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AUSTRALIAN BUILDING CODES BOARD

DIRECTIONS REPORT ON EGRESS FOR ALL


OCCUPANTS
2013

TABLE OF CONTENTS

INTRODUCTION ............................................................................................................... 3
EXECUTIVE SUMMARY ..................................................................................................... 4
BACKGROUND TO THE NCC .............................................................................................. 6
Building Regulations ............................................................................................... 6
The Australian Building Codes Board .................................................................. 6
The National Construction Code ........................................................................... 7
BACKGROUND TO ACCESS AND EGRESS FOR PEOPLE WITH DISABILITY........................... 11
The Disability Discrimination Act 1992 ............................................................... 11
Disability Egress .................................................................................................... 14
EGRESS AMENDMENTS & PROPOSALS ........................................................................... 19
D-t-S Amendments to BCA 2013 .......................................................................... 19
Proposed D-t-S Amendments for NCC 2015 ...................................................... 20
Proposals for Active Systems.............................................................................. 21
Proposals for Passive Systems ........................................................................... 26
Table 1. Summary of the intent of Proposed Changes to Achieve the
Objectives of Proposals 3 & 4. ............................................................................. 32
FUTURE PROPOSALS ...................................................................................................... 40
Considerations on a Future Model for Refuges ................................................ 42
OPPORTUNITIES FOR INVOLVEMENT ............................................................................. 45
Timeframes for Amendments ............................................................................... 45
APPENDIX A BCA 2013 CLASSIFICATIONS ....................................................... 46
APPENDIX B BUILDING EVACUATION ............................................................... 48
Strategies ................................................................................................................ 48
APPENDIX C D3 BUILDING ACCESS REQUIREMENTS.................................... 50

EXECUTIVE SUMMARY

INTRODUCTION

The purpose of this report is to seek feedback on potential changes to the


National Construction Code (NCC) to improve emergency egress from buildings
for all occupants including people with disability.
The proposals in this report seek to provide safe, equitable and dignified egress
from a building for all occupants in an emergency. The report discusses issues
related to egress for people with disability, proposals to improve early notification
and accessibility of an egress path in an emergency.
This report may be of interest to people with disability, approval authorities,
designers, building owners and builders. The buildings concerned are covered in
Volume One of the Building Code of Australia (BCA) and include Class 3,
Classes 5 to 9 and certain common areas of Class 2 buildings (see Appendix A
for a description of these classes). In addition to disability, unfamiliarity with a
building, health conditions, temporary injuries or pregnancy can affect an
occupants ability to successfully evacuate. Therefore, all building users may
benefit from these proposals to varying degrees. This report seeks to inform
further assessment of proposed changes to the NCC by engaging with
stakeholders and:

outlining proposals for consideration;

providing background on recent changes to access and egress requirements;


discussing the strategy adopted for lifts used in evacuation;
examining the need for impact analysis by seeking feedback on the
proposals;
outlining timeframes for incremental changes; and
highlighting opportunities for stakeholder involvement

EXECUTIVE SUMMARY

EXECUTIVE SUMMARY

The Australian Government's Disability Discrimination Act 1992 (DDA) has been
in effect since March 1993. The DDA prohibits discrimination against people with
disability or their associates in a range of areas including transport, education,
employment, accommodation and premises used by the public.
The DDA is complaints-based (as opposed to compliance-based) legislation. It
does not include legislative or regulatory guidance as to the specific steps that
must be taken to ensure compliance with the general duties in relation to access
to premises.
Concern with the lack of certainty regarding practical compliance obligations
under the DDA led to amendments to Section 31 of the DDA, which came into
effect in April 2000, to allow the Australian Governments Attorney-General to
formulate Disability Standards in relation to access to premises.
With this change in 2000 came the need to review the BCA access provisions.
The need for change also stemmed from:

recognition that the technical requirements of the BCA were not considered to
meet the intent and objectives of the DDA; and
the potential for inconsistencies between two legislative requirements
regulating access for people with disability to buildings, being the DDA and
through State and Territory building law, the BCA.

