At the recent Fire Australia conference, progress in delivering better fire safety in buildings was highlighted across several areas.

Of particular note is progress in New South Wales. During a keynote address at the conference, NSW Building Commissioner David Chandler outlined how a comprehensive reform program in that state is restoring confidence in building quality and ensuring that only trustworthy developers, designers and builders are being given support.

Initially, these reforms applied to buildings which are classified as Class 2 buildings under the National Construction Code (i.e. apartment complexes). Their application is now being extended to Class 3 buildings (larger boarding houses, guest houses, hostels, backpacker accommodation etc.) and Class 9c buildings (residential care buildings).

Beyond this, however, discussions during the conference highlighted several areas of concern.

In particular, more action is needed to improve practices in terms of annual fire assessments and provision of building manuals.

Moreover, further work is needed to ensure that each of the 24 recommendations contained in the Building Confidence Report prepared by Professor Peter Shergold and lawyer Bronwyn Weir for the Building Ministers Forum (now called the Building Ministers Meeting) in 2018 are implemented in a consistent manner.

Whilst building ministers agreed to a national approach to implement the reforms in July 2019, reform efforts thus far have been patchy.

By and large, consumers who purchase or rent buildings rightly expect that:

  • the buildings they occupy have been correctly designed according to the NCC and appropriate Australian Standards
  • as occupiers, they understand how fire safety measures and emergency plans work for them, and
  • all fire related building elements and fire safety systems are being maintained and assessed regularly for compliance with the original design requirements.

Should action be taken on the matters below, the building industry will go much closer to delivering upon these expectations.

(Image from Fire Australia web site
Fire Australia 2023 © Action Portraits 2023 CK)

Annual Assessments

A major panel session at Fire Australia looked at the issues around the annual assessment of essential fire safety measures and the owners’ obligation to have an Annual Fire Statement prepared each year to establish on-going compliance.

From this discussion, it was clear that problems remain. For example:

  • The fire safety schedule which outlines essential fire safety measures and is developed by the certifier at project completion and handover is often not well documented. As a result, schedules may be confusing to annual assessors who conduct fire safety reviews.
  • Where relevant, the fire safety schedule should simply refer to the NCC clauses and subclauses and to the Australian Standard (AS) that apply for each measure. In cases where a fire safety engineering report applies to the measure, the schedule should simply state what is required and should avoid making vague and unclear references to performance requirements.
  • Authors of fire safety engineering reports (FSERs) should not try to rewrite or interpret the prescriptive deemed-to-satisfy (DTS) provisions. Nor should they rewrite or interpret provisions of Australian Standards where reference to these is simply made according to DTS requirements.
  • The fire safety schedules often refer to fire safety engineering reports (FSERs). Such FSERs may include a limited number of performance solutions but may not contain a clear statement of the complete package of fire safety measures that are needed in the particular building.
  • Projects may have been subject to multiple FSERs from a number of different fire safety engineers. In some cases, these can contain conflicting fire safety requirements.
  • Given a requirement that annual assessors in NSW need to at least ‘verify the performance of each essential fire safety measure being assessed’, some assessors have interpreted this requirement to mean that they need to re-evaluate the fire engineering analysis which underpins any performance solutions that have been developed in the FSER. This is not in fact their role. Terminology here is a problem and must be clarified.

At the end of the discussion, it was agreed that two actions should occur.

First, the Society of Fire Safety (SFS) and the Fire Protection Association, Australia (FPAA) should jointly develop guidance to assist fire safety engineers to include a specific section in their FSERs that details all the essential fire safety measures in one place. This should enable the certifier to develop a clear and comprehensive schedule of essential fire safety measures. In turn, this should allow annual assessors to complete their task more easily and will improve fire safety outcomes for building owners, managers and occupiers.

Further, it was suggested that SFA and FPAA include a description of any risks that may be associated with performance solutions when producing guidance on schedules and annual assessments.

This is especially the case as there are some performance solutions which have been developed that have very little merit. These generally relate to variations to Australian Standards for sprinklers, jet fan and wiring of smoke control systems.

