Summary of Findings Fire Review

BUILDING
SYSTEMS
PERFORMANCE
BRANCH
Stakeholder Engagement
Summary of findings
Fire Safety Review 2014
Introduction
The Ministry of Business, Innovation and Employment (MBIE) is currently undertaking an
extensive review of fire safety regulations and practice in New Zealand.
The purpose of the review is to inform the development of a strategic direction for MBIE's fire
safety work, drawing on the views and experiences of practitioners. The review covers the
building life-cycle from project inception to demolition, and considers alterations, changes of
use and subdivisions. It draws on perspectives from stakeholders at each stage in the building
life-cycle. It also draws on research elements to inform MBIE where improvements can be
made in fire safety, cost, and practical outcomes.
To date, MBIE has completed two phases of stakeholder engagement, seeking feedback from
across the sector in relation to the issues that have been surfacing over the past two years.
Phase one involved holding feedback sessions in five locations across New Zealand. Phase two
involved a questionnaire that was designed to drill deeper into the key issues raised during
phase one.
This report details feedback received during both phases, detailing the key issues. This
information will be used in planning the direction in the Fire Review over the next six months,
year, two years and beyond.
Phase one Stakeholder Feedback Sessions

MBIE briefing
Key MBIE staff was briefed in September 2014 of concerns being expressed from the sector
about the implementation of the 2012 Fire Safety Building Code changes and to seek feedback
on:
The upcoming fire review stakeholder engagement approach and activities
Key issues
Feedback and views expressed during this session has been included in the broader feedback
process. The feedback provided had been broadly received as enquiries since the new Code
came into effect in July 2013. Key points included:
Errors within Acceptable Solutions and Verification Method documents

Performance based Code versus prescriptive elements
Inconsistencies in approach from fire engineers, designers and BCAs on a national scale
Concern about availability of fire engineering or fire sector resources nationwide
Code and associated documents have been open to interpretation, which has led to
inconsistencies across many areas
Sector is vocal, however with disparate views. Varying opinions and issues make it
difficult to determine the exact extent of any given issue
Would like to see better sector coordination and willingness to work with MBIE to
address issues
MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT
SUMMARY OF FINDINGS
External stakeholders
Stakeholder Engagement sessions were held across five locations including Christchurch,
Wellington, Auckland, Dunedin, and Tauranga. More than 250 participants attended all five
sessions and provided feedback on five key questions:
What is working well with the current regulations?
What is not working?
What have been the consequences?
What are the priorities in resolving any issues?
What Else
The feedback received at each session was collated and reviewed, and the following graph
summarises the most common issues raised at each session. These issues were then used as
the priority themes in the phase two questionnaire. The top 12 issues from this phase have
also been listed below.
Phase one high level summary (top 12 issues)

1. Further guidance needed for alterations to existing buildings as near as is reasonably
practicable
2. Some have expressed concern that changes have increased costs, caused delays and
loss of accountability and confidence
3. Need to clarify building inspection regime and process of Warrant of Fitness and
Compliance Schedule
4. Disconnects between legislations leading to uncertainty of requirements
5. Clarify the role of New Zealand Fire Service and Fire Fighting water requirements
6. Re-address requirement for interior surface finishes and performance levels
7. More guidance and consistent advice needed from MBIE Update commentary and
guidelines
8. Advice from BCAs varies widely education and training of BCAs, Architects and
trades on Fire Safety Design
9. Guidance needed on Passive Fire Protection and service penetrations
10. Verification Method should be more flexible and allow innovation
11. Fix errors and inconsistencies in Acceptable Solutions C/ASx
12. Review acceptable solutions for Community Care, Property Rating, Disabled
Evacuation and Fire Fighting
SUMMARY OF FINDINGS
SUMMARY OF FINDINGS
Phase two - Questionnaire

