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Page 1: Regulation Impact Statement for Consultation...Satisfy (DtS) Provisions for sprinkler protection to medium rise multi-storey residential buildings. This resulted in the ABCB commencing
Page 2: Regulation Impact Statement for Consultation...Satisfy (DtS) Provisions for sprinkler protection to medium rise multi-storey residential buildings. This resulted in the ABCB commencing

Regulation Impact Statement for Consultation

Fire safety in new Class 2 and Class 3 residential buildings

March 2018

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The Australian Building Codes Board has developed this Consultation Regulation Impact Statement, which accords with the requirements of Best Practice Regulation: A Guide for Ministerial Councils and National Standard Setting Bodies, as endorsed by the Council of Australian Governments in 2007. Its purpose is to inform interested parties and to assist the Australian Building Codes Board in its decision making on proposed amendments to the National Construction Code.

The Australian Building Codes Board The Australian Building Codes Board (ABCB) is a joint initiative of all levels of government in Australia, together with the building industry. Its objective is to oversee issues relating to safety, health, amenity, accessibility and sustainability in building. The ABCB promotes efficiency in the design, construction and performance and liveability of buildings through the National Construction Code (NCC), and the development of effective regulatory and non-regulatory approaches. The Board aims to establish effective and proportional codes, standards and regulatory systems that are consistent between States and Territories. For more information see the ABCB website (www.abcb.gov.au).

Consultation This is a consultation document where interested parties are invited to provide comment on any matter raised in this Consultation Regulation Impact Statement (RIS). A series of consultation questions have been provided throughout the document, and respondents are encouraged to address these items to assist in finalisation of the regulatory impact analysis.

Comments on this Consultation RIS are invited by close of business 13 April 2018 using the ABCB RIS response form and emailing it to [email protected] with the subject title “Fire safety in Class 2 and 3 buildings”.

The ABCB Office will review all comments received and incorporate stakeholder information and data into the regulatory analysis, as appropriate. The RIS will be revised in the light of stakeholder comments and will be forwarded to the Board as an input into its decision-making.

The Consultation RIS can be downloaded from the ABCB website at http://www.abcb.gov.au/Consultation/Regulation-Analysis/Consultation-RIS

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Disclaimer The information in this document is intended to be used as guidance material only, and is in no way a substitute for the NCC and related State and Territory legislation. The information in this document is provided on the basis that all persons accessing the information undertake responsibility for assessing the relevance and accuracy of the information to their particular circumstances. The Chief Executive Officer of the ABCB Office, as agent for the Commonwealth of Australia and States and Territories of Australia, does not accept any liability howsoever arising from or connected to the use or reliance on any information in this document to the maximum extent permitted by law.

Published by: Australian Building Codes Board First published: March 2018

GPO Box 2013

CANBERRA ACT 2601 Print version: 1.0

Phone: 1300 134 631 Release date: March 2018

Email: [email protected]

www.abcb.gov.au

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Copyright

Copyright and licence notice

© 2018 Commonwealth of Australia and States and Territories of Australia

Ownership of intellectual property rights

Unless otherwise noted, copyright (and any other intellectual property rights, if any) in this publication is jointly owned by the Commonwealth, States and Territories of Australia.

Creative Commons licence Attribution CC BY-NC-ND 4.0

All material in this publication is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International Licence, save for logos. Attribution-NonCommercial-NoDerivatives 4.0 International Licence is a standard form licence agreement that does not permit any commercial use or

derivatives of the original work. Under this licence: you may only distribute a verbatim copy of the work and must not adapt or change the work in any way. You must give appropriate credit and provide a link to the

licence. You may do so in any reasonable manner, but not in any way that suggests the Commonwealth of Australia, States and Territories of Australia or Australian Building Codes Board endorses you or your use. You may not use the material for commercial purposes. If you remix, transform, or build upon the material

for your own use, you may not distribute the modified material.

The full licence terms are available from http://creativecommons.org/licenses/by-nc-nd/4.0/legalcode.

Content contained herein should be attributed as:

The Fire Safety in Class 2 and 3 Buildings Consultation RIS© as released by the Australian Building Codes Board Office on behalf of the Commonwealth of Australia and States and Territories of Australia.

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Table of Contents Glossary................................................................................................................................ 7

Acronyms .............................................................................................................................. 8

Introduction ........................................................................................................................... 9

Problem .............................................................................................................................. 11

Summary of International Approaches ................................................................................ 20

Objective ............................................................................................................................. 20

Options ............................................................................................................................... 22

Impact Analysis ................................................................................................................... 25

Costs .................................................................................................................................. 26

Benefits ............................................................................................................................... 36

Uptake of Alternative Sprinkler Specifications ..................................................................... 41

Sensitivity Analysis ............................................................................................................. 45

Unintended Consequences ................................................................................................. 46

Business Compliance Cost ................................................................................................. 46

Additional Saleable Space .................................................................................................. 47

Regulatory Burden .............................................................................................................. 47

Consultation ........................................................................... Error! Bookmark not defined. Conclusion .......................................................................................................................... 48

Appendix A: International Comparison ............................................................................... 50

Appendix B: FPAA 101 D ................................................................................................... 51

Appendix C: FPAA 101 H ................................................................................................... 68

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Glossary Term Meaning Class 2 building A building containing 2 or more sole-occupancy units each

being a separate dwelling. Class 3 building A residential building, other than a building of Class 1 or 2,

which is a common place of long term or transient living for a number of unrelated persons, including–

(a) a boarding house, guest house, hostel, lodging house or backpackers accommodation; or

(b) a residential part of a hotel or motel; or

(c) a residential part of a school; or

(d) accommodation for the aged, children or people with disabilities1

(e) a residential part of a health care building which accommodates members of staff; or

(f) a residential part of a detention centre.

Deemed-to-Satisfy Provisions

Means provisions which are deemed to satisfy the Performance Requirements.

Performance Requirement

Means a requirement which states the level of performance which a Performance Solution or Deemed-to-Satisfy Solution must meet.

Sole-occupancy unit Means a room or other part of a building for occupation by one or joint owner, lessee, tenant, or other occupier to the exclusion of any other owner, lessee, tenant, or other occupier and includes—

(a) a dwelling; or (b) a room or suite of rooms in a Class 3 building which

includes sleeping facilities; or (c) a room or suite of associated rooms in a Class 5, 6, 7, 8

or 9 building; or (d) A room or suite of associated rooms in a Class 9c

building, which includes sleeping facilities and any area for the exclusive use of a resident.

1 Class 3 residential care buildings accommodating the aged, children or people with disability are required to have automatic fire sprinklers as a consequence of amendments to the DtS Provisions of NCC 2019 and are therefore not within the scope of this analysis.

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Abbreviations Abbreviation Full name ABCB Australian Building Codes Board BCA Building Code of Australia (Volumes One and Two of the NCC) COAG Council of Australian Governments DtS Deemed-to-Satisfy IGA Inter-Governmental Agreement NCC National Construction Code OBPR Office of Best Practice Regulation RIS Regulation Impact Statement

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Introduction Following the death and life changing injuries sustained by two occupants in an apartment fire in 2015, the NSW Deputy Coroner requested that the ABCB consider extending the current Deemed-to-Satisfy (DtS) Provisions for sprinkler protection to medium rise multi-storey residential buildings. This resulted in the ABCB commencing Stage 1 of the holistic review of fire safety measures for Class 2 and 3 buildings.

Concurrent with the work of the ABCB, advocates of fire safety including, Fire and Rescue New South Wales (FRNSW), the Australasian Fire and Emergency Services Authorities Council (AFAC) and the Fire Protection Association of Australia (FPAA), commenced developing their own proposal for change to the NCC. As justification for the proposal, the proponents suggested that the expansion of the fire sprinkler requirements to new Class 2 and 3 buildings constructed above three storeys and less than 25 m in effective height would in turn allow the removal of a number of other active and passive fire safety features currently required by the DtS Provisions, leading to an overall saving in construction costs as well as an increase in life safety in these buildings.

A Victorian variation to the NCC (VIC H103.1) provides a number of concessions for active and passive fire safety systems where fire sprinklers are installed. In 2014, the ABCB conducted a survey of all NCC users that found that some stakeholders felt these concessions better reflected minimum necessary regulation and had the potential to deliver higher economic and life safety benefits.

Under the current NCC DtS Provisions a fire sprinkler system is required in all new Class 2 and 3 buildings greater than 25 metres in effective height and in buildings accommodating the aged, children or people with disabilities2.

Fire sprinklers have proven highly effective both domestically and internationally as a means of suppressing fire in its early stages. In recent times, changes in construction methods such as timber mid-rise construction has also seen their inclusion in buildings less than 25 m in effective height.

This Consultation RIS assesses the costs and benefits of requiring fire sprinklers in the DtS Provisions, using alternative sprinkler specifications, in new multi-storey Class 2 and 3 residential buildings. It is informed by the findings of a fire risk analysis by EFT Consulting and material provided by AFAC, FRNSW and FPAA. The scope of this analysis is limited to new buildings as the solutions examined will not apply retrospectively.

The following draft FPAA sprinkler specifications on which this Consultation RIS has relied are reproduced in Appendix B and Appendix C:

• FPAA 101 D Automatic Fire Sprinkler System Design and Installation –Domestic Water Supply, DRAFT 4 December 2017; and

2 Class 3 residential care buildings accommodating the aged, children or people with disability are required to have automatic fire sprinklers as a consequence of amendments proposed to the DtS Provisions of NCC 2019 and are therefore not within the scope of this analysis.

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• FPAA 101 H Automatic Fire Sprinkler System Design and Installation –Hydrant Water Supply, DRAFT 4 December 2017.

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Problem A core goal of the NCC is the efficient achievement of minimum necessary standards for the safety of building occupants from fire. Currently, this is achieved using a number of active and passive fire safety systems that work together as one system to provide safety from the effects of fire, though some components contribute more to performance than other elements.3

The type and number of fire safety systems required by the NCC increases4 proportional to risks that increase due to the height of the building, the presence of sleeping occupants, larger populations of unrelated occupants and longer travel distance. Currently, the NCC DtS Provisions require a sprinkler system be installed in Class 2 and 3 residential buildings where any part of the building has an effective height that exceeds 25 m. In buildings less than 25 m, the NCC does not recognise the option to sprinkler protect Class 2 and 3 buildings under a DTS pathway. This is largely due to no cost-effective domestic sprinkler systems being available.

Recently, following the death and life changing injuries sustained by two occupants of a building fire in 2015, both the NSW Deputy Coroner and proponents of fire safety including FRNSW, AFAC and FPAA have proposed the ABCB consider extending the current DtS Provisions for sprinkler protection to medium rise multi-storey residential buildings. This is in recognition of the effectiveness of sprinklers and the likely benefits they bring in reducing an occupant’s individual risk.

Nature of the Problem The nature of the problem relates to the NCC’s recognition through the DtS Provisions of appropriate strategies that are more cost effective in achieving the Goals of the NCC. New sprinkler specifications prepared by the FPAA have been developed that use new technology to improve cost-effectiveness along with associated concessions intended to provide higher life safety and property protection benefits when compared with the current mix of fire safety requirements specified by the current DtS Provisions.

Performance-based building codes in Australia and internationally place the objective of occupant safety as a central goal of compliant design. Active and passive fire safety measures combine to achieve a building fire safety system, reducing exposure of building occupants to the products of fire including heat, smoke and toxic gases. Although not the only risk to building occupants, inhalation of smoke and/or toxic gases is the main cause of fatality from a fire.

The NCC Performance Requirements implicitly recognise that fire may have both a localised effect and impacts beyond the compartment of fire origin. Consequently, a fire safety system is one or any combination of the methods used in a building to—

• warn people of an emergency; • provide for safe evacuation; • restrict the spread of fire; 3 FCRC Project 1 Restructure BCA Fire Provisions Part 1. Pg.13.

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• control a fire,

and includes both active and passive systems.

Examples of active and passive fire safety systems include the following:

• Passive systems o Fire-isolated stairways, ramps and passageways o Fire walls o Other fire-resisting building elements

• Active systems o Smoke alarms and intercom systems for emergency purposes o Emergency lighting o Exit signs o Sprinkler systems o Fire hydrant systems o Fire hose reel systems o Smoke and heat vents o Mechanical smoke-exhaust systems o Portable fire extinguishers.

Under the DtS Provisions, these active and passive systems combine to-

• alert people that an emergency exists and allow them to identify a path to a place of safety; • provide people with an environment and evacuation routes which, during a fire, will minimise

the risk of them suffering illness or injury; • facilitate the role of emergency service personnel; • assist in minimising the risk of fire spread; and • not have a structural failure during a fire.

The problem this Consultation RIS considers is the degree that the current NCC DtS Provisions in non-sprinkler protected medium-rise residential buildings address an occupant’s individual risk from fire, relative to the effectiveness and cost of other options.

The Current NCC Fire Safety Requirements In the view of some stakeholders, the NCC DtS Provisions do not reflect the most effective solution to meet the Goal of the NCC when considered from the perspective of individual risk. The NCC’s Performance Requirements establish the mandatory degree of performance buildings must meet. They reflect societal expectations and recognise that risks can vary with building use and occupancy. The requirements reflect a minimum necessary standard for all buildings. However, as the Productivity Commission noted in 2004, the BCA would, for some proportion of the population at least, fall short or exceed the expectations regardless of the level of regulation adopted. Therefore, in seeking to maximise the benefits to the economy and society along with community expectations, the costs and benefits of the level of performance adopted should be considered among other factors.

The DtS Provisions contained in Sections B – Structure, C – Fire Resistance, D – Access and Egress and E – Fire Fighting Equipment are commonly used solutions for buildings. They assist industry in

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interpreting the Performance Requirements in the absence of higher level quantification. Though performance-based codes allow alternative strategies and systems to be used to the degree necessary, including the use of sprinklers, the DtS pathway is considered the most common method of demonstrating compliance with the Performance Requirements of the NCC, and hence are the focus of this Consultation RIS.

Section C – Fire Resistance The DTS Provisions of Section C relate primarily to passive systems that impart fire resistance of a building structure and prescribe, inter alia, fire-resistance levels, maximum fire compartment sizes and the protection of openings. These elements are crucial in providing the necessary level of separation to prevent the spread of fire, contain its effects and in turn reduce an occupant’s exposure, while maximising the time and opportunity for evacuation in an emergency.

Due to the high risks associated with sleeping occupants, the most stringent fire resisting construction applies to residential (Class 2 and Class 3) buildings of three or more storeys5. This is referred to as Type A construction. Buildings below this height have lower fire loads, occupancy and travel distances, and therefore are of Type B or C construction. This graduated approach aligns the increase in fire safety with increases in risk to efficiently achieve the Code’s objectives.

Section D – Access and Egress The DTS Provisions of Section D relate to means of egress from a building in an emergency including limiting the distance of travel to a place of safety, the number and dimensions of exits and their construction.

