Response 154785704

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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.

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Radio button: Unticked Do not publish

Introduction

3. What is your name?

Name (Required)
Timothy Radley

5. On whose behalf are you making this submission?

On whose behalf are you making this submission?
Please select one item
(Required)
Radio button: Ticked I am making this submission on my own behalf
Radio button: Unticked I am making this submission on behalf of a business
Radio button: Unticked I am making this submission on behalf of an industry body
Radio button: Unticked I am making this submission on behalf of a government agency

6. What is your organisation?

Organisation (Required)
TR Fire Pty Ltd

7. Which best describes your industry sector?

Which best describes your industry sector?
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 Building and plumbing products
Radio button: Unticked Building Certification/ Surveying
Radio button: Unticked Architecture and design
Radio button: Unticked Engineering
Radio button: Unticked Plumbing
Radio button: Ticked Compliance, testing and accreditation
Radio button: Unticked Legal and Finance
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: Unticked Specialist - hydraulic/ plumbing
Radio button: Unticked Student/ apprentices
Radio button: Unticked Trades and other construction services
Radio button: Unticked Education
Radio button: Unticked Community and Non-Government organisations
Radio button: Unticked Government
Radio button: Unticked General Public
Radio button: Unticked Other

8. 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

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?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure

10. Are there any additional fire safety systems not captured in the list?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
If Yes/Unsure, list the other fire safety systems
Fire Pumpsets - I believe the QBCC has it's own licence class for this.
There are many variable requirements for these across Sprinkler/Hydrant systems and often installed non-compliant (Hydrant Pumpests more-so due to Plumbers installing typically off Consultant drawings).

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?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked Unsure
If No, provide alternative suggestions on how these systems should be regulated for installation, testing and certification.
Fire Extinguishers could do with a higher level of control via certification/declaration as the Fire "Tech's" that I've come across who do only Fire Extinguishers often just go off here-say instead of strict standard breakdowns that are verified by office supervisors or Fire Consultants --- the argument not requiring is they aren't a Suppression System (Sprinklers) or a Brigade System (Hydrants) - only a first instance method of Fire extinguishment via Personnel that may or may not be used depending if the user determines it safe to use at the time.

Air handling units being used in Fire Shutdown scenarios should perhaps have some higher level of certification/declaration that it complies --- Argument against this I think is less because if the Air Unit doesn't work and allows more oxygen through sections creating draft or greater fuel for the fire, things could go bad fast.

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?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked Unsure
If No/Unsure, please provide alternative suggestions.
Plumbers should never be allowed to test any Fire System (Currently how QBCC rules), there are to many rules and regulations for them to understand without doing a 4 year apprenticeship solely focused on Fire Systems.

Only licenced Sprinkler Fitters should be allowed to test water based systems as they have installed them and understand the requirements - you can't troubleshoot systems if you've never installed one and fully understand the intentions of how they work.

QBCC do seem to have it right; Only an appropriate licenced Sprinkler Fitter/or/Fire Sparky can test their own discipline: Water Suppression/or/Alarms.

Routine testing logs as per AS1851, with a Form 72 sign-off yearly from a Fire Company & MP6.1 Occupiers Statement filled out by building owners.

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?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
If No/Unsure, please provide further comment.
Again no Plumbers should be allowed to certify any Fire System; allowing plumbers to install Hydrant Systems is just feasible due to the simplicity of those systems (They still manage to stuff it up; especially Pumpests feeding Hydrant Systems).

Only Sprinkler Fitters (Cert 3)(or Alarms Tech etc.) who have gained first hand installer experience and further educated with a Cert 4 should be allowed to Certify a Fire System (of appropriate licenced type).

Independent needs to be clarified strongly... Australia Standards (AS2118) no longer calls for it - however in QLD, the QLD Building Regulation (Section 22) does call for it, however is not worded the best and somehow seems to be not read by Building Certifiers.

