Contributing issues from the background paper

Issues by fire safety topic

Appendix D of the background paper to the consultation contained a list of 173 issues identified in the fire safety provisions in the Building Code. Comments from submissions were also analysed to identify linkages to the issues to those items from Appendix D to identify where the comments supported or opposed these issues.

Issues most mentioned

There were over 1000 comments related to issues in the background paper. There are comments received supporting 139 of the 173 issues identified with 26 issues receiving 10 or more comments supporting the issue identified. There are 47 issues identified as a priority with 22 suggested as a priority in more than two submissions.

The number one issue identified in the submissions relates to the evacuation of people of all abilities including those who are deaf, blind or disabled. This was specifically commented on by nearly half of all submitters.

Most submitters commented on the lack of certainty, consistency and clarity. There were many requests for more guidance documents to provide clarity, and more prescriptive requirements for building types and construction methods that are currently either out of scope or not covered in the AS or VMs.

Issues not supported in the comments

There are 34 issues from the background paper where no one provided any comments in support or opposition of the issue.

• 7 issues were related to the prevention of ignition and hazards in a building
• 12 issues were related to specific fire testing and construction requirements to limit fire spread
• 8 issues related to evacuations situations for specific building types or situations
• 6 related to features for fire alarms, suppression, and firefighter operations in buildings
• 1 issue related to structural fire safety.

There were 16 issues that submitters opposed in their comments. A list of these issues is provided in Table 7.1. The largest number of submitters opposed to these items are for the issues relating to keeping pace with new technologies and new fire hazards including those issues related to overseas products, the design and construction of mass timber buildings, modern housing, and fire hazards from green technologies. In all of these cases, there were significantly more comments received that supported the issues identified and some people noting these as priority issues to resolve.

Table 7.1: Number of submissions opposing specific issues in the Building Code

New issues identified

There were 10 issues identified in the submissions that were not previously discussed in the background paper or discussion document. The new issues included:

• Residential fire safety
  • Issue 3-14. Aging in place – Further considerations are required on the abilities of occupants to evacuate as they get older (Submission 022).
  • Issue 3-15. Attached garages – Garages attached to housing contain many fire hazards but there are no requirements for attached garages to be fire separated or otherwise protected from the adjacent dwelling (Submission 049).
  • Issue 3-16. Firestopping in small residential buildings – There are no solutions for firestopping between attached household units design in accordance with C/AS1. This presents challenges in maintaining the fire separation especially for routing of services (Submission 034).
• Fire hazards and prevention
  • Issue 4-21. Automatic storage and retrieval systems – Automatic storage and retrieval systems in warehouses use robots and shuttles to move items around and have limited access for people. This can be challenging to extinguish the fire and for firefighters to access the buildings. Further consideration is required for the fire protection and access needs for these types of facilities. (Submission 027)
• Fire safety systems
  • Issue 6-22. Photoluminescent exits signs – There is an inconsistent level of performance provided between photoluminescent and illuminated exit signs in smoke obscured conditions and it is unclear what the minimum level of performance is permitted (Submission 049).
  • Issue 6-23. Illuminated exit signs in marae – Illuminated exit signs in marae wharenui can be a nuisance as the light disturbs those trying to sleep which may lead to ad hoc coverings to block the light (Submission 059).
  • Issue 6-24. Carbon monoxide alarms – The performance criteria in F7 Warning Systems only covers alarms for fires and other emergencies. It does not contain specific criteria related to the detection of carbon monoxide (Submission 059).
• Emergency response
  • Issue 8-16. Confusing limits on application – The limits on application of clauses C5.3 to C5.8 are confusing and poorly worded. For example, as read, the limit on application of C5.3 would state that a hardstanding is not required within a multi-unit dwelling (Submission 041).
  • Issue 8-17. Assumption on firefighting – Assumptions for firefighting in the Building Code and C/VM2 about the contribution of firefighting and response times are no longer be valid (Submissions 043).
• Buildings undergoing alterations or change of use
  • Issue 10-8 Maintenance and checking of specific systems – Further clarity on the checking and maintenance of some fire safety systems including illuminated exit signs, ventilation systems, and passive fire systems (Submissions 015 and 024).

