Industry Alert

Issued February 2016I

PURPOSE
External walls, and BCA Following the release of the Metropolitan Fire
compliance Brigade’s post incident analysis report into the
Lacrosse apartment fire and the completed
Some terms are used in this Industry Alert which Victorian Building Authority’s (VBA) audit of Class
are common building terms but are not defined 2, 3 and 9 buildings the VBA has become aware of
in the Building Code of Australia. For clarity, the considerable variation in industry understanding
meanings of terms used for the purpose of this regarding the use of aluminium composite panels
Industry Alert are: (ACP) and other combustible materials in the
‘Attachment’ means: construction of external walls. The audit identified
A supplementary element attached to an that combustible materials including ACP have
external wall or other complete building been used in a manner that does not comply with
element. Volume One of the Building Code of Australia.

‘BCA’ means: The purpose of this Industry Alert is to clarify

Volume One of the National Construction Code. circumstances where ACPs and other combustible
materials may be used in the construction of the
‘Cladding’ means: external walls of a building in Type A and Type B
A non-loadbearing covering of a stud frame wall construction. It is clear from the audit that—
system which contributes to the functionality of
the external wall, usually weatherproofing. • Building designers, builders and building
(Note: This aligns with the definition of “direct fix surveyors are failing to identify whether
cladding wall” in Volume One of the NCC (BCA) the material is being used as an integral
and common dictionary meanings. part of an external wall, or used as an
‘External wall’ means: attachment to a complete wall system.
The entire wall system which separates the This failure can lead to the non-compliant
interior air space of the building with the outside use of a combustible material as a
air space including any componentry or elements component of a wall that is required to be
necessary for the external wall to achieve the
non-combustible;
requirements for structural performance,
weather tightness, thermal performance, non- • Appropriate evidence of suitability in
combustibility and required FRL if required by accordance with Clause A2.2 was
the type of construction, and any other commonly not being provided to, or
functionality required under the BCA . sought by, relevant building surveyors;
Except for ‘external wall’, terms in italics have • Building designers specifying and relevant
the same meaning as in the BCA. building surveyors approving ‘generic’
brand products such as “brand name or
similar” where a particular model of that

Issued February 2016

www.vba.vic.gov.au Page 1 of 6
Industry Alert
branded product may comply and another • a current Certificate issued by a product
model would not. certification body accredited by the Joint
• Assessments of the use of materials as an Accreditation System of Australia and New
Zealand (JAS-ANZ);
attachment have frequently not included
• Any other form of documentary evidence
an assessment of the conditional
that correctly describes the properties and
requirements of Clause 2.4 of Specification performance of the material or form of
C1.1. Those conditions are that — construction and adequately
o it is not located near or directly demonstrates its suitability for use in the
building.
above a required exit so as to make
the exit unusable in a fire; and A number of ACP’s, and other combustible
o it does not otherwise constitute an construction products or materials have been
undue risk of fire spread via the issued with Certificates of Conformity (Certificate)
facade of the building. under the CodeMark scheme. Certificates must
o the attachment of a facing or finish, be read very carefully to identify the specific
or the installation of ducting or any requirements of the BCA the building product or
other service, to a part of a building material is certified to comply with.
required to have an FRL must not If there is any doubt about a Certificate or other
impair the required FRL of that part form of evidence of suitability, the body who
issued the Certificate should be contacted for
While this Industry Alert focusses on ACP’s the clarification. If a Certificate does not provide
principles expressed apply to any other material certainty to a designer or relevant building
that has not been determined as non-combustible surveyor regarding the compliance of a product
in accordance with AS1530.1 and used as a for the particular proposed use, it is not
component of an external wall or attachment to appropriate to rely on the Certificate.
the external wall of a building.
Certificates also commonly contain limitations or
EVIDENCE OF SUITABILITY conditions for the installation and use of the
Evidence to support the use of a material, form of building material. For instance, a common
construction or design meets a Performance condition is a requirement that the building
Requirement or Deemed-to-Satisfy Provisions (D-t- material or product must be installed in a
S) as provided for by Clause A2.2 of the BCA may particular manner or in accordance with a
be in the form of: technical manual supplied by the manufacturer. If
• a report issued by a Registered Testing a Certificate is accepted then all conditions or
Authority (Registered with NATA or an limitations listed on the Certificate should be
authority recognised by NATA); transferred to design documentation including
• a current Certificate of Conformity issued architectural drawings, specifications, and fire
under the Australian Building Codes Board engineering reports (FER).
(ABCB) CodeMark scheme; COMPLIANCE PATHWAYS
• a Certificate of Accreditation issued by the
Building Regulations Advisory Committee; The BCA contains several pathways to compliance,
• a Certificate issued under section 238 of either D-t-S or an Alternative Solution or a
the Act by a professional engineer combination of the two.
registered in the appropriate discipline; In either case the building design must satisfy the
relevant Performance Requirements. In relation

