Many people believe building regulations guarantee occupant safety, but compliance only reflects a government-led level of risk. True safety is measured by the ability of occupants to escape a fire unharmed.
The compliance documents can quickly become out of step with new technology creating safety issues as discussed in my previous article Fire Risks of Emerging Technology. Some evidence from that article are:
- Entire homes constructed of foam plastic (EPS)
- Charging of EV vehicles in internal garages.
- Mass timber as construction material.
These are deemed compliant with the Building Code within the Acceptable Solutions but are they safe?
It is essential to distinguish between calculations to comply with the building code and actual fire safety. For example, NZ Building Code Clause C4.4 removes the need to address visibility for up to 1,000 occupants in a sprinkler-protected building. This is a measure to promote the use of sprinklers, it does not mean the building is safe.
Health and Safety Regulations (Section 39 HSWA) requires that as designers to “ensure that structures are without risk to health and safety of persons”. This is an additional step beyond building code compliance to address the safety of people using the building.
I believe we have a duty of care to ensure that buildings are not only code-compliant but are genuinely safe. Our responsibility extends to ensuring that fire safety strategy will perform when needed.
There are lot of examples of buildings that comply with building code but creates an unsafe condition for the users of buildings. For example
- Escape through hazardouse areas such as kitchens, factory floors or loading bays.
- Smoke extract systems that create large air movements that can move materials and block exits.
- Fire curtains that drop over normal access routes that block escape routes.
For all of the above, it is imperative to prioritize the safety of occupants . As fire engineers, we encounter the challenge of balancing practicality, safety, and cost-effectiveness whilst also complying with the code.
The NZ Building Act uses the terms “not safe” and “dangerous” (Sections 116B and 121) however safety is not addressed in the building code. I propose a paradox – can a building that complies with the building code as required by the Building Act be deemed unsafe or even dangerous under the same Building Act?!
The industry recognises these issues and has taken the initiative to produce best practise guidance to address emerging fire risks:
- Designing for Fire Safety for Homes
- Fire Safety In Multi-Storey Mass Timber Structures
- Advisory note on EV Charging
Unfortunately, the above are only guidance and not mandatory. To fully address safety a fire risk assessment must be undertaken to determine the level of risk that requires appropriate action. The Handbook for Fire Risk Management is an excellent tool that should be used on every project.
I believe that true performance based fire engineering requires more than meeting minimum code requirements for a building to be safe. As an industry we have a responsibility to take an extra step to address fire risk within buildings.