In residential buildings, an exit is required to be protected (fire-isolated) where it passes through or by more than 3 consecutive storeys in a Class 2 building and 2 consecutive storeys in a Class 3 building. These requirements serve to complement the maximum distance from a sole-occupancy unit to an exit in a residential building (generally 6 m or 20 m to a point where travel to different exits is available), which is less than that required in other classes in recognition of the increased time for sleeping occupants to become alert in the event of a fire.

Section E – Services and Equipment The DTS Provisions of Section E are for active fire safety systems including fire sprinklers, firefighting equipment, smoke hazard management systems, smoke detection and alarms, emergency lifts, emergency lighting and exit signs.

Fixed Fire Suppression Systems NCC Performance Requirement EP1.4 requires an automatic suppression system be installed ‘to the degree necessary’ to control the development and spread of fire appropriate to–

a) the size of the fire compartment; and b) the function and use of the building; and c) the fire hazard; and

5 NCC Volume One C1.1. p.109.

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d) the height of the building.

‘To the degree necessary’ is a term used in the NCC Performance Requirements and recognises the application of a particular requirement can differ depending on the specifics of a building6. This extends to not requiring an item to be installed, where this is appropriate. Guidance clarifies that its use in EP1.4 recognises that not all buildings require automatic fire suppression systems. When implementing a required sprinkler system, judgements relative to a number of criteria may be required. These would include the level of occupancy, the degree of passive protection available, the availability of a reliable water supply and the location. Similarly, DP1.3 uses ‘to the degree necessary’ to describe the extent fire isolation of exits required, in recognition that travel time increases with building height.

The key consideration of this analysis is the appropriate threshold required by the NCC DtS Provisions for fire safety systems. Currently, the trigger for requirement for installation of fire sprinklers in residential buildings (other than accommodation for the aged, children or people with disabilities) above 25 m (assumed to be a building greater than eight storeys for the purpose of this analysis). The 25 m trigger for sprinkler systems has existed since August 1980, when the previous Australian Model Uniform Building Code (AMUBC), was amended to reduce the trigger height from 42 m.7

In November 2017, the ABCB’s Building Codes Committee considered a proposal suggesting cost effective sprinkler protection could be achieved through associated offsets to other fire safety requirements. At its meeting in December 2017, the Board agreed to further analysis, including through this Consultation RIS, of mandatory sprinkler protection for Class 2 and 3 buildings above three storeys and with associated offsets.

Extent of the Problem The extent of the problem is influenced by the rates of fire incidents, their location and the rates of injury and fatality in non-sprinkler protected Class 2 and 3 buildings constructed between 4 and 8 storeys in height.

Risk to Life Safety The fire safety provisions in the NCC have been developed over time to address two types of risk; individual risk, that is the risk of fatality or injury to a person or persons within the room of fire origin, and societal risk, that is the risk of fatality or injury to other occupants who may have little or no control over the activities or circumstances that lead to fire, but are exposed to its effects. When considering changes to the fire safety provisions it is necessary to consider how both types of risk will be impacted.

A fire safety engineering analysis was undertaken by EFT Consulting to compare the difference in individual risk associated with each proposed solution when compared to a building complying with the current DtS Provisions. The results of this analysis are shown in Table 1.

6 Guide to NCC Volume One p. 17. 7 The 25m trigger was chosen primarily due to cost effectiveness considerations and the known satisfactory performance of sprinklers, rather than in response to an unacceptable level of risk.

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Table 1: Comparative individual risk levels per solution

Solution Risk Level Fatalities per 1000 Fire Starts

Reduction in Risk Level (Percentage)

Current NCC DtS Provisions 3.9 x 10-6 3.9 -

FPAA 101D Sprinkler System Design and

Installation – Domestic Water Supply

1.3 x 10-6 1.3 67%

FPAA 101H Sprinkler System Design and

Installation – Hydrant Water Supply

1.1 x 10-6 1.1 72%

AS 2118.1 Sprinkler System Design and Installation

1.1 x 10 1.1 72%

Source: EFT Consulting

The current risk to life is estimated to be 3.9 fatalities per 1000 fire starts. As demonstrated by the fire safety engineering analysis, the effectiveness of fire sprinklers in reducing individual risk is estimated to range from 67% and 72% depending on the adopted system. In this regard, fire sprinklers demonstrate a high degree of effectiveness in reducing individual risk when compared with the current DtS Provisions.

Societal risk is less examinable, due to the rarity of multi-fatality events, however it has been established through engineering analysis using boundaries defined in land use planning criteria8. The unintended consequences section of this Consultation RIS further discusses the impacts of the proposed solutions on societal risk.

Rate of Fires in Residential Apartment Buildings The rates of fire occurrences in residential buildings is known with some certainty. The Report on Government Services shows approximately 0.9 fires per 1000 households9. A more detailed analysis undertaken by EFT Consulting suggests apartment fires represent 2.6 fires per 1000 households10. Noting there has been a downward trend in fire starts in recent years, a mid-point of 1.75 apartment fires per 1000 sole occupancy units per annum is assumed.

8 See EFT Consulting 2575-1, (2017) Pg.18 9 Report on Government Services 2017. http://www.pc.gov.au/research/ongoing/report-on-government-services/2017/emergency-management/fire-services shows the 5 year average 2011-12 to 2016-17 89.9 fires per 100,000 households, Table 9A.15 10 Housing Choices Report No 3240.1 Australian Bureau of Statistics NSW • 2004

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The rates of fire occurrences in other multi-storey residential buildings (Class 3 buildings) is slightly less at a frequency of 0.9 fire starts per 1000 sole-occupancy units, based on an examination of United States of America statistics of 39,874 fires for the Fire Code Reform Centre.11

Current Fatality Rate from Fire

The extent of the problem is also influenced by the current rate of fatality in new Class 2 and 3 buildings. This analysis uses the best available information on the incidences of fatality from a report prepared by the National Coronial Information System (NCIS). A copy of this report can be found on the ABCB website.

Between 2000 and 2015, 46 fatalities were recorded in all multi-storey residential buildings as a result of fire. This equates to an average of 3 (2.9) deaths per year. Of these fatalities, it is known that 26 deaths (57%) occurred in buildings of three storeys or less with 2 deaths (4.3%) reported to have occurred within the four to eight storey height range. Of the remaining unknown fatalities, the estimated number to have occurred within the four to eight storey height range is calculated to be 1.3 assuming the same rate of occurrence as the known fatalities. Hence the total number of fatalities in all multi-storey residential buildings in the four to eight storey height range between 2000 and 2015 is 3.3 or an average fatality rate of 0.21.12

Contributing Factors of Fire Fatalities

The rate of fatality from fire is known to be influenced by a building’s fire safety features. Figure 1 reflects the difference in fatality within sole-occupancy units in the presence of different fire safety systems. Hardwired alarms reflect the current requirement for Class 2 and 3 buildings less than 25 m in effective height.

11 Drawn from a detailed analysis of US fire statistics between 1983 and 1995 undertaken for the Fire Code Reform Centre Project 4. 12 The four and eight storey cohort is 7.6% of all fatalities and the remainder from the ‘unknown’ category are proportionately distributed.

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Figure 1 Fatalities / 1000 fires under alternative fire safety systems expressed as a ratio

Source: Adapted from Ahrens analysis of fatality rates per 1000 fires (2003-2006)

Hall (2013) established fatality rates in the US of 7.4 fatalities per 1000 fires in apartment buildings (Class 2 buildings) and 7.3 per 1000 fires in hotel/motel buildings (Class 3 buildings) without automatic extinguishing equipment13. An examination of a variety of fire safety systems by Ahrens derived estimates for buildings with hardwired alarms (equivalent to the current NCC requirement) of 3.9 fatalities per 1000 fires.

The influence of the proximity of an occupant to a fire is relevant to the issue of individual and societal risk. Fire statistics reflect the rate of fires, their origin and spread. NSW fire brigade data from 2003-2007 suggests up to 80% of fires in Class 2 buildings begin within a sole-occupancy unit. Victorian and US statistics indicate the rate is closer to 63%.

The individual risk to life for occupants in a sole-occupancy unit of fire origin (in a non-sprinkler protected building) can be estimated as the product of the:

• frequency of reported fire (1.6 for Class 2 buildings and 0.9 for Class 3 buildings); • fatality rate / fire for non-sprinkler protected buildings; • proportion of fatalities from fires commencing within the sole-occupancy unit; and • reduction ratio from the provision of sprinklers and / or smoke detection/alarm systems.

Based on US fire statistics, Table 2 shows the risk of fatality per annum from fire in Class 2 and 3 buildings.

13 Hall J.R., US Experience with Sprinklers National Fire Protection Association June 2013.

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Table 2 Annual risk of fatality from fire in an SOU of fire origin in Class 2 and 3 buildings

Description Frequency of fire starts / 1000 SOUs

Fatality rate / 1000 SOUs

Proportion of fatal fires within SOU

Reduction factor for fire safety system

Fatalities / annum / SOU x 10-6

Class 2 1.60 7.40 0.66 0.44 3.44

Class 3 0.9 7.3 0.84 0.44 2.43

Source: EFT Consulting 2016.

The relative individual risk is calculated by dividing the number of fatalities / annum / sole-occupancy unit by the number of occupants in the sole-occupancy unit (assumed to be 2.5).

Table 3 Individual risk to occupants of an SOU

Building description Individual risk of fatality within the SOU of fire origin / annum x 10-6

Class 2 1.38

Class 3 0.93

Source: EFT Consulting 2016.

From the above statistics, it can be seen that the individual risk of fatality from fire in non-sprinkler protected buildings differs across building types, is higher in Class 2 buildings though overall is very low.

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Injury Rate from Fire The cost of fire-related injuries impacts on occupants and the wider community in the form of medical expenses, lost productivity and a reduction in overall health and welfare.

It is difficult to quantify the number of fire related injuries occurring in Class 2 and Class 3 buildings between four and eight storeys in height. Fire and Rescue NSW research identified that on average 134 fire-related injuries have occurred in Class 2 and Class 3 buildings in NSW between 1 July 2011 and 25 March 2015.

The Report on Government Services (RoGS) gives a breakdown on the proportion of fire-related injuries in Australia and is shown in Table 4.

Table 4: Proportion of fire-related injuries in Australia

Total fire injury admissions

NSW VIC QLD WA SA TAS ACT NT AUST

2014-15 29.5% 18.5% 21.8% 13.2% 8.6% 2.6% 0.8% 5.0% 100.0%

2013-14 28.1% 17.4% 22.5% 12.3% 12.0% 2.0% 0.9% 4.8% 100.0%

2012-13 28.2% 15.5% 24.6% 13.4% 10.0% 2.0% 0.9% 5.3% 100.0%

2011-12 27.5% 19.5% 23.7% 12.0% 9.4% 2.0% 0.8% 4.9% 100.0%

2010-11 24.9% 20.9% 24.3% 12.2% 9.5% 2.3% 0.5% 5.4% 100.0%

5 Year Average

27.6% 18.4% 23.4% 12.6% 9.9% 2.2% 0.8% 5.1% 100.0%

Source: Report on Government Services (2016).

Extrapolating the NSW data with the RoGs data, the estimated total number of fire-related injuries occurring each year in Class 2 and Class 3 buildings is 455. The number of injuries occurring within the four and eight storey height range is unknown, however, is conservatively estimated to be 137. This equates to 30% of all fire-related injuries in Class 2 and Class 3 buildings14. Given the uncertainty of the number of injuries occurring nationally, this parameter is also tested through sensitivity and reports the findings of a 20% and 40% increase in the annual rate.

The Australian Institute of Health and Welfare15 reports that in 2013-14, the average length of hospital stay for all burn cases was 7 days. About 16% of hospitalised burn cases were considered high threat to life (HTTL) where the average length of stay increased to 17 days. This suggests that when injuries do occur due to the effects of fire, they are often severe and require on-going treatment and rehabilitation.

14 This estimate is based on the proportion of new Class 2 and Class 3 buildings constructed in the four and eight storey height range. 15 Australian Institute of Health and Welfare (2016) “Hospitalised burn injuries Australia” Flinders University.

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Consultation Questions:

• Do you agree with the extent of the problem?

• Are there any other characteristics not described?

Summary of International Approaches The ABCB participates in an international Inter-jurisdictional Regulatory Collaboration Committee (IRCC) that includes 18 member countries and affiliates. A comparative study of international building regulations has been conducted to determine approaches to fire safety in other jurisdictions based on a survey of IRCC members. A detailed summary can be found in Appendix A.

A common rationale for the inclusion of fire sprinkler systems in buildings was reported as the practical realities faced by fire authorities when fighting fires above certain heights. Other counties such as Norway reported mandating fire sprinklers was done in recognition of the abilities of vulnerable occupants to identify and use escape paths.

Like Australia, Scotland, Sweden, Singapore and Japan include triggers beyond a nominated height or fire compartment size. Other jurisdiction’s requirements vary according to the fire safety strategy adopted.

In Norway’s case, the decision to mandate fire sprinklers is tied to the needs of vulnerable occupants and the directive to adopt mandatory sprinkler protection supports a ‘protect in place’ strategy. In Australia, such strategies are implicit in high care settings, such as hospitals and aged-care buildings. However, strategies for building evacuation management in residential buildings will be informed by the building’s fire safety features such as the presence of an Emergency Warning and Intercommunications System (EWIS). In buildings less than 25 m in effective height, evacuation is therefore reliant on established building procedures and may include a range of responses including phased evacuation due to initial localised cues to evacuate, protect in place or full evacuation at the direction of an attending fire brigade.

The effect of fire sprinkler protection on evacuation and societal risk has been examined by EFT Consulting by undertaking risk analysis and is discussed in the unintended consequences section of this Consultation RIS.

Objective The primary objective of the NCC is to address safety and health in the design, construction and performance of buildings. The objective of the analysis in this Consultation RIS is to ensure that the DtS Provisions relating to fire safety for new Class 2 and 3 buildings constructed between four and

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eight storeys in height are proportional, the minimum necessary to achieve their objectives and the most efficient of the available alternatives16. This objective aligns with the Board’s objectives to:

• protect the lives of building occupants;

• facilitate fire brigade intervention in the event of an emergency; and

• protect adjacent property from the spread of fire and physical damage in the event of structural failure17.

16 The ABCB’s Inter-governmental agreement (IGA) requires that in determining the area and level of the requirements there is a rigorously tested rationale, the regulations are effective and proportional and there is no regulatory or non-regulatory option that would generate a higher net benefit.https://abcb.gov.au/Resources/Publications/Corporate/Inter-Governmental-Agreement

17 Relevant Performance Requirements NCC Volume One Section C, D and E.

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Options There are two options presented to decision-makers for consideration in addition to the option of retaining the status quo.

Status Quo The status quo is the default choice for decision-makers in considering alternatives to achieve the objectives. Where the incremental impacts of other options would result in more costs than benefits, or would be ineffective in addressing the problem or achieving the objectives, this Consultation RIS will conclude in favour of the status quo.

The status quo will be regarded as a baseline, as a basis to determine the incremental impacts of the other options. The current DtS Provisions relevant to this Consultation RIS are described under the status quo in Table 5.

