Information Collection
2. 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.
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Publish response
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Publish response anonymously (this will remove personal identifiers including, name and organisation)
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Do not publish
Introduction
3. What is your name?
Name
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Leigh Gesthuizen
5. On whose behalf are you making this submission?
On whose behalf are you making this submission?
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I am making this submission on my own behalf
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I am making this submission on behalf of a business
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I am making this submission on behalf of an industry body
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I am making this submission on behalf of a government agency
6. What is your organisation?
Organisation
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Fire Protection Association Australia
7. Which best describes your industry sector?
Which best describes your industry sector?
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Building Commercial
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Building Residential
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Building Commercial and Residential
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Building and plumbing products
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Building Certification/ Surveying
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Architecture and design
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Engineering
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Plumbing
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Compliance, testing and accreditation
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Legal and Finance
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Specialist - disability access
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Specialist - energy efficiency
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Specialist - fire safety
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Specialist - health
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Specialist - hydraulic/ plumbing
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Student/ apprentices
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Trades and other construction services
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Education
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Community and Non-Government organisations
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Government
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General Public
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Other
8. Please select your State or Territory
State or Territory
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ACT
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NSW
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NT
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Qld
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SA
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Tas
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Vic
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WA
Principle 1- Installation and testing, certification and maintenance of nominated fire safety systems is regulated
9. Do you agree that the installation and testing, certification and maintenance of the fire safety systems listed in Attachment A should be regulated?
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Yes
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No
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Unsure
If No/Unsure, please provide alternative approaches
The FPA Australia has long advocated for competent and experienced people involved in design, installation and commissioning repair, certification and ongoing inspection and testing of fire safety systems should be licensed or accredited.
10. Are there any additional fire safety systems not captured in the list?
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Yes
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No
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Unsure
If Yes/Unsure, list the other fire safety systems
Standby power supplies (emergency power supply)
Emergency lifts
Fire Curtains
Fire isolated passageways and ramps
Elements used for the fire protection of structural components
Emergency vehicle access to and around the site
Emergency lifts
Fire Curtains
Fire isolated passageways and ramps
Elements used for the fire protection of structural components
Emergency vehicle access to and around the site
11. Do you agree that fire extinguishers and/or mechanical air handling systems do not require a declaration of installation compliance unless where requested by the statutory building surveyor?
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Yes
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No
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Unsure
If No, provide alternative suggestions on how these systems should be regulated for installation, testing and certification.
FPA Australia believe that all fire safety systems require a certificate of compliance issued prior to an occupancy certificate. This certificate of compliance is considered the initial certification of the fire safety system and ensures that the job of on-going performance assessment is made easier and more effective.
Principle 2- Installation and testing of fire safety systems is undertaken by registered practitioners
12. Do you agree with the recommendation that the fire system installer or plumber must test the installed fire safety systems and provide a Declaration of Installation Compliance?
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Yes
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No
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Unsure
If No/Unsure, please provide alternative suggestions.
On most occasions the fire safety system installer is contractually obligated to supply, install, test and commission a fire safety system. Some standards require an installers statement eg AS 1670 (installers statement) and AS 2118 (system completion statement). It is entirely appropriate that this type of installer’s statement is provided by the contracting entity.
The skill set to provide a certicate of compliance does not always reside within the contracting entity.
The skill set to provide a certicate of compliance does not always reside within the contracting entity.
Principle 3 – Certification of fire safety systems is mandatory and is undertaken by independent and registered practitioners
13. Do you agree that the certification of the fire safety systems listed in Attachment A, should be undertaken by an independent and registered fire systems installer or plumber?
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Yes
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No
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Unsure
If No/Unsure, please provide further comment.
FPA Australia believe that all fire safety systems should be certified by a licenced or accredited system certifier, who are competent and experienced in the field for which they are certifying. The system certifier could be installer or the designer but not both. i.e. The accreditation is held by the individual. An entity can not install and certify their own work.
14. Should the independent certification be undertaken by a fire systems installer or plumber with a Certificate IV qualification or should any additional qualification requirements be left to the discretion of the individual jurisdiction?
Provide comment
FPA Australia believe that all fire safety systems should be certified by a competent and experienced person authorised by the relevant authority as an accredited system certifier. A competent and experienced system certifier must have relevant nationally recognised qualifications, adequate PI and PL insurance and an appropriate level of experience
15. Are the requirements for an independent fire systems installer or plumber adequate to ensure no conflict of interest and independence exists between the original fire systems installer or plumber and independent fire systems installer or plumber?
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Yes
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No
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Unsure
If No/Unsure, please provide further comment.
For the sake of clarity, FPA Australia advocates for independent certification of a fire safety system by a competent and experienced person authorised by the relevant authority as an accredited system certifier.
FPA Australia believes that if the system certifier (as described above) is held responsible for their certification work for a prescribed period of time there would be limited instances of a conflict of interest.
FPA Australia believes that if the system certifier (as described above) is held responsible for their certification work for a prescribed period of time there would be limited instances of a conflict of interest.
16. Should the independent fire systems installer or plumber be independent of the entity (e.g. company or business) that performed the installation or can it be another employee from the same entity?
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Can be from the same entity
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Must be independent of the entity that performed the installation
Provide further comment
Given the structure outlined above we believe that it is quite appropriate for an employee of the contracting entity to undertake the system certification work, provided the individual is held responsible for the work they certify, as different to the entity.