A detailed questionnaire was emailed to stakeholders in October 2014. Approximately 220
stakeholders responded to the various questionnaires. The purpose of the questionnaire was
to gather more detail in relation to the key issues raised during phase one of the stakeholder
engagement process.
The main respondents to the questionnaire were from the Fire Engineering field and Building
Control.
Of the key issues we heard about during the phase one feedback sessions, weve focused on
analysing the statistics for the top rating themes that respondents provided feedback on in the
questionnaires. It is important to note that this is not MBIEs view of the issues facing the fire
sector.
The below graph shows how many participants answered each questionnaire.
Further follow up engagement was also undertaken with parts of the industry where the
response rates were low (ie architects and designers).
SUMMARY OF FINDINGS
SUMMARY OF FINDINGS
Phase two: statistical analysis

The following table outlines consolidated comments from the top answered questionnaires (based on graph above).
Forum Headline
Issue clarification
Question
Statistics
High level comments
Comment Summary
Acceptable Solution
Issues
This questionnaire was enquiring

about accuracy, completeness and the
new layout of the Acceptable Solutions
C/As1-7 and whether people found it
easy to use
Acceptable solutions C/AS1 to C/AS 7

meet the performance requirements
of the Building Code
49% of respondents did not

answer the question
29% strongly agree or agree
12% neutral
8% disagreed or strongly
disagreed
C/AS1 6 is easy to use

answer the question
11% neutral
disagreed
The format of C/AS 7 is easy to use

answer the question
16% neutral
9.5% disagreed or strongly
disagreed
Rate impacts of errors in C/ASx on your
organisation
SUMMARY OF FINDINGS

answer the question
Need better consideration of those

with disabilities when designing to
acceptable solutions
Current acceptable solutions have
increased costs for building owners
without increasing safety or
providing value for money
Issues within consent process and
demonstrating compliance
Councils dont understand the
documents
Spending more time justifying
designs
Lack of sector wide training on how
to use or develop acceptable
solutions
Inconsistent with objectives of the
Building Code
Errors within the document
Amalgamate into a single document
Open to interpretation, resulting in
issues with the consenting process
Badly written clauses and
inconsistencies with explanations
Create a user group where
participants actually use the
documents and have real time/ real
life examples
Create an online calculator
Amalgamate into a single document
Make C/AS7 a stand-alone
document
Vehicle parking should be removed
Create an online calculator
No consistency in how the
documents are laid out
Open to interpretation, resulting in
issues with the consenting process
Additional checking required
Open to interpretation
C/AS1-7 have significantly changed

and the seven (7) documents are
inconsistent, disconnected and
contain errors
Process has increased costs with no
foreseen benefit
Errors have caused confusion,
delays and uncertainty
Having multiple documents is
difficult to use
Forum Headline
Issue clarification
Question
Statistics
High level comments
18% had a high impact
10.5% had a medium impact
13% had a low impact
Rate impact of an MBIE interpretations

committee needed to interpret C/ASx
requirements

answer the question
18% had a high impact
11% had a medium impact
6% had a low impact
The language/ writing style used in the

C Acceptable Solutions is not clear

answer the question
14% neutral
disagreed
SUMMARY OF FINDINGS
Causing confusion and unnecessary

rework
Forcing high levels of fire safety into
designs where there is no added
value or necessity for it
Too many amendments for the
sector to get their head around
Too complex, consider simplifying
Need to reconsider definitions
Inconsistencies and contradicting
information in documents
Liability risk and increased costs to
the client due to delays
Could cause more lengthy delays
and increased costs
Would help with working through
ambiguities within the documents
as they exist
People on the committee would
need compensation for their time
to encourage participation
No requirement for a committee if
the documents were simplified,
errors rectified and a bit of common
sense applied
May assist BCAs in being consistent
across the country
Remove confusion and
misinterpretation
Fire Engineers could influence and
therefore weaken the terms of the
documents
May reach a consistent approach
nationally
May address some of the grey
areas
Difficult to understand
Results in delays to consenting
process
Bring back the Fire Advisory Panel
to provide outcomes
Clearer explanations and
clarifications
Further explanation required
around clauses
Inconsistencies and open to
Comment Summary
Forum Headline
Issue clarification
Question
Statistics
High level comments
interpretation
Interpretations Committee could
resolve these issues
Revert back to previous documents
as they worked
Items not explicitly covered by the