Table 5 NCC DtS Provisions under the status quo and proposed offsets under Option 1

NCC DtS subject matter Status quo Option 1

Sprinklers (E1.5) Not required In accordance with Option 1a, 1b* or 1c*

Non-loadbearing walls around fire-isolated stairs

-/90/90 -/60/60

Penetrations in non-loadbearing walls around fire-isolated stairways and internal bounding construction (Spec C1.1 Table 3 and Part C3)

-/60/30 -/60/15

Protect window openings in bounding construction separating a path of travel to an exit along open balcony and landing (C3.11(g)(v))

Wall wetting sprinklers; or -/60/- fire windows; or -/60/- fire shutters

Not required

Distance of travel from SOU door to exit or choice of exits (D1.4(a)(i)(A))

6 m 12 m

Distance of travel to single exit serving the storey at the level of egress to a road or open space (D1.4(a)(i)(B))

20 m 30 m

Maximum distance of travel between alternative exits (D1.5(c)(i))

45 m 60 m

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NCC DtS subject matter Status quo Option 1

Internal fire hydrants (E1.3) Where the total floor area exceeds 500 m2

External hydrant or dry fire main required. Street hydrants used as ‘feed’ hydrants for suction of water to boost the dry hydrant system need only meet the flow requirement of AS 2419.1 and not the pressure requirement. Note - no concession for the FPAA101H system feed fire hydrants used for boosting are intended to provide the necessary flow rate to the fire brigade pumping appliance.

Spandrels (C2.6) A 900 mm spandrel or horizontal construction (both non-combustible and FRL of 60/60/60) is required if a window in an external wall is above another window in the storey below

No requirement

*Scope and Limitations of the FPAA 101D and FPAA101H specifications:

• Class 3 Residential care facilities are excluded. • Buildings required to have sprinkler protection to satisfy the proposed verification method CV3

are excluded. • Other classifications (e.g. Class 5 or 6) may be situated below a Class 2 or 3 building utilising a

FPAA101H system subject to: (i) the sprinkler systems hydraulically designed in accordance with the relevant hazard class

to provide an appropriate density of discharge over the assumed area of operation applicable to the hazard class specified in AS 2118.1; and

(ii) being fire separated in accordance with the NCC fire safety provisions. • Other classifications (e.g. Class 5 or 6) may be situated below or above a Class 2 or 3 building

utilising a FPAA101D system subject to the other classifications: • not exceed 25 percent of the total floor area of the building; and • being fire separated in accordance with the NCC fire safety DTS Provisions; and • not being located above the fourth storey; and • being sprinkler protected in accordance with the concessions currently permitted in clause

4.3.4 of AS 2118.4; and • being provided with end of line sprinkler monitoring also providing water supply to toilets

serving these ancillary parts of the building.

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Option 1 – Mandatory DtS Sprinkler Protection with Concessions This option will amend the NCC DtS Provisions to mandate sprinklers in new Class 2 and 3 residential buildings having a rise in storeys of four or more and less than 25 m in effective height - and allow proportional concessions (Table 5) to requirements for other fire safety measures.

Other classifications that occupy storeys in an otherwise Class 2 or 3 building would also require sprinkler protection, due to the heavy reliance on sprinklers to maintain exit pathways that pass through or pass by these other classifications. 18,

Compliance with the DtS sub options 1a, 1b, and 1c (described below) attract similar fire safety concessions. These options are intended to be introduced as a package (1a, 1b and 1c) that encompasses a range of alternative sprinkler specifications. They are provided in recognition of the limitations of the domestic system19 and the potential for buildings of mixed classification or unique configurations, which under some circumstances require alternative options. The analysis considers all options individually, before examining the aggregate impact based on the assumed uptake of alternative specifications.

Option 1a – AS 2118.1 Automatic Fire Sprinkler Systems General Requirements Amendment 1: 1999 This sub option provides for the installation of an AS 2118.1 sprinkler system in new Class 2 and 3 residential buildings having a rise in storeys of 4 or more and less than 25 m in effective height. Subject to the inclusion of sprinklers to this specification the nominated concessions to other DtS Provisions listed in Table 5 above would apply.

Option 1b – FPAA 101D Sprinkler System Design and Installation - Domestic Water Supply This sub option provides for the installation of a FPAA 101D sprinkler system in new Class 2 and 3 residential buildings having a rise in storeys of 4 or more and less than 25 m in effective height, subject to the limitations listed under Table 5. In addition, subject to the inclusion of sprinklers to this specification the nominated concessions to other DtS Provisions listed in Table 5 above would apply.

Option 1c – FPAA 101H Sprinkler System Design and Installation - Hydrant Water Supply This sub option provides for the installation of a FPAA 101H sprinkler system in new Class 2 and 3 residential buildings having a rise in storeys of 4 or more and less than 25 m in effective height.

18 Analysis conducted recognises the potential for other uses, such as car parking, office space or retail (Class 7, Class 5 or Class 6 buildings) in an otherwise Class 2 or Class 3 building. It concludes that due to the heavy reliance on a sprinklers to maintain exit pathways that pass through or pass by these uses, it is critical these areas are also sprinkler protected. EFT Consulting (2017) 2575-1 pg. 25 19 For uses that occupy more than 25% of the building’s total floor area on other levels (below) Class 2 or Class 3 buildings, or when located above fourth storey an FPAA 101D system must not be used.

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Subject to the inclusion of sprinklers to this specification the nominated concessions to other DtS Provisions listed in Table 5 above would apply.

Option 2 – Non-mandatory Sprinkler Protection This option would amend the current DtS Provisions to include as a new (alternative DtS) option to sprinkler protect Class 2 and 3 buildings below 25 m in effective height to AS 2118.1, FPAA 101D and FPAA 101H, with proportional concessions to other fire safety features (offsets) in accordance with Options 1a and 1b and 1c and any conditions described in Table 5.

Under this option, the current DtS Provisions (no sprinkler protection) would be retained as an option to meet the NCC Performance Requirements relating to fire safety.

Consultation Question: • Are there other feasible options that could address the problem?

Impact Analysis This section provides an assessment of the incremental costs and benefits associated with each option, compared with the status quo baseline. Comments by stakeholders on all aspects of this impact analysis are welcome.

Groups Impacted by the Options This Consultation RIS identifies the following impacted stakeholder groups:

• Individuals, e.g. owners and occupiers of dwellings in new Class 2 and 3 buildings constructed between four and eight storeys in height;

• businesses, e.g. developers, builders, building practitioners and the fire safety industry; and • government, e.g. State and Territory building authorities.

Assumptions and Parameters The following assumptions and parameters have been used in preparation of this impact analysis:

1. The annual number of Class 2 and 3 building approvals is not collected nationally. Victoria collects data on the number of approvals issued each year. It is known through ABS comparisons that Victoria accounts for approximately 25% of all building activity occurring annually.

This has been verified in the following ways:

• Value of non-residential work completed 2003-2013 - Victoria accounted for 24.7% of all activity (Catalogue 8752.0 Tables 71 and 72).

• The number of other residential units completed 2003-2013 - Victoria accounted for 25.9% of all activity (ABS Catalogue 8752.0 Tables 37 and 39).

The estimated national number of Class 2 and 3 buildings constructed between 3 and 8 storeys in height approved annually is shown in Table 6.

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Table 6 – Number of new Class 2 and 3 buildings approved annually between 4 and 8 storeys in height.

Building Class Number

Class 2 688

Class 320 9

2. Based on an analysis of VBA approval data, two representative building sizes for Class 2 and 3 buildings constructed between the 4 and 8 storey height were identified; a multi-storey residential building with an average floor plate of 900 m2 per storey, and a larger multi-storey residential building with an average floor plate of 1200 m2. For the purposes of this analysis, it has been assumed that 80% of buildings impacted by the option are 900 m2 floor plate buildings and 20% are 1200 m2 floor plate buildings. Sensitivity analysis has been undertaken to test the volatility of this assumption on the outcomes of this analysis.

3. The analysis by EFT Consulting21 determined that where a Class 2 or 3 building is located above another class of building there is a need to sprinkler protect these other classes. Quantity surveying by Donald Cant Watts Corke (DCWC) suggests the practice of locating retail (Class 6 buildings) and offices (Class 5 buildings) below Class 2 or 3 buildings is not representative in buildings of this size.

4. Ongoing maintenance and replacement costs were investigated as part of this analysis. Australian Standard AS 1851: 2012 – ‘Routine service of fire protection systems and equipment’ establishes the frequency intervals for carrying out regular servicing of fire protection systems and equipment. As maintenance is a state and territory function, this standard is not referenced in the NCC, and not uniformly adopted by states and territories in maintenance legislation. This analysis assumes that the frequency intervals similar to those outlined in the standard are either obligations or applied voluntarily. For all systems with the exception of FPAA 101D, based on advice from FPAA, the analysis assumes an annual visual inspection.

Consultation Question: • Do you agree with the assumptions used to inform the impact analysis?

Costs This section considers the impacts of introducing three new DtS Solutions for sprinklers in new Class 2 and 3 buildings:

• Option 1a – AS 2118.1 Automatic fire sprinkler systems: General Requirements Amendment 1: 1999

20 Preliminary analysis by the ABCB suggests the majority of new Class 3 buildings are being constructed outside of the 4 and 8 storey height range. 21 EFT Consulting 2575-1 (2017) Cost Effective Automatic Fire Sprinkler Protection for Class 2 and 3 Buildings. Pg. 52.

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• Option 1b – FPAA 101D Sprinkler System Design and Installation – Domestic Water Supply (See Appendix B)

• Option 1c – FPAA 101H Sprinkler System Design and Installation – Hydrant Water Supply (See Appendix C)

Option 1 The costs and benefits of this option are categorised by building classification, then by technology. The range of solutions being considered is intended to provide industry with options in meeting the new obligations.

The costs of each solution are informed by two reports:

• Report on the Cost Implications of Fire Sprinklers in Class 2 and 3 Buildings – Donald Cant Watts Corke (DCWC).

• Cost Effective Automatic Fire Sprinkler Protection for Class 2 and 3 Buildings – EFT Consulting.

Both of these documents can be found on the ABCB website.

Class 2 Buildings DCWC were engaged to undertake a quantity surveying exercise to determine the cost of each sprinkler option applied to a range of representative Class 2 and 3 buildings. Two representative Class 2 apartment buildings were assessed, and these costs have been used to inform the analysis.

• Building A – An apartment building with an average floor plate area of 900 m2 over six storeys with a basement carpark and designed and constructed under the current NCC DtS Provisions. It was assumed to contain 48 two bedroom sole-occupancy units and a carpark containing over 40 car spaces.

• Building B – An apartment building with an average floor plate area of 1200 m2 over six storeys with a basement carpark and designed and constructed under the current NCC DtS Provisions. It was assumed to contain 72 two bedroom sole-occupancy units and a carpark containing over 40 car spaces.

Building A – 900 m2 Class 2 building

The cost of each option applied to a 900 m2 average floor plate Class 2 building is shown in Table 7.

Table 7 - Class 2 – 900 m2 floor plate area: Construction costs

Class 2 - Average

Cost (per m2)

Cost (per building)

Total Industry Cost

Annual Industry Saving -

Construction Costs

Present Value Industry Saving -

Construction Cost

Status quo $2,602 $14,050,800 $7,727,940,000 $0 $0

AS 2118.1 $2,605 $14,067,000 $7,736,850,000 ($8,910,000) ($66,960,719)

FPAA 101D $2,580 $13,932,000 $7,662,600,000 $65,340,000 $491,045,275

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Class 2 - Average

Cost (per m2)

Cost (per building)

Total Industry Cost

Annual Industry Saving -

Construction Costs

Present Value Industry Saving -

Construction Cost

FPAA 101H $2,600 $14,040,000 $7,722,000,000 $5,940,000 $44,640,480

Notes:

1. Present Values have been calculated using a 7% discount rate over 10 years. 2. Bracketed values represent negative savings (cost).

Two of the three options demonstrate cost savings when compared with the status quo baseline, ranging from $44.6 million for the FPA 101H option to $491 million for the FPAA 101D option. AS 2118.1 is more costly when compared with the current DtS Solution and demonstrates a cost of $66.9 million in Present Value terms.

As maintenance is expected to be undertaken routinely, these costs have also been considered over the life of the building and are shown in Table 8.

Table 8 - Class 2 – 900 m2 floor plate area: Maintenance costs

Class 2 - Average

Annual Maintenance Cost

(per Building) Total Industry

Maintenance Cost Present Value Industry

Maintenance Cost

AS 2118.1 $6,119 $3,365,450 $360,790,545

FPAA 101D $719 $395,450 $42,393,921

FPAA 101H $3,060 $1,683,000 $180,424,753

Notes:

1. Present Values have been calculated using a 7% discount rate over 40 years.

In Present Value terms, maintenance costs range from $42.4 million for the FPAA 101D option to $360 million for the AS 2118.1 option when compared with the status quo baseline. Assumed maintenance schedules and costs can be found in the DCWC report.

The total impacts to Class 2 buildings with an average floor plate area of 900 m2 is shown in Table 9.

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Table 9 - Class 2 – 900 m2 floor plate area: Total impact

Class 2 - Average

Present Value Industry Saving

Present Value Maintenance Total Saving

Status quo $0 $0 $0

AS 2118.1 -$66,960,719 -$360,790,545 ($427,751,264)

FPAA 101D $491,045,275 -$42,393,921 $448,651,354

FPAA 101H $44,640,480 -$180,424,753 ($135,784,273)

Notes: 1. Present Values have been calculated using a 7% discount rate over 10 years. 2. Bracketed values represent negative savings (cost)

Comparing the cost of installation and maintenance of sprinklers with the current DtS Solution, the AS 2118.1 and FPA 101H option demonstrate net costs for new Class 2 buildings with an average floor plate area of 900 m2. The FPAA 101D option demonstrates large cost savings of $449 million in Present Value terms.

Building B – 1200 m2 Class 2 building

The cost of each option applied to a 1200 m2 average floor plate Class 2 building is shown in Table 10.

Table 10 - Class 2 – 1200 m2 floor plate area: Construction costs

Class 2 - Large

Cost (per m2)

Cost (per building)

Total Industry Cost

Annual Industry Saving

Present Value Industry Saving -

Construction Cost

Status quo $2,602 $18,734,400 $2,585,347,200 $0 $0

AS 2118.1 $2,616 $18,835,200 $2,599,257,600 ($13,910,400) ($104,539,887)

FPAA 101D $2,594 $18,676,800 $2,577,398,400 $7,948,800 $59,737,078

FPAA 101H $2,612 $18,806,400 $2,595,283,200 ($9,936,000) ($74,671,348)

Notes:

1. Present Values have been calculated using a 7% discount rate over 10 years. 2. Bracketed values represent negative savings (cost)

Two of the three options demonstrate a net cost when compared with the status quo baseline, ranging from $74.7 million for the FPA 101H option to $104.5 million for the AS 2118.1 option. FPAA 101D is more cost effective when compared with the status quo, demonstrating a cost saving of $59.7 million in Present Value terms.

