SFPE Discussions

What happened to the MBIE 'Interpretations'?

I see MBIE have removed their fire ‘interpretations’ (previously FAQ) from their website.

What does this mean? Have they retracted their ‘interpretations’ or does it still stand? Does anyone know what’s happening?

Fortunately I print their webpages to PDF at regular intervals, as their advice seems to change without warning.

If their advice has been retracted we can obviously no longer rely on the ‘interpretations’ that allow, for example, failure of only a single fan in smoke control systems that have a single point of failure, or declarations of storage height irrespective of what the building is capable of storage as stated in C/AS5. What about the use of timber linings in crowd uses?

It’s been a long time since I’ve managed to get a response from their info@mbie address either.

I had not spotted that one …a bit worrying when you take the number of consents that rely on some sort of guidance (lines around storage the internal walls of a store for example to limit height???). Do we retreat to the published documents and have to stick to the actual wording no matter how incorrect? why woud MBIE do this - is it a cynical attempt at protection from legal actions?

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This is design by Confusion :slight_smile:

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I have received a response from MBIE on this one and am just waiting on feedback on wording before I disseminate the answer to everyone.

In the mean time don’t throw out your downloaded copies of the FAQ’s.

I read the info with some interest.

If the new AS and VM are not ready then why remove the interpretations - surely they are still all relevant?

The cynic in me says that they have been removed to limit liability and manage risk. I do find it sadly amusing that 5 years after MBIE changed things they are going back to what I suggested 10 years ago… I guess the real question is will they get it right now? The subordinate question is will they actually listen if they release another crock of contradictory rubbish and change the documents for the better now? Will the VM be a guidance document like it always should have been and will consistency across NZ be the norm?

I could suggest that they remove 99% of the stuff from the last change, go back to basics and present the industry with asset of documents that are useful.

Remember that the last multiple commercial fire death in NZ was Ballantine’s (circa 1947) and the last single one was in the mid 80s - seems that the rules were working reasonably well, although we don’t kill enough people in NZ to make a difference…but we rely on overseas accidents and local rhetoric based on bad practice to form our compliance documents…ummmmm…

Hi all,

I was just wondering if anyone has a copy of the old interpretations for crowd use? I am enquiring about the use of timber linings in a retail shop that will clearly not be a crowded space, yet it is considered ‘crowd medium – CM’. C/AS2 Table 4.3 suggest Group Number 2-S is required, however it sounds like from this thread there is some room for interpretation what a ‘crowd’ space is.

Thanks :slight_smile:

This was an error on the part of the writers who rewrote the building regulations. CM was originally “Crowd Merchandise”. “Crowd medium” has no real meaning. So in answer to your question, CM has nothing to do with being “a crowded space” but everything to do with being “retail”.

I also recall “Merchandise” but can’t find the official document stating it as the definition of CM.
Schedule 2 pre 2006 isn’t available on http://www.legislation.govt.nz/regulation/public/1992/0150/latest/DLM162576.html#DLM6632400 and I don’t have it in my library.
In the old C/AS1 it was a purpose group but not giving the meaning of CM, only that it was “Spaces for displaying, or selling retail goods, wares or merchandise.”

Just looked in C4 3rd edition, so 1995, and table A1 only uses acronyms, CS,SR, WL etc splitting these activities into crowd, sleeping, working and so on. this methodology was carried over verbatim into C/AS1 amendments 1-9 and it looks like it only changed in 2005 with the implementation of the specified systems change of use regs where they expanded the acronyms. Can’t find that CM was ever classified as merchandise but that is certainly implied in the description of intended uses

I obtained the FAQ’s from MBIE using an Official Information Request, and shortly after that the FAQ’s were published on the SFPE website. Note; relying on guidance (even if issued under Section 175 of the Building Act) if outside of the Acceptable Solutions or Verification Methods will be an alternative solution, and relying on that guidance doesn’t relieve a person of the obligation to consider any matter to which that guidance relates. A BCA can refuse to accept guidance as means of compliance if they wish, even if its officially issued by MBIE… perfect example is the Design Guide for Residential Community Housing. Likewise; a BCA can accept relying on guidance as means of compliance as an alternative solution, such as storage height signage in non-sprinkler protected buildings, but should be declared as such and not assumed to still be an Acceptable Solution.