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Stakeholder Engagement – Summary of findings Fire Safety Review 2014 BUILDING SYSTEMS PERFORMANCE BRANCH

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Page 1: Summary of Findings Fire Review

Stakeholder Engagement – Summary of findings Fire Safety Review 2014

BUILDING SYSTEMS PERFORMANCE BRANCH

Page 2: Summary of Findings Fire Review

MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT 2

SUMMARY OF FINDINGS

Introduction The Ministry of Business, Innovation and Employment (MBIE) is currently undertaking an extensive review of fire safety regulations and practice in New Zealand.

The purpose of the review is to inform the development of a strategic direction for MBIE's fire safety work, drawing on the views and experiences of practitioners. The review covers the building life-cycle from project inception to demolition, and considers alterations, changes of use and subdivisions. It draws on perspectives from stakeholders at each stage in the building life-cycle. It also draws on research elements to inform MBIE where improvements can be made in fire safety, cost, and practical outcomes.

To date, MBIE has completed two phases of stakeholder engagement, seeking feedback from across the sector in relation to the issues that have been surfacing over the past two years.

Phase one involved holding feedback sessions in five locations across New Zealand. Phase two involved a questionnaire that was designed to drill deeper into the key issues raised during phase one.

This report details feedback received during both phases, detailing the key issues. This information will be used in planning the direction in the Fire Review over the next six months, year, two years and beyond.

Phase one – Stakeholder Feedback Sessions

MBIE briefing

Key MBIE staff was briefed in September 2014 of concerns being expressed from the sector about the implementation of the 2012 Fire Safety Building Code changes and to seek feedback on:

The upcoming fire review stakeholder engagement approach and activities

Key issues

Feedback and views expressed during this session has been included in the broader feedback process. The feedback provided had been broadly received as enquiries since the new Code came into effect in July 2013. Key points included:

Errors within Acceptable Solutions and Verification Method documents

Performance based Code versus prescriptive elements

Inconsistencies in approach from fire engineers, designers and BCA’s on a national scale

Concern about availability of fire engineering or fire sector resources nationwide

Code and associated documents have been open to interpretation, which has led to inconsistencies across many areas

Sector is vocal, however with disparate views. Varying opinions and issues make it difficult to determine the exact extent of any given issue

Would like to see better sector coordination and willingness to work with MBIE to address issues

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External stakeholders

Stakeholder Engagement sessions were held across five locations including Christchurch, Wellington, Auckland, Dunedin, and Tauranga. More than 250 participants attended all five sessions and provided feedback on five key questions:

What is working well with the current regulations?

What is not working?

What have been the consequences?

What are the priorities in resolving any issues?

‘What Else’

The feedback received at each session was collated and reviewed, and the following graph summarises the most common issues raised at each session. These issues were then used as the priority themes in the phase two questionnaire. The top 12 issues from this phase have also been listed below.

Phase one high level summary (top 12 issues)

1. Further guidance needed for alterations to existing buildings as near as is reasonably practicable

2. Some have expressed concern that changes have increased costs, caused delays and loss of accountability and confidence

3. Need to clarify building inspection regime and process of Warrant of Fitness and Compliance Schedule

4. Disconnects between legislations leading to uncertainty of requirements 5. Clarify the role of New Zealand Fire Service and Fire Fighting water requirements 6. Re-address requirement for interior surface finishes and performance levels 7. More guidance and consistent advice needed from MBIE – Update commentary and

guidelines 8. Advice from BCA’s varies widely – education and training of BCA’s, Architects and

trades on Fire Safety Design 9. Guidance needed on Passive Fire Protection and service penetrations 10. Verification Method should be more flexible and allow innovation 11. Fix errors and inconsistencies in Acceptable Solutions C/ASx 12. Review acceptable solutions for Community Care, Property Rating, Disabled

Evacuation and Fire Fighting

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SUMMARY OF FINDINGS

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SUMMARY OF FINDINGS

Phase two - Questionnaire A detailed questionnaire was emailed to stakeholders in October 2014. Approximately 220 stakeholders responded to the various questionnaires. The purpose of the questionnaire was to gather more detail in relation to the key issues raised during phase one of the stakeholder engagement process.

The main respondents to the questionnaire were from the Fire Engineering field and Building Control.

