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:
Unticked
Publish response
Radio button:
Ticked
Publish response anonymously (this will remove personal identifiers including, name and organisation)
Radio button:
Unticked
Do not publish
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:
Unticked
Yes
Radio button:
Ticked
No
Radio button:
Unticked
Unsure
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:
Ticked
No
Radio button:
Unticked
Unsure
If No, provide alternative suggestions on how these systems should be regulated for installation, testing and certification.
These systems in part form part of a fire system, air ventilation can assist with the spread of a fire or air supply system can increase the intensity of a fire. Fire compartment become impacted where these systems are not appropriately maintained or tested for design performance.
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:
Ticked
No
Radio button:
Unticked
Unsure
If No/Unsure, please provide alternative suggestions.
Restricting the testing of the fire systems to the installer or plumber only will only increase the cost to building owners, so much so that you will see a reduction of regular servicing increasing the risk to occupiers and visitors to the buildings. QLD is about to head down this path where we will see hundreds of level 2 technicians put out of work.
I would like to see the introduction of qualified level 1 technicians that can conduct the basic services, i.e. monthly and 6 monthly services to sprinkler systems, splinklers fitters to conduct annual services. 6 monthly and annual services to pumps and hydrant valves, where higher level testing like flow tests are copleted by sprinkler fitters. this will maintain and improve safety while keeping maintenance cost low for building owners.
the introduction of qualified technicians over competent based will dramatically improve safety with a higher skill workforce.
I would like to see the introduction of qualified level 1 technicians that can conduct the basic services, i.e. monthly and 6 monthly services to sprinkler systems, splinklers fitters to conduct annual services. 6 monthly and annual services to pumps and hydrant valves, where higher level testing like flow tests are copleted by sprinkler fitters. this will maintain and improve safety while keeping maintenance cost low for building owners.
the introduction of qualified technicians over competent based will dramatically improve safety with a higher skill workforce.
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
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
There is a huge conflict of interest where operators are signing off their own work, there is no QA or accountability. We see this on a very regular basis where systems have been installed incorrectly but still certified, we feel that a min of Certificate III in appropriate field with an certification competency would be suitable.
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:
Ticked
No
Radio button:
Unticked
Unsure
If No/Unsure, please provide further comment.
There needs to be ethical independence between the certifier and the installer. certifiers need also be audited where appropriate evidence needs to be presented. This should include evidence of onsite assessments in the form of a audit report and photos.
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
As above
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:
Ticked
Yes
Radio button:
Unticked
No
Radio button:
Unticked
Unsure
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:
Ticked
Yes
Radio button:
Unticked
No
Radio button:
Unticked
Unsure
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:
Ticked
Statutory building surveyor
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
Provide comments
WE highly recommend AS1851-2012(a1) as the benchmark.
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:
Unticked
Yes
Radio button:
Ticked
No
Radio button:
Unticked
Unsure
If No/Unsure, please provide further comment.
As per my fist comment, there is no reason we cannot train lower level technicians to conduct minor services and inspections like monthly and 6 monthly services to pumps, hydrants and sprinkler systems. Annual inspections on valves) this will increase the number of technicians available to conduct these services especially in rural areas. more technicians will increase the safety in buildings, less missed services and lowering the cost for building owners.
I am all for higher level technicians like plumbers completing complex annuals and flow tests. So often while reviewing service books you identify the tick and flick option for technicians, every month is identical. after reviews onsite defects are identified, the concern here is that these are already qualified sprinkler fitters or plumbers.
is this because the work load exceeds the capacity to perform the role they are required to do? there is no capacity for employers and RTOs to increase the number of persons completing apprenticeships to obtain these extra qualification. the number of buildings currently requiring maintenance exceeds the number of required technicians, by adding more workload to an already overstretched workforce will cripple the safety of buildings, not including the extra cost to buildings.
Lastly by introducing the requirement will see many lower level technicians put out of work.
I am all for higher level technicians like plumbers completing complex annuals and flow tests. So often while reviewing service books you identify the tick and flick option for technicians, every month is identical. after reviews onsite defects are identified, the concern here is that these are already qualified sprinkler fitters or plumbers.
is this because the work load exceeds the capacity to perform the role they are required to do? there is no capacity for employers and RTOs to increase the number of persons completing apprenticeships to obtain these extra qualification. the number of buildings currently requiring maintenance exceeds the number of required technicians, by adding more workload to an already overstretched workforce will cripple the safety of buildings, not including the extra cost to buildings.
Lastly by introducing the requirement will see many lower level technicians put out of work.
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
Comments
23. Do you have any further comments?
Comment
Every building should be proving maintenance has been completed by qualified technicians annually , so many buildings we attend in NSW each year is being maintained by a person who has deemed themselves competent. services are not being completed correctly or to any standard.
We like the independent practitioner assessing buildings annually to confirm performance of systems and maintenance contractors are do the correct job.
We like the independent practitioner assessing buildings annually to confirm performance of systems and maintenance contractors are do the correct job.