NSW – HENDRY building certifiers provide the following part extract of a (BCA Audit – Egress & Fire Safety) Building Code of Australia audit on the egress and fire safety measures of a building. The client required an insight into these two areas because of the life safety issues raised by the tenant under the Building Code of Australia (BCA).

The following BCA Audit – Egress & Fire Safety, will give building owners, building managers and occupiers of buildings an insight into a building surveyors assessment and presentation of issues and defects found.


In accordance with your instructions, a BCA Audit and site inspection of the building occupied by XXXXXXXXX as tenant at XXXXXXXXXX was undertaken on the XXXXXXXXX, for the purpose of preparing the following report to provide an assessment of the existing building for general compliance with the fire safety and egress requirements of Sections C, D and E of the Building Code of Australia xxxx (BCA).

Drawings available to assist in the BCA Audit assessment of the building are those unscaled drawings prepared by XXXXXXXXX of the evacuation plan for the building.

In accordance with your requirements and in consideration of the age of the building and given that no fire safety order has been issued by XXXXXXXXXX Council as you have advised, this BCA Audit is limited to a review of the principal fire and life safety matters pertaining to the BCA, on the basis that XXXXXXXXX may purchase the building, and does not address other matters such as adequacy of disability access provisions, health and amenity and energy efficiency issues normally found in a BCA Audit.

In this regard, a fire safety order, Order No. 6 under Section 121B of the Environmental Planning and Assessment Act 1979, would oblige the building owner, to ‘do or refrain from doing such things as are specified in the order so as to ensure or promote adequate fire safety or fire safety awareness’.

The only other statutory obligations for a fire safety upgrade would arise from assessment of a Development Application resulting in a BCA Audit, for either a change of use or alterations and addition to the building. In this regard, Clause 93 of the Environmental Planning and Assessment Regulation 2000 (EP&A Regulation) provides the Consent Authority, i.e. XXXXXX Council, with discretion when dealing with a development application for a change of use of a building without alterations or additions to an existing building.

The Consent Authority, in determining the development application, is required to take into consideration whether the fire protection and structural capacity will be appropriate for the building’s new use during their BCA Audit. Consent must not be granted unless XXXXXX Council is satisfied that the relevant Category 1 fire safety provisions will comply for the new use. For this building Category 1 means hydrants, sprinklers and possible fire brigade intervention facilities only.

BCA Audit                                                                         Egress & Fire Safety

In addition, Clause 94 of the EP&A Regulation provides the XXXXX Council with discretion when dealing with a development application for alterations to an existing building. The XXXXX Council, in determining the development application, is required to take into consideration after their BCA Audit, whether it would be appropriate to require the existing building to be brought into total or partial conformity with the BCA having regard to the adequacy of measures contained in the building for:

  • protection of persons using the building and to facilitate their egress from the building in the event of fire;
  • restricting the spread of fire from the building to other buildings nearby.

Accordingly, having regard to the above statutory triggers for a fire safety upgrade of the building, the following BCA Audit Assessment and recommended actions are provided as a guide to a voluntary fire safety upgrade for the building and likely statutory fire safety upgrade provisions that may result from any future Order or development application scenarios.

In accordance with your requirements, this BCA Audit report is limited to a review of the principal fire and life safety matters pertaining to the BCA.

The BCA Audit report is prepared based on the information provided by the XXXXXXXXX and is intended for XXXXXXX’s use only.

The existing building situated on the xxxxxxxxx and xxxxxxxxx of xxxxxxxxxxx Street, XXXXXXXXX is best described as a 3 storey office/ warehouse building having an irregular shaped floorplate containing a Ground level and two further storeys being First and Second floors. XXXXXXXXX, the building tenants, occupy the ground and first floor with the second floor presently sub leased.

The subject building has no setbacks to xxxxxxxx Street for its xxxxxxxx front and xxxxxxxx side facades and occupies a majority of the property other than an approximate 1.3 metre wide setback from its xxxxxxxx rear property boundary. A common party wall separates the subject building from the adjoining xx xxxxx Street. The subject building and the attached xx xxxxxxxx Street were constructed of the same design and presumably at the same time, and appear to have been either constructed as attached buildings or as a single building which has subsequently been subdivided with a common party wall constructed.

