Discussion paper: Involvement of fire authorities in building design

As Certified Professional Engineers,we are subject to Code of Ethics and Code of Conduct under EA, and in QLD we are now subject to a State based Code of Conduct and/or Code of Ethics as registered engineers in those states. NSW and Victoria now have similar registration for fire safety engineers. A person that holds CPEng, RPEQ, registration in NSW and registration in Victoria (both under the new schemes) will be subject to four separate Codes of Conduct. The imposition of a fifth would hardly seem to be value adding. While there are undoubtably fire enigneers out there who (in my opinion) are falling short in their obligations to occupants as far as life safety goes, I do not think the imposition of another Code of Conduct is likely to change this.

The types of behaviour your document indicates will be addressed by the Code of Conduct are indeed problems, but in my humble opinion other methods are required to address these issues, or more importantly the underlying reasons for these issues.
Additionally, the AFEG seems to encourage the current process of a 'silo-like approach to the development of Performance Solutions as directed by teh building surveyor rater than considering holistic fire safety design...' This is one of the behaviours the Code of Conduct seeks to eradicate. This indicates a disconnect, dare I siloed approach, in the way ABCB has been developing these documents.

This code of Conduct does not solve what we see as the main reason that fire engineers exhibit the behaviours the Code is stated to be trying to address. This issue is the fact that fire engineers are normally engaged by a developer, a builder or an architect. These entities have other priorities that do not necessarily include life safety and are sometimes in conflict with life safety. There is a lot of pressure on fire engineers to provide a performance solution to save costs or to maintain the architectural intent. This pressure is dealt with in different ways by fire engineers but the threat at the end of the day is that the client will simply go and find a fire engineer who will do what they want, regardless of the validity of the performance solution. Unfortunately, there are fire engineers out there who will lower the bar and I understand that these are the ones this Code of Conduct is aimed at, but again, if they are not adhering to the various current Codes of Conduct and Codes of Ethics, what makes this Code so special that they will feel obliged to adhere to it?

IT is assumed that this refers to the 15 items detailed on Page 11 through 15 of the ABCB document 'Involvement of fire autorities in building design - A response to the Building Confidence Report'. Response is in line with that:

Comply with the law and act in the public interest.
• No issue item 1 and 2, but refer to comment for Question 2 above.
• Re item 3, I do not think we should be signing up to a blanket application of AFEG without seeing the document. It may not prove suitable for all situations, similar to the deficiencies in the IFEG.
• Re Item 4, notify government of unlawful activity of risk to health and safety. This seems very onerous at first look and potentially puts us at odds with builders and subbies.

Professionalism.
• Concur in the main with items 5 – 9. WSP do not think that the use of the phrase ‘due regard and respect for the role..’ in item 7 is appropriate and would amend it to state ‘due regard for the role…’ Respect these days is a hackneyed term and is subjective.

Honesty and Integrity.
• Concur with items 10-14.

Transparency and accountability.
• Concur with item 15.

This will provide some certainty around expectations and, inline with a nationally consistent approach to the development of Performance Solutions by Fire Engineers, will make it much easier to work in across jurisdictions.

We see Performance Solutions being implemented in Victoria that we know would not be acceptable in Queensland and would not support even if the authorities did accept them there. This makes it very hard when dealing with developers, architects and other consultants from Victoria when they are working on a project in Queensland.

Suggest reword it to be as follows:
“During the building design process, the role of fire authorities is to provide advice on the development of Performance Solutions impacting the intervention of fire authorities at a building.”

The phrase 'could be defines' in the proposed definition makes this a statement, not a definition. A definition should not be open to question, certainly not a much questions as having 'could be defined' in the definition.

The difficulty now becomes what does 'impact the intervention of fire authorities at a building' mean. Arguably, any performance solution could impact fire brigade intervention. This needs further consideration.

Refer to response to Question 4. Reasons similar.

No.