Of the key issues we heard about during the phase one feedback sessions, we’ve focused on analysing the statistics for the top rating themes that respondents provided feedback on in the questionnaires. It is important to note that this is not MBIE’s view of the issues facing the fire sector.

The below graph shows how many participants answered each questionnaire.

Further follow up engagement was also undertaken with parts of the industry where the response rates were low (ie architects and designers).

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Phase two: statistical analysis

The following table outlines consolidated comments from the top answered questionnaires (based on graph above).

Forum Headline Issue clarification Question Statistics High level comments Comment Summary

Acceptable Solution Issues

This questionnaire was enquiring about accuracy, completeness and the new layout of the Acceptable Solutions C/As1-7 and whether people found it easy to use

Acceptable solutions C/AS1 to C/AS 7 meet the performance requirements of the Building Code

49% of respondents did not answer the question

29% strongly agree or agree

12% neutral

8% disagreed or strongly disagreed

Need better consideration of those with disabilities when designing to acceptable solutions

Current acceptable solutions have increased costs for building owners without increasing safety or providing value for money

Issues within consent process and demonstrating compliance

Councils don’t understand the documents

Spending more time justifying designs

Lack of sector wide training on how to use or develop acceptable solutions

Inconsistent with objectives of the Building Code

Errors within the document

C/AS1-7 have significantly changed and the seven (7) documents are inconsistent, disconnected and contain errors

Process has increased costs with no foreseen benefit

Errors have caused confusion, delays and uncertainty

Having multiple documents is difficult to use

C/AS1 – 6 is easy to use 49% of respondents did not answer the question

28% strongly agree or agree

11% neutral

11% disagreed or strongly disagreed

Amalgamate into a single document

Open to interpretation, resulting in issues with the consenting process

Badly written clauses and inconsistencies with explanations

Create a user group where participants actually use the documents and have real time/ real life examples

Create an online calculator

The format of C/AS 7 is easy to use 50% of respondents did not answer the question

22% strongly agree or agree

16% neutral

9.5% disagreed or strongly disagreed

Amalgamate into a single document

Make C/AS7 a stand-alone document

Vehicle parking should be removed

Create an online calculator

No consistency in how the documents are laid out

Open to interpretation, resulting in issues with the consenting process

Rate impacts of errors in C/ASx on your organisation

51% of respondents did not answer the question

Additional checking required

Open to interpretation

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

18% had a high impact

10.5% had a medium impact

13% had a low impact

Causing confusion and unnecessary rework

Forcing high levels of fire safety into designs where there is no added value or necessity for it

Too many amendments for the sector to get their head around

Too complex, consider simplifying

Need to reconsider definitions

Inconsistencies and contradicting information in documents

Liability risk and increased costs to the client due to delays

Rate impact of an MBIE interpretations committee needed to interpret C/ASx requirements

58% of respondents did not answer the question

18% had a high impact

11% had a medium impact

6% had a low impact

Could cause more lengthy delays and increased costs

Would help with working through ambiguities within the documents as they exist

People on the committee would need compensation for their time to encourage participation

No requirement for a committee if the documents were simplified, errors rectified and a bit of common sense applied

May assist BCA’s in being consistent across the country

Remove confusion and misinterpretation

Fire Engineers could influence and therefore weaken the terms of the documents

May reach a consistent approach nationally

May address some of the ‘grey’ areas

The language/ writing style used in the C Acceptable Solutions is not clear

57% of respondents did not answer the question

16% strongly agree or agree

14% neutral

11% disagreed or strongly disagreed

Difficult to understand

Results in delays to consenting process

Bring back the Fire Advisory Panel to provide outcomes

Clearer explanations and clarifications

Further explanation required around clauses

Inconsistencies and open to

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

interpretation

Interpretations Committee could resolve these issues

Revert back to previous documents as they worked

Items not explicitly covered by the scope of the Acceptable Solutions are problematic

