When implementing performance-based building codes such as Australia’s National Construction Code, performance relating to important safety elements should ideally be evaluated according to criteria which are specific and measurable and against which performance can be assessed according to quantitative methods of analysis.
This is no less the case when it comes to fire safety.
Accordingly, a proposal to quantify the performance of fire safety in buildings has been put forward as part of the 2022 update of the National Construction Code (NCC).
For now, however, the proposal should be delayed.
Whilst the move to quantify fire safety performance is welcome, there are serious concerns about the proposal in its current form. These should be worked through and addressed before any change is considered in a latter NCC updating cycle.
Further, there are more urgent actions which would deliver greater safety improvements and would do so much sooner.
These should be the priority and focus right now.
The A8 Proposal
By their nature, building fires are low probability events. However, if they do happen, serious property damage and loss of life can result.
As with other potentially high-consequence hazardous events, fire safety lends itself to risk-informed design and analysis methods and acceptable risk criteria. In land-use planning as well as industries such as nuclear and oil/gas, such criteria have long been used within a well-established safety regime.
In buildings, the Australian Building Codes Board (ABCB) has been working on a proposal for quantification of fire safety performance to be included in the National Construction Code. This is based on criteria that focus on both the likelihood of serious fires exposing people and the risk of fire spread within and between buildings.
This has been proposed for inclusion in the 2022 update of the Code (NCC 2022) as “A8 – Quantification of the Fire Safety Performance Requirements”.
However, there have been suggestions that implementation of the amendment may be delayed until NCC 2025.
Granted, many fire engineers support the long-term idea that fire safety performance requirements should be quantified. Many also agree that more robust fire safety designs and supporting analysis are needed.
Due to concerns outlined below, however, few see the current A8 approach as being ready and practical in NCC 2022 – or even NCC 2025 for that matter.
These concerns include:
- Risk tolerance criteria which are highly conservative and out of step with other risk based regulatory environments.
- The absence of a clear and agreed quantitative risk methodology.
- Insufficient risk-based data, given that we have no national fire statistics in Australia.
- An absence of studies of even prescriptive building designs which meet the Deemed-To-Satisfy provisions of the NCC that have been shown to meet the risk criteria.
- A lack of fire safety engineers in Australia who have the quantified risk assessment (QRA) skills to complete a design analysis successfully at this stage.
- A huge technical challenge for certifiers and fire authorities which the approach would represent to assess the QRA analysis and adequacy of designs.
- Limitations the approach would place on opportunities for innovation where new methods of construction or materials are adopted – particularly to achieve societal goals around sustainability and climate change.
- Significant and potentially cost prohibitive challenges which the approach would represent for adaptive re-use of existing buildings that have to undergo such an assessment.
- Absence of a regulatory impact assessment of the cost and lost opportunity from adopting this approach; and
- The current structure of A8 – which does not sit withing a safety case regime.
As it stands, A8 would represent a radical, world-first approach for fire safety regulation.
If the amendment is implemented in its current form, the result could be higher building costs, more arduous fire safety provisions, much greater risks of poorly analysed buildings, slower approvals and reduced flexibility in building design along with limited opportunity to alter and adapt the building and its function in future without significant re-work.
At this stage, it appears that the ABCB may postpone or not include any consideration of the A8 quantification proposal until much more research is conducted.
Should this indeed prove to be the case, such a deferral would be welcome by industry and the fire safety engineering profession.
More Urgent Priorities
In the meantime, several things should be done which will deliver faster and more significant improvements in building fire safety.
Largely speaking, these involve implementing recommendations of the Shergold/Weir report along with those from reports arising of the Warren Centre project on “Professionalising Fire Safety Engineering”.
The actions have broad support among fire safety engineers nationwide.
- Compulsory professional registration based on Engineers Australia competencies developed in the Warren Centre project now being used for Chartered Engineers.
- Adoption of holistic design principles and design integration – looking at all fire safety performance requirements and linked to other building design aspects.
- Involvement of fire safety engineers from early concept design through to inspections/commissioning and the preparation of a fire safety manual for building owners at handover.
- Ensuring the overall fire safety strategy and package of fire safety measures includes full egress provisions and that emergency management procedures and maintenance requirements be developed at the time of design and in the preparation of the fire safety report. Management and maintenance procedures should not be developed just a week or two before practical completion as often occurs, but rather through a design process with involvement of the fire safety engineer from early stages of a project.
- Making compliance with Code of Practice for fire safety engineers mandatory and enforceable.
- Audits and enforcement of design and construction practices, as is occurring in NSW.
- Introduction of a comprehensive education and training program for fire safety engineers on the NCC/BCA DTS provisions and Performance Requirements, special skills on early design, integrated inspection and commissioning (especially cause/consequence matrix development for integrated systems testing), and fire safety manual preparation.
As a potential alternative to A8, meanwhile, the ABCB should consider funding research on the Society of Fire Safety (SFS) proposal on quantification. This was developed in 2019 but has so far not been pursued by ABCB in favour of A8. The SFS proposal consolidates some performance requirements, encourages quantification of some measures based on reliability principles and is more compatible with reasonable fire safety design practice and competency. It’s not full quantification but would get the NCC and Australian practice part way along that path.
Should the above measures be implemented, the industry would have greater confidence in the level of robustness of outcomes when adopting performance-based design for fire safety. The measures would facilitate greater flexibility in building design and adaption and would do so in a manner which is more clearly understood by governments and approval authorities.
Amendment A8 should be delayed until more work has been done.
For now, there are more urgent priorities which can deliver faster and more significant improvements in fire safety and design of buildings.