Stakeholder Engagement – Summary of findings Fire Safety Review 2014
BUILDING SYSTEMS PERFORMANCE BRANCH
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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SUMMARY OF FINDINGS
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
MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT 4
SUMMARY OF FINDINGS
MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT 5
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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SUMMARY OF FINDINGS
MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT 7
SUMMARY OF FINDINGS
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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SUMMARY OF FINDINGS
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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SUMMARY OF FINDINGS
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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SUMMARY OF FINDINGS
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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SUMMARY OF FINDINGS
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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SUMMARY OF FINDINGS
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
MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT 13
SUMMARY OF FINDINGS
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
MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT 14
SUMMARY OF FINDINGS
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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SUMMARY OF FINDINGS
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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SUMMARY OF FINDINGS
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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SUMMARY OF FINDINGS
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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SUMMARY OF FINDINGS
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
MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT
21 SUMMARY OF FINDINGS
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
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.