REG-26

AS1857-2012 Cost Savings and Potential Pitfalls

VIC  Managers should make themselves aware of recent changes to the Building Regulations 2006 (May 2016) that allow the adoption of AS1851-2012 Routine Service of Fire Protection Systems and Equipment. Managers need to acquaint themselves with the new process and other factors when changing over a building’s nominated Essential Safety Measure (ESM) maintenance regime to the AS1851-2012 standard.

In Victoria, buildings or parts thereof, are categorised into two sections under the Building Regulations as either Subdivision 1 or Subdivision 2 buildings.

/ SUBDIVISION 1 BUILDINGS
Buildings constructed or altered after July 1994 fall within the Subdivision 1 category. This category identifies the ESMs contained in the building via an Occupancy Permit (OP) or Maintenance Determination (a list attached to the Certificate of Final Inspection (CoFI)). The frequency and maintenance standard for each ESM must be listed on these two statutory documents issued by the relevant building surveyor when the building is suitable for occupation.

The new amendment to the Building Regulations, Regulation 1205A, allows the maintenance of an ESM that is listed as a condition of an existing OP or Maintenance Determination to be maintained in accordance with Regulation AS1851-2012, without the need to obtain a building permit.

Hendry advises managers to obtain written consent from the owner of the building for the following:

  • To adopt and continue to apply the maintenance standard and frequency nominated by AS1851- 2012, for the relevant ESM.
  • Include a ‘new statement’ in the Annual Essential Safety Measures Report (AESMR) stating that maintenance will now comply with AS1851-2012 (specifying the ESMs concerned).

/ SUBDIVISION 2 BUILDINGS
Buildings having a Subdivision 2 status are buildings constructed prior to July 1994. Managers must ensure that ESMs are maintained to fulfill their purpose. This requirement remains unchanged and the owner can adopt any maintenance standard applicable however for best practice, a good benchmark is AS1851-2012.

/ ANNUAL ESSENTIAL SAFETY MEASURES REPORT
Managers must also be aware that both Subdivision 1 and Subdivision 2 buildings require an AESMR to be signed and issued each year.

Adopting AS1851- 2012 (which reduces ESM maintenance costs) via the AESMR also is a legal reminder for owners of Subdivision 1 buildings that egress inspections and passive inspections are also required each year as stated in the Maintenance Determination forming part of the OP or CoFI.

ADOPTING AS1851-2012
Managers should consider the following when upgrading to AS1851-2012:

  • Additional service requirements may now have to be considered such as evacuation procedures and diagrams, including full function fire testing if specified in the OP or CoFI.
  • The egress type ESMs such as paths of travel etc are not regulated by AS1851-2012 and therefore state legislative requirements need to be adhered to. The Victoria Building Authority advises building surveyors to nominate four 3 monthly inspections for egress type ESMs in the OP and/or CoFI.
  • Building surveyors nominate the egress ESMs in the OP and/or CoFI and the owner must reflect this in service contracts and on the AESMR.
  • When a building owner/manager signs (or delegates the signing to an agent) the AESMR to achieve cost reductions under AS1851-2012, they are further acknowledging that they are aware that four egress inspections and one passive inspection are required and have been performed each year.
  • There is a risk that if maintenance and inspections have not been undertaken fully in accordance with AS1851-2012 and the current OP/CoFI, the AESMR may not be signed by the responsible contractor/agent.
  • An ESM list should be created to include the AESMR altered ESMs frequencies and the remaining original full list of ESMs. (This may be lacking in the OP/Maintenance Determination or does not exist). This would serve as the necessary documentation to form part of the AESMR.
  • Existing or current maintenance contracts need to be reviewed/updated. Advice may be required to assist procurement processes and change overs.
  • Reducing the frequency of tests may reduce maintenance expenditure i.e. from weekly to monthly maintenance of sprinkler systems.
  • Insurance companies should be notified of any changes to the maintenance regime.
  • Any variations from the original approved building design contained in an OP or CoFI stage must be reviewed i.e. if a fire engineering report or responsible authority requires a greater level of performance or additional testing, then this must be followed. This is nominated as a condition on the OP or CoFI, and in many cases, they are derived from an alternative solution being proposed during the design process and accepted by the building surveyor when issuing the building permit. Care should be taken to ensure that altering maintenance frequencies as described above will not contradict the requirements of any existing alternative/ performance solutions or authority requirements.

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