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?