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In Present Value terms, maintenance costs for the 1200 m2 floor plate Class 2 building range from a cost of $13.3 million for the FPAA 101D option to $94.9 million for the AS 2118.1 option when compared with the status quo baseline. These costs are shown in Table 11.

Table 11 - Class 2 – 1200 m2 floor plate area: Maintenance costs

Class 2 - Large

Annual Maintenance Cost

(per building) Total Industry

Maintenance Cost Present Value Industry

Maintenance Cost

AS 2118.1 $6,415 $885,270 $94,904,707

FPAA 101D $896 $123,648 $13,255,591

FPAA 101H $3,207 $442,566 $47,444,956

Notes:

1. Present Values have been calculated using a 7% discount rate over 40 years.

Comparing the cost of installation and maintenance of sprinklers, the total impact for Class 2 buildings with an average floor plate of 1200 m2 range from a cost of $199.4 million to a saving of $46.8 million in Present Value terms. Both the AS 2118.1 option and the FPAA 101H option demonstrate large net costs when compared with the current DtS Solution. This is shown in Table 12.

Table 12 - Class 2 – 1200 m2 floor plate area: Total impact

Class 2 - Large Present Value

Industry Saving Present Value Maintenance Total Saving

Status quo $0 $0 $0

AS 2118.1 ($104,539,887) ($94,904,707) ($199,444,594)

FPAA 101D $59,737,078 ($13,255,591) $46,481,487

FPAA 101H ($74,671,348) ($47,444,956) ($122,116,304)

Notes: 1. Present Values have been calculated using a 7% discount rate over 10 years. 2. Bracketed values represent negative savings (cost)

The total impact for all new Class 2 buildings under each solution is shown in Table 13.

Table 13 - Total savings – Class 2 buildings

Specification Class 2 - Average Class 2 - Large Total Saving

AS 2118.1 ($427,751,264) ($199,444,594) ($627,195,858)

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Specification Class 2 - Average Class 2 - Large Total Saving

FPAA 101D $448,651,354 $46,481,487 $495,132,841

FPAA 101H ($135,784,273) ($122,116,304) ($257,900,577)

Notes: Bracketed values represent negative savings (cost)

For new Class 2 buildings, FPAA 101D clearly demonstrates a significant cost saving to industry when compared with the current DtS Provisions. As the FPAA 101H and AS 2118.1 options demonstrate significant net costs, this RIS will consider them against the savings resulting from the uptake of the FPAA 101D option.

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Class 3 Buildings Two representative Class 3 buildings were costed by DCWC:

• Building A – A Class 3 building with an average floor plate area of 900 m2 over six storeys with a basement carpark and designed and constructed under the current NCC DtS Provisions. It was assumed to contain 96 one bedroom sole-occupancy units.

• Building B – A Class 3 building with an average floor plate area of 1200 m2 of six storeys with a basement carpark and designed and constructed under the current NCC DtS Provisions. It was assumed to contain 144 one bedroom sole-occupancy units.

Building A – 900 m2 Class 3 building

The cost of each option applied to a 900 m2 average floor plate Class 3 building is shown in Table 14.

Table 14 - Class 3 – 900 m2 floor plate area: Construction costs

Class 3 - Average Cost (per m2) Cost (per building) Total Industry Cost

Annual Industry Saving

Present Value Industry Saving -

Construction Cost

Status quo $3,472 $18,748,800 $74,995,200 $0 $0

AS 2118.1 $3,476 $18,770,400 $75,081,600 ($86,400) ($649,316)

FPAA 101D $3,453 $18,646,200 $74,584,800 $410,400 $3,084,251

FPAA 101H $3,454 $18,651,600 $74,606,400 $388,800 $2,921,922

Notes:

1. Present Values have been calculated using a 7% discount rate over 10 years. 2. Bracketed values represent negative savings (cost)

Two of the three options demonstrate cost savings when compared with the status quo baseline, ranging from $2.9 million for the FPA 101H option to $3.1 million for the FPAA 101D option. AS 2118.1 is more costly when compared with the current DtS Solution and demonstrates a small cost of $650,000 in Present Value terms.

In Present Value terms, maintenance costs for the 900 m2 floor plate Class 3 building range from a cost of $378,645 for the FPAA 101D option to $2.8 million for the AS 2118.1 option when compared with the status quo baseline. These costs are shown in Table 15.

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Table 15 - Class 3 – 900 m2 floor plate area: Maintenance costs

Class 3 - Average Annual Maintenance

Cost (per building) Total Industry

Maintenance Cost Present Value Industry

Maintenance Cost

AS 2118.1 $6,415 $25,660 $2,750,861

FPAA 101D $883 $3,532 $378,645

FPAA 101H $3,207 $12,828 $1,375,216

Notes:

1. Present Values have been calculated using a 7% discount rate over 40 years.

Comparing the cost of installation and maintenance of sprinklers, the total impact for Class 3 buildings with an average floor plate of 900 m2 range from a cost of $3.4 million to a saving of $2.7 million in Present Value terms. Both the FPAA 101D and FPAA 101H demonstrate cost savings while the AS 2188.1 option demonstrates a cost when compared to the status quo baseline. The impacts are shown in Table 16.

Table 16 - Class 3 – 900 m2 floor plate area: Total impact

Class 3 - Average Present Value Industry

Saving Present Value Maintenance Total Saving

Status quo $0 $0 $0

AS 2118.1 ($649,316) ($2,750,861) ($3,400,177)

FPAA 101D $3,084,251 ($378,645) $2,705,606

FPAA 101H $2,921,922 ($1,375,216) $1,546,706

Notes: 1. Present Values have been calculated using a 7% discount rate over 10 years. 2. Bracketed values represent negative savings (cost).

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Building B – 1200 m2 floor plate Class 3 building

The cost of each option applied to a 1200 m2 average floor plate Class 3 building is shown in Table 17.

Table 17 - Class 3 – 1200 m2 floor area: Construction costs

Class 3 - Large

Cost (per m2)

Cost (per building)

Total Industry Cost

Annual Industry Saving

Present Value Industry Saving -

Construction Cost

Status quo $3,472 $24,998,400 $124,992,000 $0 $0

AS 2118.1 $3,488 $25,113,600 $125,568,000 ($576,000) ($4,328,774)

FPAA 101D $3,467 $24,962,400 $124,812,000 $180,000 $1,352,742

FPAA 101H $3,480 $25,056,000 $125,280,000 ($288,000) ($2,164,387)

Notes:

1. Present Values have been calculated using a 7% discount rate over 10 years. 2. Bracketed values represent negative savings (cost)

Two of the three options demonstrate increases in construction costs when compared to the status quo baseline, ranging from $2.2 million to $4.3 million in Present Value terms. FPAA 101D demonstrates a small saving of $1.4 million in Present Value terms.

In Present Value terms, maintenance costs for the 1200 m2 floor plate Class 3 building range from a cost of $517,000 for the FPAA 101D option to $3.6 million for the AS 2118.1 option when compared with the status quo baseline. These costs are shown in Table 18.

Table 18 - Class 3 – 1200 m2 floor plate area: Maintenance costs

Class 3 - Large

Annual Maintenance Cost

(per building) Total Industry

Maintenance Cost Present Value Industry

Maintenance Cost

AS 2118.1 $6,710 $33,550 $3,596,703

FPAA 101D $965 $4,825 $517,261

FPAA 101H $3,355 $16,775 $1,798,351

Notes:

1. Present Values have been calculated using a 7% discount rate over 40 years. 2. Bracketed values represent negative savings (cost).

Comparing the cost of installation and maintenance of sprinklers, the total impact for Class 3 buildings with an average floor plate of 1200 m2 range from a cost of $7.9 million to a saving of $835,000 in Present Value terms. Both the FPAA 101H and AS 2118.1 options demonstrate costs while the FPAA

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101D option demonstrates a cost saving when compared to the status quo baseline. The impacts are shown in Table 19.

Table 19 - Class 3 – 1200 m2 floor plate area: Total impact

Class 3 - Large Present Value

Industry Saving Present Value Maintenance Total Saving

Status quo $0 $0 $0

AS 2118.1 ($4,328,774) ($3,596,703) ($7,925,477)

FPAA 101D $1,352,742 ($517,261) $835,481

FPAA 101H ($2,164,387) ($1,798,351) ($3,962,738)

Notes: 1. Present Values have been calculated using a 7% discount rate over 10 years. 2. Bracketed values represent negative savings (cost)

The total impact for Class 3 buildings under each solution is shown in Table 20.

Table 20 - Total savings – Class 3 buildings

Specification Class 3 - Average Class 3 - Large Total - Class 3

AS 2118.1 ($3,400,177) ($7,925,477) ($11,325,654)

FPAA 101D $2,705,606 $835,481 $3,541,087

FPAA 101H $1,546,706 ($3,962,738) ($2,416,032)

For new Class 3 buildings, FPAA 101D clearly demonstrates a cost saving when compared with the current DtS Provisions. As the FPAA 101H and AS 2118.1 options demonstrate significant net costs, this RIS will consider them against the savings resulting from the uptake of the FPAA 101D option.

Total Construction Costs and Maintenance The total impacts of Option 1 are shown in Table 21.

Table 21 – Present Value impacts – Construction costs and maintenance

Specification Class 2 Class 3 Total

AS 2118 ($627,195,858) ($11,325,654) ($638,521,512)

FPAA 101D $495,132,841 $3,541,087 $498,673,928

FPAA 101H ($257,900,577) ($2,416,032) ($260,316,609)

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FPAA 101D is the only option tested that demonstrates a combined reduction in capital costs and maintenance costs. As the other options demonstrate increases in both construction costs and maintenance costs, these will need to be considered against the other benefits described in the ‘Benefits’ section of this Consultation RIS.

Consultation Questions: • Do you agree with the information on costs that could be used to inform the RIS. If so,

provide details?

• Do you have any other data or information that would help inform the development of the final cost analysis?

Benefits There are three primary sources of benefits resulting from Option 1. These are:

• Avoided fatalities - although already infrequent, the number of fatalities from multi-storey residential fires is expected to fall.

• Avoided injuries – the number of injuries is also expected to fall at the assumed same rate of fatalities.

• Avoided property damage – the cost of property damage as a result of fire will reduce given the effectiveness of sprinkler systems to control fire in its early stages.

Avoided Fatalities The number of avoided fatalities that can be attributed to Option 1 is influenced by the current rate of fatality in new Class 2 and 3 buildings and the rate at which fatalities can decline with the presence of sprinkler systems.

Risk Reduction A fire safety engineering analysis was undertaken by EFT Consulting to compare the risk levels associated with each option when compared to an NCC DtS building and the results are shown in Table 22. It should be acknowledged that the small difference in risk between options is a result of the degree of system coverage.

Table 22: Comparative risk levels per specification

Specification Risk Level Fatalities per 1000 Fire Starts

Reduction in Risk Level (Percentage)

Current NCC DtS Solution 3.9 x 10-6 3.9 -

FPAA 101D Sprinkler System Design and

Installation – Domestic Water Supply

1.3 x 10-6 1.3 67%

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Specification Risk Level Fatalities per 1000 Fire Starts

Reduction in Risk Level (Percentage)

FPAA 101H Sprinkler System Design and

Installation – Hydrant Water Supply

1.1 x 10-6 1.1 72%

AS 2118.1 Sprinkler System Design and Installation

1.1 x 10 1.1 72%

As demonstrated by the fire engineering analysis, the effectiveness of sprinklers in reducing fatalities within sole-occupancy units is estimated to range from 67% and 72% depending on the adopted system. In this regard, all options demonstrate a high degree of effectiveness in reducing the current rate of fatality when compared with the current DtS Provisions.

Estimated Benefits The NCIS identify an average of 2.9 deaths per year between 2000 and 2015 totalling 46 fatalities, where the deceased died as a result of a fire in a multi-storey residential building. The number of fatalities by building height is shown in Table 23.

Table 23: Fire-related fatalities (2000-2015) in multi-storey buildings by number of storeys

Number of Storeys Fatalities

2 23

3 3

7 2

Unknown* 18

Total 46

Note: The incidence of “Unknown” indicates that a clear reference to the building having multiple storeys was made in the coronial reports, however, the exact number of storeys was not able to be identified.

The number of fatalities occurring in Class 2 and 3 buildings between four and eight storeys in height is estimated to be 3.3 fatalities over 16 years, or an annual average fatality rate of 0.21.22 The estimated benefits associated with reducing fire fatalities as a result of requiring sprinklers is shown in Table 24.

Table 24: Benefits from avoidable fatalities

Factor Total

Total fatalities 2000 - 2015 46

22 The four and eight storey cohort is 7.6% of all fatalities and the remainder from the ‘unknown’ category are proportionately distributed.

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Factor Total

Total fatalities occurring in 4 – 8 storey height range 3.3

Annual fatality rate occurring in 4 – 8 storey height range 0.21

Effectiveness of sprinklers on the rate of fatality (72%) 0.15

Rate of avoidable fatalities through changes to the NCC (2%) 0.003

Value of Statistical Life $4.2 million

Total Annual Benefit $12,420

Present Value Benefits $1,331,477

Notes: Present Values have been calculated using a 7% discount rate over 40 years.

The total benefits resulting from a reduction in fatalities is estimated to be $1,331,477 in Present Value terms.

Consultation Questions:

• Do you agree with the information provided on fatalities?

• Do you have any other data that would help inform the development of the final analysis on fatalities?

Injuries Table 25 shows the estimated total annual cost of fire-related injuries occurring in Class 2 and 3 buildings between four and eight storeys in height. As described in the problem section, where fire injuries occur, they are moderate to severe injuries and often require on-going treatment and rehabilitation. The costs in Table 25 are based on the Australian estimates for Quality Adjusted Life Years (QALY) and take into account productivity, welfare and medical costs of fire-related injuries.

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Table 25: Total cost of fire-related injuries each year

Incidence Avoided

Length of Hospitalisation

(days)

Disability Weight

Health Cost per Case

Medical Cost per

Case

Total Cost per Case

Total Incidence

Total Cost

Moderate 7 0.172 $618 $13,300 $13,918 115 $1,600,543

Severe 17 0.172 $644,243 $32,300 $676,543 22 $14,883,950

Total Cost - - - - - 137 $16,484,494

Notes:

1. Length of hospitalisation: AIHW (2016) found that the mean length of stay (MLOS) was 7 days for all hospitalised burn cases in 2013 – 2014. The MLOS was much higher for high threat to life cases at 17 days which accounted for 16% of all burns.23

2. Disability Weight: The disability weight index provides weight according to the severity of the injury. C. Mathers, T. Vos, C. Stevenson “The Burden of Disease and Injury in Australia (1999) AIHW Canberra. For fire-related burns the disability weight is reported as 0.172.

3. Health cost per injury: Measures the amount the community is willing to pay to avoid an adverse health outcome. It is derived from the Quality of Adjusted Life Year (QALY) in Australia which is $151,000 (Abelson, 2007). Adjusted for 2016 prices, this amounts to $187,280. Divided by the number of days in a year, a QALD is $513. Hence the cost of a moderate fire-related injury in terms of health costs is $513 x 7 day x 0.172 = $618.