This BCA Audit report is limited to a review of the xx xxxxxxxx Street XXXXXXXX building only and does not include assessment of the attached xx xxxxxxxx Street building, other than the common party wall.

The BCA Audit found the subject building is constructed of load bearing masonry external walls, masonry internal loadbearing walls and columns, partition non loadbearing internal walls and timber frame flooring. As access to the roof was not available, accordingly a sloping or low pitched metal deck roof behind the parapet façade walls of the building is assumed.

The 3 storeys of the building, each having the same floorplate, are estimated to have approximately 300m2 of floorspace per storey and hence 1,000m2 or less of total floorspace. Existing uses of the building comprise carpark and warehouse and an office entry lobby and ascending stairs at ground floor level, and office uses only at first and second floor levels.

Egress for the building is provided by the single enclosed stairway at the eastern end of the building, being of timber frame construction and having timber balustrades. The stair discharges to within the ground floor entry lobby and is separated from the first floor level by a public lobby and from the second floor level by enclosing construction.

The BCA Audit established the following list of essential fire safety measures that exist for the building:

  • Emergency lighting;
  • Exit signs;
  • Smoke alarms (3 off observed);
  • Portable fire extinguishers (CO2 & AB(E));
  • Paths of travel to exit, exit stairway, passageways.


BCA Audit                                                                         Egress & Fire Safety

Building Use : Office, warehouse and carpark
Class of Occupancy : 5, 7b and 7a
Type of Construction Required : Type B
Rise in Storeys : 3
Storeys contained : 3
Effective Height : Less than 25m

BCA Audit Classification:


Ground FloorWarehouse and carpark7b and 7a
First FloorOffice5
Second FloorOffice5

The BCA Audit assessment below is based on visual inspection of the premises and review of the drawings provided with comments as follows:3.1 Section C – Fire Resistance and Stability3.1.1 The building with a rise in storeys of 3 is required to be of at least Type B construction with 120/120/120 Fire Resistance Levels (FRL) generally for the office use first and second floor external walls and 240/240/240 FRL generally for the ground floor warehouse external walls (refer Clause C1.1 and Table C1.1 of the BCA).

Specifically, Specification C1.1 of the BCA and Table 4 within, require the following FRLs for the building:

  • External walls (including the common party wall with attached No. 8):
    • Ground floor (Class 7b – warehouse) – 240/240/240 *1;
    • First and Second floors (Class 5 – office) – 120/120/120 *1;
  • Internal loadbearing columns (*2 excluding topmost second floor level):
    • Ground floor (Class 7b – warehouse) – 240/-/-;
    • First (Class 5 – office) – 120/-/-;
  • Internal loadbearing walls bounding public corridors, lobbies and sole-occupancy units (*2 excluding topmost second floor level):
    • Ground floor (Class 7b – warehouse) – 240/-/-;
    • First (Class 5 – office) – 120/-/-;
  • Any non loadbearing walls bounding – -/120/120; required fire-isolated stair shafts
  • Floors – -/-/- (Nil) *3;
  • Roof – -/-/- (Nil).

BCA Audit Note:

*1 Table 4 – ‘Type B Construction’ of Specification C1.1 has a range of FRLs required for loadbearing external walls dependant upon setback from fire source feature (the property boundary or far side of xxxxxxx Street), i.e. the 240/240/240 and 120/120/120 FRLs stated above relate to the xxxxx rear and xxxxx common walls of the building less than 1.5m from their respective property boundaries. The xxxxxxx front and xxxxxxx side facades of the building, known to be more than 3m and assumed to be less than 9m from the far side of xxxxxxx Street (the fire source feature), are required to have minimum FRLs of:

    • Ground floor (Class 7b – warehouse) – 240/90/60;
    • First and Second floors (Class 5 – office) – 120/30/30.

*2 Clause 4.1(g) of Specification C1.1 excludes internal columns and walls (other than shaft or fire walls) in the storey immediately below the roof, from requiring an FRL.

*3 Hence, the 3 storeys of the building represent one single fire compartment.

Should any future refurbishments or major alterations be proposed, it is recommended that the services of a structural engineer be sought to determine the existing FRLs of the building elements as part of a BCA Audit.

