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BCA Volume One - Fire safety amendment

The NCC Volume One external wall requirements for Class 2-9 buildings have received significant attention in the last few years and there has also been a raft of changes to these requirements in past years and most notable as part of an NCC 2016 amendment.

In this article

  • Overview of the BCA fire safety of external walls provisions
  • Changes to the NCC 2016 Volume One
  • FAQs regarding the changes and fire safety provisions

 Overview of the BCA fire safety of external walls provisions

It is important to firstly understand the BCA fire safety requirements for external walls generally. 

Below is a brief description of the BCA fire safety/combustibility requirements: 

  • The NCC classifies buildings according to their use – there are 10 different classifications 
  • NCC Volume One contains the requirements for multi-residential, commercial and institutional buildings. These buildings fall into Class 2-9 buildings 
  • Houses, including row houses and townhouses, are Class 1 buildings and the requirements are in BCA Volume Two. The amendments do not affect Class 1 buildings 
  • C1.1 of Volume One and, in turn, Table C1.1, sets out the minimum type of fire-resisting construction required by the NCC Deemed-to-Satisfy (DTS) Provisions for Class 2–9 buildings 
  • The required ‘type of construction’ of a building depends on the Class of building and the building’s height as indicated by the ‘rise in storeys.’ i.e. a five-storey Class 2 (apartment) is required to be Type A construction, whereas a two-storey Class 5 (office building) need only be Type C construction 

Table C1.1 Type of construction required

Rise in storeys
Class of building
2, 3, 9 5, 6, 7, 8
4 or more A


3 A B
2 B C
1 C C
  • Type A construction is the most fire-resistant, Type C construction is the least fire-resistant, and Type B construction falls between these two
  • Under the DTS Provisions, buildings required to be of Type A and B Construction are required to be of non-combustible construction. This includes the external walls of those buildings including the cladding/façade covering
  • Type C construction is excluded from the non-combustible construction requirements
  • A building element that complies with the DTS Provisions of Section C automatically complies with the corresponding NCC Section C  Performance Requirements – i.e. if the building has non-combustibility external walls it would comply with the DTS Provisions
  • There are a number of known non-combustible products, such as bricks, concrete, glass, structural steel and some metals, where these materials are used for example for the external walls of buildings they would comply with the DTS Provisions
  • For products other than those known non-combustible products, they can be determined to be classified as non-combustible by testing of the product to AS 1530.1
  • The NCC also lists some products that are ‘deemed’ to be non-combustible, including fibre cement sheeting, plasterboard and pre-finished metal sheeting and these products can be used where a non-combustible material is required
  • Where a building design wishes to incorporate a cladding for example that may contain combustible elements this could be done via the development of a Performance Solution directly to the NCC Performance Requirement(s)
  • The most relevant Performance Requirement for the fire performance of cladding on high rise buildings in CP2(a) –
  • The building must have elements which will, to the degree necessary, avoid the spread of fire:

    • to exits, and
    • to sole-occupancy units and public corridors, and
    • between buildings, and
    • in a building.
  • One way of demonstrating compliance with this Performance Requirement as part of the NCC   is through the use of Verification Method CV3, which includes the adoption of the new façade assembly standard AS 5113
  • As part of using this CV3 it also requires additional fire safety measures be incorporated such as sprinkler protection for the building
  • The NCC also allows for other type of Performance Solutions to be used other than just use of CV3
  • The above information focuses on the NCC combustibility requirements but there are also other fire safety requirements applicable to external walls, including certain external walls being required to have specific Fire Resistance Levels, internal linings and finishes to meet fire hazard property requirements and other such requirements.

NCC combustibility requirements for external walls and cladding for buildings of Type A and B

Effective from 12 March 2018

If my product has been tested and passed AS 1530.1, do the changes affect this?
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No. This product can continue being used under a Deemed-to-Satisfy Solution.


Does this mean I now need to test all products for non-combustibility?
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No. Many products such as bricks, concrete, glass, structural steel and some metals are known to be non-combustible and have a proven history of performance and shouldn’t require any further verification. By their very nature and manufacture they demonstrate suitability.

Do non-combustible products now need to be tested to AS 5113?
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No. The AS 5113 test only applies to cladding materials and assemblies that contain combustible elements.

Products can still use the non-combustibility test and where they pass this test, they can be used as part of a Deemed-to-Satisfy Solution.

Are there requirements in addition to passing AS 5113 as part of the new Verification Method?
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Yes, CV3 also requires additional fire safety measures in addition to using a product that passes AS 5113.