4. Medical cost per injury: Medical costs have been estimated using the National Hospital Cost Data Collection Report (2016) prepared by the Independent Hospital Pricing Authority (IHPA). The average cost per night was $1900 in the 2014-2015 year. This cost has been multiplied by the length of stay based on the severity of the burn, e.g. the medical cost associated with a moderate burn is estimated to be $1,900 x 7 days = $13,300.

In line with the estimated impact of the NCC on all building stock, the change would impact an estimated 2% of buildings. Assuming the same rate of effectiveness in reducing injuries as that of fatalities (72%), the total avoided injury cost is calculated to be $237,377 or $25,447,792 in Present Value terms under Option 1.24 That is 72% (effectiveness) of 2% (impact of new buildings) of $16,484,494 (total cost of injuries) each year.

Consultation Questions:

• Do you agree with the information provided on injuries?

• Do you have any other data that would help inform the analysis on injuries?

23 AIHW: Pointer S & Tovell A. (2016) “Hospitalised burn injuries, Australia 2013 – 2014” 24 The Present Value saving of avoiding injuries has been calculated using a 7% discount rate over 40 years.

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Avoided Property Loss There are some difficulties associated with quantifying property damage arising from fire-related incidents. Fires may not be reported and homes may not be insured, in which case the property damage is not recorded for statistical purposes.

Smoke and fire-related damage can also result in loss of personal possessions, essential documents and valuables that resist complete quantification.

The total cost of fire-related property damage and the expected annual avoidable costs from installing sprinklers is shown in Table 26.

Table 26: Total cost of fire-related property damage each year

State Percentage of Fires Cost of Fire Avoidable Costs Present Value

NSW 36% $17,245,285 $124,166 $13,380,879

VIC 30% $14,741,857 $106,141 $11,150,732

QLD 14% $6,691,427 $48,178 $5,203,675

WA 7% $3,354,346 $24,151 $2,601,838

SA 8% $3,637,986 $26,193 $2,973,529

TAS 3% $1,556,318 $11,205 $1,115,073

ACT 1% $589,477 $4,244 $371,691

NT 1% $337,901 $2,433 $371,691

AUS 100% $48,154,596 $346,713 $37,169,107

Notes: 1. Information has been sourced from unpublished AFAC data and extrapolated using RoGS. 2. Present Values have been calculated using a 7% discount rate over 40 years. 3. The avoidable costs are based on the proportion of new construction compared with the existing stock (2%).

Assuming the same effectiveness of reducing injuries and fatalities, the benefits of avoiding fire-related property damage from the installation of sprinklers is $37,169,107 in Present Value terms.

Consultation Questions:

• Do you agree with the information provided on property loss?

• Do you agree with the assumed effectiveness of reducing property damage would be the same as injuries and fatalities?

• Do you have any other data that would help inform the analysis on property loss?

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Comparative Impacts of Each Specification The total impacts resulting from each specification are presented in Table 27.

Table 27: Total savings under alternative specifications

Present Values AS 2118.1 FPAA 101D FPA 101H

Construction and maintenance impacts

($638,521,512) $498,673,928 ($260,316,609)

Total Avoidable Injuries $25,447,792 $23,680,561 $25,447,792

Total Avoidable Fatalities $1,331,477 1,267,047 $1,331,477

Avoidable Property Loss $37,169,107 $34,587,951 $37,169,107

Total ($611,742,243) $558,209,487 ($233,537,340)

Note: bracketed costs are negative savings (costs).

As shown in Table 27, the individual impacts of each specification range significantly from a net cost of $611.7 million for the AS 2118.1 option to a net saving of $558.2 million for the FPAA 101D option in Present Value terms. Due to the large variation in outcomes depending on which specification is used, these results should be considered in conjunction with the expected uptake of each technology.

Uptake of Alternative Sprinkler Specifications The aggregate impact of the options will be dependent on the rate at which all specifications are adopted, as not all specifications assessed generate a net benefit in their own right. This analysis considers the aggregate impacts for both options based on the expected uptake of technology. Stakeholders are encouraged to provide advice as to whether these estimates are reasonable.

Assumptions and Parameters The degree to which each specification will be selected in practice is not known with certainty. However a central case is assessed that is based on the following assumptions:

1. Designers will apply a top down approach to system design – selecting a system on its ability to serve the proposed design, based on the limitations of the standard. These limitations may depend on the: • availability of materials and skilled labour; • familiarity and recognition of a system; and • building characteristics including floor area, compartment sizes and inclusion of other

classifications and their location within a building25.

25 Discussed in EFT Consulting 2575 -1 pg.25 and 52.

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2. Individual specification costs suggest there would be a strong preference for the domestic specification where the limitations of the system are not exceeded and the configuration provides the opportunity to reduce the number of fire-isolated stairs. This is based on the specification being shown to be cost-effective when compared to the current DtS Provisions. The limitations of the domestic specification include-

• other classifications (eg Class 5 or 6) being situated below or above a Class 2 or 3 building utilising a FPAA101D system and:

• not exceed 25 percent of the total floor area of the building; and • are fire separated in accordance with the NCC fire safety DTS Provisions; and • not being located above the fourth storey; and • being sprinkler protected in accordance with the concessions currently permitted in clause

4.3.4 of AS 2118.4; and • being provided with end of line sprinkler monitoring also providing water supply to toilets

serving these ancillary parts of the building.

3. Building configurations assessed are selected as being representative (average). That is to say, designs using the FPAA 101D specification are assumed to be in the majority.

Therefore, the analysis applies the following proportions informed by the individual costs for the purposes of estimating an aggregate approach. Sensitivity testing is then used to assess the potential influence of these assumptions on outcomes:

Under Option 1, of Class 2 and 3 buildings between four and eight storeys in height: • 60% will adopt FPAA 101D (Domestic specification) • 30% will adopt FPAA H101H (Hydrant specification) • 10% will adopt AS 2118.1.

Under Option 2, of Class 2 and Class 3 buildings between four and eight storeys in height:

• 60% will adopt FPAA 101D (Domestic system) • 40% will revert to current DtS (status quo).

The results of this assessment are shown in Tables 28 and 29.

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Option 1

Table 28 Total Net Present Value of Option 1 - Aggregate estimate

DtS AS 2118.1 FPAA 101D FPAA 101H Option 1

0% 10% 60% 30% $203,690,265.90

Discussion Under Option 1, life safety and property protection benefits accrue in all buildings. These contribute in addition to savings in construction costs arising as a result of a combination of factors, relative to the status quo, and include the following:

• Lower construction costs from removal of a fire-isolated stair through a concession for increased travel distances26.

• Lower capital (material) costs associated with new technology for the FPAA 101D and FPAA 101H specifications

• Lower maintenance cost assumptions as a result of system design of the FPAA 101 D specification.

Under the conditions described above, this option presents moderate savings in Class 2 and Class 3 buildings between four and eight storeys where the FPAA 101D specification can be used. Due to some uncertainty with the expected uptake of each technology, an alternative uptake rate has been tested under sensitivity analysis.

Option 2

Option 2 would include, as an option, compliance with AS 2118.1, FPAA 101H and FPAA 101D while maintaining the current DtS Solution for compliance. This option has the potential to harness the benefits of Option 1, where industry identifies it as cost effective to do so, while minimising impacts on buildings and the industry in other circumstances, such as a result of the following:

• Unique building configurations, or mixed use classifications. • Water supply or industry capability27. • Existing infrastructure in mixed-use buildings.

Option 2 assumes the uptake of the FPAA101 D (domestic) specification is consistent with Option 1 (60%) in recognition that it will be used where it can be, assumed to be in the majority of circumstances. Where FPAA101 D is unable to be used, this option assumes that building practitioners would not opt for a higher cost technology, but rather continue using the current DtS Provisions to

26 This value does not include gains in net lettable area. 27 AFAC/FPAA proposal notes that mandating the installation of sprinklers would lead to higher demand on experienced trades than could likely be met, particularly in regional areas.

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achieve compliance. In these circumstances, the current DtS Provisions would be the most cost effective solution.

Hence, the costs and benefits under Option 2 reflect the assumption that industry will not adopt a higher cost specification voluntarily in circumstances where it is not cost effective to do so. This has the effect of reducing the benefits from life safety and property protection proportionally to the uptake of alternatives to FPAA 101D, and decreasing costs relative to the efficiency of the alternatives. This is shown in Table 29.

Table 29 Total Net Present Value of Option 2 – Aggregate estimate

DtS AS 2118.1 FPAA 101D FPAA 101H Option 2

40% 0% 60% 0% $311,111,468.60

This option presents moderate net saving in Class 2 and 3 buildings between four and eight storeys.

It is intended that feedback received on the consultation questions including those below will inform further examination of this option in the Final Decision RIS.

Consultation Questions:

• Do you have any comment on the ability of industry to meet the demand for sprinkler protection in four to eight storey Class 2 and Class 3 buildings that are more than 3 storeys and less than 25 m in effective height?

• Are you aware of other information that would affect the uptake of alternative specifications 1a, 1b or 1c under Option 1 (mandatory sprinkler protection) or Option 2 (voluntary sprinkler protection)?

• Are the building types used in the RIS representative of common Class 2 and 3 buildings within the affected range? Do you have data that can inform these assumptions?

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Sensitivity Analysis This section examines the sensitivity of the quantitative analysis to variations in key assumptions underpinning the aggregate gross impact analysis. The sensitivity analysis has been conducted on the following areas noting the following:

• A real discount rate of 7% has been used in the quantitative analysis, and sensitivity will be tested from a lower bound of 3% to an upper bound of 11%.

• Construction costs may vary between States and Territories. The sensitivity analysis will test a variance of ±10%.

• The approval rate of small and large size Class 2 buildings may vary. The sensitivity analysis will test a variance of ±10%.

• Not all buildings will be capable of meeting the requirements of the FPAA 101D option. As such, the analysis may be sensitive to the uptake of the option and the sensitivity analysis will test a ±20% variation.

• The rate of injury and fatality will also be tested and the analysis will apply a high (20% increase) and very high (40% increase) to the results.

Table 30 shows the outcomes of the sensitivity analysis of each varied parameter on the Present Value of the options.

Table 30: Sensitivity testing of outcomes

Parameter Option 1 Option 2 Net Present Value Benefits

of Option 2

Discount Rate Low (3%) $156,774,571 $346,345,953 $189,571,382

Discount Rate High (11%) $204,125,702 $276,382,397 $72,256,696

Construction Costs Low (-10%) $187,964,544 $281,191,033 $93,226489

Construction Costs High (+10%) $219,415,988 $341,031,904 $121,615,916

New Building Stock Composition 70% - 30% $167,907,540 $292,346,235 $124,438,695

New Building Stock Composition 90% - 10% $239,999,209 $333,152,662 $90,153,453

Specification uptake FPAA 101D Low (-20%) $45,340,901 $187,562,459 $142,221,558

Specification uptake FPAA 101D High (+20%) $362,039,631 $434,660,478 $72,620,847

Rate of Injury and Fatality High (+20%) $208,826,320 $312,109,373 $103,283,053

Rate of Injury and Fatality Very High (+40%) $213,362,375 $313,107,277 $99,144,902

All parameters tested under the sensitivity analysis demonstrated moderate net benefits.

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Unintended Consequences A potential unintended consequence that could result from the inclusion of measures to decrease individual risk (within a sole-occupancy unit) is the potential impact on societal risk arising from providing concessions to current DTS Provisions.

The fire engineering analysis concluded that for the buildings modelled, using the proposed sprinkler options, the societal risk was consistently lower than an equivalent building under the status quo with the same building population.

Other classifications were also acknowledged as being potential components of an otherwise Class 2 or 3 building. The risks associated with evacuation using an exit that passed through or passed by these parts were considered significant enough to require these ancillary uses to also be sprinkler protected, which is reflected by both specifications.

The resulting conclusions of the fire engineering analysis found that all options being considered by this Consultation RIS did not increase the societal risk of occupants in buildings, but on balance, reduced this risk.

Business Compliance Cost Industry will incur a one-off education cost to become aware of the proposed NCC DtS Provisions for sprinklers, and to reflect how to respond to them and their objectives. The ABCB seeks to effectively communicate changes to the NCC, and hence minimise education costs, by holding seminars in each jurisdiction to explain the changes. The building industry takes time and effort to become familiar with the changes each year, including through strong participation in the ABCB seminars (about half a day). As an indication of the size of the one-off education costs, the incremental contribution of the sprinkler provisions would be a small part of this education exercise, around 10 minutes in a half-day seminar.

Consultation Question:

• Are there any other business compliance costs that should be considered in the Final RIS?

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Additional Saleable Space This Consultation RIS has not considered the potential gain from increasing the saleable/lettable space as a result of the reduction in the number of fire-isolated stairs required under both options. The value of this space is difficult to quantify and will vary across Australia. Due to a lack of information on this potential benefit, the ABCB is asking stakeholders if they have any information that would assist in informing the Final Decision RIS. Responses to the below questions will assist the ABCB in quantifying this benefit.

Consultation Questions:

• Do you have any information that could inform the extent an increase in saleable/lettable space will be achieved in practice?

• Do you have any information that would assist in quantifying the impacts of increasing the saleable/lettable space of new Class 2 and 3 buildings?

• In the absence of information, what is a reasonable estimate of the value of saleable/lettable space in a new Class 2 and 3 building on a per square metre basis?

Regulatory Burden The Australian Government has introduced the ‘Guide to Regulation’, which discusses the importance of cutting red tape.

A key principle for Australian Government policy makers in the Guide to Regulation is that:

The cost burden of new regulation must be fully offset by reductions in existing regulatory burden.

All regulatory costs, whether arising from new regulations or changes to existing regulation, must be quantified using the Regulatory Burden Measurement framework. The framework must also be used for quantifying regulatory savings, where applicable.

As measured in accordance with the framework, the regulatory saving from implementing Option 2 would be a total of $52.6 million. The Commonwealth’s share of this would be $5.84 million.

Governments of the States and Territories are not required under COAG policy to identify regulatory offsets. Some jurisdictions may have their own mechanisms regarding regulatory offsets, which would be a matter for those jurisdictions to consider.

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Conclusion The analysis reveals that both options are capable of delivering a moderate net benefit relative to the status quo.

The proposed sprinkler specifications and associated offsets present a range of benefits for Class 2 and Class 3 buildings that include reductions in individual and societal risk, improved property protection, and where larger buildings are constructed, more flexibility in building design and configuration associated with the removal of other fire safety features.

Under Option 1, a range of specifications are proposed that enable solutions to be provided for buildings outside of the assumed average configuration. The capital cost of these systems is offset to differing extents primarily by increased travel distances allowing a reduction in the number of exit stairs. The representative impacts are based on a configuration that allows for the highest capital cost saving associated with this offset, but does not quantify the benefits associated with additional saleable/lettable space28. The FPAA 101D specification was deemed the most cost effective of all specifications under the assessed building configurations as it is assumed that industry will use domestic plumbing fixtures and fittings and designs requiring lowest ongoing maintenance cost.