BCA Audit                                                                         Egress & Fire Safety

BCA Audit Assessment 

3.1.2 The existing carpets, coir mat carpets and vinyl flooring of the first and second floor levels and the existing carpets and coir mat carpets of the stair flights have unknown fire hazard properties (the ground floor warehouse/ carpark and the entry lobby have bare concrete and ceramic tile finishes respectively).

Any future refurbishment of the building must confirm compliance of proposed floor materials with the critical radiant flux (CRF) requirements of Specification C1.10a of the BCA. Given that the building is not sprinkler protected, all proposed floor materials (including carpet underlay) and carpet and vinyl floor coverings must have a CRF of not less than 2.2 kW/M2.

3.1.3 The building with its mixed warehouse, carpark and office uses and approximate total single fire compartment size of 1,000m2 maximum floorspace and 5,000m3 maximum volume, easily complies with the Type B construction fire compartment limits of 3,500m2 floorspace and 21,000m3 volume.

3.1.4 In accordance with Clauses C3.2 and C3.4 of the BCA, openings in a wall that are less than 3 metres from a side or rear boundary are required to be protected with external wall wetting sprinklers to automatic or permanently fixed closed windows, -/60/- fire windows automatically or permanently closed, or -/60/- automatically closing fire shutters. Doorways are required to be provided with -/60/30 self-closing fire doors and frames or self-closing doors with external wall wetting sprinkler protection.

However, these provisions do not apply to openings in walls on a boundary with a public road more than 6m wide such as is assumed to be the case for the xxxxxxx Street xxxxx front and xxxxx side building facades. It is recommended that the width of xxxxxxx Street be confirmed.

As the xxxxxx rear façade of the building is within 3m of the boundary, measured at approximately 1.3m, protection of the numerous window openings and single door opening is required.

Presently, a single external door exists at first floor level in the xxxxxx rear wall. This door, adjacent to the amenities and kitchen area of the first floor, was used to serve an external exit stair within the rear 1.3m setback of the building, leading to xxxxxxxx Street to the xxxx. This external exit stair has at some stage been demolished by the building owner, presumably due to it being in a dilapidated and unsafe state. Other than the real life safety risk that this doorway poses, albeit that it is presently locked and has warning signs that it is not to be used, this doorway is required to be protected in accordance with the above requirements given that it is less than 3m from the xxxx xxxxx property boundary.

Accordingly, due to these two life safety and fire protection non compliances that the doorway represents, it is strongly recommended that this doorway be removed and replaced with ‘two way’ -/120/120 FRL masonry or lightweight infill wall construction.

With regard to window openings of the northern rear wall, casement timber frame windows exist at the ground floor level warehouse/ carpark and at both the first and second floor level office floorspace and amenities areas, albeit that the windows at first floor level have previously been infilled with plasterboard. Irrespective that the nearby xxxxxx external wall on the boundary of the high rise building under construction to the xxxx has no openings, the existing windows in the xxxxx façade of the subject building represent a non compliance with the abovementioned protection of opening requirements for windows.

Accordingly, if future major refurbishment works were to be proposed for the building, it is recommended that the windows be removed and infilled with ‘two way’ -/120/120 FRL masonry or lightweight infill wall construction to achieve ‘deemed to satisfy’ compliance. Alternatively, if there are any windows that are desired to be retained, it will be necessary for a performance based Alternative Solution to be developed by the applicant, justifying retention of the unprotected windows and incorporated as part of any proposed Development Application process. Depending on building works, a future BCA Audit may be required.

BCA Audit                                                                         Egress & Fire Safety