This may include horizontal spandrels (Type B buildings), sprinkler protection for Type A buildings regardless of height and enhanced sprinkler protection for buildings with an effective height greater than 25m. CV3 also requires cavity barriers where the wall assembly contains cavities and other components.

Is AS 5113 (CV3) compliance the only means of meeting the BCA as part of Performance Solution?
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No. The new Verification Method is only one means of compliance with the BCA Performance Requirements. Other paths such as use of another testing standard or report from an expert such as a fire engineer are also available pathways, subject to acceptance by the building approval authority.

Does the BCA still permit the use of a combustible attachment over a non-combustible external wall (subject to certain additional conditions)?
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No, the amendment has removed this clause (previously Specification C1.1 clause 2.4(a)).

Feature panels, decorative façade coverings, etc. that use materials with combustible elements would need to be undertaken as part of Performance Solution. This may be through the use of the new Verification Method or another type of Performance Solution.

How about sun blinds, awnings, signs, etc? Are these all now required to be of non-combustible materials?
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No. The BCA continues to allow these elements to be combustible but it places some restrictions on size and location.

A new clause C1.14 has been included and lists common ancillary elements that are fixed to, installed or within an external wall, but are not required to be non-combustible, power points, light fittings, flashings, etc.

What’s changed with the A5.2 evidence of suitability provisions?
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While much of the attention on the amendment has been on the changes to the external wall fire safety provisions equally important is the revision of the NCC’s evidence of suitability provisions. 

The revision, which HIA was heavily involved in, is a key part of the broader issues with building product conformity and the compliant use of building products. 

The revision includes: 

  • clarifying the application and language of A5.2 
  • strengthened wording of the current options 
  • linking the evidence to indicating how it has been demonstrated that it complies with relevant BCA 
  • provisions and scope of use and any limitations/conditions that apply 
  • inclusion of a new requirement to consider the ‘appropriateness’ of the evidence being presented to 
  • support the use of the material, product, design or form of construction 
  • introducing and encouraging use of Product Technical Statements (PTS). 

For NCC 2019 the corresponding changes were  included in NCC Volume Two. 

Will my product need to be retested/certified?
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No. Approval authorities may, however, request information on the appropriateness of the form evidence, particularly for higher risk products, or in some instances question the adequacy of the supporting evidence of the material, product, form of construction or design.

Will this mean manufacturers and suppliers will need to update current building product information/test reports/certificates?
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Yes and no. Many manufacturers and suppliers already produce comprehensive building product evidentiary material on the compliance of their products to the NCC.

However, in some instances, the building certifier/surveyor or a subsequent authority may request further evidence of the products’ suitability for a particular application. The ability to request this already exists under the current provisions but with the inclusion of the new requirement to consider the ‘appropriateness’ of the evidence being presented to support the use of the material, product, design or form of construction this type of request may occur more often.

It is recommended that manufacturers and suppliers of building products review the changes to the evidence of suitability provisions and assess their current product technical information against the revised provisions.

Product Technical Statements – What are these?
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The introduction of PTSs is an example of another form of documentary evidence under A5.2 in the and is intended to promote the provision of consistent and comprehensive technical information in a format that is easy to read and understand. A PTS differs from advertising brochures and other marketing material, including product warranties, as it focuses on technical detail.

A PTS summarises key details about a building component. It is a statement from the manufacturer or supplier who declares compliance with the NCC. HIA encourages people supplying and manufacturing products to produce PTSs for their products to assist those using their products.

What is the Evidence of Suitability/Product Assurance Handbook?
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An ABCB Evidence of Suitability Handbook has been developed as a companion document to the NCC evidence of suitability provisions . 

This Handbook has been developed to provide practitioners, product manufacturers and suppliers with further detail in understanding how to interpret and apply the NCC provisions to ensure that materials, products, forms of construction and designs being used are fit for their intended purpose in accordance with the requirements of the NCC. 

Of most importance is that the Handbook includes an evidence of suitability framework and a decision flow chart to assist in the correct use of the evidence of suitability provisions of the NCC. This framework provides guidance on selecting appropriate forms of evidence using a risk-based approach. 

The framework looks at the likelihood of a building component failing and what the consequences might be if it did fail. The combination of these two factors will give an indication of the level of risk. In turn, this will indicate what level of rigour is likely to be required to demonstrate compliance with the NCC. The higher level of rigour generally means that the assessment of the product be undertaken by an independent third party. 

The ABCB handbook has more information and is available online.

To find out more, contact HIA’s Building Services team.

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