Review of Evacuation of Buildings Regulations 2006 - Submissions for HOFFE

This is a subject I am passionate about so I am forwarding on an email from the FPA and encourage you to make a submission in support since a significant number of fires are extinguished with fire equipment without the need to call the Fire Service/FENZ, saving millions of dollars in damage.

Nicky Marshall

FPA email:

For some time now we have wanted to find a way to utilize the valuable information & data we collected during our NZFS sponsored survey, I believe that time is now. Simon Davis recently brought to our attention there might be an opportunity to have the requirement for Hand Operated Fire-Fighting Equipment mandated in the review of the Building and Evacuation regulations so, if we pass up this opportunity we do ourselves a disservice. The HOFFE Sig Group has put a submission in on behalf of the FPA and EVAC SIG who are heavily involved have also endorsed our view point . However, some HOFFE members may wish also to make their own submission. You can also do so by emailing the DIA directly on the link below, you use any of the supplied wording below by cutting and pasting onto your own company letterhead or altering your comments as you see fit. Unfortunately all submissions need to be in 5pm Friday 8 September 2017

NZFS HOFFE Research Review 2016.pdf

Thank you in advance, Steve Smith- HOFFE SIG Chairman

DIA link for more information on submissions

Or you can email your submission to

Draft wording for your use below

Re: Submissions for the “Fire & Emergency New Zealand Regulations (Fire safety & evacuation of buildings, & offences & penalties).

To whom it may concern,

We work with many groups within the fire equipment industry including what was the New Zealand Fire Service (NZFS) & has now become Fire & Emergency New Zealand. As an industry initiative, the then NZFS commissioned funded & supported a survey to determine the costs & benefits of installing hand operated fire-fighting equipment in relation to fires in non-residential buildings. In order to independently quantify the results, the results were quantified by Civic Futures a report made available by the then New Zealand Fire Service .

Our HOFFE group agree that as stated in the report there is a substantial benefit for our economy that can be realized if the there was a mandated requirement for suitable hand operated fire-fighting equipment to be installed in non-residential buildings. This view is stated within the study undertaken & expressed in the published conclusion that “This report concluded that a positive cost benefit case can be made for the installation of fire extinguishers in specific types of buildings.”, these findings are consistent with similar overseas studies.

We would like to see the proven results of the study recognized by inclusion in the current revision of the “Fire Safety & Evacuation of Building Regulations”. As demonstrated by the attached report (148) the inclusion of Hand Operated Fire-Fighting Equipment in non-residential buildings can be of significant benefit to the New Zealand community & economy.

The guidelines for how to select, supply, install & maintain Hand Operated Fire-Fighting Equipment (HOFFE) are already published in NZS 4503:2005. This means that should the equipment be formally mandated for non-residential buildings the mechanisms are in place for ensuring the right equipment goes into the right places & is maintained correctly so as to ensure that it is fit for purpose should it be required either by the occupants, the Fire & Emergency personnel or a member of the public who may be present.

Kind regards
Team @ FPA

Fire Protection Association NZ
P: +64 9 414 4450
F: +64 9 414 5707

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First of all, my personal preference is to specify hand held fire fighting equipment.
The basis of our fire safety building codes is life safety and protection of “Other Property”.
Hand held fire fighting equipment is largely about protection of property, not “Other Property”.
A building correctly built in accordance with the NZ Building Code is not reliant on hand held fire fighting equipment for life safety.

In order to mandate hand held fire fighting equipment there needs to be a policy shift in the direction of “Property Protection”. A cost benefit analysis would need to show an economic benefit to the country, not just the purveyors of the equipment. I suspect this would not be too hard.

Some years ago NZ suffered from a plethora of regulations from disparate areas affecting building code compliance. The joy of the 1992 Building Regulations was that all regulations for fire safety of buildings were supposedly placed under one set of regulations. Implementing requirements for hand held fire appliances using the Evacuation of Buildings Regulations would be a retrograde step. I do not believe requirements for hand held appliances have any logical place in such regulations - hand held appliances are dominantly a property protection resource.

The industry should consider focusing on demonstrating an economic benefit for NZ.

Hi Robert

Firstly, at the risk of being abused by Lance Hunt, I believe that requiring extinguishers in our sprinkler standard is wrong. But it is there, as there seems to be no other place in our legislative system

The Fire Equipment Industry has carried out a number of studies to show that the economical benefits of fire equipment is sound. If I recall correctly, it showed that 84% of fires in the U.K. Are extinguishers

Sorry. Pressed wrong button on my phone. Continuing:

. 74% of fires are extinguished without fire service intervention.

The Building code is concerned with the Building. One argument why extinguishers are not required is that they are not part of the building

The Fure Safety and Evacuation Regs go beyond the building and seem. Sensible place to address this

Perversely, I suspect that the reason why we may not have an issue here in NZ is that the installs of hand held fire fighting equipment are significant, and mimic the UK statistics. Tongue in cheek - If the industry wants to gain legislative muscles they should stop selling equipment and let a few buildings burn down. Perhaps the industry is already successful in protecting buildings. Is it possible that only a hand full of hardened developers and certain architects, who don’t want any fire safety blemishes on their “creations”, abstain from some form of hand held protection? Fire and Emergency NZ may choose to point out buildings without extinguishers OR sprinklers in their public commentaries whilst gazing at a pile of ashes after a fire.
Can someone quantify the magnitude of the problem?

  • The proportion of buildings without hand held protection
  • The number of buildings lost to fire without handheld protection.
  • The number of buildings that could have been saved with hand held protection
  • etc

I don’t see how requiring provision of hand held fire fighting equipment is going to protect the occupants of a building, which is the real priority. Consumer goods and buildings can be replaced whereas people’s lives can’t.

Provision of hand held fire fighting equipment needs to be selected or not selected based on the specific building. There is a building where I have advised that the occupants to trained to leave immediately on discovering a fire or the fire alarm sounders activating. If the occupants stay in the building fruitlessly fighting a fire they are at risk. The potential fire may be severe enough that the Fire and Rescue Service may follow their advice from Worksafe and not risk their lives carrying out a rescue. Hand held fire fighting equipment may be too risky to use. Therefore is it a good idea to provide it? In that case why require it? Would losing lives benefit our economy?

Contrast this with some rural locations where in some cases I have required a lot of hand held fire fighting equipment. It may be the only equipment available in a large area and coupled with the likelihood of a very slow Fire Service response it’s more likely to save lives as well as potentially limit widespread property damage. These locations are the least likely to require an evacuation scheme yet would gain the most benefit.

Given the above I think that regulating hand held fire fighting equipment via evacuation schemes is a terrible idea.

I have done my research on the benefits of fire extinguishers in Buildings. Link below. I believe that fire extinguishers have their place in our buildings but it has been banded to be expensive to maintain and dangerous to use. Fire extinguishers are much more simpler to use today and therefore no different then trying to use a portable defibrillators to save someone’s life. It needs proper training and procedure for one to use an extinguisher safely.
It is ironic that we don’t want to recommend or use extinguishers in our places of work but we are happy to have them in our cards and homes!!!

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