REG 10 – Commissioning of Buildings Under the Building Regulations2017-06-19T16:31:24+00:00

March 2017

Commissioning of Buildings under the Building Regulations

AUST  Hendry advises building surveyors are often called upon to consider departures from codes and the building regulations after building works are complete. Unfortunately supervision during a building project is diminishing, which means designers are not supervising, or not allowed to monitor the installation of systems to their designs. This can result in untimely delays in obtaining a final sign off should faults be identified by the building surveyor.

The following briefly outlines the direction from which a Building Surveyor operates when performing a final inspection and signing off a project.


The role and responsibilities of a Building Surveyor are set out in an Act of Parliament and subsequent regulations in each state and territory. The law imposes a community interest and duty of care obligation on the Building Surveyor and makes them responsible to ensure buildings are safe, and are suitable for occupation

The legal obligations empowered by the legislation, in turn set out a hierarchy of control on a development through legislation. The requirements of the legislation can sometimes be at odds with industry best practice or the use of newly issued codes or Standards, e.g. NFPA Standards, Building Code of Australia (BCA), Australian Standards (AS), Approvals and Building Regulations.

Building Control Legislation in Australia is structured as follows:
1. Acts
2. Regulations
3. Building Code of Australia (BCA)
4. Australian Standards (AS)

Whilst industry may simply rely on codes and standards, the effect of legislation can modify or amend these standards. This is the case where for example the BCA affects changes on AS 2118.1 for sprinkler systems and AS 1670.1 for occupant warning and provision of detectors in some buildings, e.g. Class 9a buildings. Industry, however, says that they should also be designing to the latest Australian Standard or NFPA Standard, whereas the BCA states which edition of a Standard that should be used in the design.  In this regard the BCA may well be calling up an earlier version of a particular standard.

Applying a non BCA referenced standard is a departure from the BCA which needs to be properly considered and addressed.  To avoid any misunderstandings the Building Surveyor needs to be made aware of what the design is based on and whether subsequent changes in construction have occurred to Australian Standards other than those specified in the BCA or the actual approval.

Most competent Building Surveyors will accept an alternative solution to adopt standards other than those specified in the BCA, but they must be informed of your intentions early in the design process under the building regulations.

It is also important to note that where an alternative solution applies because of the adoption of a different standard to that specified in the BCA, the long term effect could be reflected in the ongoing essential safety measures maintenance regime for a building following the issue of a final certificate, occupancy permit, certificate of classification, etc. at the end of the project by the Building Surveyor.

An alternative solution acceptable to the Building Surveyor could also have an impact on the commissioning of an installation, factors which need to be made known to the contractor.


In the increasing high technology building environment, designers and contractors need to become more involved with the intricacies of a performance design or referral authority approved departures prior to lodging a building permit application with the Building Surveyor.  This is of particular importance during the construction phase where typically, what is being built is not necessarily what is reflected in the original approved design.

Buildings such as aged care facilities, shopping centres, places of public assembly, hospitals and multi-storey buildings are particularly at risk of as built changes, since they are required to have complex fire safety features that are included in passive construction or active systems, as set out in the originally approved design/building permit by the Building Surveyor.

Building Surveyors and others who have spent enormous time and effort to have a design documented to an approval stage often find a Contractor, Owner, Builder or Project Manager that is not fully informed, have affected changes during construction which have a negative impact on the original design intent.  To overcome this, it is important for Design Consultants to be engaged to supervise, inspect and approve installations progressively during the construction of a building and for Contractors, particularly Design and Construct contractors, to constantly query that their installation is complying with the original approval. Further approvals and permits by a Building Surveyor must be put in place should a design be changed.

Building Surveyors see this as being an area of concern when Consultants are not adequately engaged to inspect the work relative to their expertise.  This causes the Building Surveyor to escalate their due diligence when faced with the completion phase of a project.