Issued February 2016

www.vba.vic.gov.au Page 2 of 6
Industry Alert
to fire safety of external walls, the principal thermal performance, non-combustibility and
Performance Requirement is CP2. However a required FRL if required by the type of
number of other Performance Requirements may construction, and any other functionality required
need to be considered depending on the material under the BCA . A simple test to determine
used, its location on the external wall, the extent whether a material or product is a component of
of coverage on the wall, whether there are an external wall or an attachment is to determine
openings in the wall, its location in relation to exits whether the wall remains fully compliant with all
and potential impact on fire brigade intervention. requirements of the BCA if the material or product
Given the occurrences at the Lacrosse apartment is removed. If the external wall remains fully
compliant, then the material or product is likely to
fire, where the fire threatened to enter the
be an attachment. If the external wall is no longer
building on numerous floor levels, the failure of
the early warning system and the challenge to the fully compliant then the material or product is a
fire services, Performance Requirements CP1, CP3, component of the external wall.
CP4, CP7, CP8 and CP9 may apply and Clause C1.1
Performance Requirements from other Sections of Clause C1.1 specifies the type of construction
the BCA may also need to be considered. required for classes of buildings in relation to the
rise in storeys. Type A construction is required for
DEEMED-TO-SATISFY (D-T-S) Class 2, 3 and 9 buildings with a rise in storeys of 3
or more and Class 5, 6, 7 and 8 buildings with a
A number of requirements apply to an external rise in storeys of 4 or more. Type B construction is
wall in Type A or B construction including: required for Class 2, 3 and 9 buildings with a rise in
• Fire- resistance level (FRL) (Specification storeys of 2 and Class 5, 6, 7 and 8 buildings with a
rise in storeys of 3. Clause C1.5 provides a
C1.1 Tables 3 and 4)
conditional ‘concession’ to allow Type C
• Non-combustible elements (Specification construction in a Class 2 or 3 building with a rise in
C1.1 Clause 3.1(b) and 4.1(b) storeys of 2 and a Class 9c building.
• Fire hazard properties of linings, materials
Clauses 3.1(b) and 4.1(b) of Specification C1.1
or assemblies (Specification C1.10)
In accordance with Clauses 3.1(b) and 4.1(b) of
IS IT A WALL OR ATTACHMENT? Specification C1.1, external walls are required to
WALLS be non-combustible for Type A and B construction.
In type A or B construction this means that all
The BCA contains a definition of external wall componentry of the wall system must be non-
which is defined as “an outer wall of a building combustible. This view is supported by the
which is not a common wall”. The BCA does not definition of non-combustible which states that
define ‘wall’. A review of dictionary definitions of “when applied to construction or part of a
wall and external wall, and of various provisions building, constructed wholly of materials that are
and definitions of the BCA leads the VBA to not deemed combustible.”
conclude that a reference to an external wall in
the context of the BCA is a reference to the entire This means that for panel wall construction in
wall system which separates the interior air space Type A or B construction, (commonly used as non-
of the building with the outside air space including loadbearing infill walls between columns and
any componentry or elements necessary for the beams), the internal lining, the lightweight frame,
external wall to achieve the requirements for insulating material and the outer cladding must all
structural performance, weather tightness, be non-combustible and not deemed to be