Despite alternative specifications imposing a net cost, benefits are achieved under Option 1 largely as a result of construction cost savings from the adoption of FPAA 101D. Conversely, Option 2 assumes industry will opt for the most cost effective specification FPAA 101D at the same rate as Option 1 and in other cases, revert to the current DtS Solution.

A number of key assumptions were varied to assess the robustness of this outcome. The variance of market uptake of the most cost effective specification (FPAA 101D) was found to be most sensitive to change. However even under low uptake, this would not influence the achievement of a net benefit under both scenarios. Equally, raising the uptake of FPAA 101D would have the effect of increasing benefits under both options. This and other sensitivity testing did not change the proportional standing of the options.

Option 2 generates the highest net benefit of $311,111,468 in Net Present Value terms, $107,421,202 higher than Option 1.

Option 2 is the recommended option for the purposes of further Consultation. Refer Table 31.

Table 31 Net Present Value of Alternative Options

Option 1 Option 2 Difference in NPV

$203,690,265 $311,111,468 $107,421,202

28 Feedback will be sought on the net value associated with this space and the extent to which it will accrue.

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Consultation The ABCB believes meaningful consultation can promote trust between industry, the community and government. Transparency allows stakeholders to see and judge the quality of government actions and regulatory decisions. Consultation also provides an opportunity for stakeholders to participate in the development of policy solutions and encourages broad ownership of those solutions. For more information on the ABCB’s consultation philosophy and objectives, visit http://www.abcb.gov.au/Consultation/Consultation

This is a consultation document where interested parties are invited to provide comment on any matter raised in this Consultation RIS. Respondents are encouraged to address the Consultation Questions to assist in finalisation of the regulation impact analysis.

Comments on this Consultation RIS are invited by close of business 13 April 2018 using the ABCB RIS response form and emailing it to [email protected] with the subject title “Fire safety in Class 2 and 3 buildings”.

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Appendix A: International Comparison Scotland In Scotland new apartment buildings where the top floor is more than 18m above the ground require automatic fire suppression systems to be installed. Under the Technical Handbook 2017 – Non-Domestic, automatic fire suppression such as that which would be used in hotels is an option as part of a fire engineered solution or where the building is designed on the principle of phased evacuation and the top floor is more than 25m above ground. Where a design accommodates simultaneous evacuation of occupants automatic sprinkler protection is not required.

Research from 2015 provided a marginal case for installing sprinklers in halls of residence (student accommodation) based on the benefits associated with property protection.

Norway In 2010 the Norwegian building regulations were amended to require an automatic fire extinguishing system in residential buildings greater than two storeys (where a lift is required). This change complemented the recognition of a ‘protect in place’ strategy for occupants with disabilities and coincided with a requirement for automatic sprinkler protection in hotels, hospitals, health care facilities, care homes or supported accommodation and housing specially designed and intended for persons with disabilities to ensure the fire safety of vulnerable occupants.

United States of America The International Building Code is a model code published by the International Codes Council for adoption by jurisdictions both within and outside the United States. Since 2003, the model code has required all residential occupancies to be sprinkler protected throughout the entire building. This requirement is reported to be universally adopted for buildings other than single houses.

Sweden Automatic sprinkler protection is only mandatory in hospitals and in some nursing homes. All buildings greater than 16 storeys (approximately 48 m) are subject to ‘analytic design’ and hotels are suggested to commonly install sprinkler systems to gain concessions to other fire safety requirements.

Singapore Automatic sprinkler protection is required where the height of a building is greater than 24m or where minimum compartment sizes are exceeded. In a building of mixed use, where a residential component forms the upper storeys, this requirement applies to every storey of the non-residential portion only and any basement not used for residential purposes.

Japan Residential buildings greater than 11 storeys (approximately 33 m) require automatic sprinkler protection. For hotels greater than 11 storeys, the trigger applies where the floor area exceeds 6,000m2. For buildings of lesser height, floors from 4th to 10th with a floor area that exceeds 1,500 m2 require sprinkler protection. In other residential type buildings such as hospitals and welfare facilities, a requirement to install sprinklers exists where a floor area trigger of greater than 275 m2 is exceeded

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Appendix B

Appendix B: FPAA 101 D FPAA Sprinkler specification FPAA 101D Automatic fire sprinkler system design and installation – Domestic Water Supply, Draft 4 December 2017, is reproduced below for the information of stakeholders.

FPAA101D

Automatic Fire Sprinkler System Design and Installation – Domestic Water Supply

DRAFT

4 December 2017

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Appendix B

FPA Australia Fire Protection Association Australia (FPA Australia) is Australia’s major technical and educational fire safety organisation and the national industry peak body for fire safety, which provides information, services and education to the fire protection industry and the community.

FPA Australia is a not for profit association and is supported by approximately 1500 members, consisting of leading companies and organisations around Australia employing an estimated 30,000 individuals, and operating across every aspect of the fire protection, building and construction industry.

Our vision is: Leading and supporting a professional industry to minimise the impact of fire on life, property and the environment, for a safer community.

The objective of FPA Australia’s Technical Specifications is to realise this vision by providing fit-for-purpose solutions to make buildings safer.

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Appendix B

Preface This Technical Specification provides for a fit for purpose, cost-effective automatic fire sprinkler system supplied from the domestic water supply.

It was developed as a result of research and testing funded by Fire & Rescue New South Wales (NSW) and conducted by CSIRO in conjunction with FRNSW staff and FPA Australia members to identify a fit for purpose, cost-effective sprinkler system for residential accommodation—namely Class 2 and 3 buildings—and was undertaken as a direct result of the NSW coronial inquest into the death of Connie Zhang and inquiry into the 6 September 2012 fire at Unit 53, Tower B, 4 West Terrace, Bankstown.

Two fit for purpose sprinkler systems were developed, both with reference to existing requirements of Australian Standards and the use of listed sprinkler heads within the scope of their listing but with an emphasis of providing a more cost-effective solution that still provided a suitable level of safety.

One of the key ways this was achieved was by using existing water supplies in the building either the domestic water supply or the hydrant water supply.

This Technical Specification covers a sprinkler system fed by the domestic water supply.

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Appendix B

Table of contents 1.0 .................................................................................................................................................. Scope ........................................................................................................................................... 55

2.0 ......................................................................................................................................... Application ........................................................................................................................................... 55

3.0 ........................................................................................................................... System Description ........................................................................................................................................... 55

4.0 ............................................................................................. Adoption of AS 2118.5 with variation ........................................................................................................................................... 55

5.0 .............................................................................................................. Variations from AS 2118.5 ........................................................................................................................................... 57

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Appendix B

Scope This Technical Specification specifies minimum requirements for the components, design, installation, commissioning and routine service of a fit for purpose fire sprinkler system for Class 2 and 3 buildings not more than 25 m in effective height and fed from the domestic water system. Referred as a FPAA101D system.

Application This Technical Specification must be read in conjunction with Australian Standards AS 2118.5-2008, Automatic fire sprinkler systems - Home fire sprinkler systems and AS 2118.1:2017, Automatic fire sprinkler systems – General systems. See Clause 4.0.

System Description The FPAA101D system is a fit for purpose fire sprinkler system for Class 2 and 3 buildings not more than 25 m in effective height and fed from the domestic water system.

The FPAA101D system takes its water supply from the building’s domestic water riser, downstream of the domestic pump. This eliminates the need for a dedicated sprinkler system water supply tapping, pump set, control valve assembly and riser.

Each floor will have a branch from the domestic riser to feed the sprinkler system and domestic water for that floor. The branch shall include an isolation valve to isolate the domestic water and sprinkler system on the floor. Downstream of the isolation valve is the take-off point for a branch serving the sprinkler system and sole occupancy unit (SOU) toilets. This branch starts with a backflow prevention device at the take-off point and then runs throughout the corridors and common areas and into each SOU on that floor.

A FPAA101D system has the added benefit of having a continually monitored water supply. As the system is fed from the building’s domestic water system, any interruption or reduction in water supply to domestic appliances (taps, showers, etc.) will indicate an interruption or reduction in the water supply to the FPAA101D system.

See Figure 1 for an illustration of this system configuration. Note: As illustrated in Figure 1.3, a building with a FPAA101D system will have two pipes entering each SOU:

• The domestic service (as present); and

• The FPAA101D sprinkler system pipe.

• The connection of the toilets within the SOU to the sprinkler system pipework effectively provides end-of-line monitoring within each SOU.

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Appendix B

Figure 1 Sample system diagram of a FPAA101D system

Adoption of AS 2118 standards A sprinkler system in accordance with this Technical Specification shall meet the requirements of Australian Standard AS 2118.5-2008 except where varied by this Technical Specification, see Clause 5.0.

This Technical Specification also references some clauses from AS 2118.1:2017, primarily in regards to components and the location of sprinklers. Note: AS 2118.5 has been referenced as the basis for this Technical Specification. However, this Technical Specification varies aspects of AS 2118.5 to create a fit for purpose and cost effective system for Class 2 and 3 buildings not more than 25 m in effective height fed from the domestic water supply. It has been informed by research and testing conducted by CSIRO in conjunction with Fire and Rescue NSW and FPA Australia members.

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Appendix B

Variations from AS 2118.5 Sprinkler systems in accordance with this Technical Specification shall meet AS 2118.5 with the following variations:

NOTE: The below text includes a number of notes in blue boxes like this one.

These notes are not part of the variations to AS 2118.5 but rather notes to this FPAA101D Technical Specification intended to clarify why certain information is added, modified or deleted.

Notes that are not in these boxes are part of the variation itself, such as that for Clause 4.3.2.4 below.

There is also one commentary box which is clear (no fill) and is also part of the variation itself, see C4.2.3 in Clause 4.2.3 below.

Global change (entire Standard)

All instances of “home fire sprinkler system” are references to a “FPAA101D system” and any variations on this are to be read accordingly, e.g. a reference to a “home sprinkler” is a reference to a sprinkler in a FPAA101D system.

Preface and Foreword (page 2 and 5)

Delete Preface and Foreword.

SECTION 1 SCOPE AND GENERAL

Clause 1.1 (page 6)

Delete text (including Notes) and replace with the following:

This Standard specifies minimum requirements for the components, design, installation, commissioning and routine service of a fit for purpose fire sprinkler system for sole-occupancy units (SOUs) in Class 2 and 3 buildings less than 25 m in effective height and fed from the domestic water supply.

An FPAA101D system shall not be used to protect buildings where more than 25% of the floor area is not classified as Class 2 or Class 3. See Clause 2.5.3.2.2 for guidance on protection of ancillary areas.

Clause 1.3.2 (page 7)

Delete text (including notes) and replace with;

The sprinkler system installation downstream of the floor take-off backflow prevention device shall be installed by a licenced plumber or sprinkler fitter who also holds the specific licence/accreditation to conduct work on FPAA101D systems.

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Appendix B

Clause 1.5.2 (page 8)

Delete Clause 1.5.2.

Clause 1.5.3 (page 8)

Delete Clause 1.5.3.

Clause 1.5.4 (page 8)

Delete “tank or” and Note.

Clause 1.5.11 (page 9)—NEW

1.5.11 Domestic water system

Domestic plumbing system comprising all components from the water supply tapping, including backflow prevention, pump, pipework and plumbing fixtures.

Clause 1.5.12 (page 9)—NEW

1.5.12 Floor isolation valve

Valve used to isolate the sprinkler system and domestic water for the residential floor.

Clause 1.5.14 (page 9)—NEW

1.5.14 FPAA101D system

A fit for purpose sprinkler system for Class 2 and Class 3 buildings not more than 25m in effective height, fed from the domestic water system.

Clause 1.5.15 (page 9)—NEW

1.5.15 Shadowed area

An area rendered unprotected by a vertical feature, such as a protruding wall, obstructing the spray pattern of a sprinkler.

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Appendix B

Clause 1.5.16 (page 9)—NEW

1.5.16 Sole-occupancy unit (SOU)

Has the meaning as per the NCC definition except that (c) and (d) of that definition are not relevant in the context of this Standard.

Clause 1.5.17 (page 9)—NEW

1.5.17 Sprinkler, residential (RES)

See Clause 1.3.36 of AS 2118.1:2017.

Clause 1.5.18 (page 9)—NEW

1.5.18 Sprinkler, sidewall

See Clause 1.3.37 of AS 2118.1:2017.

SECTION 2 INSTALLATION

Clause 2.2 (page 10)

Delete text (including Table 2.2 and Figures) and replace with the following:

The building shall be sprinkler protected throughout except in the following areas:

(a) For the entire building:

(i) Concealed floor, ceiling and roof spaces not used as living areas.

(ii) Toilets, bathrooms and ensuites, excluding dual use as a laundry.

(b) For SOUs only:

(i) Hallways, entries, stairs and the like not exceeding 1.5m in width.

(ii) Cupboards, wardrobes, walk-in wardrobes, pantries, alcoves and recesses less than 3.0 m2; not containing clothes driers, gas water heaters, cooking appliances and the like, or used for the storage of flammable liquids.

(iii) Small architectural features such as planter box windows and bay windows.

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Appendix B

Clause 2.2.1 (page 10)—NEW

2.2.1 Covered balconies

Balconies on residential floors shall be protected in accordance with Clause 5.9.10 of AS 2118.1:2017.

Clause 2.3 (page 12)

Delete Clause.

NOTE: Smoke alarms or smoke detection is also an important fire protection measure in Class 2 and 3 buildings but already required by the National Construction Code and state legislation and therefore does not need to be included in this Technical Specification.

Clause 2.5.1 (page 13)

Delete Clause 2.5.1

Clause 2.5.2 (page 13)

Delete Clause 2.5.2 including associated Figures.

Clause 2.5.3 (page 13)

Delete text including Figures and replace with the following:

2.5.3.1 General

The FPAA101D system is a fit for purpose fire sprinkler system for Class 2 and 3 buildings not more than 25 m in effective height and fed from the domestic water system.

The FPAA101D system takes its water supply from the building’s domestic water riser, downstream of the domestic pump.

2.5.3.2 Sprinkler system

Take-offs feeding the sprinkler system for the floor shall incorporate a floor isolation valve to allow the supply to the sprinkler system on that floor to be isolated. This valve shall be upstream of the branch feeding the domestic water meters on the protected floor.

NOTE: The floor isolation valve is fitted upstream of the water meters so that domestic water usage “monitors” the floor isolation valve. If the valve is inadvertently left shut, occupants are alerted that the sprinkler system is inoperative as they will have no water available at their SOU taps.

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Appendix B

2.5.3.2.1 Connection to SOU toilets

All SOU toilets shall be fed directly from the SOU’s sprinkler system. Pipework and connection to the toilet cistern shall be in accordance with AS/NZS 3500.1 except that the feed shall be from the sprinkler system.

NOTE: The purpose of the connection to SOU toilets is to monitor the water availability at every SOU in the building. Such ‘end-of-line’ monitoring increases system reliability by protecting against deliberate or inadvertent isolation to parts of the protected floor.