scope of the Acceptable Solutions are
problematic

answer the question
10% neutral
disagreed
Impact on business
Acceptable solution fire design should

be Licensed Building Practitioner work

answer the question
Mixed use facilities

Halls in residences
Existing linings
Vertical fire spread
Existing buildings over 5,000m2
External fire spread
Fire evacuation regulation
requirements
Large horticultural buildings
Subdivisions
Some building types are in the
grey area
Party walls and boundary walls
Mezzanine floors
Causes rework
Work is turned away
Wastes time due to inconsistencies
Unable to confirm extent of design
requirements
C/AS1 were better documents to
use
No comments recorded

6% neutral
disagreed
Acceptable solutions should address
disabled evacuation more effectively

answer the question

13% neutral
disagreed
SUMMARY OF FINDINGS
Cost vs benefit analysis required

Increased costs with design and
construction and limitations on
design opportunities
Cost for compliance would increase
Huge costs for small percentage of
building occupiers. Need to
consider use of buildings prior to
making decisions
Code should address access and
Comment Summary
Forum Headline
Issue clarification
Question
Statistics
High level comments
Other issues
Alterations to existing
This questionnaire was asking about
buildings, change of use the impact of s112 on work carried out
and sub-division issues to existing buildings. Explicitly,
whether the requirements were well
understood and whether there were
any implications of uncertainty
Information about means of escape

from fire for existing buildings needs to
be expanded

answer the question
5% neutral
disagreed
A change of evacuation strategy from

all out to one that has refuge to a
place of safety should be building
work, and require a building consent

answer the question
2% neutral
disagreed
10
SUMMARY OF FINDINGS
Comment Summary
egress issues for disabled people

Need to consider hidden
disabilities like cognitive, lung or
heart defects that impact ability to
exit buildings in a fire
Being able to self-evacuate or not
should be considered and requires
thought when writing the Code
requirements
Simplify the documents
Rewrite definitions
Ensure consistency across
documents and links to other
legislation
Consider tailored sector education
Consider disability issues in terms of
access and egress
Undertake cost benefit analysis of
any further changes
Passive fire protection should be
included in sector education
7% would like guidance on
assessing what is as near as
reasonably practicable
6% would like guidance on how to
undertake a gap analysis including
assessment of as near as reasonably
practicable to the Building Code
limits of visibility and fractional
effective dose
5% would like guidance on what the
list of fire safety features and
statement of changes should
include
Will result in safer buildings
Ensures appropriate design
expertise and review is applied to
change in fire evacuation strategy
Less injuries and enhanced life
safety Will cause increased
compliance costs
Greater risk to life safety
May bring comfort that design
meets necessary fire safety
requirements
More guidance on gap analysis and

use of what is near as is reasonably
practicable (ANARP)
Uncertainty increases cost and
possible illegal work
Wide variation in BCA
interpretation
Introduce inspections to existing
buildings
Forum Headline
Issue clarification
Question
Statistics
High level comments
Fear of 112 upgrades leads to illegal

building work

answer the question
10.5% strongly agree or

agree
3% neutral
Fear of 112 upgrades leads to

avoidance of consents

answer the question
agree
3% neutral
disagreed
The benefit of a full building review is

only realised when it is done well and
includes site visits

answer the question
2% neutral
>1% disagreed or strongly
disagreed
Commercial pressures mean that

shortcuts are being taken on Section
112 full building reviews

answer the question
3% neutral
disagreed
11
SUMMARY OF FINDINGS
Buildings do not get upgraded