57% of respondents did not answer the question

24% strongly agree or agree

10% neutral

6% disagreed or strongly disagreed

Mixed use facilities

Halls in residences

Existing linings

Vertical fire spread

Existing buildings over 5,000m2

External fire spread

Fire evacuation regulation requirements

Large horticultural buildings

Subdivisions

Some building types are in the ‘grey’ area

Party walls and boundary walls

Mezzanine floors

Impact on business Causes rework

Work is turned away

Wastes time due to inconsistencies

Unable to confirm extent of design requirements

C/AS1 were better documents to use

Acceptable solution fire design should be Licensed Building Practitioner work

58% of respondents did not answer the question

16% strongly agree or agree

6% neutral

19% disagreed or strongly disagreed

No comments recorded

Acceptable solutions should address disabled evacuation more effectively

58% of respondents did not answer the question

17% strongly agree or agree

13% neutral

12% disagreed or strongly disagreed

Cost vs benefit analysis required

Increased costs with design and construction and limitations on design opportunities

Cost for compliance would increase

Huge costs for small percentage of building occupiers. Need to consider use of buildings prior to making decisions

Code should address access and

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

egress issues for disabled people

Need to consider ‘hidden’ disabilities like cognitive, lung or heart defects that impact ability to exit buildings in a fire

Being able to self-evacuate or not should be considered and requires thought when writing the Code requirements

Other issues Simplify the documents

Rewrite definitions

Ensure consistency across documents and links to other legislation

Consider tailored sector education

Consider disability issues in terms of access and egress

Undertake cost benefit analysis of any further changes

Passive fire protection should be included in sector education

Alterations to existing buildings, change of use and sub-division issues

This questionnaire was asking about the impact of s112 on work carried out to existing buildings. Explicitly, whether the requirements were well understood and whether there were any implications of uncertainty

Information about means of escape from fire for existing buildings needs to be expanded

82% of respondents did not answer the question

9% strongly agree or agree

5% neutral

4% disagreed or strongly disagreed

7% would like guidance on assessing what is as near as reasonably practicable

6% would like guidance on how to undertake a gap analysis including assessment of as near as reasonably practicable to the Building Code limits of visibility and fractional effective dose

5% would like guidance on what the list of fire safety features and statement of changes should include

More guidance on gap analysis and use of what is near as is reasonably practicable (ANARP)

Uncertainty increases cost and possible illegal work

Wide variation in BCA interpretation

Introduce inspections to existing buildings

A change of evacuation strategy from ‘all out’ to one that has ‘refuge to a place of safety’ should be building work, and require a building consent

83% of respondents did not answer the question

13% strongly agree or agree

2% neutral

1% disagreed or strongly disagreed

Will result in safer buildings

Ensures appropriate design expertise and review is applied to change in fire evacuation strategy

Less injuries and enhanced life safety Will cause increased compliance costs

Greater risk to life safety

May bring comfort that design meets necessary fire safety requirements

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

Fear of 112 upgrades leads to illegal building work

82% of respondents did not answer the question

10.5% strongly agree or agree

3% neutral

Buildings do not get upgraded

Increased costs and additional work associated with the alteration when a BC is applied for, may result in a number of buildings not complying

No building is done due to costs of bringing building up to code compliance

Building work is illegal and unsafe

Fear of 112 upgrades leads to avoidance of consents

83% of respondents did not answer the question

10.5% strongly agree or agree

3% neutral

1% disagreed or strongly disagreed

Concerned upgrade requirements will be unreasonable

Inconsistent application of exemptions by BCA’s

Increased costs of compliance leads to lack of compliance

Results in unsafe buildings and building stock not being improved across NZ

The benefit of a full building review is only realised when it is done well and includes site visits

83% of respondents did not answer the question

13% strongly agree or agree

2% neutral

>1% disagreed or strongly disagreed

Depends on quality and age of the plan and associated records

Fire safety is about the whole building and should result in a full building review

It depends on the building. If there are not many non-compliance issues and the alterations are minor, then site visits may not be required

May result in better fire designs and better understanding of the whole building, rather than relying on piece-meal assessments

Site visits are a must on every alteration to an existing building

Increased costs

Commercial pressures mean that shortcuts are being taken on Section 112 full building reviews

82% of respondents did not answer the question

8% strongly agree or agree

3% neutral

4% disagreed or strongly disagreed

Cost of design and construction

BCAs need to carry out systematic inspections of all buildings on an annual or bi-annual basis

More consistency in application of ‘as near or reasonably practicable’ and less trying to make all buildings be upgraded to current standards, when this is clearly not required or practicable