Inspecting and signing off a project can be a time consuming and complex task.  Unfortunately from a Building Surveyor’s perspective, too little regard is given to progressively documenting the actual construction and testing an installation during a project, resulting in embarrassments and time driven contract pressures not allowing sufficient resources to be devoted to commissioning at the end of a project.

The Building Surveyor considers the signing off of a project as being a separate ‘permit’ in its own right.  This is presently the case in Victoria at the moment as an applicant must submit a Form 5 ‘Application For Occupancy Permit’.

Consequently, an acceptable level of documentation will be demanded by the Building Surveyor.  This means that if you have failed to collate evidence of the installation during construction or have not followed the approved plans etc., you may be faced with significant delays and the need to back track and explain what was installed, to update permits and to undertake rectification of unacceptable work.


An experienced Building Surveyor is well versed with this important step in the project and they will also ensure the owner  liaises with the relevant authorities such as the Fire Brigade. In Queensland and the Northern Territory, for example, the Fire Service is required to undertake a fire inspection if involved in the approval stage.

Most Fire Brigades and Building Surveyors require verification of meeting requirements of Fire require Engineers solutions and that the construction reflects those requirements. Fire Brigades are also becoming increasingly diligent in this area stage and  may want to inspect and witness commissioning tests.

In New South Wales and Victoria for example, if a fire engineer has been originally engaged to issue an alternative solutions report, the Building Surveyor/ Building Certifier and the Fire Brigade may require a sign off on the completed project by that Fire Engineer who must also inspect the work and perhaps witness testing.


So with the scene set, what are the expectations for the Whole of Building Commissioning and how should this be achieved.

When considering this aspect, one could consider two types of projects:

  • One that is in essence an alteration to an existing installation.
  • New installations whether simple or complex.

It is possible provided adequate competencies are in place, when dealing with alterations to an existing installation, for the Building Surveyor to accept Contractor statements together with their own inspection regimes.  The Building Surveyor will also check that the original building permit documents have been complied with. Independent verification could be required for some installations.

For new work, in particular complex installations, the Building Surveyor is likely to require Consultant statements outlining their supervision of the work, Contractor statements and independent verification by a suitably qualified and experienced person, together with documentary evidence for the work done by the Contractor. An independent person could be one that is listed by the Australian Fire Safety Practitioner Accreditation Board or other Registered Practitioner. The competency of this design is critical since a poor sign off will only delay completion.


The Australian Fire Safety Practitioners Accreditation Board has a list of practitioners who are accredited to have proficiencies in certain key categories.  Typically, these are:

  • Hydrants and hose reels
  • Automatic sprinkler systems
  • Detection and alarm systems
  • Portable fire equipment
  • Fixed suppression systems
  • Emergency warning and evacuation
  • Smoke exhaust systems.

You will note that mechanical zone smoke or stair pressurisation systems are not listed therefore the person or organisation to provide the independent verification for these systems will need to be approved by the Building Surveyor.  Their credentials and experience would need to be established and agreed.


If one considers a typical multi-storey building, the whole of Building Commissioning will usually involve the key steps outlined below. (The same philosophy will apply to other projects however the depth to which one may go to will alter).
Contractors and Consultants would be expected to follow the same logic prior to the Building Surveyor or a Fire Brigade attending site.

Step One – Commissioning Phase

  • Verification and check that installation complies with approved plans or if not, amended approvals are in place.
  • Carry out commissioning of individual installations by the contractor.
  • Document commissioning.
  • Inspection and report by relevant consultant.
  • Independent certification.
  • As Built Plans

Step Two – Verification Phase

  • Inspection of installations by the Fire Brigade and Building Surveyor
  • Witness of tests by Building Surveyor and the Fire Brigade
  • Integrated testing of complete installations
  • Fault rectification and certification
  • Re-inspection and testing
  • Product Information