Increased costs and additional work
associated with the alteration when
a BC is applied for, may result in a
number of buildings not complying
No building is done due to costs of
bringing building up to code
compliance
Building work is illegal and unsafe
Concerned upgrade requirements
will be unreasonable
Inconsistent application of
exemptions by BCAs
Increased costs of compliance leads
to lack of compliance
Results in unsafe buildings and
building stock not being improved
across NZ
Depends on quality and age of the
plan and associated records
Fire safety is about the whole
building and should result in a full
building review
It depends on the building. If there
are not many non-compliance
issues and the alterations are
minor, then site visits may not be
required
May result in better fire designs and
better understanding of the whole
building, rather than relying on
piece-meal assessments
Site visits are a must on every
alteration to an existing building
Increased costs
Cost of design and construction
BCAs need to carry out systematic
inspections of all buildings on an
annual or bi-annual basis
More consistency in application of
as near or reasonably practicable
and less trying to make all buildings
be upgraded to current standards,
when this is clearly not required or
practicable
Comment Summary
Forum Headline
Issue clarification
Question
Statistics
High level comments
The need to do a full building review

for a tenancy fit out can mean a vacant
tenancy for some time

answer the question
4% neutral
>1% disagreed or strongly

disagreed
When seismic upgrades are being

undertaken, fire and accessibility
shouldnt also require upgrading

answer the question
4.5% neutral
disagreed
12
SUMMARY OF FINDINGS
Better guidance and tools

This may lead to non-compliant
buildings
Potential for more enforcement
action, which will be contentious
Site visits with owners and
designers, then meet with BCAs to
ensure all parties know what is
happening
C documents are onerous and
ridiculous to use when certain
buildings have no evidence of
deaths due to fire
May result in dispute and
frustration
Red tape will cause increased costs
and delays
Will result in lost jobs, and clients
undertaking illegal work
Allow competent fire engineers to
make their own decisions
Clarification on gazette notice and
what is a minor change
More clarity around what should be
accepted
Giving BCAs more leeway to
decided when a full building review
is required
Needs to be a more simplified
process
Less emphasis on ensuring existing
building stock is fully compliant
when the majority of fires are
residential
These types of upgrades should be
aligned
Let the Building Act determine this
A benefit of not doing this work
would be cost related, but it needs
to be assessed on a case-by-case
basis
It will increase costs
To combine this seems the most
cost effective, but risks vs benefits
of doing so need to be considered
Comment Summary
Forum Headline
Issue clarification
Question
Statistics
High level comments
The cost of compliance is out of kilter

with cost of alteration works

answer the question

agree
4% neutral
disagreed
The process to establish if a change of

use has occurred is unclear
Response rates low
Availability of qualified
people and education
Due to changes to the fire safety

regulations, are people sufficiently
qualified within the industry to carry
out fire designs within cost and time
parameters
N/A
N/A
What training is considered necessary

for each role listed
13
SUMMARY OF FINDINGS
Comment Summary
BCAs should take into account

extent and nature of alterations
when determining what is
reasonably practicable
Need to prioritise works and
development an improvement plan
for the building
Project dependent
Nothing changes. If occupants were
safe before, why all of a sudden is
there a risk?
Work is not done as it requires
compliance and the costs are not
economically viable
Building owners and tenants
oppose best practice fire safety
Simplify the process
Consider sector education
17% have found it difficult to find

qualified people in the fire sector
CPEng or equivalent qualified
people in the fire sector
10.5% have found it difficult to find
qualified fire designers in the fire
sector
qualified fire protection engineers
in the fire sector
qualified NZFS Engineering Unit
personnel
qualified Building Control Officers in
the fire sector
qualified Independently Qualified
Persons (IQPs) in the fire sector
Fire Engineer (in order):
Construction monitoring
What other disciplines require
What is near as reasonably
practicable
What needs to be submitted for
building
Difficult to find qualified fire

engineers and BCAs with sufficient
knowledge and proper training
Forum Headline
Issue clarification
Question
Statistics
High level comments
Comment Summary
Specified use regulations