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

Better guidance and tools

This may lead to non-compliant buildings

Potential for more enforcement action, which will be contentious

Site visits with owners and designers, then meet with BCA’s to ensure all parties know what is happening

C documents are onerous and ridiculous to use when certain buildings have no evidence of deaths due to fire

The need to do a full building review for a tenancy fit out can mean a vacant tenancy for some time

82% of respondents did not answer the question

8% strongly agree or agree

4% neutral

>1% disagreed or strongly disagreed

May result in dispute and frustration

Red tape will cause increased costs and delays

Will result in lost jobs, and clients undertaking illegal work

Allow competent fire engineers to make their own decisions

Clarification on gazette notice and what is a minor change

More clarity around what should be accepted

Giving BCA’s more leeway to decided when a full building review is required

Needs to be a more simplified process

Less emphasis on ensuring existing building stock is fully compliant when the majority of fires are residential

When seismic upgrades are being undertaken, fire and accessibility shouldn’t also require upgrading

82% of respondents did not answer the question

7% strongly agree or agree

4.5% neutral

4% disagreed or strongly disagreed

These types of upgrades should be aligned

Let the Building Act determine this

A benefit of not doing this work would be cost related, but it needs to be assessed on a case-by-case basis

It will increase costs

To combine this seems the most cost effective, but risks vs benefits of doing so need to be considered

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

The cost of compliance is out of ‘kilter’ with cost of alteration works

82% of respondents did not answer the question

10.5% strongly agree or agree

4% neutral

3% disagreed or strongly disagreed

BCAs should take into account extent and nature of alterations when determining what is reasonably practicable

Need to prioritise works and development an improvement plan for the building

Project dependent

Nothing changes. If occupants were safe before, why all of a sudden is there a risk?

Work is not done as it requires compliance and the costs are not economically viable

The process to establish if a change of use has occurred is unclear

Response rates low Building owners and tenants oppose best practice fire safety

Simplify the process

Consider sector education

Availability of qualified people and education

Due to changes to the fire safety regulations, are people sufficiently qualified within the industry to carry out fire designs within cost and time parameters

N/A N/A 17% have found it difficult to find qualified people in the fire sector

15% have found it difficult to find CPEng or equivalent qualified people in the fire sector

10.5% have found it difficult to find qualified fire designers in the fire sector

7% have found it difficult to find qualified fire protection engineers in the fire sector

7% have found it difficult to find qualified NZFS Engineering Unit personnel

15% have found it difficult to find qualified Building Control Officers in the fire sector

7% have found it difficult to find qualified Independently Qualified Persons (IQPs) in the fire sector

Difficult to find qualified fire engineers and BCA’s with sufficient knowledge and proper training

What training is considered necessary for each role listed

Fire Engineer (in order):

Construction monitoring

What other disciplines require

What is near as reasonably practicable

What needs to be submitted for building

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

Specified use regulations

Evacuation regulations

Verification methods

Acceptable solutions

Building Code Fire Protection Engineer (in order):

Construction monitoring

QA processes

Acceptable solutions

Building Code Fire Service (in order):

Acceptable solutions

Building Code

What other disciplines require

As near as reasonably practicable

Specified use regulations

Evacuation regulations

Verification methods

Building Act Building Control Officer (in order):

What other disciplines require

Construction monitoring

QA processes

As near as reasonably practicable

What needs to be submitted for building

Verification methods

Acceptable solutions

Building Code

Building Warrant of Fitness

Do compliance schedules contain sufficient information and are BWOF inspections and the Form 12A system clear and operating correctly?

It should be possible to nominate storage height signage on the BWOF

82% of respondents did not answer the question

11% strongly agree or agree

3% neutral

2% disagreed or strongly disagreed

Allows large warehouse buildings to have fire systems installed appropriate to their level of proposed use

Enhanced fire protection fit for purpose

May help control fireload

Buildings can be used effectively without onerous fire design and implementation issues

More cost effective designs

Specified use of the building should be included in the BWOF

Compliance Schedule should extend to include signage and passive fire protection measures

Compliance Schedule should be more comprehensive to include inter-dependency of systems

The BWOF check should include an interoperability test of integrated fire systems

83% of respondents did not answer the question

Would increase costs

Common sense approach as it would guide the evacuation process

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

12% strongly agree or agree

3% neutral

1% disagreed or strongly disagreed

Ensures the system works as intended, resulting in safer buildings and better occupant protection

Isn’t this already happening?

