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AS1851-2012 and your Building

AUST  Safety measures in buildings such as fire protection systems and equipment need to be tested, serviced and maintained in order to ensure they are able to function as designed when they are needed. AS 1851 is the Standard available to address the routine servicing of fire protection systems and equipment in Australia, and most building owners are required to comply with AS 1851-2005 or the newest version of Standard, AS 1851-2012.

/ HISTORY OF AS 1851
AS 1851, in its various forms, has a long and chequered history, appearing first in 1939 and expanding to multiple sections through the 1980s and 1990s. The 2005 version (currently used in the majority of buildings) was completely re-written and appeared in September 2005 as a single document – ‘AS 1851-2005 Maintenance of fire protection systems and equipment’. This version has since had amendments in July 2006 and again in May 2008.

In theory, the stages introduced in AS 1851-2005 represented a logical progression in the evolution of the Standard but in practice, regulators in the States and Territories had serious issues with the complex and costly operational requirements interpreted with the Standard. The second round of amendments released in May 2008 saw the removal of some of these requirements. Since further amendments were deemed too substantial however, the Standard had a major revision, and AS 1851-2012 was released in December 2012, as ‘AS 1851-2012 Routine service of fire protection systems and equipment’.

/ SUMMARY OF KEY CHANGES TO AS 1851-2012

  • A simplification of the Standard structure, making it easier for stakeholders to understand
  • Restructured documentation requirements for reporting (logbooks, tags, labels & summary records)
  • A more concisely defined relationship between initial installation, routine service and annual regulatory compliance
  • Introduction of a new section relating to water storage tanks, section 5
  • A critical appraisal and refinement of routine service technical requirements
  • An overhaul of the general requirements of Section 1
  • Easier to interpret tables in Sections 2 to 14 (tables changed from type based to frequency based, and yearly service separated from supportive routine service schedules)
  • The clarification of the requirements for system interface testing
  • A clarification of the role of commissioning and baseline data as part of the approved design
  • A distinction made between critical defects, non-critical defects and non-conformances
  • The removal of the ambiguity relating to current design Standards versus the design Standards applicable at the time of original approved systems installation, (that is, the approved design)
  • Several new appendices were included to expand on Section 1 content— baseline data

The Standard establishes a systematic basis for minimum routine service activities, and as such, it may be used to form the basis for developing specific routine servicing regimes. The Standard requires evidence in the form of records and reports, with the documentary evidence intended to support responsible entities in satisfying regulatory obligations.

/ REGULATORY REQUIREMENTS FOR STATES &  TERRITORIES
Currently each Australian State and Territory Government is responsible for establishing the requirements for the servicing of fire protection systems and equipment for buildings and land under their control, or for privately owned buildings and land. The Federal Government is responsible for Commonwealth land and buildings, regardless of which State or Territory the land is located in. Each State or Territory establishes this control through an Act of Parliament (Act), and this is their primary form of legislation. These Acts in turn, can authorise the making of Regulations to administer the Act. Put simply, the Act establishes the principles and objectives for compliance, while the Regulations detail how these objectives are to be achieved.

Regulations, in turn, can reference external documents such as Codes or Standards in whole, in part or in modified form. This allows for documents such as the National Construction Code (Building Code of Australia) and Australian Standards to form part of the regulatory regime of State or Territory governments. An Act can “reference” Regulations, which in turn can “reference” Codes or Standards. Where Regulations, Codes or Standards are referenced, (or partly referenced), there is a lawful requirement to comply with the provisions, or with those provisions that are referenced. Where Codes or Standards are not specifically referenced, they are not compulsory. This is commonly referred to as the hierarchy of legislation. Since each State and Territory has their own legislative and regulatory framework governing safety measures (of which Fire Protection Systems and Equipment form a part), they also have their own terminology.