Evacuation regulations
Verification methods
Acceptable solutions
Building Code
Fire Protection Engineer (in order):
QA processes
Building Code
Fire Service (in order):
Building Code
As near as reasonably practicable
Specified use regulations
Evacuation regulations
Building Act
Building Control Officer (in order):
QA processes
As near as reasonably practicable
What needs to be submitted for
building
Building Code
Building Warrant of
Fitness
Do compliance schedules contain

sufficient information and are BWOF
inspections and the Form 12A system
clear and operating correctly?
It should be possible to nominate

storage height signage on the BWOF

answer the question

3% neutral
disagreed
The BWOF check should include an

interoperability test of integrated fire
systems
14
SUMMARY OF FINDINGS

answer the question
Allows large warehouse buildings to

have fire systems installed
appropriate to their level of
proposed use
Enhanced fire protection fit for
purpose
May help control fireload
Buildings can be used effectively
without onerous fire design and
implementation issues
More cost effective designs
Specified use of the building should
be included in the BWOF
Would increase costs
Common sense approach as it
would guide the evacuation process
Compliance Schedule should extend

to include signage and passive fire
protection measures
Compliance Schedule should be
more comprehensive to include
inter-dependency of systems
Forum Headline
Issue clarification
Question
Statistics
High level comments
3% neutral
Fire engineering brief

issues
Does the FEB process allow early

stakeholder engagement and is NZFS
role clear in the process?
The FEB process results in safe and

more cost effective building
disagreed
Fire Engineers statistics:
5% neutral
3% agreed
disagreed
Building Control Officer
statistics:
2% neutral
1% agreed
The FEB process reduces consenting
risk
Fire Engineer statistics:

10% agree or strongly agree
2% neutral
disagreed
Building Control Officer
statistics:
Ensures the system works as

intended, resulting in safer
buildings and better occupant
protection
Isnt this already happening?
Councils should perform purely
administrative roles on FEB process
FEB process is about expediting
consent and ensuring stakeholders
have a say it doesnt make
buildings safer as design still has to
comply with VM2
FEB process has not decreased
consenting time
Provides better guidance for the
process, and what needs to be done
at each stage
There is confusion around when or
if the NZFS should be involved at
this stage
Process is time consuming and
unnecessary
Have a clear VM2 so FEB is not
required unless going outside of the
VM2
Make the use of FEB process
optional or remove it altogether
2% agreed
What benefits does the FEB process
provide?
N/A
What problems does the FEB process

create?
N/A
15
SUMMARY OF FINDINGS
Comment Summary
It can reduce rework

Stakeholders are all informed of the
parameters and feasibility of design
at an early stage
Provides a forum for discussion on
specifics of a building and proposed
fire design
Less risk through building consent
process
It is treated as a tick the box
exercise and doesnt add value
Generally misunderstood by all
involved
FEB process is tedious and time
consuming
FEB has assisted with engaging

stakeholders on fire designs
NZFS role is unclear in FEB process
Process is uncertain and results in
increased costs and delays to
projects
Forum Headline
Issue clarification
Question
Statistics
High level comments
Legislation alignment
Are the various pieces of legislation for

fire safety aligned, or are there
disconnects? Are stakeholders aware
of the legislative requirements for fire
designs?
Have you been affected by disconnects

between the evacuation regulations
and the Building Code?

answer the question
15.5% responded yes
5.5% responded no
Legal status of FAQs and C/ASx and

C/VM2 commentary is clear

answer the question

disagreed
Has your business been affected by

disconnects between the HSNO
regulations and the Building Code
Inconsistent implementation of MBIEs
16
SUMMARY OF FINDINGS
9% responded yes
Gives parties their own agenda to

influence design and prevent
progress
Increases costs and causes delays
Loss of work due to non-compliance
Confusion as to what is required
Liability risk
Increase in cost and delays with
reviewing existing buildings
No consistency on what is agreed
during resource consent, consent
and the evacuation regulations
Designers hide behind the building
code level of performance creating
conflict and issues for their client
down the track
Commentary to C/VM2 helps
establish the intended level of
safety, and should be available as a
reference for alternative solutions
attempting to provide an equivalent
level of safety
The inability for the commentary to
be considered binding means BCAs
can put whatever interpretation
they like on things
Uncertainty which is difficult for
clients
Designers consider advice to be
non-binding and therefore
disregard it leaving the building
owner in an untenable position
Disconnections in legislation are not
cost effective
Better integration of HSNO

