection for Vulnerable Buildings

A fourth area of change responds to a recommendation from the 2009 Victorian Bushfires Royal Commission and subsequent investigations.

That Commission recommended that bushfire protection provisions for certain non-residential buildings with vulnerable occupants such as hospitals be included in the NCC.

The proposed changes reflect analysis and recommendations of a subsequent quantified risk assessment (QRA). That assessment recommended several changes including development of a new performance requirement, modification of the existing bushfire Verification Method and appropriate DTS Provisions.

The changes apply to buildings which are occupied by people who may be unable to readily evacuate the building prior to a bushfire, such as young children or those who are elderly or disabled. It applies to hospitals and healthcare buildings, schools or early childhood centres and residential care buildings (Class 9a, 9b and 9c).

Many of the changes have been inserted through a new specification in the auxiliary provisions of the NCC (S43C1).

Under the new specification, for buildings referred to above:

• Buildings will need to be separated from classified vegetation, other buildings and allotment boundaries/car parking areas. External walls and roofs will also need to be separated from on-site hazards such as gas bottles, fuel storage, storage of combustible materials, waste bins, vehicles and machinery. Required separation distances are detailed within the specification.
• There must be a non-combustible path which is at least 1.5 metres wide around the perimeter.
• Access pathways which lead to roads or open spaces will need to be clearly identifiable, have an even surface and be at least one metre wide by clear width.
• External areas which are designed to hold people unable to be safely accommodated within the building and which may be exposed to radiant heat flux from a fire front during a bushfire must have maximum incident radiant heat flux from the fire front must not exceed 1 kW/m2 above background solar radiant heat flux.
• An air handling system must be provided (for internal tenability) that is capable of being adjusted for full recycling of internal air for limited periods to avoid the introduction of smoke into the building and maintaining an internal air temperature of not greater than 25°C. The building envelope must be designed such that if an air handling system fails, internal air temperatures can be maintained below 39°C and internal surface temperatures can be maintained below 60°C.
• External walls and roofs must be non-combustible (exceptions apply) and be constructed in accordance with AS 3959 for BAL—19 or greater.
• Water for fire-fighting purposes must be available. This must consist of— (a) a fire hydrant system complying with E1D2, or (b) a static water supply consisting of tanks, swimming pools, dams or the like, or a combination of these, together with suitable pumps, hoses and fittings, capable of providing the required flow rate for a period of 4 hours, determined in consultation with the relevant fire brigade.
• Emergency power must be provided to support, for not less than 4 hours before and 2 hours after the passing of the fire front during a bushfire event, the ongoing operation of— (a) air handling systems to maintain internal tenability; and (b) any pumps for firefighting; and (c) any emergency lighting, exit signs, and (d) any other emergency equipment listed in C3D14(6) and required to be provided.
• Signage must be provided to warn building occupants against storing combustible materials under or adjacent to the building.
• Vehicular access to the building must be provided in accordance C3D5(2), as if the building were a large isolated building for the purposes of C3D4.

5) Quantification of Performance Requirements

Finally, performance requirements have been quantified across several areas. These spread across all volumes of the NCC.

The quantification comes as part of longer-term efforts from the ABCB to quantify performance requirements of the Code where possible. This aims to provide greater clarity about the level of performance which is needed across important aspects of the building’s design.

Specific matters regarding which quantification has taken place include structural reliability, glass at risk of human impacts, bushfire prone areas, fire safety, noise isolation, fire detection and early warning, flow rate and pressure, water efficiency, sanitary plumbing and microbial growth.

Feedback Sought

Feedback on the above changes is being sought (refer link).

Consultation is open until Friday July 2.