Discussion paper: Mandatory Inspections - A response to the Building Confidence Report

We suggest that mandatory inspections are carried out by the designer who participated in the building design to verify that the completed building or building part complies with the original design documentation . This will ensure accountability across all building design areas including lighting.

Lighting Council Australia conditionally agrees with the proposed definition based on a prescribed author of the certificate of compliance remaining accountable for the compliance of the design and construction of the building element. Furthermore, an appropriate authority must exist within each jurisdiction with powers to evaluate building compliance. We are aware that currently in many jurisdictions building regulation authorities make determinations on certifier conduct and not building compliance. Without the establishment of an appropriate regulatory authority that can make expert determinations on compliance, accountability within the building industry will not be improved.

Occupants of all buildings require an equal level of certainty that the building they occupy is safe and reliable. We suggest that a risk-based approach target areas that are identified based on frequency of non-compliance and perceived hazards associated with failure. This would allow a dynamic model that can be readily adjusted to target problem areas as they are identified. A static risk-based model, as has been proposed, undermines other areas of building compliance and is likely to lead to the development of a culture of non-compliance where certain areas of building compliance are known to rarely if ever be checked for compliance.

In agreement with the Building Confidence Report, we suggest that minimum mandatory inspections for commercial buildings are required.

We suggest that mandatory inspection be extended to include the following performance requirements: FP4.2, EP4.1, EP4.2 and JP1.

Emergency lighting, EXIT signs and general lighting provide visibility which is fundamental to our ability to safely navigate spaces and orientate ourselves. The provision of adequate illumination is essential for the recognition of hazards, the performance of physical/visual tasks and for avoiding conditions such as mental fatigue and eye strain, especially in potentially hazardous environments.

Yes, as above we believe that elements used to demonstrate compliance to performance requirements FP4.2, EP4.1, EP4.2 and JP1 should be included for minimum mandatory inspection.

At a minimum, emergency lighting and EXIT signs are critical life safety devices that should be considered equally important along with fire safety systems. In an emergency egress situation where a building experiences power failure, these systems turn on automatically to provide a level of illumination essential for safe egress and identification of exits.

Currently, mandatory inspection of emergency lighting and EXIT signs does not appear to be included for any level of building complexity. We suggest that they are included for all building types that require emergency lighting and EXIT signage.

Building surveyors are generalists who do not possess the specialised expertise required to assess all products, designs or building areas during inspection. We suggest that the designer who participated in the building design documentation be used to verify/certify that the completed building complies with the original design plans. Third party independent review should be required for certain high risk design components or in areas where non-compliance and risk are detected.

A systematic framework should be established to determine the minimum number of notifications, timing of inspections and what content is inspected.

All design areas should be verified by the designer.

Yes based on risks due to the builder/developer/contractor history, the building type, the history of non-compliance in certain building areas and the significance of risk if failure occurred.

No, a summary of the recommendations we have made as a part of this consultation submission are detailed below:

- Registered design practitioners and authors of design documentation should verify, by inspection, that the original design documentation has been fulfilled.
- An appropriate regulatory authority must exist in each jurisdiction to make determinations based on building compliance and not simply certifier conduct alone.
- Mandatory inspection utilises a dynamic risk-based approach that targets areas that are identified based on frequency of non-compliance and perceived hazard associated with failure.
- Lighting systems are essential to safe orientation and hazard identification. Design elements used demonstrate compliance to performance requirements FP4.2, EP4.1, EP4.2 and JP1 should be included in mandatory inspection. Emergency Lighting and Exit Signs are essential life safety devices and should be considered of equal importance with fire safety systems.