Fire engineering brief issues

Does the FEB process allow early stakeholder engagement and is NZFS role clear in the process?

The FEB process results in safe and more cost effective building

Fire Engineers statistics:

5% neutral

3% agreed

5% disagreed or strongly disagreed

Building Control Officer statistics:

2% neutral

1% agreed

Councils should perform purely administrative roles on FEB process

FEB process is about expediting consent and ensuring stakeholders have a say – it doesn’t make buildings safer as design still has to comply with VM2

FEB process has not decreased consenting time

Provides better guidance for the process, and what needs to be done at each stage

There is confusion around when or if the NZFS should be involved at this stage

Process is time consuming and unnecessary

Have a clear VM2 so FEB is not required unless going outside of the VM2

Make the use of FEB process optional or remove it altogether

FEB has assisted with engaging stakeholders on fire designs

NZFS role is unclear in FEB process

Process is uncertain and results in increased costs and delays to projects

The FEB process reduces consenting risk

Fire Engineer statistics:

10% agree or strongly agree

2% neutral

2% disagreed or strongly disagreed

Building Control Officer statistics:

2% agreed

What benefits does the FEB process provide?

N/A It can reduce rework

Stakeholders are all informed of the parameters and feasibility of design at an early stage

Provides a forum for discussion on specifics of a building and proposed fire design

Less risk through building consent process

What problems does the FEB process create?

N/A It is treated as a ‘tick the box’ exercise and doesn’t add value

Generally misunderstood by all involved

FEB process is tedious and time consuming

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

Gives parties their own agenda to influence design and prevent progress

Increases costs and causes delays

Legislation alignment Are the various pieces of legislation for fire safety aligned, or are there disconnects? Are stakeholders aware of the legislative requirements for fire designs?

Have you been affected by disconnects between the evacuation regulations and the Building Code?

79% of respondents did not answer the question

15.5% responded yes

5.5% responded no

Loss of work due to non-compliance

Confusion as to what is required

Liability risk

Increase in cost and delays with reviewing existing buildings

No consistency on what is agreed during resource consent, consent and the evacuation regulations

Designers hide behind the building code level of performance creating conflict and issues for their client down the track

There are disconnects between the various pieces of legislation

HSNO and RMA requirements need to be included in fire safety document

There is confusion and a loss of accountability

Increased costs and time delays

Legal status of FAQs and C/ASx and C/VM2 commentary is clear

80% of respondents did not answer the question

10% agree or strongly agree

10% disagreed or strongly disagreed

Commentary to C/VM2 helps establish the intended level of safety, and should be available as a reference for alternative solutions attempting to provide an equivalent level of safety

The inability for the commentary to be considered binding means BCAs can put whatever interpretation they like on things

Uncertainty which is difficult for clients

Designers consider advice to be non-binding and therefore disregard it leaving the building owner in an untenable position

Disconnections in legislation are not cost effective

Has your business been affected by disconnects between the HSNO regulations and the Building Code

9% responded yes

10% responded no

Better integration of HSNO regulations into the C Clauses and make consideration of HSNO requirements compulsory under the C Clauses

Make HSNO, the Evacuation Regulations and the Building’s structure and systems part of the same planning and consenting process

Inconsistent implementation of MBIE’s 79% of respondents did not Employ competent staff who

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

guidance by BCA’s causes issues answer the question

15% agree or strongly agree

4% neutral

1% disagree or strongly disagree

understand MBIE’s advice

Clearer interpretation required

Provide clearer documents

Use plain language documents

We need sensible rules addressed in a pragmatic manner

New Zealand Fire Service issues

Is the Fire Service review requesting information consistent with the Act and are the right type of consents being sent to the Fire Service?