Independent perhaps should be defined as a Third Party from the Installing Company (Certifiers sitting in the office of Wormald should not be able to certify the installation completed by their own workers - to big of a conflict of interest to 'just sign it off and look the other way' over non-compliances). - Eg: Wormald installs the System, but has to get a certifier from Chubb to come in and certify it - this places much greater responsibility on both parties to do things right.

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
From Q13 Answer:
Again no Plumbers should be allowed to certify any Fire System; allowing plumbers to install Hydrant Systems is just feasible due to the simplicity of those systems (They still manage to stuff it up; especially Pumpests feeding Hydrant Systems).

Only Sprinkler Fitters (Cert 3)(or Alarms Tech etc.) who have gained first hand installer experience and further educated with a Cert 4 should be allowed to Certify a Fire System (of appropriate licenced type).

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?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked Unsure
If No/Unsure, please provide further comment.
From Q13 Answer:
Independent needs to be clarified strongly... Australia Standards (AS2118) no longer calls for it - however in QLD, the QLD Building Regulation (Section 22) does call for it, however is not worded the best and somehow seems to be not read by Building Certifiers.

Independent perhaps should be defined as a Third Party from the Installing Company (Certifiers sitting in the office of Wormald should not be able to certify the installation completed by their own workers - to big of a conflict of interest to 'just sign it off and look the other way' over non-compliances). - Eg: Wormald installs the System, but has to get a certifier from Chubb to come in and certify it - this places much greater responsibility on both parties to do things right.

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?

Please select one item
Radio button: Unticked Can be from the same entity
Radio button: Ticked Must be independent of the entity that performed the installation
Provide further comment
From Q13 Answer:
Independent perhaps should be defined as a Third Party from the Installing Company (Certifiers sitting in the office of Wormald should not be able to certify the installation completed by their own workers - to big of a conflict of interest to 'just sign it off and look the other way' over non-compliances). - Eg: Wormald installs the System, but has to get a certifier from Chubb to come in and certify it - this places much greater responsibility on both parties to do things right.

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?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked Unsure
If No/Unsure, please provide further comment.
This actually could be a smart way to do it... allows for 'buddies' with-in the Fire Industry from signing off each others work.
However the bad thing is the Building Owner/Applicant might be able to shop around for the dodgiest cheapest certifier and/or a 'buddie' of another guy.
Guess both situations are much of a muchness, so unsure.

Benefit of allowing Fire Company to engage a 3rd Party Independent is the routineness of knowing which documents (Form 71, Installers Statement etc.) need to be completed and issued - where as an Owner/Applicant who doesn't do it often would have a hard time understanding all the requirements creating delays which leads to pressure to just sign things off.

Maybe best to leave the Fire Company to source a 3rd Party Certifier due to common Industry knowledge.

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?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked Unsure
If No/Unsure, please provide alternative suggestions
To think they could perform a full inspection is a bit rich.
Doing a walk through themselves and confirming no obstructions to sprinkler heads and raising questions is definitely good however.

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?

Please select all that apply
Checkbox: Ticked Fire safety designer (fire safety engineer)
Checkbox: Unticked Statutory building surveyor
Further comment
Building Surveyor doesn't know enough about Fire Systems to check things thoroughly.
Fire Designer should perhaps be used to confirm that any Alternative Solution will perform as intended.

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?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure

21. Do you agree that the maintenance of specified fire safety systems should only be undertaken by registered fire systems installers or plumber?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
If No/Unsure, please provide further comment.
No Plumbers competent in testing any Fire System.

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?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure
If No/Unsure, please provide further comment.
Just like a MP6.1 Occupiers Statement.

Comments

23. Do you have any further comments?

Comment
Think I've covered most in previous questions...

Plumbers do not understand how to test/maintain or certify Fire Systems - they must not be allowed to do so or you will see a large further decline in works across the industry.
They often work off consultants drawings and never engage Fire Designers.

3rd Party Certification (Independent from Installation Company) is the way forward for new builds.

Licenced Fire companies for routine testing is essential (Fire Sprinkler Fitters for water based etc.) - having annual statements is a good way to go.