NCC 2019 Amendment 1 Public Comment Draft

Clause2.5(b)(i)

(b) A Class 9b early childhood centre must comply with the following:
(i) The Class 9b early childhood centre must be divided into at least 2 fire compartments of equal size or as appropriate to satisfy compliance with D1.11.

Are the fire compartments that divide a Class 9b early childhood centre required to be of equal size or ratio? If not clause D1.11 is the only DtS provision to regulate this as each compartment must be of suitable size to accommodate the total number of persons served by any horizontal exit.

Maintain current requirement in these concessions for:

“any insulation installed in the cavity of a wall required to have an FRL is non-combustible.”

Combustible installation can still spread fire in the cavity of a wall required to have an FRL.

Spec E1.5 Clause 14(a)

Amend “fast response” to “quick response”

Reference is made to “fast response” sprinklers.

The new amendment to AS 2118.1-2017 (public comment recently closed) updates this terminology to “quick response” as this refers to the responsiveness of the sprinkler in its installed situation. By comparison “fast response” simply refers to the individual sprinkler head bulb or fusable link RTI.

Using the term “quick response” will align with the impending AS 2118.1.

Spec E1.5 Clause 14(b)

Remove proposed Spec E1.5 Clause 14(b)

Why are concealed sprinklers not permitted in just Class 9b early childhood centre building parts?

Table E2.2b
Clause (b)(iii)

Why are schools suddenly exempt?

A2.2(4)

1. PBDB should be in italics as it’s a defined term.

2. Relevant stakeholders is not defined. If such a definition cannot be included in the NCC, it should be discussed in the NCC Guide or separate ABCB guidance.

3. Analysis may also include calculations in addition to modelling and / or testing. Also if this list of analysis types is not meant to be exhaustive of all acceptable types, it should say “not limited to….”

4. Acceptance criteria is not defined and is only listed as an element that should be included in the PBDB and again referenced by the definition of the PBDB. Guidance developed or referred to by the ABCB should be available regarding establishing acceptance criteria for the community and also firefighters when the Performance Solution addresses Performance Requirements that include “fire brigade intervention” as an element that must be satisfied.

5. Reference is made to a “final report” this should be referenced as a PBDR (Performance Based Design Report) and supported with a definition similar to how the term PBDB is included in this new clause.

6. Presumably reference is not made to the International Fire Engineering Guidelines (IFEG) regarding how this process should be applied because it applies to any Performance Solution not just those associated with fire. Despite this, the concepts in the IFEG are transportable. This new clause should be supported by guidance drawn from / informed by the IFEG and appropriately adapted to other sectors covered by the NCC beyond fire safety.

FPA Australia supports the inclusion of a process for development of Performance Solutions in the NCC. It is acknowledged that this is a difficult process to capture in simple steps however we make the following comments regarding the proposed wording the NCC2019 Amdt 1 public comment draft.

Definitions

Building Complexity

Make “Complexity Levels” individual definitions or simply make the definition of “Building Complexity” refer to Table 2.

Move the proposed definition for “Building Complexity” in the NCC2019 Amdt 1 Public Comment Draft to part of the explanatory notes.

For consistency make the order of key components used in Figure 2 align the order expressed in the Complexity Level definitions.

FPA Australia supports the introduction of a definition of building complexity to support future identification of thresholds for determining process rigour.

The explanatory information is better at clarifying the actual definition than the proposed definition itself, which is cumbersome. An alternative may be to simply define the complexity levels instead.

The Complexity Levels made much more sense upon reading the proposed Figure 2. Recommend for consistency that the order of key components used in Figure 2 (Consequences -> Vulnerability -> Complication) is the order used to describe each Complexity Level in Table 2 (or separate definitions as suggested above)

Definitions
Complicated Building

Consider additional guidance

This is extremely subjective and the explanatory information provided may not provide enough guidance to ensure consistent application.

Definitions
PBDB

Change to:

“Performance-based design brief (PBDB) means the process and the associated report that defines:

(i) The scope of work for the performance-based design analysis, including: relevant Performance Requirements and design objectives, identification of relevant stakeholders, and identification of building and occupant characteristics; and

(ii) The technical basis for analysis including relevant assessment methods, approach and methods of analysis proposed; and

(iii) The criteria for acceptance of any resultant Performance Solution as agreed by relevant stakeholders and how standards of construction, commissioning, management or use and maintenance will be met.

This definition lists what the process and associated report should define. But it does this in one long sentence. The information would be easier to comprehend if listed in individual points.

Also it could include additional elements informed by the IFEG that are adaptable to or should be considered by any Performance Solution