Do not see any for fire engineers. It would, however, give some certainty to designers around what will brigade can comment on and what they can't.

The list below AFAC is the drawback. AFAC wants a piece of every pie. WSP are of the opinion that they are the experts in fire brigade intervention and will take their advice any day of the week on hydrants, some sprinkler issues, operational matters, fire control centres and structural issues where collapse on to firefighters is a potential outcome. We are less inclined to take brigade advice on occupant life safety issues.

CP4: The assessment of this is something that can be adequately and easily assessed by the fire engineer without input from fire brigade.

CP8: Few fire brigade officers we have dealt with have the understanding of testing behind passive systems and the factors to consider in a passive fire assessment. When properly done, the is little risk to fire brigade intervention.

DP4: This is about occupant egress and occupant life safety. Fire engineers are the specialists in this area and a properly done Performance Solution will have little impact on fire brigade operations, but will consider the benefits of fire brigade assisted evacuation if it can be demostrated brigade will arrive at the building in time to assist with evacuation.

DP6: Where an assessment against this clause shows potential to hinder fire brigade intervention brigade input should be sought. This will not always be the case.

DP7: This is about occupant egress and occupant life safety. Fire engineers are the specialists in this area and a properly done Performance Solution will have little impact on fire brigade operations, but will consider the benefits of fire brigade assisted evacuation if it can be demostrated brigade will arrive at the buidling in time to assist with evacuation.

EP2.1: This is about occupant life safety. Fire engineers are the specialists in this area and a properly done Performance Solution will have little impact on fire brigade operations, but will consider the benefits of fire brigade assisted evacuation if it can be demostrated brigade will arrive at the buidling in time to assist with evacuation.

EP2.2: This is about occupant evacuation and occupant life safety. Smoke exhasut is provided to allow suficent time for occupants to evacuate. While smoke exhaust can improve conditions for fire brigade intervention, this is not (and should not be considered as) its purpose. Fire engineers are the specialists in this area and a properly done Performance Solution will have little impact on fire brigade operations, but will consider the benefits of fire brigade assisted evacuation if it can be demostrated brigade will arrive at the buidling in time to assist with evacuation.

EP4.1: This is about occupant evacuation and occupant life safety. Smoke exhasut is provided to allow suficent time for occupants to evacuate. Fire engineers are the specialists in this area and a properly done Performance Solution will have little impact on fire brigade operations, but will consider the benefits of fire brigade assisted evacuation if it can be demostrated brigade will arrive at the buidling in time to assist with evacuation.

EP4.3: This is about occupant evacuation and occupant life safety. Smoke exhasut is provided to allow suficent time for occupants to evacuate. Fire engineers are the specialists in this area and a properly done Performance Solution will have little impact on fire brigade operations, but will consider the benefits of fire brigade assisted evacuation if it can be demostrated brigade will arrive at the buidling in time to assist with evacuation.

No.

If done properly it would lower the amount of referrals needed to be made, without lowering the life safety standards.

Needs to be based on real data. There is no adequate database in Australia that can be used to make such decisions. The existing database has been based on input by untrained or poorly trained fire fighters.

No. A simple buidlng with multiple Performance Solutions may present more risk that a complex building with a single Performance Solution.

To assist with fire infrastructure planning.

But must be done propoerly, a blanket requirement would be of no benefit. A project should meet designated thresholds before this is a requirement.

Fire engineers are, in general, competent and have occupant life safety at top of mind. No fire engineer wants to be standing before a coroner or judge justifying himself with people dead as a result of a fire. In general fire brigade offcers providing advice on these matters have no skin in the game, i.e. they are not on the litigation hit list if things go wrong. Fire engineers most definitely are held responsidble in court for their work if things go wrong.

If brigade personnel are are going to provide advice on matters outside the field of fire brigade intervention then they need to be appropriately qualified.

Hydrant systems, vehicular access requriements.

No.