In 2009, the Commonwealth House of Representatives Standing Committee on Legal and Constitutional Affairs stated “every Australian has the right to expect that reasonable provisions will be made to allow them to leave buildings safely in the event of an emergency.” But is that really the case?

Australia is a diverse country with a population that includes over 24 million people, each with their own unique physical characteristics, skills and abilities. This is what it means to be human – we are all different, and we must acknowledge these differences across the vast spectrum of human life when we plan for emergencies in buildings.

When we consider this in terms of universal design and people with disability, this planning process during the design stage of any new building must include consideration of occupants with a diverse range of sizes, ages, awareness and familiarity, cognitive skills, sensory abilities and mobility abilities.

This is critically important for occupants who may not be able to use typical evacuation paths or those who may not hear standard emergency alarms. Taking a universal approach to evacuation that goes beyond meeting the minimum building code requirements will help to ensure that every Australian can safely evacuation a building in an emergency.

Any such approach that differs from the prescriptive requirements of the National Construction Code, including the Building Code of Australia (BCA), is considered a performance-based approach, which must be developed by a fire engineer.

Fire engineering has been described as an “evolving discipline” in the International Fire Engineering Guidelines (IFEG). As a new discipline, it has been recognised that engineering judgement plays a greater role in fire engineering than in most other engineering disciplines.


Therefore, there are similarities to access consulting, in that this too is a new profession within the built environment and so too relies on what is referred to as “expert judgement” in the BCA.

The IFEG acknowledges that there are several forms of specialisations amongst engineers working within performance-based building codes, such as building services engineers, fire systems engineers and structural engineers, but could it be time to extend this to include access consultants?

A recent update of Australia Standard AS 3745-2010 Planning for emergencies in facilities identified this relationship when discussing the use of passenger lifts for evacuation purposes. It states:

“In developing the regulatory approval, a team including a fire safety engineer, a mechanical services engineer, a lift engineer, an emergency planning consultant and an access consultant should jointly produce a strategy document that would be both part of the documentary evidence and of the emergency plan.”

When a fire engineer documents a building design that does not meet the applicable deemed-to-satisfy (DtS) provisions, it is generally presented as a ‘performance solution’ in the form of a fire engineering report. This report will identify the relevant performance requirement(s) that need to be considered, and outline how compliance can be achieved. When doing so, the IFEG suggests that this process will often require input from other stakeholders conversant with the practical application of the BCA, which could include access consultants.

The performance requirement(s) within the BCA are effectively the only parts of the BCA that must be complied with, which can be by way of a DtS approach, performance solution, or a combination of the two. In terms of meeting the needs of people with disability, there are several references to consider in any fire engineered approach. Here are some of them:

  • CP3 requires a building to be protected from the spread of fire and smoke to allow sufficient time for the orderly evacuation of a building
  • CP4 requires that tenable conditions are maintained during occupant evacuation, appropriate to the number, mobility and other characteristics of the occupants
  • DP4 requires that safe exits are provided, with their number, location and dimensions appropriate to the number, mobility and other characteristics of the occupants
  • DP6 requires that safe paths to the exits are provided, with dimensions appropriate to the number, mobility and other characteristics of the occupants
  • DP7 requires that, where a lift is to be used for evacuation purposes, it must be appropriate to the number, mobility and other characteristics of the occupants
  • EP2.1 requires buildings with sleeping accommodation to have smoke detection and warning
  • EP2.2 requires sufficient time for evacuation appropriate to the number, mobility and other characteristics of the occupants.

As we can see, reference to features of a building being “appropriate to the number, mobility and other characteristics of the occupants” is a consistent theme when developing any fire engineered performance-based solution.

When a fire engineer and access consultant work together, they can carefully plan for the characteristics of all occupant. Factors they must take into account include:

  • physical abilities and how a person will move safely from the building
  • sensory capabilities and how a person will register the emergency
  • cognitive abilities and how these might affect a person’s ability to interpret emergency warnings
  • whether occupants will require assistance to evacuate
  • how their disability aids or equipment will be transported
  • any reliance on assistive technologies or assistive animals
  • incorporation of an individual’s needs into emergency plans
  • some general provisions for everyone

The International Organisation for Standardisation (ISO) has defined engineering judgement as “the process exercised by a professional who is qualified by way of education, experience and recognised skills to complement, supplement, accept or reject elements of a quantitative analysis.”

Notwithstanding the above, whilst a fire engineer will have appropriate education and experience to enable them to understand how people respond and behave in fire situations, there will be great benefit in working with an experienced access consultant to ensure the abilities of all occupants are considered with respect to the evacuation process.