FENZ fire alarm panel approval

Hi Ian

Once again I think people are getting confused about the fire report and the plans and specifications. As you aptly point out:
“As per section 49 of the Act, a BCA must issue a building consent only is satisfied on reasonable grounds that the provisions of the building code would be met if the building work were properly completed in accordance with the plans and specifications that accompanied the application”.
I consider that it is reasonable for the fire alarm panel location, mimic panel locations, and brigade inlet locations along with their respective dispositions to be included in the building consent documentation.
Where it is in the documentation is irrelevant and I support the fire protection systems main equipment locations and dispositions being placed in either the fire protection documentation or the architectural documentation - not the fire report. The fire report should not be a construction document.
The fire report is a report to the design team on what they need to include in their plans and specifications in order for their designs to comply with C1 to C6.
The BCA may choose to use the fire report to check the adequacy of the plans and specifications for compliance with C1 to C6 along with all the other building codes.
I suspect that some BCA’s are so bound up in “marking the fire report exam” that they totally lose touch with checking the plans and specifications for compliance with C1 to C6. The focus in this discussion with the fire alarm panel location and disposition being in the fire report is a perfect example of this.
Going a little off topic - Some BCA’s are forgetting the “satisfied on reasonable grounds” bit and pursue to the death any minor error or omission in the fire report that once rectified makes absolutely no change to the fire safety design in the plans and specifications whilst ignoring gaping holes in the compliance of those plans and specifications.

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There is no requirement in the building code or C/AS2 for the approval of a third party to grant consent. Council could ask for FENZ comment on the position of panels or inlets if they believe this could become a problem during construction but they cannot ask for stamped and signed drawings. Fire engineer drawings are only indicative and not for construction so cannot be stamped as the panel final location. Requesting signed drawings of fire protection equipment is only going to slow down every consent with FENZ being so busy and at time we need to get these housing built!

Absolutely Mike, the fire alarm and FENZ should be talking and the location agreed prior to CCC as part of the D and B of the building.

What an interesting discussion!
I firmly believe that the panel and inlet locations, along with sprinkler valve/pump room, need to be confirmed and agreed before consent.
There can be substantial changes required to a building’s configuration to accommodate these items.
I think that this is a reasonable request for council to have this at consent time as failure to do so can result in significant issues (in my opinion, more reasonable than council requesting that consent documentation be “for construction” issue documentation.)
If the Fire Engineering design is requiring compliance to NZS 4541, NZS 4512 or NZS 4510 then all of these standards require location approval of items by FENZ. To prove compliance with the standards, is it not reasonable to ask for this approval? I think so.

Who does the agreement? Being slightly biased, I would suggest you engage a competent fire protection consultant! :slight_smile:
Or perhaps form a relationship contractor who can assist.


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I agree, to a point, Nicky.

However the fire engineer is not the one to design the system to 4512 or 4541 etc…
Fire engineers ask for a performance to be achieved, and for the purposes of consent that should do, with the understanding that the system has to be designed and signed off appropriately.

Once the BCA/TA agrees that the Code is met based on the provision of the alarm or sprinkler system then the system designer is charged with designing to 4512, or whatever.
The certification is provided CCC is issued and the World moves on.

I do agree that the right person is the system designer who agrees the location…

Refer NZBC C/AS2 Para 6.2.1. Therefore a requirement of a C/AS2 fire report. Think of good, better and best design work. What fire safety professional would leave something as critical as gaining FENZ approval of fire fighting operations to others, when these are so well embedded in NZBC clause C5, C/AS2 part 6, and C/VM2 Design Scenario FO.

A BCA needs to see how a building will comply with the standards, to demonstrate compliance.

Just stating that it will be constructed to NZSxxxx is insufficient. Otherwise we wouldn’t need any details for any of the Codes, just state that the work will comply and be inspected before CCC.

On a really simple single zone type 2 the BCA may leave it for inspection and producer statement. But multizone systems need to be seen fully to demonstrate compliance. That is a specification and plan showing all the elements of the system.