3.2 BCA Audit Section D – Access and Egress

3.2.1 The BCA Audit reveals that the single exit stairway of the building connects three storeys, it is required by Clause D1.3 of the BCA to be a fire-isolated exit stairway. However, the stairway is presently not a compliant fire-isolated stairway as the following non compliances/ unknown parameters exist:

a) the stairway is enclosed at second floor level by plasterboard wall construction that is assumed not to achieve the required FRL of -/120/120 (refer to item 3.1.1 above);

b) the stairway is enclosed at first floor level by plasterboard stair lobby wall construction that is assumed not to achieve the required FRL of -/120/120 (refer to item 3.1.1 above);

c) the stairway is enclosed/ separated at ground floor level from the warehouse/ carpark by plasterboard entry lobby wall construction that is assumed not to achieve the required FRL of -/120/120 (refer to item 3.1.1 above);

d) the underside of the first ascending stair flight is not separated from the ground floor warehouse/ carpark by 120/120/120 FRL construction in accordance with Table 4 of Specification C1.1 of the BCA;

e) the internal doorways which open onto the stairway from all storeys are not self-closing -/60/30 FRL fire doors in accordance with Clause C3.8 of the BCA;

f) a telecommunications cupboard exists within the stair lobby at first floor level which does not comply with Clause D2.7(a) of the BCA;

g) the timber frame construction and timber balustrades of the stairway do not satisfy the non combustible and structural independence requirements of Clause D2.2 of the BCA.

Accordingly, unless compliance is confirmed/ achieved with items a) to g) above, by either a ‘deemed to satisfy’ approach and/ or a performance based Alternative Solution approach (involving fire engineering and a Development Application to XXXXX Council), the stairway is not fire-isolated as required by Clause D1.3 of the BCA. This is a major shortfall in the building’s overall level of fire safety.

3.2.2 However, there is a concession within Clause D1.3(b)(iii) of the BCA that allows the existing stairway to remain as a ‘deemed to satisfy’ non fire-isolated 3 storey stairway. The concession requires fire separation of the stairway from the ground floor level only, by:

  • achieving -/60/60 FRL non loadbearing separating wall and underside of stair flight construction between the ground floor warehouse/ carpark and the stairway;


  • removing the access door between the warehouse/ carpark and the ground floor stair entry lobby as the stairway is not permitted to provide egress for, or access to the third additional storey. This would necessitate the provision of a new external exit door from the warehouse/ carpark directly to xxxxxxx Street as the existing exit route from warehouse to stair entry lobby is lost and the existing roller shutter vehicle entry door does not represent a complying exit door (given that the warehouse/ carpark has a floorspace in excess of 200m2).


  • providing a sprinkler system complying with Specification E1.5 of the BCA and AS 2118.1 throughout the building.

As a result of the BCA Audit, our recommendation is to upgrade the fire-isolation of the stairway at all levels.

3.2.3 Travel distances throughout the three storeys of the building, accounting for the existing partition walls and room layouts, appear to comply as best as can be determined on site, with the 20m maximum distance to a single exit (the entry to the enclosed stairway) requirement of Clause D1.4 of the BCA.

3.2.4 Generally, paths of travel throughout the building comply with the 1,000mm minimum required by Clause D1.6 of the BCA.

3.2.5 Any distribution boards within the building that are located in a corridor, hallway or lobby leading to the exit stairway are required to be enclosed in non combustible construction or a fire-protective covering with doorways or openings suitably sealed against smoke spreading from the enclosure in accordance with Clause D2.7 of the BCA.

The existing telecommunications cupboard that is within the first floor stair lobby (detailed at item 3.2.1(f) above), must either be relocated outside of the stairway if the stairway is to be fire-isolated (refer item 3.2.1 above), or enclosed in the same manner as is detailed above for distribution boards, if the stairway is to be a non fire-isolated stairway (refer item 3.2.2 above).

BCA Audit                                                                         Egress & Fire Safety

 BCA Audit Section D – Access and Egress

3.2.6 The riser (generally 190mm high) and going (tread) dimensions of the stair flights of the stairway comply with the limitations and 2R+G formula of Table D2.13 of the BCA. Notwithstanding that the 190mm high risers are at the upper limit of allowed steepness of stair flights, this steepness results in a perception that the stairs are unsafe.

In addition, the single stair flight connecting the first and second floor levels has 20 consecutive risers which exceeds the maximum 18 permitted by Clause D2.13. This exacerbates the perception that the stairs are unsafe.

The stairs connecting the ground floor level to the first floor level are separated into three complying stair flights by two mid landings.

The four tiled stairs at the ground floor entry lobby are non compliant winder stairs with irregular going dimensions. Although required to have constant going dimensions, these winder stairs are easy to negotiate and do not feel unsafe.