2.5.3.2.2 Ancillary Areas

The whole building shall be sprinkler protected subject to the minor exceptions specified in Clause 2.2.

If more than 25% of the floor area of a building is not classified as Class 2 or Class 3, an FPAA101D system shall not be used.

If other classifications apply to ancillary parts of a Class 2 or 3 building protected by a FPAA101D system (e.g. Class 7 carparks, Class 6 retail etc.), these parts of the building shall—

• not be located above the fourth storey;

• be sprinkler protected in accordance with Clause 4.3.4 of AS 2118.4 and be provided with end-of-line sprinkler system monitoring via also providing water supply to toilets serving these ancillary parts of the building.

2.5.3.4 Connection to other systems

No part of the sprinkler system shall be connected to any other service including drencher systems, hose reels or the like.

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Appendix B

SECTION 3 WATER SUPPLIES

Clause 3.3 (page 18)

Delete Clause 3.3 (including Clauses 3.3.1 and 3.3.2 and associated Figures) and replace with the following:

Clause 3.3 Source of supply

The domestic water system shall be fed from the network utility operator drinking water supply and the FPAA101D system shall be fed from this domestic water system.

NOTE: See typical FPAA101D system configuration in Figure 1 of FPAA101D.

Clause 3.4

Delete Clause 3.4.

Clause 3.5

Delete “100 L/Min” and replace with “132 L/min”.

Delete “10 min” and replace with “60 min”.

Clause 3.6.1 (page 23)

Delete text and replace with “Pumpsets shall be installed in accordance with AS/NZS 3500.1”.

Clause 3.6.2 (page 23)

Delete Clause 3.6.2.

Clause 3.6.3 (page 23)

Delete Clause 3.6.3.

Clause 3.6.4 (page 23)

Delete Clause 3.6.4.

Clause 3.6.1 (page 24)

Delete Figure 3.6.1.

Clause 3.6.5 (page 25)

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Appendix B

Figure 3.6.5—Delete “FIRE SPRINKLER PUMP” and replace with “FIRE SPRINKLER/POTABLE WATER PUMP”

Clause 3.6.6 (page 25)

Delete Clause 3.6.6.

Clause 3.6.7 (page 25)

Delete Clause 3.6.7.

Clause 3.6.8 (page 25)

Delete Clause 3.6.8.

Clause 3.6.9 (page 25)

Delete Clause 3.6.9.

Clause 3.7 (page 26)

Delete Clause 3.7 including Figures.

SECTION 4 DESIGN AND HYDRAULICS

Clause 4.2.1 (page 27)

Delete “50 L/min” and replace with “66 L/min”.

Clause 4.2.3 (page 27)

Delete Clause 4.2.3.

Clause 4.2.3 (page 27)—NEW

4.2.3 Simultaneous flow

The network utility operator drinking water supply shall be capable of supplying simultaneously the FPAA101D system flow demand, the domestic flow demand and the demand of the wet or dry hydrant system.

C4.2.3 Where a network utility operator drinking water supply supplies a sprinkler system, it should be capable of providing simultaneously the required flow for the domestic water system and fire hydrants. It is expected that the fire brigade would not isolate the sprinkler system until the fire is extinguished and may use the hydrants to supplement sprinkler operation.

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Appendix B

Clause 4.3.2.4 (page 32)—NEW

4.3.2.4 Ceiling fans

Sprinklers shall be located a minimum of 300mm beyond the outside radius of ceiling fans.

NOTE: A ceiling fan blade may present a significant obstruction if stopped immediately below a sprinkler.

Clause 4.3.2.5 (page 32)—NEW

4.3.2.5 Shadowed Areas

Shadow areas shall be treated in accordance with Clause 5.7.10 of AS 2118.1:2017.

Clause 4.3.2.6 (page 32)—NEW

4.3.2.6 Pendant sprinkler near columns

Pendent sprinklers near columns shall be located in accordance with Clause 5.7.4 of AS 2118.1-2017.

Clause 4.3.3.4 (page 32)—NEW

4.3.3.4 Ceiling pockets

Ceiling pockets shall be sprinkler protected in accordance with Clause 5.7.11.3 of AS 2118.1:2017.

Clause 4.4.1 (pages 39-42)

Delete text including all Tables and associated notes and replace with the following:

FPAA101D systems shall be fully hydraulically calculated in accordance with Section 14 of AS 2118.1:2017 using the design criteria as per Clause 4.2, the sprinkler spacing as per Clause 4.3 and the minimum sprinkler pressure as per Clause 4.4.2.

NOTE: This Clause uses 4.2, 4.3 and 4.4.2 to hydraulically calculate the requirement for an FPAA101D system. The required flow and pressure determined will need to be made available from the domestic water system.

Clause 4.4.3 (pages 42-51)

Delete Clause 4.4.3 including all Tables and Figures.

SECTION 5 COMPONENTS

Clause 5.1 (page 52)

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Appendix B

Delete Items (c) and (f).

Clause 5.1.1 (page 10)—NEW

5.1.1 WaterMark

All components installed downstream of the floor backflow prevention device (including sprinklers) shall be certified and authorised under the WaterMark Certification Scheme.

Clause 5.2.1.1 (page 52)

Delete Clause.

Clause 5.2.1.3 (page 52)

Delete Clause.

Clause 5.2.2 (page 52)

1. Delete first sentence.

2. Delete “Plastics” at the start of the second sentence and replace with “plastic”.

3. Delete Note.

Clause 5.2.3 (pages 52 and 53)

Delete Clause 5.2.3.

Clause 5.3 (page 53)

Delete entire Clause and replace with the following new Subclauses:

5.3.1 Backflow protection

The floor backflow valve shall be a non-testable dual check valve and shall not be fitted with isolation valves.

NOTE: Minimising the possibility of inadvertent isolation of the sprinkler system in Class 2 and 3 buildings is of paramount importance. Isolation valves fitted at backflow devices are used to perform testing on the device and to facilitate its maintenance or replacement. As a non-testable device is specified and provisions for isolation and drainage are available, dedicated isolation valves are not required to be installed.

5.3.2 Drain Valve

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Appendix B

A 15mm locked shut drain valve shall be installed immediately downstream of the dual check valve backflow device to facilitate de-pressurizing the installation downstream of the device if required.

NOTE: This Technical Specification does not include test valve assemblies. Such assemblies are used for routine testing (“maintenance” under AS 2118.5). The requirements to use this have been removed due to the nature of the system whereby the availability of water will be monitored with day to day water usage of the occupants.

5.3.3 Location plate

Where the floor isolation valves are located within a cupboard, a location plate shall be installed on the exterior of the cupboard bearing the following words “SPRINKLER STOP VALVE INSIDE” in clear permanent lettering, in letters at least 25mm high and in a contrasting colour to the background.

Clause 5.4 (pages 54-55)

Delete Clause 5.4 (including Figure).

Clause 5.5.1 (page 55)

1. Delete text in Clause 5.5.1(b) and replace with the following:

(b) be of the concealed, flush or domed pendent type or sidewall type; and

2. Delete last sentence and Note.

Clause 5.5.2

Delete text (excluding note) and replace with the following:

Six (6) spare sprinklers and a compatible spanner shall be kept in a locked box fixed adjacent to the fire indication panel (FIP), where fitted. Where no FIPs are used, the spares box shall be installed adjacent to the ground level floor isolation valve.

Clause 5.5 (pages 56 to 57)

1. Delete Figure 5.5(A).

2. Delete Figure 5.5 (B).

3. Delete Figure 5.5(C).

SECTION 6 COMMISSIONING

Section 6 (page 59)

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Appendix B

1. Add “6.1 GENERAL” between the Section heading and the first paragraph.

2. Delete Item (d).

NOTE: This Standard does not include test valve assemblies.

3. Delete Item (e).

4. Delete Item (f).

5. Delete Item (g).

6. Delete Item (h).

7. Delete Item (i).

SECTION 7 ROUTINE SERVICE

Section 7 (page 59)—NEW

Add new Section 7 as follows:

SECTION 7 ROUTINE SERVICE

7.1 GENERAL

Routine service of a FPAA101D system shall consist of an annual inspection of the sprinkler system to ensure that sprinklers have not been damaged, painted or unduly obstructed.

Stock of spare sprinklers and spanner should also be checked at this time. NOTE: This activity could be conducted at the same time that the SOU is accessed to undertake the annual inspection of smoke alarms.

APPENDICES

Delete all appendices.

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Appendix C

Appendix C: FPAA 101 H FPAA Sprinkler specification FPAA 101H Automatic fire sprinkler system design and installation – Hydrant Water Supply, Draft 4 December 2017, is reproduced below for the information of stakeholders.

FPAA101H

Automatic Fire Sprinkler System Design and Installation – Hydrant Water Supply

DRAFT

4 December 2017

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Appendix C

FPA Australia Fire Protection Association Australia (FPA Australia) is Australia’s major technical and educational fire safety organisation and the national industry peak body for fire safety, which provides information, services and education to the fire protection industry and the community.

FPA Australia is a not for profit association and is supported by approximately 1500 members, consisting of leading companies and organisations around Australia employing an estimated 30,000 individuals, and operating across every aspect of the fire protection, building and construction industry.

Our vision is: Leading and supporting a professional industry to minimise the impact of fire on life, property and the environment, for a safer community.

The objective of FPA Australia’s Technical Specifications is to realise this vision by providing fit-for-purpose solutions to make buildings safer.

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Appendix C

Preface This Technical Specification provides for a fit for purpose, cost-effective automatic fire sprinkler system supplied from the hydrant system water supply.

It was developed as a result of research and testing funded by Fire & Rescue New South Wales (NSW) and conducted by CSIRO in conjunction with FRNSW staff and FPA Australia members to identify a fit for purpose, cost-effective sprinkler system for residential accommodation—namely Class 2 and 3 buildings—and was undertaken as a direct result of the NSW coronial inquest into the death of Connie Zhang and inquiry into the 6 September 2012 fire at Unit 53, Tower B, 4 West Terrace, Bankstown.

Two fit for purpose sprinkler systems were developed, both with reference to existing requirements of Australia Standards and the use of listed sprinkler heads within the scope of their listing but with an emphasis of providing a more cost-effective solution that still provided a suitable level of safety.

One of the key ways this was achieved was by using existing water supplies in the building either the domestic water supply or the hydrant system water supply.

This Technical Specification covers a sprinkler system fed by the hydrant system water supply.

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Appendix C

Table of contents 1.0 ........................................................................................................................... Scope and General ........................................................................................................................................... 73

1.1 Scope 73

1.2 Application 73

1.3 System Description 73

1.4 Definitions 74

2.0 ................................................................................................................................. Hydrant System ........................................................................................................................................... 76

2.1 General 76

2.2 Compliance with AS 2419.1-2005 76

3.0 ............................................................................................................................... Sprinkler System ........................................................................................................................................... 77

3.1 General 77

3.2 Extent of sprinkler protection 77

3.3 Sprinkler system design 77

3.4 Water supply 78

3.5 Sprinklers 78

3.6 Spacing and location of sprinklers 78

3.7 Sprinkler System Piping 79

4.0 ........................................................................................................................................... Pumpsets ........................................................................................................................................... 80

4.1 General 80

4.2 Pumpset requirements 80

5.0 ..................................................................................................... Valves and Ancillary Equipment ........................................................................................................................................... 81

5.1 General 81

5.2 Alarms 81

5.3 System Control Valves 81

5.4 Isolating Valves 82

5.5 Block Plans 83

5.6 Other required documentation 83

6.0 .................................................................................................................... System commissioning ........................................................................................................................................... 84

6.1 General 84

6.2 FPAA101H system tested as one system 84

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Appendix C

6.3 Water supply proving test (flow test) 84

6.4 Hydrostatic pressure test 84

6.5 Inspection of system 84

6.6 Commissioning report 85

7.0 ................................................................................................................................. Routine Service ........................................................................................................................................... 86

7.1 General 86

7.2 Hydrant system routine service 86

7.3 Pumpset routine service 86

7.4 Sprinkler system routine service 86

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Appendix C

1.0 Scope and General

1.1 Scope This Technical Specification is for the design, installation, commissioning and routine service of a fit for purpose sprinkler system for Class 2 and Class 3 buildings not more than 25m in effective height fed from the hydrant system. Referred to as a FPAA101H system.

1.2 Application This Technical Specification must be read in conjunction with the following Australian Standards:

• AS 2118.1:2017, Automatic fire sprinkler systems - General systems

• AS 2118.4:2012, Automatic fire sprinkler systems - Sprinkler protection for accommodation buildings not exceeding four storeys in height

• AS 2419.1-2005, Fire hydrant installations - System design, installation and commissioning

• AS 2941-2013, Fixed fire protection installations - Pumpset systems

1.3 System Description This system consists of a typical internal hydrant installation commonly required for a Class 2 or Class 3 buildings where coverage cannot be achieved by external hydrants, and also includes, a feed for the sprinkler system which is taken at each floor level directly from the hydrant riser. A typical sprinkler piping layout is then provided from this feed to each residential floor.

See Figure 1.3 for an illustration of this system configuration. Note: In comparison to an AS 2118.1 or AS 2118.4 system, this Technical Specification eliminates the need for a dedicated sprinkler system water supply tapping, pumpset (if necessary), sprinkler control valve set and sprinkler riser.

It should be noted that AS 2118.6 also covers a combined hydrant and sprinkler system. However, AS 2118.6 is designed for use in much taller buildings and in all Classes from Class 2 to Class 9 buildings. To account for this complexity, AS 2118.6 includes many requirements in excess of what is required for this Technical Specification which is restricted to Class 2 and 3 buildings not more than 25 m in effective height.

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Appendix C

Figure 1.3 Sample system diagram of a FPAA101H system

1.4 Definitions • Alarm initiating switch – Pressure or flow switch installed at the control

valves used to automatically sense the operation of the FPAA101H system and initiate an alarm condition. Note: An alarm initiating switch is only required where the NCC requires a building occupant warning system, see Clause 5.2.

• FDCIE – Fire detection control and indicating equipment.

• FPAA101H system – A fit for purpose sprinkler system for Class 2 and Class 3 buildings not more than 25m in effective height, fed from the hydrant system. It consists of both a hydrant system and sprinkler system as per the definitions of this Technical Specification.

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Appendix C

• Hydrant system – For the purpose of this Technical Specification, the hydrant system includes all piping and components of the FPAA101H system fitted downstream of the hydrant system water supply tapping excluding the sprinkler system.

• Listed – See Clause 1.3.15 of AS 2118.1:2017.

• Shadowed area – An area rendered unprotected by a vertical feature, such as a protruding wall, obstructing the spray pattern of a sprinkler.

• Shall – See Clause 1.3.23 of AS 2118.1:2017.

• Should – See Clause 1.3.24 of AS 2118.1:2017.

• Sole-occupancy unit (SOU) – Has the meaning as the NCC definition except that (c) and (d) of that definition are not relevant in the context of this Technical Specification.

• Sprinkler, residential (RES) – See Clause 1.3.36 of AS 2118.1:2017.

• Sprinkler, sidewall – See Clause 1.3.37 of AS 2118.1:2017.