Requests for further information arising from the Fire Service consent review cause consent delays

81% of respondents did not answer this question

12% agree or strongly agree

2% neutral

2.5% disagree or strongly disagree

Process causes increased costs and time delays when information request is sent by a BCA

Causes delays which result in business revenue loss

Uneconomic to use VM2 as faced with extra costs at having to use conservative solutions

Fire Service involvement is uncertain and causes delays and increased costs

Fire Service is not limiting advice to that which is required by the Act

How could this issue be addressed? N/A Do not allow the situation to occur – present complete consent documentation to the BCA in the first instance

Fire Service should be better resourced with qualified fire engineers

NZFS should get back to basics looking at evacuation scheme approvals and administration of trial evacuations

Provide a time limit for FEB responses and a complaint process for NZFS failings

NZFS should restrict activities that are covered under the Building Act

No need for the NZFS to do an engineering review on top of the peer review

NZFS should be limited to an operations review only

The NZFS raise safety and evacuation regulation issues that cannot be enforced in the consent process

N/A Building Code and Evacuation Regulations need to be better aligned

Raise valid issues

Get it right the first time

The NZFS Engineering Unit should be accountable

N/A Accountability for an appropriate level of review

They should be accountable just like any other engineer under IPENZ

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

Gazette notice 49 should be clearer about what minor works are, and which building consent applications should be sent to the NZFS

N/A Shouldn’t be in a gazette notice

Should be made clearer and more specific

Minor works causes confusion

Remove the gazette notice and the BA requirement for BCAs to consult with the NZFS

Seems to be confusion with the BCAs

MBIE should review the gazette and do a proper risk analysis of what is to be sent to the DRU

Passive fire protection Is passive protection being installed correctly and are systems within existing buildings being inspected and maintained?

Installation of passive fire protection should be Licensed Building Practitioner work

N/A Increased costs and another layer of inspections

Better control over fire protection measures during and post construction

Delays in having LBPs available to do the work

Restrictive practice and will affect small project sites

Considerable cost in upskilling, training and licensing

Make installers accountable for their work

Would create an increase in competent and compliant work

Safer buildings and lives saved

Concerns with the standard of passive protection

Trades need improved skills and accountability in terms of installing passive fire protection measures

Prescriptive surface finishes

Are new requirements for internal surface finishes having an impact on the industry?

N/A 8% of respondents strongly agree or agree that surface finishes have a significant impact on life safety outcome of a fire

15% of respondents strongly agree or agree that specific prescriptive surface finish requirements in the Code causes difficulty

Remove the prescriptive elements from the Code

Revisit the issue with the Fire Advisory Panel, consult more broadly with industry

Remove the explicit numbers from the Code

Undertake a proper study on surface finish requirements, which includes relationship to fire protection

Create more timely and regular guidance via a Committee that can assist industry with settling disputes and answering issues with misinterpreting documents

Consider risk in terms of number of fires in NZ where surface finishes

The new requirements are too prescriptive and are not justified

New requirements do not allow for alternative solutions

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Forum Headline Issue clarification Question Statistics High level comments Comment Summary

resulted in unquestionable damage to a building as it is very low

No leeway for alternative solutions

Verification method C/VM2 issues

Is the new C/VM2 comprehensive and flexible enough for fire engineering design and who should be permitted to use it?

N/A N/A VM2 process has not been around long enough to evaluate

Delays in the process due to finding a suitably qualified person is problematic

Delays due to consenting process

Issues lie with those requiring alternative designs, and as a practitioner I avoid work that requires VM2 as it is a massive cost with little return

Delays in design approvals process

Training for BCA’s is required

VM2 should be better written

Remove NZFS from the process

Inconsistent approach to interpretation, creates confusion, increases costs and causes delays

Consider VM2 and the consenting process as it’s all too difficult

C/VM2 is causing design delays and the process is unclear

Increased costs

VM2 needs more time to be established before evaluating

Shortage of engineers to carry out design work

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20 SUMMARY OF FINDINGS

Focus group sessions

Focus group sessions were held from 17 November to 26 November with international experts, as well as representatives from specific areas of the sector, where stakeholder participation or input into the Fire Review was considered low.

The purpose of these sessions was to discuss the key themes we had heard previously, and to gather information on how these parts of the sector felt about these issues.

Information received as part of this process is outlined in the table below, and has been consolidated into the feedback received from the previous phases of engagement.