Although predominantly carpeted, except for the four tiled stairs at the ground floor entry lobby, all stair nosings are fitted with non slip strips, which satisfy the non slip requirements of the Clause.

3.2.7 The 800 mm height of the 3 rail timber balustrades above the stair nosings to the stair flights does not comply with the 865 mm minimum required by Clause D2.16 of the BCA. Neither does the 945 mm height of the 2 rail timber balustrade at first floor landing level comply with the minimum 1,000mm required by Clause D2.16. In addition, the balustrade throughout the stairway has openings between the rails which do not comply with the 125mm maximum opening size permitted by Clause D2.16 for office use buildings.

As this stair is the only egress and general circulation stair for the building, compliance would require the replacement or major modification of these balustrades.

3.2.8 The final exit door from the building, all doors to the stairway and doors in the path of travel are required to have lever only single hand action door handles, in the direction of egress, in order to comply with Clause D2.21 of the BCA.

Currently, the knob handles to the entry doors to the stairway at ground, first and second floor levels must be replaced with lever type door handles. Likewise, the knob handles predominant throughout the second floor level and the amenities areas of both office floor levels should also be replaced with lever type door handles.

3.2.9 The deadbolts fitted to the male and female toilet entry doors at first floor level must be removed. The external security shutter of the entry lobby to the building represents a life safety risk and non compliance with Clause D2.21 and should be removed.

BCA Audit                                                                         Egress & Fire Safety

BCA Audit Section D – Access and Egress 

3.2.10 Dependant upon items 3.2.1 and 3.2.2 above, if the stairway is proposed to be fire-isolated, signage complying with D2.23 of the Building Code of Australia must be provided to all required fire doors providing direct access to fire stairs and passageways and doors discharging from such. Signs must consist of capital letters not less than 20 mm high in a contrasting colour to the background and state:

  • for a self-closing door accessing a fire-isolated stair:
  • for an automatic door held open by an automatic hold open device:
  • on both sides of a door discharging from a fire-isolated exit:

In addition, notices complying with Clause 183 of the Environmental Planning and Assessment Regulation 2000, ‘Offence relating to fire exits’ must be displayed adjacent to the doorway providing access to but not within the fire-isolated stairs at each level.

3.3 BCA Audit Section E – Services and Equipment

3.3.1 The building is not served by fire hydrants other than the street hydrants of xxxxxxx Street, located approximately xxm to the xxxx and xxm to the xxxx of the entry lobby to the building. Given that the building has a total floorspace in excess of 500m2, hydrants are required by Clause E1.3 of the BCA and it is unlikely that the street hydrants alone will provide for complying coverage to the building in accordance with AS 2419.1-2005, albeit that this is an operational issue faced regularly by the NSW Fire Brigades in older buildings.

3.3.2 The building is not served by fire hose reels, which given that the building represents one fire compartment in excess of 500m2, does not comply with Clause E1.4 of the BCA. Compliance necessitates the installation of fire hose reels to serve all storeys in accordance with Clause E1.4 and AS 2441-2005.

3.3.3 Portable fire extinguishers of CO2 or AB(E) type are located on each floor level in the vicinity of the exit stairway and are well positioned to provide complying coverage to the building in accordance with Clause E1.6 of the BCA and AS 2444-2001.

3.3.4 As the building has a rise in storeys of 3 and Class 5-office, 7a–carpark and 7b-warehouse uses, the building is required to be provided with a smoke hazard management system in accordance with Clause E2.2a and Table E2.2a of the BCA which requires, either:

  • automatic stair pressurisation (if the stairway is to be fire-isolated); or
  • zone smoke control system in accordance with AS/NZS 1668.1-1998; or
  • automatic smoke detection and alarm system complying with Specification E2.2a of the BCA; or
  • sprinkler system complying with Specification E1.5 of the BCA.

As the building is comprised of a single fire compartment, a zone smoke control system is not applicable and would not achieve compliance with Clause E2.2a. Likewise, a stair pressurisation system would only be applicable if the stairway were to be a fire-isolated stairway (refer to item 3.2.1 above).

Inspection noted a partial smoke alarm system exists for the building as a single smoke detector is located at the western corner of the first and second floor levels and within the ground floor entry lobby. However, this minimal system would not achieve compliance with Specification E2.2a of the BCA.