Additionally, there were comments on 20 issues that highlighted additional scenarios or provided additional details of the problem the issue was creating. These issues included:

• Objectives of the Building Code
  • Issue 2-2. Fire and other emergencies – Emergency access also needs to account for the operational safety of ambulance and police personnel in addition to firefighters. Any emergency response can be greatly affected by the design and layout of a building or development (Submission 31).
  • Issue 2-6. Unacceptable risks and low probabilities – There are also differences in the level of onerousness and conservatism between C/AS2 and C/VM2 (Submission 013).
• Residential fire safety
  • Issue 3-1. Residential specific requirements – Small, attached units with fire separation may also require specific solutions for fire stopping (Submission 034).
  • Issue 3-2. Accommodation buildings and at risk populations – The MBIE guidance for the fire safety of residential community housing recommends a declaration of support and management systems to be in place but does not cover what this should contain (Submission 022).
  • Issue 3-5. Classification of residential buildings – Residential buildings for people with disabilities may trigger a change in use and upgrades to the building which may be a barrier for disabled people living in the community (Submission 022).
  • Issue 3-12. Soffits – There is also a lack of clarity around the fire rating of shared entrances with shared eaves (Submission 055).
• Fire hazards and prevention
  • Issue 4-1. Hazards for different buildings – Smaller single or two-storey commercial buildings which may have limited size and fire risks but rather onerous fire safety requirements (Submission 018).
  • Issue 4-6. Fire hazards on the outside of the building – Fire hazards on the outside of the building also include electric transformers, overhead wires, or other electrical infrastructure (Submission 088).
• Fire spread
  • Issue 5-3. Performance criteria of passive fire protection – The New Zealand Building Code clauses C1-C6 do not contain any performance requirements for fire separations. There are no statements on how fire separations are to be constructed or how openings and penetrations must be protected to maintain the integrity of the fire separation. (Submission 026).
  • Issue 5-11. Building description for surface finishes – There is confusion on the application of surface finishes in escape routes in multi-unit apartment buildings (Submission 055).
  • Issue 5-17. Modelling rules and fire dynamics for current construction methods – Greater airtightness, increased insulation, sound proof construction, and material changes can also impact on the performance of fire safety systems and present additional challenges for responding firefighters not captured in the C/VM2 firefighting operations scenario (Submissions 043 and 044).
  • Issue 5-39. Notional boundaries – Notional boundaries are not clear for C/AS1 type buildings nor for eaves, overhangs, or irregularly shaped buildings (Submission 034).
• Fire safety systems
  • Issue 6-16. Interfaces with other parts of the Building Code – Occupant loads used in fire safety design also impact other parts of the code including importance levels, accessibility, and toilets (Submission 080).
• Evacuation and means of escape
  • Issue 7-8. Fractional effective doses – Clause C4.3 only works practically in reference to C/VM2 as the measurement of fractional effective dose requires computer modelling to determine the value. Alternative solutions to determine FED without using computer modelling or other methodologies are virtually non-existent (Submission 078).
  • Issue 7-24. Occupant load densities – Occupant load densities for early childhood centres also require further consideration (Submission 046).
• Emergency response
  • Issue 8-1. Access and facilities for firefighting – Specific concerns for firefighting access exist when there are multiple buildings configured on a single site and for non-fire rated roofs and canopies made of lightweight materials that may collapse (Submissions 022, 043, 044).
  • Issue 8-2. Protection of staging areas – Specific concerns exist where non-fire rated roofs and canopies made of lightweight materials may collapse on firefighters and firetrucks (Submission 044)
  • Issue 8-3. Responding to other emergencies – The operational safety and needs of ambulance and police personnel also need to be taken into account (Submission 031)
• Structural fire safety
  • Issue 9-3. Timber structures – Lightweight timber elements can also face issues when used in more complex buildings (Submission 007).
• Buildings undergoing alterations or change of use
  • Issue 10-1 Multiple building classification systems – There are also issues in the alignment of building classifications with warehouse and factories, buildings with emergency management classifications for post-disaster use, and the National BCA competency assessment system levels (Submissions 031, 034, 052).

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