A BCA need to be satisfied on reasonable grounds that if constructed in accordance with the plans and specifications the relevant provisions of the building code would be met. The would refers to the situation at the point of CCC and it is possible for the specifications to be performance based. It is also possible to place differing levels of reliance on plans or specifications or a combination of the two, and reasonable grounds is very different to proof.

The Objective of building code clause C5 is to ‘facilitate firefighting operations’

The Functional requirement of C5 is that ‘buildings must be designed and constructed so that there is a low probability of firefighters ……being delayed in or impeded from assisting in rescue operations and performing firefighting operations’

C5.2 ‘Buildings must be designed ………etc.’

The Performance requirements in C5.7 is that ‘Buildings must be provided with means of giving clear information to enable …….’

I think demonstrating compliance with this in the design may imply more that simply referencing NZS/4512.

C/AS2 - 6.2.1 states ‘ If fire alarm or sprinkler systems are installed, the control panel shall be located in a position close to the Fire and Emergency New Zealand attendance point and in accordance with NZS 4512, NZS 4515 and NZS 4541 as appropriate.’

I think it is reasonable to expect that plans and/or specifications should identify the location rather than merely referencing NZS/4512.

The BCA processor who considers it reasonable to request confirmation of the location of the AP from the designer prior to issue of the BC(not the FE) is not requesting something more that the building code or Acceptable Solution support.

The Alarm control panel is the primary initial reference for the direct control and facilitation of firefighting operations at the building.

The location of this information is critical to achieving all of the above.

Everything in C5 as well as C/AS2 supports that it is reasonable to expect the design should identify the location of the Alarm Panel before the consent is issued.

Whether or not the Fire Engineer references the need for the location to be confirmed by FENZ, the responsibility ultimately sits with the applicant which will be the designer - not the fire engineer.

I think leaving the location of the AP to ‘sort on site’ falls short of satisfying the requirements of C5.

The fact that the correct location needs to be confirmed by FENZ (a 3rd party) does not somehow create an exception from an applicant having to demonstrate compliance with C5.7 by C/AS2 at the design stage and prior to issue of consent.

Fire engineers like FENZ, are also 3rd parties often required to provide information to the designer (applicant) to substantiate compliance with C clause.

The BCA Processor does not send RFI’s to the FE but to the designer (2nd party for the owner) who in turn seeks the information from the FE.

So if the BCA processor considers it is reasonable to establish the location of the AP to demonstrate compliance with C5.7 along with C/AS2 6.2 if chosen as a means of compliance, and requests the information from the designer, it is up to the designer to satisfy the BCA of the correct location.

Just because FENZ must be consulted to approve the AP location to the designer does not morph the reasonable request to an unreasonable one.

The BCA will not be satisfied the information is correct unless FENZ have confirmed it.

The argument is - ‘ because AS/4512 is referenced in C/AS2 and is ’deemed to comply’ and the location of the AP in this Standard is in the ‘Installation’ section, therefore a BCA is not authorised to require more.

I suggest that a BCA requesting a designer confirm the location of the AP is not asking for more than the Acceptable Solution, but confirmation of precisely what it does require - only prior to the issue of the consent, not leaving to ‘sort on site.’

There are many building components and products that by the same argument can be satisfied by ‘referencing’ multiple Standards.

If the BCA considers it is reasonable to request more clarity to ensure that, if the building work was constructed in accordance with the Plans and specifications, the building will comply with the building code (in this case C5), then the BCA is empowered under the Act to require the information.

S45 (1) (ii ) ‘ if the Regulations do not so require, required by the BCA’

The level of ‘information’ a BCA is authorised to request is defined by the term ‘reasonable.’

s45 (c ) ‘……any other information that the building consent authority reasonably requires’

I suggest it is incorrect to conclude that a BCA ‘cannot’ require the location of the Alarm panel at the design stage and that it is not within the power of the BCA to do so.

A BCA may consider that such information is related to satisfying the requirements of C5.7 and therefore is in accordance with s49 of the Act.

This position is further evidenced by what FENZ advise us happens on the ground. A lot of ‘noncompliance.’ That the Alarm panel is often in the wrong place and they were not consulted in accordance with NZS 4512.

