NCC 2019 Amendment 1 Public Comment Draft

Volume 1 C2.5
The concession should include allowance for a childcare centre in a two storey building without the need for separate fire compartments.

The clause allows concession where a childhood centre that provides direct egress to a road or open space.

Many childcare centres have two storey portions and the total building is a childcare centre. The clause would require fire compartmentation of such centres.

Volume 1 Specification C1.1
The concession applies to Class 2 and Class 3 building of Type A & B construction – which would be buildings of two storeys and above. These buildings of Class 2 or 3 are required under Table E2.2a to have an automatic smoke detection and alarm system complying with Specification E2.2a. Requiring such within the concession clause appears to be redundant. The concession should also include Class 5, 6 & 9b buildings up to three storeys rise in construction. Installation of an automatic smoke detection and alarm system complying with Specification E2.2a may be appropriate.

There is no definition of timber framing in NCC therefore this is a matter of interpretation of what timber framing can be involved. Note – bracing sheets of timber materials are part of the timber framing. External walls sheets used to brace external walls can be assessed as timber framing.

Plasterboard suppliers have many products with timber frame construction that are tested to provide the fire resistance of FRL 60/60/60 up to FRL 120/102/120.

Why should the concession only apply to Class 2 and 3 buildings? Buildings of Class 5, 6, 9b can be two storey or three storey Type B construction and not able to have the concession for timber framing. Where those buildings can conform to the required fire resistance levels of the NCC 2019 with timber framing then the risk to the occupants would be similar to Class 2 or 3.

D1.2 & D1.11 Volume 1
For D1.11 (a) (ii) horizontal exits cannot be counted as a required exit in an early childhood centre.

There is therefore a conflict with Clause D1.11 (c) (ii) that allows an horizontal exit for an early childhood centre. Also Clause D1.11 (f) is in conflict. Both these need not be included.

D1.2 & D1.11 Volume 1
For D1.11 (a) (ii) horizontal exits cannot be counted as a required exit in an early childhood centre.

There is therefore a conflict with Clause D1.11 (c) (ii) that allows an horizontal exit for an early childhood centre. Also Clause D1.11 (f) is in conflict. Both these need not be included.

Table E1.5
Amendment requires full sprinkler system in any building with an early childhood centre, effectively over one storey.

This appears to be over conservative in respect to providing a sprinkler system in the building where there is an early childhood centre. Limiting the requirement for sprinklers to a building with an effective height over 25.0m should be acceptable for an early childhood centre.

Table E1.5
Amendment requires full sprinkler system in any building with an early childhood centre, effectively over one storey.

This appears to be over conservative in respect to providing a sprinkler system in the building where there is an early childhood centre. Limiting the requirement for sprinklers to a building with an effective height over 25.0m should be acceptable for an early childhood centre.

Table E2.2b Volume 1
The new Clause appears to require an automatic smoke detection and alarm system for any building over one storey. With proposed E1.5 amendment the building would be sprinkler protected.

Part (a) of the subject clause allows a sprinkler system complying with Specification E1.5 as an option to an automatic smoke detection system. This option should be available for a building with an early childhood centre.

Pursuant to Table E2.2a the Class 9b early childhood centre even in part of a building would require an automatic smoke and detection system to Specification E2.2a for a building with a rise in storeys more than 2. This requirement should be acceptable for the early childhood centre. The new clause amendment is therefore not required.

The new Clause appears to require an automatic smoke detection and alarm system for any building over one storey.

Part (a) of the subject clause allows a sprinkler system complying with Specification E1.5 as an option to an automatic smoke detection system. This option should be available for a building with an early childhood centre.

Pursuant to Table E2.2a the Class 9b early childhood centre even in part of a building would require an automatic smoke and detection system to Specification E2.2a for a building with a rise in storeys more than 2. This requirement should be acceptable for the early childhood centre. The new clause amendment is therefore not required.

The terminology of Building Complexity should not be included within the NCC. Should the States need to have a common supervision role of building construction then that should be established between the States and the Federal Government in preparation of the relevant Building Act of each State.

Similarly the definition of complicated building and non complicated building and vulnerable occupants should not be included in the NCC.

The introduction of the new definition of Building Complexity will create confusion within the construction industry. Should State legislation require an increase in supervision of construction then the State governing requirements should detail such level of supervision for the type of building that the State considers need such construction supervision. At present the NCC 2019 has requirements to establish higher levels of structural integrity and fire safety for buildings of different uses and number of storeys.

To introduce into NCC a third determination of how a building should be constructed including supervision will create confusion when using the NCC for construction of buildings.

The following are examples of confusing identification under Table B1.2a (Importance Level of Buildings) and Table 3 (Typical Examples of Complexity Level);

Typical Building Importance Level Complexity Level

Class 1a dwelling 2 0
4 storey office building 3 1
Data centre 2 1
Class 1b dwelling 2 1
Low rise Class 2 2 1
Shopping centre 3 2
Concert hall 3 2