Prescriptive format of AFSS & problems

Sent to NSW Planning,

As part of our consultancy business conducting independent fire safety assessments based upon AS4655 We’ve just had a couple of AFSS submissions knocked back by City of Sydney Building Compliance under the regulatory changes for submissions from 1 December 2017, because we did not complete the AFSS form exactly as required (as we didn’t have the owners signature on the form as required in Sect.9).

So I’m making this representation as a representation of our membership and for the sake of others similarly afflicted by your form as we have identified that the prescriptive nature of this form is also impacting upon members of various other associations such as the Property Council of Australia, Institute of Strata Title Management, etc.

Firstly – We’re quite ok with sections 1 to 5 (Type of Statement, Building address, building description, owner & owner’s address, schedule of fire safety measures detailing measure, date assessed, nominated assessor, and minimum performance requirement)

Whilst Section 6 (details of each competent fire safety practitioner/assessor) is partially ok in that CFSP’s are identified, we would be knocked back for the lack of signature (even though we can produce separate supporting service records and / or reports signed by these CFSP assessors – can you remove this mandatory requirement for signatureswe suggest that the CFSP simply be initialled on the AFSS in Sect.5 and named in Sect. 6 but that a referenced document and having the name, contact number, email and signature be acceptable – this would allow CFSP assessors checking a portfolio of buildings to use this one document as a point of reference.

We also approve of the competency matrix example published by NSW Planning and suggest that such a competency matrix would be completed by anyone claiming to be a CFSP, and this be provided to the AFSS Issuer with or as the CFSP signed document.

 If the submitter of the AFSS are required to obtain the signatures on each AFSS and for each CFSP conducting performance tests, as well as the requirement to have the building owner provide signed authorisation on every AFSS form, this shall blow the AFSS preparation costs way out without any enhancement of a delivered complying and performing building.

We’re so far ok with Section 7 (signed AFSS Declaration by issuer) and ask if, on an AFSS (not supplementary), Section 8 be deleted or simply have n/a rather than including the full text as on the form.

Section 9 (owner’s authorisation) is a real problem as regulators such as City of Sydney will not currently accept any attached authorisation letter, stating that Planning’s Form requires each AFSS to have the owner signed authorisation.

We suggest that such a referenced letter should be deemed acceptable and that such a letter nominate:

  • detail the Building owner details to include: building or for a portfolio of buildings (such as City of Sydney owned Property Portfolio),
  • Entity (Building Owner) Name, entity representative, entity representative title,
  • declaration that the entity representative is duly authorised to make this authorisation,
  • the ABN of the entity if applicable, the contact mailing address of the entity, the contact phone number of the entity representative, the email address for the entity,
  • the agent subject to the authorisation, the ABN of the agent, the representative of the agent,
  • the expiry date for the agency agreement whence the authorisation becomes void unless replaced by a new authorisation letter, the signature of the entity representative and date of the authorisation.

We also see Section 11 as a duplication of Section 5. The Regulator (Council) already have a copy of the Fire Safety Schedule of record for the building and usually issue this with their 90-day reminder letters. We simply see no real purpose in requiring as demanded by the AFSS form a separate copy of the FSS as part of the AFSS when Section 5 clearly replicates that same schedule.

Another alternative would be to remove the prescriptive requirements for some of the form content such as is the case with EP&AR2000 cl.181

Note that EPAAR2017 ref to this clause (181) requires the change: A fire safety statement for a building or part of a building must “be made in the form approved by the Secretary and must” contain the following information:

  1. the name and address of the owner of the building or part,
  2. a description of the building or part (including its address)
  3. a list identifying:
    1. each essential fire safety measure in the building or part(for an annual statement),
    2. each critical fire safety measure in the building or part (for a supplementary statement),

together with the minimum standard of performance specified in the relevant fire safety schedule in relation to each such measure,

  1. the date or dates on which the essential fire safety measures were assessed,
  2. The date on which the building or part was inspected,
  3. The type of statement issued (Annual/Supplementary),
  4. A statement to the effect referred to in cl.175 for an Annual or cl.178 for a Supplementary
  5. The date of issue of the statement.

So the real trigger for all of this angst is that we may now only use that PRESCRIPTIVE form as approved by the Secretary for submission after 1st December and all other forms of the AFSS conforming to EP&AR2000 cl.181 such as those previously developed and which were previously in a format approved by the Secretary are now deemed as voided.

Please call with any queries.


Ian Childs | NSW Chair – Society, Building Services Engineers |
Member – Engineers Australia Learned Society Advisory Council

Representative – Standards Australia, Technical Committee ME/62 |

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Are older buildings really safe (Fire Dampers & Duct Breakaway)

In Australia once a building is built, there is little requirement for retrospective upgrading (except when major work mandates upgrade using the 50% refurbishment within a 3-year period rule, whereupon it is required to update to those code requirements or equivalent at that time – though many do whatever is possible to avoid this and most goes unnoticed).

We have observed that many hi-rise building with HVAC installations pre-dating AS1682.1&2-1990 are without appropriate breakaway on the ductwork.

Why is the breakaway requirement so important?