In addition, some fire safety engineers are varying requirements of AS/NZ 3000, AS/NZ 1670.1 or AS/NZ 1668.1 without adequately understanding that these standards are interrelated and need to be consistently applied.


Building Manuals

If the buildings have been designed and constructed correctly, an important step at project completion is that the builder hand over to the building owners the necessary documentation to verify how design decisions were made and to adequately ensure that safety systems can be properly routinely serviced, tested, and managed over the life of the building.

Recommendation 20 of the Building Confidence Report (BCR) highlighted the need for a comprehensive building manual. This will facilitate better ongoing maintenance and management of buildings. It will also provide a sound basis to inform decisions and actions regarding building repair, renovation or alternation.

This is critical. Over recent decades, many building owners across Australia have often been provided with a large number of outdated system drawings, poor operation and maintenance manuals and a lack of clear information about how to manage the building safely into the future.

Potential consequences can include:

  • A lack of understanding on the part of owners, managers and occupiers regarding how to effectively manage evacuations during a fire. This includes whether the evacuation should be phased or all out, whether or not have lifts been designed for evacuation and the location of assembly areas.
  • Difficulty for owners and managers in establishing contracts for proper systems testing and maintenance.
  • Fire safety engineers being called to buildings to examine the operation of complex smoke control systems. This can occur where owners and managers do not properly understand how the systems were designed to work in the event of fire.
  • A lack of understanding of the original design to be used as a basis to inform new design decisions in cases where buildings are to be modified.

All this can contribute to greater occupant risk during a fire.

Pleasingly, NSW has embraced a requirement for building manuals as part of its aforementioned reform program.

Meanwhile, Victoria has now passed legislation that anticipates that building manuals will be become mandatory in that state for all new commercial buildings and most likely be retrospectively required for all existing commercial buildings after a period.

As of yet, no dates for implementation of building manual requirements have been announced. Understandably, there are likely to be IT related challenges that need to be resolved should building manual documentation be required to be lodged electronically with councils or governments though an e-platform.

However, it is important that this reform is implemented in a nationally consistent manner across all states and territories as soon as possible.


National Consistency

Finally, the conference further highlighted the need for national consistency in the adoption and implementation of all recommendations in the Building Confidence Report.

This is particularly important in order to enable Automatic Mutual Registration (AMR) for building practitioners operating across state and territory borders.

Dr James Cameron from the Australian Construction Industry Forum provided a summary of the current status surrounding implementation of the 24 BCR recommendations. This showed that whlist most States and Territories had fully or partially implemented some recommendations, adoption and implementation efforts have been patchy thus far. Despite five years having passed since the report’s publication, it is clear that some states and territories are struggling for resources to enact the necessary changes.

On the positive side, as pointed out at the conference by David Chandler and Michael Lambert, reforms in New South Wales are powering ahead. Already, the introduction of the Design and Building Practitioners Act (DBPA) and Regulations along the Residential Apartment Buildings (Compliance and Enforcement Powers) Act (RAB) have made a significant difference. The results of building audits, the identification of significant defects before the issuance of occupancy certificates, the need for design declarations, the new codes of conduct, the enforcement actions and penalties being applied to parties for defective work, and the practitioner registration requirements have all added to a growing sense of trustworthiness and improvement in the building design and construction industry in that state.

However, it is imperative that all States and Territories implement the BCR recommendations in some consistent manner, especially in relation to practitioner registration.

Unless this occurs, Automatic Mutual Recognition of registered practitioners operating across borders may not become a full reality.



The very recent multi-fatality fire in the hostel in Wellington, New Zealand reminds us all that we need to be ever vigilant when it comes to fire safety and the protection of occupants. We need to follow all the relevant codes, standards and regulations. We need to match the design and fire safety measures to the risks and potential consequences of fires for occupants. We must develop fire safety schedules with the required fire safety measures clearly identified so that maintenance and annual assessments can be undertaken in the most right and proper manner. And builders must provide building manuals which include all the fire safety information in the form needed for understanding of the occupants and for the future use or modification of the building.




For more details of the Fire Australia conference program go to: Home – Fire Australia

And for highlights of the conference go to and click on Latest News.