Record Keeping: Know Your Responsibility 1

Monday, August 15th, 2016
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In Australia, like most developed countries, we have a general expectation of safety. In the built environment, much of this safety (after the construction and occupation phases) is ensured by the ongoing maintenance of relevant life safety systems such as fire protection equipment.

There are a number of relevant standards that work in combination to ensure that people, property and the environment are protected. In the fire protection space, two important standards are AS 1851-2012 Routine Service of Fire Protection Systems and Equipment, and AS 2293.2 Emergency escape lighting and exit signs.

Building owners and/or occupiers must routinely maintain a building’s fire protection systems and equipment in accordance with these and other relevant standards and keep hard copy records as evidence of such maintenance.

In many ways, accurate documentation and record keeping of maintenance work conducted is equally as important as the work itself. This is because accurate records provide clarity, peace of mind and assurance for building owners, managers and occupiers that work has been conducted correctly and with the appropriate frequency.

Undertaking and documenting regular routine service of fire protection systems and equipment to ensure they remain ‘fit for purpose’ is an important fire safety objective that is enshrined in legislation in every Australian state and territory.

Moreover, there is a community expectation that installed fire protection systems and equipment will work if they are required to, even if this only occurs once in the lifetime of a building.

So why record maintenance and retain records?

Fire protection systems and equipment are nominated safety equipment, fittings, systems or management measures provided in or for a building that are required in the event of fire or other emergency to protect against loss of life or property. Examples of fire protection systems and equipment include automatic fire sprinklers, smoke detection and control systems and passive fire protection elements like fire doors or dampers.

Each state and territory’s legislative and regulatory framework requires or expects that servicing of these systems and equipment be recorded in accordance with the relevant standard called up by the legislation.

All states and territories now accept the use of AS 1851-2012 as the relevant maintenance standard. This national harmonization means there are uniform standards not only for the actual work, but also for the required record keeping for routine servicing work around the country.

In any case, regardless of the standard used, all building and planning regulations require that maintenance of fire protection systems and equipment be undertaken. They also require evidence of this work, such as records of maintenance, to be kept demonstrating compliance and activities undertaken.

Beyond the legislative requirements, there is also a common law duty of care held by building owners (and by extension, building and facility managers and occupiers) for the safety of occupants. Additionally, service providers will have a contractual obligation to their client and should therefore maintain their own copies of records.

Completing and retaining detailed records of service form an essential part of complying with an owner/occupier’s and service provider’s legal obligations. Unfortunately, all too often it is not until something goes wrong and there is an incident or enforcement action is pursued that focus shifts to the need for evidence.

In these circumstances, the responsible entity (generally the building owner or occupier) will need to produce records demonstrating that a building or facility has undergone routine service in accordance with regulation and standards and that performance was verified to be in accordance with specific design requirements.

In addition, the service provider may also have to produce their own evidence to demonstrate compliance with their contractual obligations.

Failure to produce records will make it more difficult to defend the actions taken by a building owner, building occupier, their agent or the service provider in any legal proceedings.

Complying fully with the appropriate service requirements of AS 1851 and AS 2293.2, including keeping appropriate records, is one way of demonstrating that you have met your legal obligations should a fire emergency situation arise or enforcement action be pursued.

Section 1.16.2 of AS 1851-2012 requires that service records, including the pass/fail criteria, shall be captured at the time of the routine service. These records may be captured via a hard copy logbook, an electronic log or tags and labels with hard copy summary records.

Importantly, AS 1851 requires that, no matter the method of recording, a hard copy of the service record (or a printed and signed copy of the electronic log) must be left on site at the completion of any testing. Where tags or labels are used, a printed and signed paper-based copy of the summary record must be provided within one week of the date of service.

The standard goes on to specifically address the requirements of logbooks and summary records, including noting that logbooks must contain the name and address of the building or site, the date and frequency of the service performed, the location and identification of installed systems and equipment, each activity performed, details of non-compliance, the name of the responsible entity (owner, manager or occupier), the name and signature of the service person with the date of service, and the name of the service provider or company.

The importance of accurate and appropriate record keeping cannot be overstated.  However your responsibilities and potential legal exposure in this regard will vary depending on your relationship with the facility being maintained.

Are you responsible for completing the records after carrying out routine servicing? Perhaps you are a building or facility manager responsible for reading the record of service and acting to rectify defects or identified problems.

Whatever your exposure to the risk of poor record keeping, don’t wait until enforcement action occurs to determine the accuracy and conformance of your records.

If you can’t produce evidence to confirm what you did to make sure required systems and equipment were operating to avoid property damage, take the necessary steps to begin appropriate maintenance record keeping such as using best practice logbooks.

If you are a building manager and you don’t know if your maintenance contractor is leaving appropriate records – find out – and don’t be shy about asking your provider to show you where these records are being kept on site and how they meet the requirements under the standard. You have a legal requirement to know.

Ask yourself, if you were forced to answer legal questioning about maintenance record keeping after a fatal fire, would you feel confident in your answers?

Understand your role and your potential level of exposure, and ensure you have the necessary records in place. Both the legal requirements, and your own peace of mind, make it thoroughly worthwhile.

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  1. Ed Ahern

    Excellent post and ideas! Thanks!