Issued February 2016

www.vba.vic.gov.au Page 3 of 6
Industry Alert
combustible in accordance with AS1530.1 or, Building and Plumbing Amendment (Balcony
under Clause C1.12 may be used where a non- Sprinkler Protection) Interim Regulations 2015.
combustible material is required 1. The use of “any other material that does not
It is noted that Clause C1.12 provides for bonded significantly increase the hazards of fire” must
laminated materials where – now be justified through an appropriately
formulated Alternative Solution.
(i) each laminate is non-combustible;
and
(ii) each adhesive layer does not exceed Clause 2.4 of Specification C1.1
1 mm in thickness; and Clause 2.4 of Specification C1.1 allows combustible
(iii) the total thickness of the adhesive materials that meet certain fire hazard properties
layers does not exceed 2 mm; and to be conditionally used as an attachment to the
(iv) the Spread-of-Flame Index and the outer element of a building with a required FRL.
Smoke-Developed Index of the Attachments include “a finish or lining to a wall or
laminated material as a whole does roof or other attachments, such as signs,
not exceed 0 and 3 respectively. sunscreens, blinds or awnings.” A ‘lining’ should
not be mistaken for a cladding.
In accordance with C1.12, all laminates of a
Combustible attachments such as a lining to an
bonded laminated material including ACP must be
external wall are subject to conditions. An
non-combustible within the meaning of the BCA.
attachment such as a lining can only be used on an
Therefore, under the D-t-S provisions of the BCA,
external wall, including a lightweight panel wall
ACPs with a polyethylene based core (including
that is already compliant with all relevant parts of
with mineral fibre content) cannot be used as the
the BCA. A non-loadbearing wall that is greater
cladding component of a lightweight external wall
than 3m from a fire-source feature needs to
system in Type A or B construction unless
achieve a FRL of -/-/-. The definition of FRL in the
supported by an appropriately formulated
BCA states ” -/-/- means there is no requirement
Alternative Solution.
for an FRL.” The BCA does not provide any
ATTACHMENTS TO WALLS concessions that allow combustible attachments
Clause C1.10 to be installed on an external wall not having a
required FRL.
Clause C1.10 is principally applied to assess the
fire hazard properties for internal linings, Where a combustible lining or other attachment is
materials and assemblies, however Clause fixed to an external wall, unless exempt under
C1.10(c) provides a list of exempt materials Clause C1.10, it must meet the fire hazard
allowed for use as an attachment to an external properties of Specification C1.10 and specifically
element of a building under Specification C1.1 attain a Group number of 1, 2 or 3 in accordance
Clause 2.4. with Clause 4 and Table 3, ‘Other areas’.

In Victoria, Clause C1.10(c)(xiv) “any other As a condition of compliance, Sub-Clauses

material that does not significantly increase the 2.4(a)(ii) and (iii) of Specification C1.1 also requires
hazards of fire” has recently been removed as an assessment of a design to ensure that the lining
an exempt option by regulation 4 of the “is not located near or directly above a required
exit so as to make the exit unusable in a fire” and
“it does not otherwise constitute an undue risk of
1
A concession to Clauses 3.1(b) and 4.1(b) of Specification C1.1 is fire spread via the facade of the building.” Sub-
provided by Clause 3.10 or Clause 4.3 of Specification C1.1 or Clause Clause 2.4(b) also requires that an attachment
C1.5.

