PN22 rev 2 draft out for comment

For those who haven’t seen the email from Martin, there is a draft update in Practice note 22 (documenting fire designs). There are significant changes, so all SFPE members need to read it and put in their 2c.
I am still going through it at present. I have concerns about liability and expecting the fire engineer to detail items such as the compliance schedule - where services are specified by others, and hence the design and maintenance standards must also be by them.

In the meantime, to kick off the discussion, I have been asked to post the following from a SFPE member who can’t log in at present.
Geoff

Hi All,

Despite our differing views on compliance and the role of the stakeholders in the design and construction area (which I appreciate and respect) I think that there is a significant issue that we need to get together with in regards the direction of the new draft PN22 document.

From my differing viewpoints, as a CPEng Fire Engineer, Owner of an IANZ accredited processing organisation, ex MBIE and co-author of the IFEG including my other work history, there are some horrific errors in terms of BCA requirements/risk and liability to the fire engineer and on the face of it the document is, quite simply, an overreach in terms of what it requires.

For example, how many FE understand fully F6, F8, H1, D1 etc and what the compliance inspection, maintenance and reporting procedures are for the various systems in a building…especially as MBIE and IANZ are continually shifting the goal posts on the requirements and the method of recording that information and the difficulties of aligning Form 2, the body of evidence and Form 5. An IANZ TE works for me and so I understand this area and what the issues are.

I also wonder how many FE claim competency and understand and want to sign off the architectural details, appraisals and multiproof, not to mention willing to gather, check, collate and confirm information on building elements on items that have not been specified yet (such as smoke curtains). I would strongly content that this is not a FE role…

*I also see that there is erroneous information about the role and what the BCA requires, I question if that should be in this document. *

*All that said of most concern is the expectation that the fire engineer works well outside their individual competency, and potentially the ethical code, and the issues with the increased liability to both the individual and the company. *

*I wonder if this draft has received legal and insurance liability input from the insurers…especially in light of the case in Wellington currently at the Supreme Court…where the engineers are being sued well past the 10 year limitation period for “providing information on which the BCA made a decision”. Notably this is at the Supreme Court, which shows that the lower Courts all agree that the engineers can be sued and the 10 year limitation does not protect them….(let that sink in for a bit…). *

*Apart from that what is proposed will, in my view, add significant cost to the process and open the door for others doing fire designs that are not FE CPEng and don’t follow the practice note…do we want this at this point in the building cycle when the market is rapidly constricting and the signs are that it will not improve for at least a year? *
Alan

I have had a couple of people ask me for my 2c on the PN22 given the recent Regulations Review Committee (RCC) hearings, and at a general level I share the concerns regarding liability, as I studied many a failed project (some settled out of court) as well as failed delegated legislation and failed guidelines that have resulted in massive claims against private sector engineers as part of preparing for the RRC hearings that I did not cover in my parliamentary submissions.

I won’t go into forensic detail about my thoughts on PN22 as there is too much to cover, but PN22 is not law (unless you put it in a contract) and never will be. Follow the Building Act and its associated secondary instruments issued under the Act (guidelines issued under Section 175 of the Act is not law), and the common law and liability will be no higher than the minimum (assuming the secondary instruments are not ultra vires). But a summary of my thoughts are:

  1. In Mt Albert Borough Council v Johnson (1979), the Court of Appeal ruled that the private sector (generally) pays 80% of any claim in tort, with councils picking up the 20% (this is before the joint component of joint and severable liability kicks in). Therefore, look after yourself first and make sure that the plans and specifications comply with the building code for the work you have done under contract. This liability ratio is still applied today as a starting point, so when there is a claim, it is the private sector that gets hit the hardest first – and this will never change – so learn how to make it work for you rather than against you (a big subject in itself).

  2. In Body Corporate No. 207624 v North Shore City Council, Chambers J of the Supreme Court made it very clear about the importance of the Building Code: “No one can be party to the construction of a building which does not comply with the building code”. You do not need to contract beyond what is required under the Building Act (as a Designer) and if the plans and specifications comply with the building code, you are entitled to a building consent.

  3. Putting PN22 in a contract will (likely) expand your liability beyond what is required under the Building Act as you are going beyond what the Act mandates by contractually agreeing to do so, so consider leaving PN22 out of any contract and simply use it as a ‘list of things worthy of consideration’, as there are some valid points in PN22 (my view). But keeping PN22 out of a contract frees up your choices rather than compels you to comply with an instrument that has not been passed into law as a secondary instrument (PN22 has not gone through, say, the Parliamentary Counsel Office for quality control to determine its consistency with the Building Act and associated regulations, other statutes, and the common law).