regulations into the C Clauses and
make consideration of HSNO
requirements compulsory under the
C Clauses
Make HSNO, the Evacuation
Regulations and the Buildings
structure and systems part of the
same planning and consenting
process
Employ competent staff who
10% responded no
Comment Summary
There are disconnects between the

various pieces of legislation
HSNO and RMA requirements need
to be included in fire safety
document
There is confusion and a loss of
accountability
Increased costs and time delays
Forum Headline
Issue clarification
Question
Statistics
guidance by BCAs causes issues
answer the question

4% neutral
1% disagree or strongly
disagree
New Zealand Fire

Service issues
Is the Fire Service review requesting

information consistent with the Act
and are the right type of consents
being sent to the Fire Service?
Requests for further information

arising from the Fire Service consent
review cause consent delays

answer this question
2% neutral
2.5% disagree or strongly
disagree
How could this issue be addressed?
High level comments
N/A
The NZFS raise safety and evacuation

regulation issues that cannot be
enforced in the consent process
N/A
The NZFS Engineering Unit should be

accountable
N/A
17
SUMMARY OF FINDINGS
Comment Summary
understand MBIEs advice

Clearer interpretation required
Provide clearer documents
Use plain language documents
We need sensible rules addressed
in a pragmatic manner
Process causes increased costs and
time delays when information
request is sent by a BCA
Causes delays which result in
business revenue loss
Uneconomic to use VM2 as faced
with extra costs at having to use
conservative solutions
Do not allow the situation to occur
present complete consent
documentation to the BCA in the
first instance
Fire Service should be better
resourced with qualified fire
engineers
NZFS should get back to basics
looking at evacuation scheme
approvals and administration of
trial evacuations
Provide a time limit for FEB
responses and a complaint process
for NZFS failings
NZFS should restrict activities that
are covered under the Building Act
No need for the NZFS to do an
engineering review on top of the
peer review
NZFS should be limited to an
operations review only
Building Code and Evacuation
Regulations need to be better
aligned
Raise valid issues
Get it right the first time
Accountability for an appropriate
level of review
They should be accountable just like
any other engineer under IPENZ
Fire Service involvement is

uncertain and causes delays and
increased costs
Fire Service is not limiting advice to
that which is required by the Act
Forum Headline
Issue clarification
Question
Statistics
High level comments
Gazette notice 49 should be clearer

about what minor works are, and
which building consent applications
should be sent to the NZFS
N/A
Passive fire protection
Is passive protection being installed

correctly and are systems within
existing buildings being inspected and
maintained?
Installation of passive fire protection

should be Licensed Building
Practitioner work
N/A
Prescriptive surface
finishes
Are new requirements for internal

surface finishes having an impact on
the industry?
N/A
8% of respondents strongly
agree or agree that surface
finishes have a significant
impact on life safety
outcome of a fire
15% of respondents strongly
agree or agree that specific
prescriptive surface finish
requirements in the Code
causes difficulty
18
SUMMARY OF FINDINGS
Comment Summary
Shouldnt be in a gazette notice

Should be made clearer and more
specific
Minor works causes confusion
Remove the gazette notice and the
BA requirement for BCAs to consult
with the NZFS
Seems to be confusion with the
BCAs
MBIE should review the gazette and
do a proper risk analysis of what is
to be sent to the DRU
Increased costs and another layer of
inspections
Better control over fire protection

measures during and post
construction
Delays in having LBPs available to
do the work
Restrictive practice and will affect
small project sites
Considerable cost in upskilling,
training and licensing
Make installers accountable for
their work
Would create an increase in
competent and compliant work
Safer buildings and lives saved
Remove the prescriptive elements

from the Code
Revisit the issue with the Fire

Advisory Panel, consult more
broadly with industry
Remove the explicit numbers from
the Code
Undertake a proper study on
surface finish requirements, which
includes relationship to fire
protection
Create more timely and regular
guidance via a Committee that can
assist industry with settling disputes
and answering issues with
misinterpreting documents
Consider risk in terms of number of
fires in NZ where surface finishes
Concerns with the standard of