  • > Because if there is a fire, there is every likelyhood that the duct shall collapse and this shall result in the duct without breakaway pulling the fire damper from the wall as well as that action leading to partial wall collapse.
  • > If there was breakaway, the duct would collapse but the fire damper would be retained within the firewall and provide the required protection.

It is my personal belief that whenever there is the opportunity (vacant possession, refurbishment, etc.), that every opportunity is made to update these systems in that accessible part of older buildings to reflect current performance requirements (or deemed equivalent).ImageIt should also be recognised that those maintaining and assessing these systems are referencing them back to the performance standards associated with their installation (operational check) and this means that the assessment reporting fails to identify non-conformance to what is current “minimum best practice“.

It has also been observed that inappropriate practices by other trades are not being reported by service technicians/ maintainers and this degrades the performance from that of the original installation (cables and pipes adjacent to duct penetrations of firewalls, etc).

It needs to be known that the assessors are actually obliged to endorse performance based entirely upon the standard of installation and such a process while conforming to the legislative requirements (and covering the assessor from liability), still leave a residual risk until that building is fully upgraded.
The building owner/building controller, remain as the responsible entity for the safety of those in occupation and should give consideration to management of those risks as well as any risks introduced by those occupants.

Building owners require that any new works reflect current requirements but are under no obligation to elevate the base building.


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AS1851-2012 Service & Repair of Essential Services in Buildings – finally published


Ok – so it’s only some 5 months latter than expectations. It’s still great to see this standard finally appear.

AS1851 provides a task schedule and scope to those who service and repair essential services measures in buildings (except those which for some idiotic reason weren’t included).

It clearly defines the requirements and expectations required of the building owner (base building data, alternate solution documentation, tactical plans and procedures) as well as the how and when to service.

The essential services measures which were inappropriately excluded were: Emergency Lifts, Emergency Lighting & Exit Signs, and Standby Power Systems. Hopefully the next review can see these included.

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Some things we do

Contact us at if you see where we could be of use to your team.Image

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Premises Access

In Australia, we have had legislation put in place since May 2011 requiring access for those with impairments into buildings where they shall enjoy not less than that same level of access provided to the unimpaired.

Any new or refurbishment of the whole or any part of a public accessed building must provide satisfactory access from public space (street) through the entry and to the new work area as well as throughout that new work area.

Exemptions are available where it can be established that the provision of such access would cause and these is evidence to support undue hardship for the stakeholder/s.

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Legionella can be controlled

Forced draft counterflow cooling tower

In Australia, we’ve completed our review of the Australian Standard for microbial control in cooling water systems and HVAC including a new part for performance based maintenance on air-handling plant.

To assist in this, we at NDIBS have developed a presentation talk to briefly explain the history and readily identify observable failings in systems as well as some of the more advanced methods that we use to mitigate such risks and elevate plant efficiency.

The talks are currently freely available to our current and prior customer base with presentation at the customer’s premises. We will also consider offering the same to others where practicable.

Anyone interested should contact us at

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Men Meeting the Challenge Conference 1st Sept 2012 at King’s School North Parramatta

ImageOn Fire for Christ
For all those Sydneysiders who call themselves Christian – It would be great if you could think about attending the Men Meeting the Challenge event on Saturday September 1st . It is best to book as soon as practicable so that you may take advantage of early bird rates as well as the 10 for 8 offer (arrange this through your local men’s ministry convenor, etc.)

The conference is a non-denominational, biblically referenced teaching event with the aim of assisting us in reflecting Christ to all of those with whom we have contact.

For those with a Dad around, take him along and be with him (day preceding father’s day on Sunday Sept 2nd), or for Dad’s think about bringing your son/s!

For the Girls, this is a great opportunity to get your men out of the house (together) on a Saturday and have them return better for it. As I quiter rightly point out to my Loving wife “I may not be the perfect husband and father – but without the influence of going to talks such as these, I’d definitely be a whole lot worse…” She is mindful that I dramatically improved after my committment to our Saviour and that I’m slowly getting easier to live with in spite of being a grumpy older man!

Talk program will be: Ian Powell who shall challenge us with the commission to make Christ as Saviour known, followed by Leigh Hatcher querying where we stand in our culture, then there will be a group of choice options for sessions on: ministering to mates, seeding with children, witnessing in groups, grandparenting ( I’ll be probably choosing this one) – then another choice session on: contacting young guys with the Gospel, lifetime commitment (marriage), being a chaplain in your workplace (Graham Clark), being genuine and committed with those of differing culture (Frank Hawkes). We would then be closing with a summation by Dominic Steele.

If you see that all of the talks are appealing (as I do) and you’re having difficulties on which breakout to attend then prioritise what you feel would benefit you most (and let your Dad or son or guest choose what he’d like) – then order the MP3’s for the event. This will also make a great ministry resource and reference (we stick them in the slot in the car when driving around and seem to get something more out of such talks and find ourselves refreshed each time we pray and then listen). We also have some of the earlier MMC event talks should anyone be interested (but we would like to have them back to share with others as well as refresh ourselves) or go to the website and download last years MP3’s of the talks as well as check out the promo video.

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