  4. It’s worth noting that there may be future changes in the Building Act. For instance, the Determination system could become non-compulsory in the future, and some disputes might go directly to the High Court in the future where Determination precedents hold no weight. The Petitions Select Committee is considering a submission to make Determinations optional (by changing Section 182 of the Building Act), as there is an argument that Section 182 is inconsistent with Section 27(2) of the New Zealand Bill of Rights Act 1990 and the common law right to access the courts for things like resolving property rights disputes.

In summary, nobody else owes you a duty of care to ensure that PN22 complies with the law, so whatever you sign up for you have to look after yourself.

If anyone wants a copy of the case law and/or legal references to read and further challenge their understanding of these issues as they relate to PN22, feel free to contact me. If I have the time to respond and consider the request, I will.

Christian

Whata J (2011) for a leaky building claim against a building surveyor in the High Court: “I reject for that purpose a supposed “industry standard” of the time. That may or may not set an acceptable benchmark.

Posting below on behalf of Alan Moule who cannot get the login to work. Comments anyone?
G

Hi all,
I wrote to the CE of Engineering New Zealand, who, in his reply, confirmed that the original scope of the workgroup that has produced the Draft PN22 was to provide a ‘Fire Report Exemplar and Template’.

The original scope was seemingly overtaken by “stakeholders” at the first meeting to become a total review of PN22, and what has been released for comment.

I have some rhetorical questions for you to throw around as you consider things:

  1. Why were Auckland and ChCh on the working group in the first instance. They do not represent the views of most BCAs.
    a. Were they there to look at the report content, or to influence their own requirements beyond what they can ask for under the Building Act 2004?
  2. Why were FENZ and MBIE there?
    a. Were they there to look at compliance (MBIE) given that is the BCA role or to add requirements beyond what they can ask for (FENZ)?
  3. Why was there such a scope slip and what was the intended end point?
  4. With such a slip in the scope this should have been considered and communicated to the wider membership to discuss.
  5. Has this been tested for technical correctness?
  6. Has it been tested for legal correctness?
  7. Has it been considered by your insurers, are they happy to take on the liability?
  8. Why was the wider membership not aware what the working group was up to, or even that a review was underway?

Should have been a document reviewed, developed and agreed on with practicing fire engineers, circulated agreed on in the SFPE and then sent to the BOINZ for circulation, FENZ for comment and MBIE for record.
As an engineering discipline we can not give our sovereignty away to the BCAs, FENZ or MBIE.

Alan

In returning your comments back to those who are collating PN22 feedback, my view is the legal disclaimer in this proposed instrument is woefully inadequate. You may wish to suggest something like this in bold text within PN22 when you submit (not that PN22 is even justified):

The terms in this Practice Note have been developed independently of any statutory interpretation principles under the Legislation Act 2019, s 10(1), and therefore, these terms may be inconsistent with New Zealand law.

This Practice Note may contain provisions that:

  • Breach the Building Act 2004 and subsequently may result in building work not complying with the building code, specify procedures that are ultra vires the Building Act 2004, or delegate responsibilities that are ultra vires the Building Act 2004:
  • Breach the Fair Trading Act 1986 and subsequently may result in civil claims or prosecutions for false, misleading and deceptive conduct, or unsubstantiated representations:
  • Breach the Commerce Act 1987 and subsequently may result in prosecutions for anti-competitive behaviour by the Commerce Commission:
  • Breach any other applicable statute or statutory requirement(s) not listed above.

This Practice Note has not been developed in conjunction with any type of insurance policy that typically covers a person’s commercial activity associated with fire engineering services. Subsequently, where a person adopts this Practice Note, whether under contract or otherwise, they may expose themselves to claims for breach of specific performance, be held liable for expectation damages, and/or held liable for claims in tort (accidental and/or intentional) that may not be covered under that person’s insurance policy/policies.

As this Practice Note has not been enabled under any statute or regulation as a legislative instrument, it has no legal status. Subsequently, any administrative decision by a regulatory entity that relies on or enforces provisions of this Practice Note may be ultra vires and, therefore, may not be enforceable.

A simple guide to dealing with PN22, if it ever comes your way is:

  1. Never put PN22 in a contract (same for construction industry council guidelines).
  2. If PN22 is specified by a BCA, their request is ultra vires, and return the RFI (or similar) for a question that relates to compliance with the building code (or other request that they are entitled to make under the Building Act).

Councils owe a duty of care in tort for compliance with the building code. This comes from the Act. As long as the plans and specifications comply with the building code, how each company goes about its business is nobody else’s business. PN22 has no legal merit of any kind and how fire engineers choose to contract with their clients cannot be regulated by anyone.

