Information Collection
By making a submission to this consultation you agree to the collection of the information you provide in your submission; and the use and disclosure of the information you provide in your submission as outlined above.
Please select one item
(Required)
Radio button:
Ticked
Publish response
Radio button:
Unticked
Publish response anonymously (this will remove personal identifiers including, name and organisation)
Radio button:
Unticked
Do not publish
Personal Information
What is your name?
Name
(Required)
Queensland Regulatory Authority
Please select your State or Territory
State or Territory
Please select one item
(Required)
Radio button:
Unticked
ACT
Radio button:
Unticked
NSW
Radio button:
Unticked
NT
Radio button:
Ticked
Qld
Radio button:
Unticked
SA
Radio button:
Unticked
Tas
Radio button:
Unticked
Vic
Radio button:
Unticked
WA
Which best describes your industry sector?
Organisation (if submiting comments as an individual please leave blank)
Queensland Regulatory Authority
Please select one item
(Required)
Radio button:
Unticked
Building Commercial
Radio button:
Unticked
Building Residential
Radio button:
Unticked
Building Commercial and Residential
Radio button:
Unticked
Plumbing and Drainage
Radio button:
Unticked
Building Certification and Surveying
Radio button:
Unticked
Architecture and Design
Radio button:
Unticked
Engineering
Radio button:
Unticked
Plumbing
Radio button:
Unticked
Specialist Disability Access
Radio button:
Unticked
Specialist Energy Efficiency
Radio button:
Unticked
Specialist Fire Safety
Radio button:
Unticked
Specialist Health
Radio button:
Ticked
Government
Radio button:
Unticked
Other
Questions
Do you agree with the description of the problem?
Type answer
Strongly agree. The current National Construction Code does not take into account the particular risks involved in the evacuation of young children from early childhood education and care services especially where they are located above ground in multi-storey buildings.
Are there any other characteristics of the problem not identified?
Type answer
- Design/fit out of egress and evacuation stairs for any part of an education and care service above ground level that will ensure the safety of young children when they use these facilities for regular rehearsals and in any emergency.
- Size of staircases where there are other building tenancies with adult occupants and impact when all occupants (including children) need to evacuate.
- Design and fit out of outside areas above ground level for children to play safely.
- Design and fit out of high fire risk areas within an early childhood education and care service where any part of the service is above ground level. For example: kitchens, food preparation areas and laundry.
- Size of staircases where there are other building tenancies with adult occupants and impact when all occupants (including children) need to evacuate.
- Design and fit out of outside areas above ground level for children to play safely.
- Design and fit out of high fire risk areas within an early childhood education and care service where any part of the service is above ground level. For example: kitchens, food preparation areas and laundry.
Are there any other feasible options not identified?
Type answer
1. Requirements for child height handrails on egress and evacuation stairs (550 - 650 mm)
2. Requirements for fall barriers on egress and evacuation stairs (minimum 1.5m height)
3. Perimeter fencing heights for outdoor areas for children located above ground level (minimum non-climbable 1.8m height)
4. Smoke compartmentation of kitchen and laundry areas that directly adjoin children's indoor and outdoor spaces
2. Requirements for fall barriers on egress and evacuation stairs (minimum 1.5m height)
3. Perimeter fencing heights for outdoor areas for children located above ground level (minimum non-climbable 1.8m height)
4. Smoke compartmentation of kitchen and laundry areas that directly adjoin children's indoor and outdoor spaces
Do you have any other comments to make on the options?
Type answer
- The Queensland Regulatory Authority prefers Option 2.The importance of including all applicable building elements into the National Construction Code for any part of an education and care service above ground level is vital, including the additional details outlined above in the other feasible options outlined above.
Feedback received by the Queensland Regulatory Authority from most Queensland multi-storey approved providers reviewed, including their Architects, Fire Engineers and Certifiers is that they would prefer that all applicable information be included in the National Construction Code upfront rather than the incurring the time and cost of having to adjust a building once under construction or completed.
- The National Construction Code would still allow, in applicable circumstances, for a Building Certifier to engage an applicable qualified, practising and insured Fire Engineer or any other appropriate expert to write a report for the purposes of developing an alternative solution for any of the deemed to satisfy provisions, should any specific circumstance arise where any of these provision may not be appropriately deemed to be required.
- Will the amendments just apply to new builds? Have any requirements been considered for existing buildings where any part of an education and care service is located above ground level. For example: Will such existing premises be required to be retrospectively compliant (undertake renovations) to comply with any new deemed to satisfy provisions by a particular date or could the approved provider/building owner be required to engage a Fire Engineer to complete a review report to determine any safety risks requiring any actions be completed by a specific date to ensure the ongoing safety of children in such premises.
Feedback received by the Queensland Regulatory Authority from most Queensland multi-storey approved providers reviewed, including their Architects, Fire Engineers and Certifiers is that they would prefer that all applicable information be included in the National Construction Code upfront rather than the incurring the time and cost of having to adjust a building once under construction or completed.
- The National Construction Code would still allow, in applicable circumstances, for a Building Certifier to engage an applicable qualified, practising and insured Fire Engineer or any other appropriate expert to write a report for the purposes of developing an alternative solution for any of the deemed to satisfy provisions, should any specific circumstance arise where any of these provision may not be appropriately deemed to be required.
- Will the amendments just apply to new builds? Have any requirements been considered for existing buildings where any part of an education and care service is located above ground level. For example: Will such existing premises be required to be retrospectively compliant (undertake renovations) to comply with any new deemed to satisfy provisions by a particular date or could the approved provider/building owner be required to engage a Fire Engineer to complete a review report to determine any safety risks requiring any actions be completed by a specific date to ensure the ongoing safety of children in such premises.
Do you have information that can assist in informing the analysis?
Type answer
The Queensland Regulatory Authority has been reviewing its existing approved multi-storey education and care services and assessing new service approval applications for new multi-storey education and care services since November 2017. This work has included some visits to services, information and advice from applicable qualified experts engaged by the Queensland Regulatory Authority including RED Fire Engineers, Queensland Fire and Emergency Services, the Department of Housing and Public Works and the Queensland Building and Construction Commission. The above outlined characteristics and options have been identified from the work undertaken to ensure the health, safety and wellbeing of children in accordance with the National Quality Framework.
Of the options discussed, which is your preferred option?
Type answer
Option 2 is the preferred option for the Queensland Regulatory Authority.
Having the stipulated applicable fire safety features that are required is vitally important and will ensure the safety of young vulnerable children where any part of an education and care service is above ground level.