• Sprinkler system – For the purpose of this Technical Specification, the sprinkler system includes all piping and components of the FPAA101H system fitted downstream of the sprinkler system connection point.

• Sprinkler system connection point – The point where the sprinkler system connects to the hydrant system.

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Appendix C

2.0 Hydrant System

2.1 General This section relates to the hydrant system part of the FPAA101H system alone.

It does not cover the sprinkler system part of the FPAA101H system, which is downstream of a sprinkler system connection point. This is covered in Section 3.0.

2.2 Compliance with AS 2419.1-2005 The hydrant system shall be in accordance with Australian Standard AS 2419.1-2005 with the following variation—the system performance shall be in accordance with Clause 2.3 of AS 2419.1-2005 except that the flow rate required shall be as per Table 2.2.

Table 2.2 FPAA101H system flow rate

Outlets required as per Table 2.1 of AS 2419.1-2005

1 2 3 or more

No pumps required by AS 2419.1-2005

1 outlet at 10 L/s

plus

Sprinkler demand

1 outlet at 10 L/s

plus

Sprinkler demand or 10 L/sec, whichever is the greater.

n-1 outlets at 10 L/s

plus

Sprinkler demand or 10 L/sec, whichever is the greater.

Pumps Required by AS 2419.1-2005

1 outlet at 5 L/s

plus

Sprinkler demand

1 outlet at 5 L/s

plus

Sprinkler demand or 5 L/s, whichever is the greater.

n-1 outlets at 5 L/s

plus

Sprinkler demand or 5 L/s, whichever is the greater.

Note: The pressure requirements will still be as per Table 2.2 or Table 2.3 of AS 2419.1-2005, as applicable.

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Appendix C

3.0 Sprinkler System

3.1 General This section relates to the sprinkler system part of the FPAA101H system alone.

It does not cover the hydrant system part of the FPAA101H system, which is upstream of a sprinkler system connection point. This is covered in Section 2.0.

3.2 Extent of sprinkler protection • Sprinklers shall be installed within all areas of the building including inside

and outside of the SOU except where excluded below.

• Exceptions

Sprinklers are not required in the following areas:

o Concealed spaces;

o Garbage chutes;

o Lift shafts;

o Non walk-in cupboards or wardrobes;

o Roof overhangs; and

o Fire isolated stairs.

3.3 Sprinkler system design • Residential sprinklers shall be spaced in accordance with their listed data

sheet with maximum spacing from a wall of half the maximum spacing as listed in the datasheet.

• The sprinkler system shall be designed to provide for the two most hydraulically unfavourable sprinklers. The minimum discharge density shall be 4.1 mm/min/m2.

• The system shall be designed such that the minimum end head pressure shall be maintained for the specific sprinkler selected and its design spacing with two operating sprinklers and the required number of fire hydrants.

• The sprinkler system shall be fully hydraulically calculated in accordance with Section 14 of AS 2118.1 – 2017 using the 4.1mm/min/m2 density and the operating hydrants. Any flexible tube assemblies shall also be included in these calculations. Note: This Technical Specification may allow for flow rates above 150 L/min per sprinkler. Consideration should be given to the friction loss characteristics of flexible tube assemblies when selected for use. Larger than DN 25 assemblies may be required to ensure adequate pressures are available at the sprinkler at the worst case bend and tube length allowance for the selected flexible tube assembly.

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• Minimum pipe sizes shall be in accordance with Clause 9.5.2 of AS 2118.1:2017.

• If other classifications apply to Parts of a Class 2 or 3 building protected by a FPAA101H sprinkler system, the following criteria applies to the Parts that are not Class 2 or 3:

o The system shall be designed in accordance with the relevant hazard class to provide an appropriate density of discharge over the assumed area of operation applicable to the hazard class as specified in AS 2118.1; and

o be fire separated from the Class 2 and 3 parts in accordance with existing NCC deemed-to-satisfy requirements.

3.4 Water supply • The sprinkler system shall be supplied with water from the hydrant system

via sprinkler system connection points.

• All hydraulic calculations shall identify the required pump duty with simultaneous flow as nominated under Table 2.2.

3.5 Sprinklers • Only residential sprinklers of the pendant or horizontal sidewall type shall

be used.

• All sprinklers shall be installed in accordance with their data sheet requirements and this Technical Specification whichever is the more stringent.

• Only escutcheons and guards approved for use with the residential sprinkler shall be used.

3.6 Spacing and location of sprinklers Spacing of sprinklers shall be in accordance with Table 3.4 of this Technical Specification. Clauses 3.6.1 to 3.6.6 shall also be considered in the spacing and location of sprinklers.

3.6.1 Obstructions to water distribution Sprinklers shall be located to avoid obstruction to water distribution in accordance with Clause 4.4.3 of AS 2118.4-2012. Note: A ceiling fan blade may present a significant obstruction if stopped immediately below a sprinkler. Sprinklers should be located a minimum of 300mm beyond the outside radius of ceiling fans.

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Appendix C

3.6.2 Impact on response time Sprinklers shall be positioned to reduce impact on response time in accordance with Clause 4.4.4 of AS 2118.4-2012.

3.6.3 Compatibility Sprinklers within a compartment shall be compatible in accordance with Clause 4.5 of AS 2118.4-2012.

3.6.4 Shadowed Areas Shadow areas shall be treated in accordance with Clause 5.7.10 of AS 2118.1:2017.

3.6.5 Ceiling Pockets Ceiling pockets shall be sprinkler protected in accordance with Clause 5.7.11.3 of AS 2118.1:2017.

3.6.6 Pendant sprinklers near columns Pendent sprinklers near columns shall be located in accordance with Clause 5.7.4 of AS 2118.1-2017.

3.7 Sprinkler System Piping • All sprinklers shall be fed from the hydrant system only.

• All sprinklers shall be piped such that any one operated sprinkler will automatically start the fire pump (where fitted) and activate the FPAA101H system alarm initiating pressure or flow switch (where fitted).

• All sprinkler system piping and supports downstream of a sprinkler system connection point shall be in accordance with Section 7 of AS 2118.1:2017 with the following exceptions and provisions:

o Plastic pipe and fittings shall not be used.

o Sprinkler system pipes and fittings shall not be required to be galvanized unless installed externally.

o Pipework downstream of sprinkler system connection points shall not supply any other services including hose reels, tail-end systems and drenchers.

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Appendix C

4.0 Pumpsets

4.1 General Pumpsets for FPAA101H systems shall be in accordance with the requirements of Clause 4.2.

4.2 Pumpset requirements • Pumpsets shall be in accordance with AS 2941-2013.

• Pump start pressure sensors shall be duplicated and installed as per AS 2941-2013.

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Appendix C

5.0 Valves and Ancillary Equipment

5.1 General FPAA101H systems shall have alarms and valves as per Clauses 5.2 to 5.4 (as required), a block plan as per Clause 5.5 and other documentation as per Clause 5.6.

5.2 Alarms Where a building occupant warning system (BOWS) is required by the NCC, the following system components shall be required so as to activate the BOWS in the event of activation of the FPAA101H system:

• The system shall include a listed flow or pressure switch connected upstream of any sprinkler system connection points and hydrant valves to provide system operation indication to the FDCIE for operation of building occupant warning systems.

• The FPAA101H system pressure maintenance jacking pump discharge shall be fitted with a suitably sized restricted orifice so that:

o The system alarm is generated within 90 seconds of opening the test drain.

o The combined system pump, where fitted, starts within 90 seconds of operating the test drain.

o The most hydraulically disadvantaged hydrant shall be maintained at a minimum of 700kPa.

Where the orifice is a drilled ball valve, it shall be a lock-shut valve. All restricted orifices, regardless of type, shall be clearly labelled “restricted orifice”.

• Where there is a pump room, the flow or pressure switch shall be in the pump room. Where there is no pump room, the flow or pressure switch shall be installed in at the control assembly.

• A water motor alarm shall not be required. Audible bell and strobe shall be required in accordance with AS 2941-2013 where pumps are installed.

5.3 System Control Valves • A test valve with an orifice the similar size as the smallest orifice sprinkler

head used shall be provided to facilitate the alarm function test as required by Item 1.12 of Table 2.4.2.1 of AS 1851-2012 where an alarm initiating switch is required by Clause 5.2.

Where flow switches are fitted, the test valve shall be fed immediately downstream of the alarm generating flow switch.

Where pressure switches are fitted, the drain shall be fed from the large diameter main, downstream of the pump discharge non-return valve.

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Appendix C

The test valve shall be hydraulically connected to waste.

• A DN 10 remote test valve shall be fitted at the top of each combined riser. The test valve should be hydraulically connected to waste or piped such that its discharge is no higher than 200 mm above ground level and in a location considered safe and suitable for a 200 litre discharge. Note: Connection of hoses or temporary pipe for the purpose of conducting this test should not be considered a solution.

• Where pumpsets are required, an annubar shall be provided within the pump room. The annubar drain shall not discharge to open areas. Drains shall be hydraulically connected to waste without tun-dish or air gap arrangements. Note: Consideration should be given to the significant pressure and flow requirements of the drain facilitating the annubar. Typically, the annubar will be DN 65 and discharge approximately 1500 L/min at significant pressure. It is recommended that annubar drain pipework be upsized by a minimum two standard pipe sizes to reduce the pressure, velocity and friction loss that would occur.

• Gauge-cocks shall be fitted to pumpsets as per AS 2941-2013.

• A “Sprinkler Stop Valve Inside” shall be displayed in accordance with Clause 8.4 of AS 2118.1:2017 and displayed on the outside of the pump room door. Where pumps are not installed a permanent sign at the FDCIE indicating the location of sprinkler isolation valves shall be provided.

• See Appendix A for sample control assemblies.

5.4 Isolating Valves • A main stop valve shall be installed in the pump room, downstream of the

pump discharge non-return valve and upstream of control valve assembly.

• The sprinkler system connection points shall not require an isolation valve.

• All isolating valves shall be strapped and locked open.

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Appendix C

5.5 Block Plans • The FPAA101H system block plan shall be a combination of the

requirements of Clause 8.3 of AS 2118.1:2017 and Clause 7.11 of AS 2419.1-2005 with the following variations:

o The block plan shall be provided in the pump room and booster cabinet.

o The block plan shall be titled “FPAA101H System Block Plan”.

o The block plan shall include the following table and be completely populated:

Duty - Measured At Annubar FLOW L/M

PRESSURE kPa

Hydrant Duty Sprinkler Duty

Combined Duty For Annubar Flow Testing

Pump Duty

Note: The location for where a duty was calculated is important. For example, a duty that was calculated for the annubar will be significantly different to that measured at the most hydraulically disadvantaged hydrant.

5.6 Other required documentation • A pressure gauge schedule and valve list shall not be required.

• Emergency instructions and isolation procedures shall be provided in accordance with Clause 8.5 of AS 2118.1:2017.

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Appendix C

6.0 System commissioning

6.1 General FPAA101H systems shall be commissioned in accordance with Clauses 6.2 to 6.6.

6.2 FPAA101H system tested as one system A FPAA101H system consists of a hydrant system and sprinkler system as per the definitions of this Technical Specification. Both shall be commissioned as one system not a separate hydrant and separate sprinkler system because as per this Technical Specification it is one system whereby the sprinkler system is fed from the hydrant system.

Commissioning shall consist of a water supply proving test (flow test) as per Clause 6.3, a hydrostatic pressure test as per Clause 6.4 and an inspection of the system as per Clause 6.5 and shall be documented in a commissioning report as per Clause 6.6. Note: It should be understood that both plumbing contractors and fire protection contractors may be required to complete the design and installation. It may be possible that the allowance for the sprinkler water supply capacity may be overlooked during the hydrant design or installation process. As such, it is critical that the system is commissioned as a whole by a competent person experienced in fire sprinkler and hydrant systems design and flow testing procedure.

6.3 Water supply proving test (flow test) A water supply proving test (flow test) shall be conducted using the annubar at the pumpset or where there are no pumps, at the most hydraulically disadvantaged hydrant to determine that the flow and pressure required by Clause 2.2 is achieved.

6.4 Hydrostatic pressure test The hydrostatic pressure test shall be carried out in accordance with Clause 10.2.2 of AS 2419.1-2005.

6.5 Inspection of system A full visual survey of the FPAA101H system, including sprinkler system connection points shall be conducted.

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Appendix C

6.6 Commissioning report The results of the activities in Clauses 6.3 to 6.5 shall be documented in a commissioning report which identifies not only these results but:

• The details of the site (client, address, premises name, type of system)

• The details of the individual and company that undertook the commissioning (name of individual, name of company, address and contact details of company)

• Date of commissioning and signature of individual that completed the commissioning.

• Any notes of relevance.

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Appendix C

7.0 Routine Service

7.1 General FPAA101H systems shall be routinely serviced in accordance with AS 1851-2012 with the service frequencies and service activities applicable to these systems identified in Clauses 7.2 to 7.7.

7.2 Hydrant system routine service The hydrant system part of a FPAA101H system shall be serviced in accordance with Section 4 of AS 1851-2012 (there are no variations).

7.3 Pumpset routine service The pumpset(s) in a FPAA101H system shall be serviced in accordance with Section 3 of AS 1851-2012 (there are no variations).

7.4 Sprinkler system routine service The sprinkler system part of a FPAA101 system shall be serviced in accordance with Clauses 7.4.2 to 7.4.5.

7.4.1 Monthly service Conduct the following service activities from Table 2.4.2.1 of AS 1851-2012:

• Items 1.2, 1.7, 1.9, 1.10, 1.11, 1.12, 1.13, 1.14, 1.16, 1.17 and 1.18.

7.4.2 Six-Monthly service Conduct the following service activities from Table 2.4.2.2 of AS 1851-2012:

• Items 2.1, 2.4 and 2.5.

7.4.3 Yearly service Conduct the following service activities from Table 2.4.2.3 of AS 1851-2012:

• Items 3.1, 3.5, 3.6, 3.8, 3.17, 3.18, 3.19, 3.20, 3.21, 3.22 and 3.23.

Survey items—Items 3.17 through 3.23—shall only be required within areas outside the SOUs.

Item 3.5 shall be conducted for the FPAA101H system, as per Clause 6.3 of this Technical Specification.

7.4.4 Five-Yearly service Conduct the following service activities from Table 2.4.2.4 of AS 1851-2012:

• Items 4.1, 4.5, 4.7, 4.8 and 4.11.

7.4.5 Ten-Yearly, Twenty-Five Yearly and Thirty-Yearly service

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Appendix C

The ten-yearly, twenty-five yearly and thirty-yearly activities under Table 2.4.2.4 of AS 1851-2012 shall not be required to be conducted. Note: It is recommended that when a building or part of a building is being refurbished that the age of the sprinklers be checked and if over 25 years of age should be replaced.

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Appendix C

Appendix A – Sample Control Assemblies The following drawings illustrate sample control assemblies for FPAA101H systems: Figure A1 Control Valve Assembly at the ground floor hydrant cupboard

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Appendix C

Figure A2 Control Valve Assembly at the Booster Cupboard