Reminder: If you wish to submit comments or feedback on the draft update to Practice Note 22, the deadline is approaching (May 30th). Please send comments/feedback by email, in the prescribed format where possible (i.e. when commenting on the wording of a specific section in the draft).

My submission on PN22. See below…

PN22 is not needed; follow the Building Act (and comply with other statutes and common law).

I will not discuss PN22’s flaws in forensic legal and economic detail, as it is not necessary. But it is interesting why there was a PN22 in the first place. Based on an SFPE NZ letter dated 19 January 2023, it appears that the impetus for the original PN22 came about as a result of audits of private-sector fire reports submitted to the FENZ DRU under section 46 – 47 of the Building Act and included auditing FENZ DRU responses. Specifically, there were two audits (2006 and 2009), which, in part, concluded there were issues with private-sector fire reports.

I fail to see how such audits carry any weight in law, and my reason is that unless that government department is authorised by statute to conduct such an audit, then their findings cannot be acted upon. Neither the Building Act nor the (law at the time) Fire Service Act 1975 (in my opinion) authorises such audits by third-party consultants of fire reports produced by the private sector. Moreover, the audits are the opinion(s) of the author(s) of the audit – that’s it – and cannot be acted on, whether the opinion is right or wrong. Whether or not fire reports produced by the private sector that are held by government departments can be released to other consultants for auditing (and if so, on what terms) is a question I have yet to come to a conclusion on.

It is the Office of the Auditor-General that is responsible for auditing government departments, and their powers are specified by Parliament under the Public Audit Act 2001. Under this Act, the Auditor-General may examine a public entity’s compliance with its statutory obligations (section 16(1)(b)). The Auditor-General may also inquire, either on request or on the Auditor-General’s own initiative, into any matter concerning a public entity’s use of its resources (Section 18). So, any concerns about whether a government department is complying with the law should be reported to the Auditor-General so that the Auditor-General can do their job. The Auditor-General is independent of any other government department and reports to the House of Representatives without instruction from any Minister. The Auditor-General’s findings can be acted upon by other government enforcement agencies, as the Auditor-General’s findings are evidence and, therefore, potentially have legal weight.

As for any ‘defects’ in any fire report produced by the private sector, the Building Act addresses this. A building consent cannot be issued unless the submitted plans and specifications comply with the building code (section 49(1)). Every building consent authority must be accredited to the conformance standard: Building (Accreditation of Building Consent Authorities) Regulations 2006. This includes being able to process building consent applications for compliance with the building code, inspection of buildings during construction, certification of building work, and issuing compliance schedules. So, a building consent authority should simply not approve any submitted plans and specifications that do not comply with the building code, give the reasons why, and allow for those plans and specifications to be amended as required, as they have the skills (as per their accreditation) to audit each set of submitted plans and specifications that comes before them (otherwise their accreditation comes into question).

Thus, the production of the original PN22 should never, in my opinion, have ever got off the ground, but it did. Now, PN22 seems to be coming back from the dead on the basis of a similar argument that perhaps should have been shut down well over 10 years ago.

Now a few thoughts on each section of the draft PN22 (far from detailed):

  1. Section 3: References to other guidelines (e.g., Construction Industry Council), which are not secondary legal instruments. Delete the entire section as it should be a matter of routine that professionals can produce plans and specifications that comply with the building code, and empirically, this must be the case as there are over 10,000 commercial building consents issued every year across the country. Moreover, there is no ‘process for carrying out performance-based fire engineering design’. That is a total myth that is only sustained by erroneous guidelines. The Act allows Designers, when doing a performance-based design, to design however they like, and if the outcome is plans and specifications that comply with the building code, a building consent cannot be denied.

  2. Section 4: Again, there is no ‘Fire Design Process’ under the Act. Delete. Worse still, it specifies a ‘Fire Engineering Brief’ that has no basis in law outside of the C/VM2 and mandates that it be approved by the BCA, FENZ, and peer reviewers. The Act does not grant such approval powers and never will. The entire concept of a ‘Fire Engineering Brief’ suggests that fire engineers need to rethink what they are really doing – getting someone else to grant a building consent on that other person’s terms despite that person not having the authority to dictate such terms, and the Designer sacrificing procedural freedom during the design process that they are entitled to under the law. The underlying issue is that fire engineers, and engineers in general, have not developed the skills of statutory interpretation, an important area of law (and is not complicated) that is well-covered in various law books but usually not even known to engineering departments that teach engineering, whether it be fire engineering or otherwise. Consequently, the entire fire engineering profession globally has got off on the wrong foot and fire engineers rely on a “per-project get every person’s requirements” exercise, try to make it work, but find out it fails because it is too difficult and full of subjective opinions and unreasonable demands from ‘stakeholders’, so the end result is to stay away from performance-based design, or write ‘industry-sanctioned guidelines’ which could be even worse. The proper way to do performance-based design (whether for fire safety or any other discipline) is to learn how to interpret statutory law, design to that law (in this case, the building code), and reference it appropriately not just with engineering data (facts) but legal references. This is a large topic that I won’t go any further on here, but it is worth noting the word ‘stakeholder’ is not in the Building Act and, therefore, has no legal weight. It is the building code that specifies the legal thresholds and is, therefore, the design criteria, not ‘stakeholder requirements’.