passive protection
Trades need improved skills and
accountability in terms of installing
passive fire protection measures
The new requirements are too

prescriptive and are not justified
New requirements do not allow for
alternative solutions
Forum Headline
Issue clarification
Question
Statistics
High level comments
Verification method
C/VM2 issues
Is the new C/VM2 comprehensive and

flexible enough for fire engineering
design and who should be permitted to
use it?
N/A
N/A
19
SUMMARY OF FINDINGS
Comment Summary
resulted in unquestionable damage

to a building as it is very low
No leeway for alternative solutions
VM2 process has not been around
long enough to evaluate
Delays in the process due to finding
a suitably qualified person is
problematic
Delays due to consenting process
Issues lie with those requiring
alternative designs, and as a
practitioner I avoid work that
requires VM2 as it is a massive cost
with little return
Delays in design approvals process
Training for BCAs is required
VM2 should be better written
Remove NZFS from the process
Inconsistent approach to
interpretation, creates confusion,
increases costs and causes delays
Consider VM2 and the consenting
process as its all too difficult
C/VM2 is causing design delays and

the process is unclear
Increased costs
VM2 needs more time to be
established before evaluating
Shortage of engineers to carry out
design work
Focus group sessions

Focus group sessions were held from 17 November to 26 November with international experts,
as well as representatives from specific areas of the sector, where stakeholder participation or
input into the Fire Review was considered low.
The purpose of these sessions was to discuss the key themes we had heard previously, and to
gather information on how these parts of the sector felt about these issues.
Information received as part of this process is outlined in the table below, and has been
consolidated into the feedback received from the previous phases of engagement.
Stakeholder group/ organisation
Designers Institute of New
Zealand (DINZ)
Key issue raised
New Zealand Institute of

Architects (NZIA)
Architectural Designers New

Zealand (ADNZ)
Timing and costs associated with developing

verification methods and the need to engage fire
engineers early
Staging of the fire report
Some BCAs are pedantic about designs
Some s112 issues
Construction monitoring and BWOFs and how fire
engineers are reluctant to verify
More sector education required
Fire reports are too complex
Added costs are stifling small projects
Primarily use acceptable solutions as VMs are too
expensive
Qualified fire engineers are scarce, and are not
economical to use
NZFS involvement is unnecessarily over the top and
advice is often conflicting
Surface finish treatments are inhibiting use of wood
panelling
Negative view of fire engineering processes
BCAs not accepting architects fire reports
inconsistent view
Joint and Several Liability is an issue
Uncertainty in the sector about what is good practice
Would like to see a slower rate of change
There is currently no motivation to keep up with the
changes
Would like to see national consistency in applying
the Code and in consenting
More sector education required
Cultural change is required across the board
Involving fire engineers early (when cost allows it)
would help reduce issues further along in the process
CAS/2 structured well and allows consent process to
be easier
Time pressures due to BCA inconsistencies in
approach to approving designs
20
SUMMARY OF FINDINGS
Stakeholder group/ organisation
Key issue raised
Lack of qualified industry resources

Consider opportunities for sector education to be
included in Trade based literature
Association of Building
Compliance (IQP)
Inconsistencies between BCAs

Would like to see interface testing of integrated
systems using a cause/ effect matrix
Building Officials Institute of New

Zealand (BOINZ)
Why are there seven (7) acceptable solutions when

one could do the job
Need to reconsider the role of the NZFS in the
consenting process
Inconsistent approach from BCAs
Joint and Several Liability is an issue
Priorities for sorting the issues should include:
Making sure acceptable solutions are correct
What needs to be applied or defined in the
use of these
Working on improving the relationship
between BCAs and the Fire Service
PN22 (Practice Note 22)
Property Council
Society of Fire Protection