Stakeholder group/ organisation Key issue raised

Designers Institute of New Zealand (DINZ)

Timing and costs associated with developing verification methods and the need to engage fire engineers early

Staging of the fire report

Some BCA’s are pedantic about designs

Some s112 issues

Construction monitoring and BWOF’s and how fire engineers are reluctant to verify

More sector education required

New Zealand Institute of Architects (NZIA)

Fire reports are too complex

Added costs are stifling small projects

Primarily use acceptable solutions as VM’s are too expensive

Qualified fire engineers are scarce, and are not economical to use

NZFS involvement is unnecessarily over the top and advice is often conflicting

Surface finish treatments are inhibiting use of wood panelling

Negative view of fire engineering processes

BCA’s not accepting architects fire reports – inconsistent view

Joint and Several Liability is an issue

Uncertainty in the sector about what is good practice

Would like to see a slower rate of change

There is currently no motivation to keep up with the changes

Would like to see national consistency in applying the Code and in consenting

More sector education required

Cultural change is required across the board

Involving fire engineers early (when cost allows it) would help reduce issues further along in the process

Architectural Designers New Zealand (ADNZ)

CAS/2 structured well and allows consent process to be easier

Time pressures due to BCA inconsistencies in approach to approving designs

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Stakeholder group/ organisation Key issue raised

Lack of qualified industry resources

Consider opportunities for sector education to be included in Trade based literature

Association of Building Compliance (IQP)

Inconsistencies between BCA’s

Would like to see interface testing of integrated systems using a cause/ effect matrix

Building Officials Institute of New Zealand (BOINZ)

Why are there seven (7) acceptable solutions when one could do the job

Need to reconsider the role of the NZFS in the consenting process

Inconsistent approach from BCA’s

Joint and Several Liability is an issue

Priorities for sorting the issues should include:

○ Making sure acceptable solutions are correct ○ What needs to be applied or defined in the

use of these ○ Verification methods ○ Working on improving the relationship

between BCA’s and the Fire Service ○ PN22 (Practice Note 22)

Property Council Fire designs for existing buildings are not appropriate and ANARP is adding unnecessary costs

Areas working on processing BWOF’s and Consents are under resourced and lacking experience causing time delays and increased costs

Silo’s between disciplines and should aim for better integration

Lack of qualified fire engineers

Need further sector education

Society of Fire Protection Engineers (SFPE)

Cost of using a VM has bred conservatism in the sector

Weakness is the variable interpretation

Language of the Code has led to prescriptive mindset, rather than focusing on performance based outcomes and innovation

Inconsistencies with peer review process

Fire Protection Association of New Zealand (FPANZ)

Linkages with the Workplace Health and Safety Act and HSNO

Confusion around some of the regulations

Evacuation schemes are constrained by the Building Act

BCA’s require further sector education to reach consistency

No compliance schedule template or guidelines

Page 22: Summary of Findings Fire Review

MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT

22 SUMMARY OF FINDINGS

Phase three - Auckland presentation

Approximately 80 participants, including international experts, attended two presentations held in Auckland on Thursday 20 November 2014. The purpose of this presentation was to provide a high level update to the sector on the issues and themes identified during the stakeholder sessions and questionnaire.

Discussion at the presentation focused on the priority theme, which was the clarity of the Acceptable Solutions. A summary document of the presentation was also emailed to the Fire Sector database in mid-December 2014.

Analysis of the stakeholder feedback and questionnaire data is ongoing and it is anticipated more research will be required into some of the issues raised. A Summary Report outlining the strategic direction for fire engineering over the short, medium and long-term timeframes will be made available in mid-2015.

Next steps

As the review progresses, further stakeholder engagement will be undertaken to test ideas, and gather feedback on potential courses of action to address key issues raised.

It will be important that stakeholder engagement activities are designed in a way that provide varying, yet multiple opportunities for stakeholders to provide input, and gain understanding about the review as it takes shape into a plan of action.

Setting the Future Direction for the Development of Fire Regulation

The results from the 2014 stakeholder engagement programme are an important input to formulating the future direction for the development of Fire regulation. Our objective for the next phase of this work is to deliver by mid-2015 a plan of work, providing short, intermediate and long term actions to address the issues that have been raised by stakeholders

Engage with all stakeholders (BCAs, Government agencies, sector groups, professional societies, fire engineers) to enable a collaborative sector-wide approach for attaining over time an effective and efficient best practice regulatory system for fire safety in New Zealand.