17. Do you agree that the owner or building approval applicant should engage the independent fire systems installer or plumber, ensuring they are competent and registered as per the NRF?
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Yes
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No
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Unsure
If No/Unsure, please provide further comment.
Yes it is entirely appropriate that the owner is able to engage an independent person authorised by the relevant authority as an accredited system certifier.
Principle 4 – Statutory building surveyor is responsible for inspecting certified fire safety systems prior to issuing an occupancy approval or final certificate
18. Do you agree on the role of the statutory building surveyor in relation to visual inspections of certified fire safety systems installation?
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Yes
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No
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Unsure
If No/Unsure, please provide alternative suggestions
The statutory building surveyor should be able to rely on the independent certification provided by an accredited system certifier.
19. Should a fire safety designer (fire safety engineer) undertake the inspection of fire safety systems involving Performance Solutions prior to occupancy approval or should this be the role of the statutory building surveyor?
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Fire safety designer (fire safety engineer)
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Statutory building surveyor
Further comment
Yes fire safety designer (fire safety engineer) must inspect and validate that the performance solution. This process shall inform the statutory building surveyor of the compliance with the performance solution.
Principle 5 – Routine maintenance of essential fire safety systems is regulated, undertaken by registered practitioners and reported to the building regulator annually
20. Do you agree that the occupancy approval should state which fire safety systems must be maintained and to which standard and maintenance interval?
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Yes
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No
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Unsure
Provide comments
The occupancy documentation or permit issued by the building surveyor must include the conditions of occupation, inclusive of each fire safety system, standard of performance for ongoing maintenance and frequency of inspection.
Where a performance solution is applicable, the fire safety designer (fire safety engineer) must also provide as part of the performance solution details of the standard of performance for ongoing maintenance, frequency of inspection for the routine servicing of each performance solution.
Where a performance solution is applicable, the fire safety designer (fire safety engineer) must also provide as part of the performance solution details of the standard of performance for ongoing maintenance, frequency of inspection for the routine servicing of each performance solution.
21. Do you agree that the maintenance of specified fire safety systems should only be undertaken by registered fire systems installers or plumber?
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Yes
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No
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Unsure
If No/Unsure, please provide further comment.
It is important to differentiate between rectification and routine inspection, test and survey activities. Repairs that are required to maintain a standard of performance are generally a different skill set to routine inspect and test activities.
Maintenance refers to a repair activity, then this work should be undertaken by a registered fire systems installer or plumber.
If the term maintenance refers to a routine inspect, test and survey activities (i.e. validating a fire safety measure is present and performs), then this can be carried out by someone with the skillset suitable for the inspect and test activity and not mandated to be done by a registered fire systems installer or plumber.
Maintenance refers to a repair activity, then this work should be undertaken by a registered fire systems installer or plumber.
If the term maintenance refers to a routine inspect, test and survey activities (i.e. validating a fire safety measure is present and performs), then this can be carried out by someone with the skillset suitable for the inspect and test activity and not mandated to be done by a registered fire systems installer or plumber.
22. Do you agree that annual maintenance statements should be prepared and lodged with the state or territory building regulator for Class 2-9 buildings?
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Yes
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No
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Unsure
If No/Unsure, please provide further comment.
Annual maintenance statements do not provide a guarantee that the system will perform as designed.
FPA Australia believes that routine servicing (inspect, test and survey requirements) must provide confidence to the building owner or other stakeholders that the intended performance of the fire safety system or systems will comply with the performance requirements for the building as set out of A2.1 of the NCC Vol 1
To achieve this, a consolidated yearly statement should be prepared by each entity responsible for the routine servicing of each fire safety system. Defects or non-conformances that have not been previously rectified at the time of issuing the statement shall be listed with the yearly statement.
FPA Australia believes that routine servicing (inspect, test and survey requirements) must provide confidence to the building owner or other stakeholders that the intended performance of the fire safety system or systems will comply with the performance requirements for the building as set out of A2.1 of the NCC Vol 1
To achieve this, a consolidated yearly statement should be prepared by each entity responsible for the routine servicing of each fire safety system. Defects or non-conformances that have not been previously rectified at the time of issuing the statement shall be listed with the yearly statement.
Comments
23. Do you have any further comments?
Comment
The question relating to what state the FPA Australia is from. Whilst we responded with NSW, the FPA Australia represents and speaks on behalf of all states and territories of Australia.
FPA Australia operates an accreditation scheme under a co-regulatory model with the NSW government.
Currently the scheme
• Accredits practitioners that design fire safety systems and
• Accredits practitioners that assess and endorse the annual fire Safety statement
The next phase of accreditation scheme is to accredit system certifiers
A fire system certifier provide validation prior to the issuance of the occupancy certificate that the Fire Safety Measure has been installed in accordance with the performance requirements (including evidence of suitability requirements) for the building as set out of A2.1 of the NCC Vol 1
FPA Australia operates an accreditation scheme under a co-regulatory model with the NSW government.
Currently the scheme
• Accredits practitioners that design fire safety systems and
• Accredits practitioners that assess and endorse the annual fire Safety statement
The next phase of accreditation scheme is to accredit system certifiers
A fire system certifier provide validation prior to the issuance of the occupancy certificate that the Fire Safety Measure has been installed in accordance with the performance requirements (including evidence of suitability requirements) for the building as set out of A2.1 of the NCC Vol 1