Engineers (SFPE)
Fire Protection Association of

New Zealand (FPANZ)
Fire designs for existing buildings are not appropriate

and ANARP is adding unnecessary costs
Areas working on processing BWOFs and Consents
are under resourced and lacking experience causing
time delays and increased costs
Silos between disciplines and should aim for better
integration
Lack of qualified fire engineers
Need further sector education
Cost of using a VM has bred conservatism in the
sector
Weakness is the variable interpretation
Language of the Code has led to prescriptive
mindset, rather than focusing on performance based
outcomes and innovation
Inconsistencies with peer review process
Linkages with the Workplace Health and Safety Act
and HSNO
Confusion around some of the regulations
Evacuation schemes are constrained by the Building
Act
BCAs require further sector education to reach
consistency
No compliance schedule template or guidelines
21
SUMMARY OF FINDINGS
Phase three - Auckland presentation

Approximately 80 participants, including international experts, attended two presentations
held in Auckland on Thursday 20 November 2014. The purpose of this presentation was to
provide a high level update to the sector on the issues and themes identified during the
stakeholder sessions and questionnaire.
Discussion at the presentation focused on the priority theme, which was the clarity of the
Acceptable Solutions. A summary document of the presentation was also emailed to the Fire
Sector database in mid-December 2014.
Analysis of the stakeholder feedback and questionnaire data is ongoing and it is anticipated
more research will be required into some of the issues raised. A Summary Report outlining the
strategic direction for fire engineering over the short, medium and long-term timeframes will
be made available in mid-2015.
Next steps
As the review progresses, further stakeholder engagement will be undertaken to test ideas,
and gather feedback on potential courses of action to address key issues raised.
It will be important that stakeholder engagement activities are designed in a way that provide
varying, yet multiple opportunities for stakeholders to provide input, and gain understanding
about the review as it takes shape into a plan of action.
Setting the Future Direction for the Development of Fire

Regulation
The results from the 2014 stakeholder engagement programme are an important input
to formulating the future direction for the development of Fire regulation. Our objective
for the next phase of this work is to deliver by mid-2015 a plan of work, providing short,
intermediate and long term actions to address the issues that have been raised by
stakeholders
Engage with all stakeholders (BCAs, Government agencies, sector groups, professional
societies, fire engineers) to enable a collaborative sector-wide approach for attaining
over time an effective and efficient best practice regulatory system for fire safety in New
Zealand.
22
SUMMARY OF FINDINGS

Summary of Findings Fire Review

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BUILDING

Phase one Stakeholder Feedback Sessions

Errors within Acceptable Solutions and Verification Method documents

MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT

Phase one high level summary (top 12 issues)

MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT

MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT

Phase two - Questionnaire

MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT

MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT

Phase two: statistical analysis

High level comments

This questionnaire was enquiring

Acceptable solutions C/AS1 to C/AS 7

49% of respondents did not

29% strongly agree or agree

C/AS1 6 is easy to use

49% of respondents did not

28% strongly agree or agree

The format of C/AS 7 is easy to use

50% of respondents did not

22% strongly agree or agree

MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT

51% of respondents did not

Need better consideration of those

C/AS1-7 have significantly changed

High level comments

18% had a high impact

10.5% had a medium impact

13% had a low impact

Rate impact of an MBIE interpretations

58% of respondents did not

The language/ writing style used in the

57% of respondents did not

16% strongly agree or agree

MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT

Causing confusion and unnecessary

High level comments

Items not explicitly covered by the

57% of respondents did not

Acceptable solution fire design should

58% of respondents did not

Mixed use facilities

16% strongly agree or agree

58% of respondents did not

17% strongly agree or agree

MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT

Cost vs benefit analysis required

High level comments

Information about means of escape

82% of respondents did not

9% strongly agree or agree

A change of evacuation strategy from

83% of respondents did not

MINISTRY OF BUSINESS, INNOVATION & EMPLOYMENT

egress issues for disabled people

More guidance on gap analysis and

High level comments

Fear of 112 upgrades leads to illegal

82% of respondents did not

10.5% strongly agree or

Fear of 112 upgrades leads to

83% of respondents did not

The benefit of a full building review is