Step Three – Sign Off Phase

  • Labeling, identification, signage, tactical fire plans, etc. in place
  • Test Certificate
  • Submission of test reports, component information, as built drawings, commissioning reports, consultant reports and independent certification, etc. to Building Surveyor
  • Inspection and report by the fire engineer
  • Submission to Fire Brigade
  • Fire Brigade approval and sign off
  • Building Surveyor final approval leading to project sign off
  • Witness that on site documents are provided
  • Validation of adhering to alternate solutions
  • Tactical Fire Plans

Historically, Building Surveyors were comforted in the knowledge that projects were being well inspected and safeguards were in place to ensure projects were completed in compliance with the approved plans. This happened through  the understanding that the Consultant was knowledgeable and doing regular inspections, the
Contractor performing the work was competent, the Project Manager had measures in place to validate the work and the Owner had their Clerk of Works on site.

Today, there is more reliance on Design and Construct where Contractors need to operate as if they were Consultants.  This means that the Building Surveyor must place more emphasis on inspections and proving the compliance of installations towards the end of a project and their commissioning.

Consequently, a Building Surveyor will be requiring an Owner or Builder or Project Manager to furnish a significant amount of documentation to prove the installation complies.  This in turn means that consultants, who may not be engaged sufficiently during the project and the contractors must more adequately document and prove what is being installed as they go.  Doing catch up from a list from a final inspection issued by a Building Surveyor at the end of project may be too late.

Certain states may also require the completion of mandatory forms by each contractor, e.g. Form 16 in QLD.

The philosophy outlined above will equally apply to other installations in a building such as:

  • Smoke and thermal detection systems (includes VESDA) and occupant warning systems
  • Smoke control and exhaust systems (arcades, atriums, large buildings)
  • Hydrants, hose reels, fire mains, pump sets and static water supplies
  • Sprinkler systems
  • Emergency lights and exit signs (too a lessor degree when they are a single point unit)
  • Stair pressurisation
  • Lifts (including emergency lifts)
  • Kitchen exhaust systems
  • Emergency warning and intercommunication systems
  • Fire rated switchboards, sub boards and cabling.

Of course, with many buildings containing complex active fire safety systems, where each contractor does their own bit, it is mandatory that a number of integrated fire alarm tests are conducted (Full Function Fire Test) to validate system functions. This is usually based on a fire alarm being triggered via a number of inputs and the reaction of each installation is to be witnessed for correct operation.

Fire alarms would be triggered through various smoke detectors for example and one would note whether the smoke detector locations are correctly display at the fire indicator panel. Similarly, sprinkler activation would be simulated and the response of installation recorded and measured.

The Building Surveyor will expect this testing to be properly documented and presented as a report and certification.

One may question why the Building Surveyor will go to such lengths of requiring adequate proof of operational compliance of installations in buildings.  It is important for Consultants, Contractors and Facility or Project Managers, etc. to note that the Building Surveyor will issue a list of Essential Safety Measures applying to the building or the building work either at the issue of an approval or at the issue of an occupancy permit, etc., depending on your State or Territory requirements.

It is expected by law, that an Owner (occupier) must maintain the items listed to the standard and frequency specified in the schedule.  This means that if an installation is poorly installed, or does not comply with the approval or does not perform as required, how is an Owner expected to maintain the installation to the correct standard?

The discovery of poor quality or non compliant installations leads to litigation and practitioners will be disciplined for their inappropriate actions by the relevant State/ Territory Regulatory Boards.

The flow down consequence is that there is a duty of care obligation on the Building Surveyor (putting aside negligence) and this means that the Building Surveyor will not sign off a project unless completely satisfied with the compliance and performance of its installations. Compliance in this case means compliance with the BCA and the approved documents.

Whilst this might sound overwhelming, experienced Contractors, Consultants and Project Managers will foresee these issues and plan their installation and commission phases to incorporate establishing proof of compliance and demonstrable operational compliance early during the completion of a project.

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