Issued February 2016

www.vba.vic.gov.au Page 4 of 6
Industry Alert
“must not impair the required FRL” of the building Cases of fires involving external facades have
element it is attached to. provided some very useful observations about fire
Many of the buildings audited had behavior involving combustible facades. Some of
canopies/verandahs over the main entrance. Most the key observations are that a façade fire has the
of these canopies were designed as attachments potential to enter a building at multiple levels and
and were commonly completely lined with ACP. threaten life safety unless mitigating techniques
There was no evidence in the entire audit to are utilised.
demonstrate that consideration had been given to
Other contributing risk factors identified are the
Sub-Clauses 2.4(a)(ii) and (iii) or Sub-Clause 2.4(b).
configuration and alignment of the material on
These conditions are not supported by established the facade. Vertical alignment, re-entrant corners,
standards and are likely to be difficult to evaluate channels in the facade, openings in the facade and
without suitable analysis. If it is not understood areas of potential ignition source such as
how a particular ACP or other combustible balconies and service areas, including rubbish skip
material could constitute an “undue risk of fire collection points, should all be considered in any
spread via the façade”, it would be appropriate to risk analysis2.
obtain the opinion of a person with the necessary
It is not appropriate to make simple assumptions
expertise such as a registered fire safety engineer.
about the fire properties of any combustible
The same would apply in determining how ‘near’ a
material. Many ACP and other combustible
particular ACP could be to a required exit to materials have been subjected to extensive fire
ensure the exit is usable in a fire. testing other than to AS1530.1, including other
SUMMARY OF D-T-S: prescribed BCA referenced fire testing standards
and other international fire tests. As no
• A combustible material must not be used as a
cladding (within the meaning of this document) polyethylene based ACP core is non-combustible
within the meaning of the BCA, where it is
or any other component of an external wall in
Type A or B construction. proposed to use an ACP as a component of an
external wall required to be non-combustible, it
• In accordance with Specification C1.1 Clause
2.4, a combustible material may be used as an must be treated as an alternative solution.
attachment to an external building element Relevant test results for the specific product must
with a required FRL if— be presented for analysis by a registered fire
o The combustible attachment achieves a safety engineer to determine its likely behavior in
Group number of 1, 2 or 3. a fire for the proposed use and therefore enable
o The combustible attachment is not proper analysis of the design for compliance with
located near or directly above a required relevant Performance Requirement/s of the BCA.
exit so as to make the exit unusable in a Considering the challenges and complexities a
fire. facade fire can present to occupants and fire
o The combustible attachment does not services, it is also considered that a qualitative
constitute an undue risk of fire spread via analysis is not appropriate. In accordance with
the façade of the building. the International Fire Engineering Guidelines, a
o The combustible attachment of a facing quantitative analysis should be undertaken for an
or finish must not impair the required FRL Alternative Solution which is of a more complex
of the part of the building to which it is
attached.
2
More detailed information can be found in the research paper ‘Final
ALTERNATIVE SOLUTIONS Report–Fire Hazards of Exterior Wall Assemblies Containing
Combustible Components’ published by the Fire Protection Research
Foundation.

Issued February 2016

www.vba.vic.gov.au Page 5 of 6
Industry Alert
nature such as the use of a combustible material Victorian Building Authority 733 Bourke Street
as a component of, or attachment to, an external Docklands VIC 3008
wall.
It is also important that if a specific product,
model and method of fixing has been assessed in
a FER, the design team must ensure that the
particular product and method of fixing is
The VBA acknowledges the contribution made by
consistent in all documentation and specifications.
other State and Territory jurisdictions, the FPAA
It has been noted that some specifications
and CSIRO in the development of this Victorian
nominate a specific brand but not the exact model
Industry Alert
and often include the words “or similar”. A brand
only nomination is not adequate when a fire
safety engineer has incorporated a specific
material’s properties into a design. A number of
ACP suppliers/distributors have several ‘models’
marketed under the same brand name. These are
commonly identified due to the proportion of
mineral fibre embedded within a polyethylene
core, PE (or solely polyethylene) A2 and FR being
common nomenclatures.
The manufacturers/suppliers of ACP products and
other combustible products may have specific
fixing methods that may vary according to the
type of construction required, i.e. Type A, B or C.
If a specific fixing type has been assessed under a
FER, or is required by the manufacturer/supplier,
this fixing type must also be transferred to any
approved construction drawings and
specifications. The specification should also
ensure that the builder must seek approval from
the fire safety engineer and relevant building
surveyor if the builder proposes to use an ACP
product and/or model differing from that
specified in the FER and other approved
documentation.

If you have a technical enquiry please email:

[email protected] or
phone 1300 815 127

Issued February 2016

www.vba.vic.gov.au Page 6 of 6