SFPE Fire Engineering Brief Guidance

1

Hi All,

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

  1. A deviation from an Acceptable Solution
  2. To discuss the means of determining the parameters around how an ANARP assessment should be carried out and what the acceptance criteria might be.
  3. A verification method design
  4. 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

  1. 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
  2. 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

  1. For complicated projects should more than one peer reviewer be engaged?
  2. Can SFPE regulate or recommend who is suitable to undertake designs and peer reviews
  3. The FEB is an opportunity to receive input from other design professionals
  4. THE FEB is an opportunity to receive fire service operational input rather than wait till the construction phase of the project.
  5. 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.
  6. For peer reviewing alternative solutions could a panel of approved reviewers be set up.
  7. What is the competence and experience of the designer.
  8. 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

  1.  BCA's are overworked, short on physical resources and skill levels to review FEB documents

  2.  BCAs  don't have a mechanism for charging for looking at FEB's so are not always interested in taking part in the process.

  3.  An FEB is not a legally binding document in the regulatory process.  Therefore it is possible to apply for consent without an FEB.

  4.  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.

  5.  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.

2

Hi All
An engineering brief is a conceptual outline of the project, not a design document. The original FEB as produced by the Fire Code Reform Centre (part of the ABCB) was never intended to be a design document.
The content of an FEB therefore does not allow for a number of design elements to be considered and agreed, which is why I would recommend that the “Fire Engineering Brief” be replaced by a “Preliminary Fire Report”, which can incorporate all of the relevant design decisions that need to be allowed for at the preliminary stage.
In regard to the “Miscellaneous Thoughts”

  1. No. The peer reviewer is competent, or do not use him/her.
  2. Yes. SFPE needs to get pro active in this regard. We have had 25 years of BIA/DBH/MBIE operating in a vacuum, without any ability to actually have a combination of working experienced fire engineers who have a direct input (without changes by other parties) into the technical aspects of fire engineering design.
  3. Agreed
  4. Agreed. NZFS needs to be part of the design process, and not (as currently) only able to snipe from the sidelines. A good example is the very positive input by the NZFS to a hypoxic cold storage facility, where the NZFS opted to have a positive approach, which assisted Council.
    5, A preliminary fire design report that includes all of the FEB inputs, plus a basic design for discussion is a necessity for any complex alternative design.
  5. Yes. The main problem will be the determination of “approved”. There are a number of CPEng who are competent to review alternative designs, and then there are a number who may not have the relevant breadth of experience. How many CPEng can produce a safety case study, or determine whether a combustible fluid settling pond design is correct?
    The advantage of a panel is that a practice cannot use a “tame” reviewer all of the time ie the designer would need to use the next cab off the rank. The disadvantage is that the next cab off the rank may not have the specific experience for the review to be competently undertaken.
  6. Good question. The breadth of experience in NZ fire engineers is generally quite narrow, as our geographical size limits the number of “exotic” projects. If you consider the industrial scene alone, and particularly petro chemical sites, how many fire engineers can list multiple projects on their CV? This problem means that for specific projects we need to go shopping for a competent reviewer. In the case of the hypoxic system mentioned above, the review was undertaken by a combination of NZ and Norwegian reviewers.
  7. Guidance prepared by the profession is problematical, as the guidance preparation needs to be funded. There are a number of big picture generic guidance documents in the world, but for specific complex projects, particularly ones with a specified reliability (as required by a safety case study) the design team are normally on their own. This is great if the expertise has been assembled, but bringing a member of the team up to speed can be a frustrating process.

Paul Clements

1 Like
3

I think that the fundamental question is not “is the FEB a good idea” but rather “is the FEB a mandatory document”. We can all agree that the first answer is yes. The second is more complex. Given that no one can ask for more than the Building Act required the FEB is purely voluntary. If a CPEng asks or requires an FEB they are then in danger of breaching a statue (the Building Act itself)…

Also if an FEB is required for everything other than an Acceptable Solution design then it will apply to ALL 112, 115 specific designs, waiver and most modifications (by default)…again noting that the VM is a compliance document, why doe sit apply here (and the wording in the VM is that the FEB is not a normative part of the VM itself.

Whist I think that the FEB is good I think that the SFPE needs to wait until the outcome of the working groups before it gets pushed into a corner trying to do what MBIE clearly can not do…oblige the use of the FEB…
.

Just my thoughts…

Alan

1 Like
4

First post updated with comments from Wellington that had not been raised in other centres.