Accordingly, it is necessary that a smoke detection and alarm system be installed throughout the building in accordance with Specification E2.2a of the BCA which requires compliance with AS 1670.1 and the provision of a building occupant warning system (system monitoring is not mandatory for office and warehouse buildings).

Alternatively, a sprinkler system throughout the building would satisfy the requirements for smoke hazard management plus negate the need for fire-isolation of the stairway (refer to item 3.2.2 above).

BCA Audit                                                                         Egress & Fire Safety

BCA Audit Section E – Services and Equipment 

3.3.5 The BCA Audit established that the building is provided with some emergency lighting and exit signs however, a few additional wayfinding exit signs are recommended and additional emergency lights are required within the stairway and variously throughout the floor levels to achieve compliance with the location and spacing requirements of Part E4 of the BCA and AS 2293.1-2005.

3.3.6 In accordance with Clause NSW I1.1 of the BCA and Part 9 of the Environmental Planning and Assessment Regulation 2000 (EPA Reg), evidence in the form of an Annual Fire Safety Statement for maintenance of each Essential Fire Safety Measure should be available.

The Fire Safety Statement is required to confirm that the essential fire safety measures have been inspected and tested by a competent person periodically as required, and were found to be capable of performing to a standard not less than that required at the time of installation. The “standard” means the standard of design and installation and not the maintenance code. For example, the standard for emergency lighting would be AS/NZS 2293.1.

The Fire Safety Statement is required to be submitted to the Sydney City Council, a copy (together with a copy of the current Fire Safety Schedule) to the Commissioner of the NSW Fire Brigades and a further copy (together with the current Fire Safety Schedule) is required to be prominently displayed in the building.

At the time of inspection, no Annual Fire Safety Statement and Schedule was displayed within the building nor was one provided for our review.


The building does not comply with the main fire safety requirements of the BCA particularly in terms of fire hazard properties of floor materials and coverings, protection of openings, construction of exits and active fire safety measures. It is recommended that all items raised by this BCA Audit report be reviewed and addressed.

With regard to XXXXXXX’s potential purchase of the building, and XXXXXX Council’s powers to require a fire safety upgrade after the BCA Audit by Order or via the Development Application / Construction Certificate process, it is recommended that the following major cost issues discussed above in the BCA Audit be considered carefully by XXXXXXXXX:

a) Unprotected window and door openings of xxxxxx rear wall (refer to item 3.1.4);

b) Confirm width of xxxxxxxxx Street (6m minimum width required to negate protection of openings of xxxxxx front and xxxxxxx side facades – refer to item 3.1.4);

c) Non fire-isolated stairway connecting 3 storeys should be fire-isolated
(refer to items 3.2.1 & 3.2.2);

d) Non complying 20 riser stair flight and non complying balustrades
(refer to items 3.2.6 and 3.2.7);

e) Lack of complying hydrant and fire hose reel coverage (refer to items 3.3.1 & 3.3.2); and

f) Lack of required smoke hazard management system – smoke detection and alarm or sprinkler system throughout recommended (refer to items 3.3.4).

Not being as of high importance under the BCA Audit, the following issues should nevertheless be considered by XXXXXXXXX:

g) Critical radiant flux requirements for floor materials and coverings (refer to item 3.1.2);

h) Non combustible construction or a fire-protective covering required for distribution boards and telecommunications boards/ cupboards (refer to item 3.2.5);

i) Lever type single hand action door handles are required (refer to item 3.2.8);

j) Remove deadbolts to the doors of the first floor amenities and remove the security shutter to the ground floor entry lobby (refer to item 3.2.9);

k) Additional emergency lights and exit signs are recommended (refer to item 3.3.5);

l) A Schedule of fire safety measures and an Annual Fire Safety Statement for the building must be issued by the building owner on an annual basis, forwarded to xxxxxxx Council and the NSW Fire Brigades and prominently displayed in within the building (refer to item 3.3.6).

We trust that these BCA Audit comments will adequately address your requirements and should you need clarification of any of the matters raised herewith, please do not hesitate to contact me by phone on (02) 9262 1565 or by email (xxxxxxxxx).

BCA Audit                                                                         Egress & Fire Safety