S.112 and existing buildings

I have come across a BCA who are adamant that the application of S.112 to alterations to an existing building requires that ALL floors within the building need to be re-certified as to their fire resistance. This means that the Code Compliance Certificate, as produced by the BCA for any particular building cannot be relied upon ie the BCA does not accept its own documentation.
An example would be a 4 level building, one floor of which is an intermediate floor, and which received a CCC about 2 years ago. The BCA state that each floor is to be independently certified, under the “all active and passive systems associated with means of escape from fire”. Under these circumstances, where the BCA will not accept its own certification, what is the point in applying for a CCC?
Is this a common interpretation, or jus an aberration?
Paul C

I haven’t come across this other than as part of a building assessment where the fire resistance affects means of escape - e.g. a unrated cupboard with the switchboard and old tins of paint in the stairwell where the issue and answer is fairly self evident. it certainly hasn’t come up for say the rating of a concrete floor where their is no change of use or subdivision.

I assume that since it is an alteration of a recent building, that the fire ratings aren’t changing in this work anyway against what was consented (and hopefully built).
A proper assessment of what has been built and it’s rating is a difficult and expensive exercise to do fully, with intrusive inspections, intumescent coating lab tests, etc and even then you can be sure that you only have a “balance of probabilities” answer since you can’t see how the GIb is fixed and blocked, or see every join, junction and penetration, etc.

There are a couple of points to consider

  1. If the building has a current BWOF, it must then have been inspected by an IQP, whcih should (but often doesn’t) include fire ratings. You could point out to the Council that it has a current BWOF by an IQP accepted by the Council for assessing this item and since they have signed it off, it must be ok. If they have any concerns, maybe the Council should have a chat with the IQP about their competence…

  2. Under S94 of the Building Act, the BCA can’t issue a CCC unless it is satisfied on reasonable grounds that it complies with the consent -

Matters for consideration by building consent authority in deciding issue of code compliance certificate
(1)A building consent authority must issue a code compliance certificate if it is satisfied, on reasonable grounds,—
(a) that the building work complies with the building consent.

Since they issued the CCC, they must have issued the CCC, they must have been satisfied that it was built correctly, otherwise it would be illegal. If in fact they feel they are mistaken or led astray by the original builder, then they have to follow the procedures for a “notice to fix” or a dangerous building notice.

I would say that either the building official concerned does not understand the processes of the CCC, or, he/she knows their CCC was a dud and is trying to remedy the situation. Sounds like a determination issue to me (eg you are going to have to jump through the BCA’s additional hoops to get a consent anyway).

There seem to be certain BCAs that are being particularly difficult at the moment. While I’m sure they are busy they seem to be intentionally time wasting and operating outside of the Building Act.

It is common that they are too lazy to look up any previous consents or documentation. They usually aggravate the situation by refusing to phone anyone directly to speed up their requests. In one case I’ve seen the BCA fight all the way through a determination even though there was no possibility of winning.

I’m taking up a number of issues relating to BCAs directly with the Minister. Even if what they are doing is not deliberate they are definitely understaffed and untrained.