AS 1851-2012 and your Building

AUST – Hendry advises building owners, property managers, facility managers and facility engineers to be well aware of the safety measures in buildings; such as fire protection systems and equipment that need to be tested, serviced and maintained under the AS 1851 in order to ensure they functioning as designed. AS 1851 addresses the routine servicing of fire protection systems and equipment in Australia. Building owners are required to comply with the AS 1851-2005 or the latest AS 1851-2012. This article discusses the features of the new 2012 AS 1851, and how will it apply to your building.

History of AS 1851

AS 1851 in its various forms, has a long and chequered history, appearing first around 1939 and expanding to multiple sections through the 1980’s and 1990’s. The 2005 version (currently used in a majority of instances) was completely re-written and appeared as one document in September 2005 as “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 evolution, but in practice, regulators in the States and Territories had serious issues with the complex and costly operational requirements interpreted with the AS 1851. 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, AS 1851 had a major revision, and 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

Key changes in the redesign of the AS 1851-2012 were:

  • a simplification of the structure, making it easier for stakeholders to understand
  • Restructured documentation requirements for reporting.
  • A more concisely defined relationship between initial installation, routine service and annual regulatory compliance.
  • 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.
  • Extensively revised records (logbooks, tags, labels and summary records) and reporting requirements.
  • The removal of the ambiguity relating to current design versus the design applicable at the time of original approved systems installation, (that is, the approved design).
  • Several new appendices have been included to expand on Section 1 content— baseline data.

AS 1851-2012 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. AS 1851-2012 requires evidence in the form of records and reports, with the documentary evidence intended to support responsible entities in satisfying regulatory obligations.

Regulatory requirements in States and 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. Each State or Territory establishes this control through an Act of Parliament (Building Act), and this is their primary form of legislation. These Building Acts in turn, can authorise the making of Building Regulations to administer the Building Act. Put simply, the Building Act established the principles and objectives for compliance, while the Building Regulations detail how these objectives are achieved. Building Regulations in turn, can reference external documents such as the Building Code of Australia (BCA) or Building Standards in whole, in part or in modified form, and 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. A Building Act can “reference” Building Regulations, which in turn can “reference” Building Codes of Australia 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 have 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.

State or TerritoryDefined Term for Fire Protection Systems and Equipment
Commonwealth – National Construction Code (Building Code of Australia)Safety Measures
Australian Capital TerritoryActive Fire Safety Systems
New South WalesEssential Fire Safety Measures
Northern TerritorySafety Measures
QueenslandFire Safety Installations & Special Fire Services
South AustraliaEssential Safety Provisions
TasmaniaEssential Safety and Health Features / Measures
VictoriaEssential Safety Measures
Western Australia(No specifically defined term)

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
  • A variation or addition to I Volume 1  Part I of the Building Code of Australia
  • 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 Certificate, (which specifies safety measures maintenance requirements and makes the use of the edition mandatory).

Implementation of AS 1851-2012 in your State or Territory

The following provides a summary on the adoption and use of AS 1851-2012 in your State or Territory 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 While not directly prescribed within the Northern Territory Fire and Emergency Act or Regulations, the Northern Territory has a variation to Part I Equipment and Safety Installations of the BCA, which details the maintenance to be carried out to safety installations within a building. These generally nominate earlier versions of the Standard.

Queensland  MP 6.1 states it is mandatory for testing be carried out to AS 1851-2005 or older versions as appropriate. Queensland Development Code and Regulations would need to be changed to nominate AS 1851-2012.

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 current version of SA 76 lists pre-1851-2005 editions.

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 applies from 1 September 2013.

Victoria – Testing to AS 1851-2005 may only be used if this Standard is nominated on the building Occupancy Permit or Certificate of Final Inspection (building approval documents), or for buildings constructed before 1994. It is expected that testing to AS 1851-2012 would require amendment to existing building approval documents to permit testing to the new Standard.

Western Australia – There are currently no restrictions on which version to use.

In 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 AS 1851-2012.

Integral to the successful uptake of AS1851-2012 will be how readily the States and Territories formally adopt the new AS 1851-2012. For now Tasmania leads the way, and time will tell it 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.