  3. Section 5: Delete with prejudice. The whole purpose of this section seems to be to encourage Design Coordination Statements. It is not required under the Building Act, and if you sign one, your liability (likely) goes up whether you have agreed to it via contract or not.

  4. Section 6: Fire Design Documentation Guidelines: This section prescribes roles despite the Act not doing so. It is a contractual freedom of the Designer as to how to design and who will take responsibility. Refer Vector Limited v Electricity Authority CA481/2017 [2018] NZCA 543 at [53]:

Seventhly, any asserted constraint upon freedom of action or association, including the freedom to contract, must be justifiable by reference to a lawful power. Where the source of the power is said to lie in statute, the statute must authorise the constraining power, either expressly or by necessary implication. Plainly that principle applies where the right constrained is a fundamental one, such as the right of citizens to contract with one another.

Delete entire section.

  1. Section 7: BCA requirements are specified in the Act, and regulated in Building (Accreditation of Building Consent Authorities) Regulations 2006. Peer reviews cannot be enforced by a BCA as a BCA does not have the legal power under the Act to compel practitioners in the private sector to contract for the purposes of a peer review. Recommend delete.

  2. Section 8: Monitoring building work during construction is, at statute level, the BCA’s role; refer Section 12(1)(b), and Building (Accreditation of Building Consent Authorities) Regulations 2006, regulation 7(2)(e). An engineer can freely contract with a Client to do site inspections, but the building owner is not compelled to contract with a fire engineer on this matter anymore than a fire engineer is compelled to provide a PS4. Delete the entire section and replace it with statutory requirements and common law entitlements.

  3. Section 9 Compliance schedules: Delete and replace with ‘refer Section 103 of the Building Act’.

  4. Section 10 References: Delete and replace with Building Act.

  5. Appendix B: Delete with prejudice.

  6. Appendix C, D, E, F: Delete.

It may be worth noting that under the Fair Trading Act, if you advise your client that something is required but the Building Act does not require it, the Commerce Commission may prosecute you (this is a deep subject that I won’t go into here).

Also, if you all agree to produce designs in a procedural manner that reduces competition, you may be prosecuted under the Commerce Act for cartel conduct (again, a deep subject I won’t go into here).

It would be better to revamp PN22 as a technical guide that does not specify how to do your job, but rather a list of items derived from the Building Act, common law, and case law from the HC/CA/SC for failed buildings, and relevant technical facts, so that engineers get better at the law and better identify legal errors in any plans and specifications so as to reduce the potential for being litigated, rather than make it up and hope for the best. And as it is supposed to be for Designers, it should be lead by Designers.

As a simple solution to dealing with PN22 should it not be revamped, the following may help:

  1. Never put PN22 in a contract (same for construction industry council guidelines).
  2. If PN22 is specified by a BCA, their request is ultra vires, and return the RFI (or similar) for a question that relates to compliance with the building code (or other request that they are entitled to make under the Building Act).

As a final thought, every communication that fire engineers have over ‘problems in their industry’ is a potential ‘dinner bell’ for litigation firms. The logic behind openly publishing things like ‘uncertainty over how fire design documentation was being incorporated into the plans and specifications produced by other members of the Design team’ (proposed Introduction to PN22), is something that could perhaps be thought through a bit more.

As a qualifier to the above statements, and which is hopefully already clear, the building code is delegated legislation and can be ultra vires the Building Act and/or common law. Under such circumstances - which is the thrust of the Regulations Review Committee proceedings - designing for fire protection needs to be broader than just complying with the building code (or any of its compliance documents). Failing to observe and/or failing to correct for ultra vires delegated legislation when designing, with the resultant building’s design not being safe, is an actionable claim in tort against a Designer.

This is where statutory interpretation is beneficial, and it is key to understand how the courts adopt the common law doctrines of negligence and nuisance when determining whether a building’s design is correct, and if not, questions as to who is liable begin. ‘Stakeholder requirements’, FEBs, peer reviewers, guidelines, industry practice, etc. do not change the common law.