‘Sorting on site’ will likely create far greater delays with 50 other contractors running around site than early in the design stage, especially if the work was done without FENZ approval and in the wrong place.

Doesn’t happen? Ask FENZ- it does.

Furthermore, if any FENZ pre approved AP after consent is desired to be moved to another location with consultation from FENZ, this is not a formal amendment but a simple onsite minor variation.

If BCA’s requiring this information slows the consenting process down, or FENZ are potentially delayed, what is stopping the designer getting this approval early and FE’s supporting and encouraging this even if there is no FEB?

NZS/4512 'Note: The fire service should be consulted at an early stage in the design to facilitate the approval of the proposed arrangement’ - Isn’t this with respect to the location of the Alarm Panel? If so, this is not ‘sort it out on site’

Nicely put. A fire fighting operations drawing depicting all FENZ requirements is best so that snags can be resolved early in design… like access, hose run, hardstanding location.

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Surely approving consents on a ‘she’ll be right’ reasonable grounds approach without proof is how we have the present issues of non compliance on site. Lintel sizes and drainage are specified despite being built to known standards by licensed tradespeople, so why aren’t FENZ access, hardstanding, hose run etc also specified. They are just as important.

Very much agree Grant. I think the root cause could be a lack of proper respect for C5 and design management to specifically addresses this code clause prior to the consent application stage.
Due attention should be given by the designer to start the FENZ approval process so that any changes or corrections can be made early. This is a no brainer and precisely what 4512 recommends.
Many designers instead leave this to bottleneck at the consent application stage and then complain the BCA is holding up the process due to the RFI. It needs its own plan and schematic detailing the whole lot as you say. If this means earlier involvement with the Alarm specialist then that should happen. But even a high level approval could be sought early to get things reasonable right. Minor variations can play a part if specialist and FENZ approve changes on site.

I really think the conversation could be headed down a rabbit hole. I have already had numerous BCA’s asking for sprinkler layouts and smoke detector layouts. Why ??? It is very unlikely that anyone at Council can say anything about a plan covered in little circles and joined by lines. This is only done by the fire sub contractor to NZS4512/4541.
C5.7 is easily met when the fire engineer specifies NZS4512 as the Standard itself covers this aspect along with many others. NZS4512:2021/ was reviewed by the Standards committee, as was every other clause, and did not require any change. It remains therefore the responsibility of the fire alarm contractor installing the system to gain fire brigade approval for the indicating unit as mandated by this clause. They are also required to take into account “signs, vegetation, sprinkler inlets (which require the same approval) that might hinder visibility or prevent close access to the unit”. Will the BCA require the garden layout for consent issue?
If the fire engineer agrees to provide the panel/inlet location to the BCA at consent stage what is to stop the BCA asking for even more information that doesn’t actually exist yet?

John I think everyone has agreed that the BCA only requires the location of the key fire protection equipment that FENZ are required to interface with, and not detailed fire protection layouts. Additionally who provides the design information is not specified - only that the design is approved by FENZ.
Agreed locations of key fire protection equipment can involve significant architectural and structural facilitation. Hence the need to include the approvals at building consent stage.

I sort of agree with Robert, but only if the design has already been done (i.e. the information has been considered and the agreement reached). not providing it should not affect the processing of an application for consent. I do agree with John in that C5 has been met if the performance is to NZS4512…then the agreement is a D and B issue with FENZ input and the designer of the system and possibly the architect.
Just a point though 4512:2021 is an alternative solution by default (by the fact it is not a cited Standard in C/AS2)…unless I have missed something :slight_smile:

After all is said and agreed or disagreed here, it’s pretty much irrelevant anyway.

Because if a BCA considers they need a fire warning system design before granting consent, then someone has to supply that - or take it to determination for a final decision.


You are so right Natalie. I would hope that any responsible BCA would only resort to requiring the fire protection detailed design if they considered that the fire protection installation could affect the design of the building which can happen from time to time. Some architectural creations are not protectable - but they are far and few between.