MBIE have asked the SFPE NZ Chapter to prepare guidance on the Fire Engineering Brief (FEB) process. We have now had meetings in Auckland, Tauranga and Christchurch (Wellington to come shortly) to discuss the FEB process and what might be in the guidance document. The feedback in the three centres has been reasonably consistent and I will summarise it below to give everybody an opportunity to see what the common ground is and add anything else that they think is important or was missed out at the seminars.
What is the purpose of an FEB
Almost universally it was agreed that the FEB was a document aimed at de-risking the design and consenting process.
In all three centres examples were cited where an FEB process had not been followed and the design had been held up at the consent stage. Frustrated clients had often called the Mayor, lawyers or someone similarly high up in the hierarchy to try and force a resolution. When this happens all parties with fire in their job title get tared with the same brush and either considered obstructive or incompetent. In Tauranga it was pointed out that this tarnished the image of the profession as a whole and it was in the interests of the profession as a whole to ensure a smooth consenting process.
Peer reviewers also gave a consistent message that when an FEB was not carried out and they disagreed with the final design it put them in the unenviable position of having frustrate the whole design team if a major redesign was in order.
What sort of projects can an FEB be used for?
It was generally accepted that an FEB could be used in the following circumstances
- A deviation from an Acceptable Solution
- To discuss the means of determining the parameters around how an ANARP assessment should be carried out and what the acceptance criteria might be.
- A verification method design
- An alternative solution design
What happens if agreement can not be reached with all the stakeholders?
It was generally agreed that a design evolves throughout the design process and the FEB was a living document. Disagreements at an early stage often sort themselves out as the design develops for reasons other than fire engineering.
It was considered that if agreement was not reached on critical items then the level of risk was transferred to the consenting stage. As and example the proposed guidance on Alternative Solutions currently states that an FEB is recommended but that if it is not carried out then the Fire Engineer needs to advise the client the level of risk that they are being exposed to by not carrying out an FEB.
What needs to be in an FEB
Generally it was considered that an FEB needed to be scaleable dependent on the project and the level of risk that was involved. An FEB might consist of an email with some drawings for small departures from an acceptable solution to a full blown FEB with stakeholder meetings, minutes and lengthy documentation of the proposed design methodology, calculation methods and performance criteria.
Two important components were
- The FEB needs to establish context with the building/ project, the context of the fire design, the context of the FEB and the risks seeking clarification
- Drawings that enabled reviewers to get a feel for the project.
If a verification method was being carried out then the location and choice of design fires was important.
Also if a verification method design was being carried out it was not essential to repeat all the predetermined design inputs except where there were options.
It was considered that the FEB can often be an iterative process and details added to the FEB as the design developed.
Other miscellaneous thoughts on the FEB process
- For complicated projects should more than one peer reviewer be engaged?
- Can SFPE regulate or recommend who is suitable to undertake designs and peer reviews
- The FEB is an opportunity to receive input from other design professionals
- THE FEB is an opportunity to receive fire service operational input rather than wait till the construction phase of the project.
- Other design professionals produce design features reports and concept designs to inform/ discuss with their clients key design decisions. An FEB may or may not fulfill that function for the Fire Engineer. A separate document may be required.
- For peer reviewing alternative solutions could a panel of approved reviewers be set up.
- What is the competence and experience of the designer.
- Guidance prepared by the profession is more likely to gain general acceptance that guidance prepared by MBIE
Additional comments from Wellington not raised in the other centres
BCA's are overworked, short on physical resources and skill levels to review FEB documents
BCAs don't have a mechanism for charging for looking at FEB's so are not always interested in taking part in the process.
An FEB is not a legally binding document in the regulatory process. Therefore it is possible to apply for consent without an FEB.
The FEB process can provide significant delays, whereas the statutory timeframe for processing a building consent application is 20 days, so it may be quicker to not do an FEB and simply submit for consent.
If a peer reviewer provided comment on the FEB then that may be inferred as offering design advice. This removes the independence of the reviewer. The reviewer then accepts liability under the Building Act as a designer.
Please reply with any comments on what you think should or should not be in the guidance.