The requirement to use a particular edition of AS 1851 in each State or Territory jurisdiction may be enacted through:

  • A direct reference to a specific edition in their legislation;
  • Regulation referencing a Code, Standard, Practice Note, Policy or other document specifying maintenance provisions; or
  • A reference to a specific edition in an Occupancy Permit or Occupancy Certificate, (which specifies safety measures maintenance requirements and makes the use of that edition mandatory).
State or Territory Defined Term for Fire Protection Systems and Equipment
Commonwealth – National Construction Code (Building Code of Australia) No current terminology with removal of essential safety measures from the NCC (refer to states)
Australian Capital Territory Active Fire Safety Systems
New South Wales Essential Fire Safety Measures
Northern Territory Safety Measures (previous NCC reference)
Queensland Fire Safety Installations and Special Fire Services
South Australia Essential Safety Provisions
Tasmania Essential Safety and Health Features/Measures
Victoria Essential Safety Measures
Western Australia Safety Measures

/ IMPLEMENTATION OF AS 1851-2012
The following provides a summary on your local adoption and use of AS 1851-2012 based on the primary legislation operating in your jurisdiction.
Note: This is basic information only – for full details refer to the relevant regulatory authority in your State or Territory.

Australian Capital Territory
Testing may be carried out to the previous suite of AS 1851 Standards, AS 1851-2005 or AS 1851-2012. Currently there is no mandatory requirement to test to any particular AS 1851 Standard.

New South Wales
Testing may be carried out to the previous suite of AS 1851 Standards, AS 1851-2005 or AS 1851-2012 providing documentation is provided in accordance with EPA 2000. Currently, there is no mandatory requirement to test to any particular AS 1851 Standard, as emphasis on annual certification is system capability based, not maintenance based.

Northern Territory
Testing may be carried out to the previous suite of AS 1851 Standards, AS 1851-2005 or AS 1851-2012. Currently there is no mandatory requirement to test to any particular AS 1851 Standard.

Queensland
Queensland Development Code (QDC) Mandatory Part MP 6.1 states it is mandatory for testing to be carried out to AS 1851-2012 or older versions as appropriate, from the 1st Jan 2015.

South Australia
Buildings are required to be maintained in accordance with Minister’s Specification SA 76 in force at the time of Building Rules consent. The original version of SA 76 lists pre-1851-2005. The Minister’s Specification SA 76 has been amended to require maintenance to AS 1851-2012 as of 1 May 2015 with a transition process for existing buildings.

Tasmania
Tasmania has adopted AS 1851-2012 by way of an amendment to the Director of Building Control’s Specified List. The Building Act 2000 and its Regulations provide for the Director to prescribe certain matters including time periods and documents to be provided with applications. They are contained in the Director’s Specified List. The newly amended list was adopted from 1 September 2013.

Victoria
Maintenance must generally be carried out to the standard and frequency nominated on the building’s Occupancy Permit or Certificate of Final Inspection. Where the nominated maintenance frequency is AS1851-2005 or earlier, building owners and operators are permitted to commence maintenance to the requirements of AS1851-2012 without the need for a statutory approval.
The only conditions associated with this transition are that:

  1. Once the maintenance frequency of an essential safety measure has been varied to align with the requirements AS1851-2012, maintenance to this version of the standard must be continued on an ongoing basis; and
  2. A statement must be included on the Annual Essential Safety Measures Report to the effect that the relevant essential safety measure is now being maintained in accordance with AS1851-2012 in lieu of the version nominated on the Occupancy Permit or Certificate of Final Inspection.

Western Australia
Western Australia’s Building Regulations 2012 has been updated to now include the requirement for maintenance of buildings under Reg 48A. Building must be maintained in accordance with the relevant standards at the time of the most recent Certificate of Design Compliance. Testing maybe carried out to the AS 1851 standards at the time or with AS 1851- 2005 or AS 1851-2012.

/ SUMMARY
The body charged with the responsibility of ensuring AS 1851-2012 meets community and stakeholder expectations has made the necessary improvements to ensure that the key objectives of the revision were met, while the revised testing, servicing and maintenance frequencies, and the clarified fit for purpose as designed requirements have made it easier to understand and implement the requirements of the Standard.

Integral to the successful uptake of AS 1851-2012 will be how readily the States and Territories formally adopt the new Standard. For now Tasmania, Queensland and South Australia leads the way, and time will tell if this Standard achieves acceptance across the nation. Jurisdictional differences in the adoption and implementation of regulatory compliance regimes costs the property industry millions of dollars each year, and the time for national harmonisation in regulatory compliance is long overdue.

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