The Australian Building Codes Board (ABCB) was requested by the Australian
Government to develop proposals for a revised BCA, to enable it to form the
basis of draft Premises Standards. Once the Premises Standards had been
formulated, the BCA would be amended so that the technical details of each
document mirror each other. Therefore, compliance with State and Territory
building law and the access provisions of the BCA would mean compliance with
the Premises Standards and the DDA.
Prior to the development of the Premises Standards, the ABCB undertook work
towards a national approach to access to buildings for people with disability
through a discussion paper and technical proposal RD097/01. These proposals
included some egress provisions in the form of enhanced emergency notification
and accessible evacuation refuge areas as a means of providing protection from
the effects of fire. Comments received in response to these initial egress
proposals were polarised with some suggesting refuges were less preferable and
equitable than alternatives such as suitably designed lifts. While lifts were seen
as a desirable solution for emergency egress needs, it was acknowledged that
solutions were either not currently available or were under-developed.
4

EXECUTIVE SUMMARY

In 2000, the ABCB established the Building Access Policy Committee (BAPC) to
recommend changes to the BCA, to consult widely with industry and the
community and to provide advice to the ABCB on access-related issues.
Through the BAPC and its Technical Working Group, draft Premises Standards
were developed, and recognising the need for technical solutions for egress, the
BAPC recommended that the ABCB continue research in the area of egress for
all occupants.
Research commissioned by the ABCB in 2005 on optimal strategies for the
evacuation of people with disability highlighted the difficulties faced by people
with mobility impairment when using stairs. This research also highlighted that
any Deemed-to-Satisfy (D-t-S) Provisions were likely to be very complex
considering the numerous building, system and configuration scenarios.
The Access to Premises Standards were launched in 2010 and central to
matters not covered by the Standards was emergency egress for people with
disability. In recognition of the needs of people with disability and the complexity
of potential solutions, the ABCB were tasked with the identification of D-t-S
provisions as soon as possible.
The ABCB adopted a strategy to include amendments to D-t-S Provisions
incrementally, and the development of a non-regulatory handbook for lifts used in
evacuation. This was in recognition of the limitations of the BCA in applying
management practices, the finalisation of the Premises Standards and little
international progress towards solutions involving lifts in emergencies. In
accordance with this incremental strategy, changes proposed in this Directions
Report build upon improvements to the accessibility of egress paths which were
included in National Construction Code (NCC) 2013 Volume One. The future
regulatory proposals outlined in this report are intended to be included in NCC
2015 and include:

supplementing existing audial emergency warning systems with visual


warning in accessible areas;
intuitive and perceptible building design to assist people with vision
impairment in locating an exit; and
improving the accessibility of exits for people with mobility impairments.

Issues associated with requiring places of refuge to achieve the objectives of


the DDA are also explored in this report. These proposals are an area of
particular focus for feedback, as previous consultation revealed differing opinions
on their safety, equity and dignity. The practical limitations of the NCC in
requiring the use of refuges as part of an evacuation strategy, and feedback on
these issues will inform any future proposals.

BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

BACKGROUND TO THE NCC


Building Regulations

Each State and Territory has building control legislation including Building Acts and
Regulations that reference the NCC.
While State and Territory governments may include minor variations to the NCC in
their legislation and different criteria or triggers for how they apply it to existing
buildings, essentially the NCC applies to:

all new building and plumbing work;


new building and plumbing work in existing buildings, such as additions and
alterations; and
existing buildings that are to be used for a purpose different from that which they
were originally approved, also known as a change of use.

The Australian Building Codes Board


The ABCB develops and maintains the NCC on behalf of the and State and Territory
Governments, who each have statutory responsibility for building and plumbing
control and regulation within their jurisdiction and the Australian Govenments. By
virtue of an intergovernmental agreement, the ABCB is responsible for developing
minimum necessary standards for the design and construction of buildings on behalf
of the governments.
The ABCB follows the Council of Australian Governments (COAG) best practice
regulation guidelines when considering proposals to change the NCC. The
principles detailed in these guidelines require that:

there is a rigorously tested rationale for the regulation;

the proposals would generate benefits to society greater than the costs (that is,
net benefits);

there is no alternative (whether regulatory or non-regulatory) that would generate


higher net benefits; and

the competitive effects of the regulation have been considered and the regulation
is no more restrictive than necessary in the public interest.

BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

The National Construction Code


The NCC is an initiative of COAG, developed to incorporate all on-site construction
requirements into a single code.
The NCC is amended annually to reflect government policy initiatives and societal
issues, changes to building practices and technology, to address market failures,
and in response to feedback from users.
The NCC is comprised of the BCA Volume One and Volume Two; and the Plumbing
Code of Australia (PCA) as Volume Three.
BCA Volume One: contains requirements for the design and construction of public,
industrial, commercial and multi-residential buildings, i.e. Class 2-9 buildings, plus
some Class 10 matters.
BCA Volume Two: contains requirements for the design and construction of
housing, i.e. Class 1 and 10 buildings (garages, carports etc.).
PCA Volume Three: pertains primarily to plumbing and drainage associated with all
classes of buildings.
BCA Objectives & Functional Statements
The goals of the BCA are to enable the achievement of nationally consistent,
minimum standards of relevant, health, safety (including structural safety and safety
from fire), amenity and sustainability objectives efficiently. The BCA covers matters
such as structure, fire resistance, access and egress, services and equipment, and
energy efficiency as well as certain aspects of health and amenity. The BCA is a
construction code and therefore, does not seek to control the administration of
buildings. Issues relating to building management, evacuation plans, procedures or
evacuation strategies, while complementary, are building specific and not regulated
through the BCA (see Appendix B).
A core goal of the BCA is the efficient achievement of minimum necessary
standards for the safety of building occupants from fire. Objectives of the relevant
BCA Sections provide guidance to reflect the level of safety the community expects
buildings to provide. Functional Statements state how the building solutions should
meet this expectation. These statements are advisory in nature, whereas
Performance Requirements are the only mandatory provisions that building
solutions must achieve.
BCA Performance Requirements
Performance Requirements are based on the risks to occupancy and these vary
depending on the use of the building. Buildings are designated by classification
(class) which is determined by the purpose that it is designed, constructed or

BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

adapted to be used. As the purpose of buildings varies, the BCA applies different
requirements for different classes of buildings.
BCA Deemed-to-Satisfy Provisions
The Deemed-to-Satisfy (D-t-S) Provisions provide solutions that are common
prescriptive methods of meeting the Performance Requirements. As Performance
Requirements are applied generally and in some cases limited in their application
(e.g. to particular classifications) so are the D-t-S Provisions, which may be general,
specific or exclusive as triggered by the characteristics of the building and the
number and characteristics of the occupants. Therefore these factors influence the
scope of the D-t-S fire safety systems that are to be installed. A fire safety system
means one or any combination of the methods used in a building to
warn people of an emergency; or
provide for safe evacuation; or
restrict the spread of fire; or
extinguish a fire,
and includes both active and passive systems. 1
The Guide to BCA Volume One lists some examples of active and passive fire
safety systems as follows:
Passive systems

fire-isolated stairways, ramps and passageways;


fire walls; and
other fire-resisting building elements.

Active systems

sound systems and intercom systems for emergency purposes;


emergency lighting;
exit signs;
sprinkler systems;
fire hydrant systems;
fire hose reel systems;
smoke and heat vents;
mechanical smoke-exhaust systems; and
portable fire extinguishers.

BCA Classifications
The BCA classification system broadly categorises buildings into 20 building classes
and sub-classes (see Appendix A) and uses this as a means of minimising occupant
1

Australian Building Codes Board, Building Code of Australia Volume One (2013), A1.1 pg. 27

BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

risk associated with a buildings use. It has been described as the gateway to the
BCA and classes are often used as a means to differentiate which Performance
Requirements and D-t-S Provisions apply to the design and construction of a
building.
BCA Structure
BCA Volume One is divided into Sections and Parts that contain both the mandatory
Performance Requirements, Verification Methods for assessing Alternative
Solutions, D-t-S Provisions and in some cases Specifications. While these are
interrelated, each Part has a particular focus and is prefaced by Objectives,
Functional Statements and mandatory Performance Requirements.

Figure 1 BCA Hierarchy

The Sections of the BCA that contain the majority of requirements relating to fire
safety systems and occupant egress are:

Section C Fire Resistance

Section D Access and Egress

Section E Services and Equipment.

Below is a brief description of the role these Sections play in providing safety from
fire.
Section C Fire Resistance
The requirements of Section C relate primarily to the passive fire resistance of a
building structure and prescribe maximum fire compartment sizes and the protection
of openings. These elements are crucial in providing the necessary level of
separation to prevent the spread of fire, contain its effects and in turn reduce
occupants exposure, while maximising the time and opportunity for evacuation in an
emergency.
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BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

Section D Access and Egress


The requirements of Section D relate to means of egress from a building in an
emergency including limiting the distance of travel to a place of safety, the number
and dimensions of exits and their construction. This Section also contains the
provisions relating to access for people with a disability.
Section E Services and Equipment
The requirements of Section E are for active fire safety systems including fire
sprinklers, fire fighting equipment, smoke hazard management systems, smoke
detection and alarms, the installation of emergency lifts and emergency lighting as
well as exit signs for wayfinding in an emergency.

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BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

BACKGROUND TO ACCESS AND EGRESS


FOR PEOPLE WITH DISABILITY
The Disability Discrimination Act 1992

International Declarations such as the 1975 Declaration on the Rights of People with
a Disability, to which Australia was a signatory, was symbolic of a growing
international awareness of rights of people with a disability. This also served to
underpin need for federal legislation to replace a patchwork of State and Territory
Discrimination Acts and also improve coverage to include federal government
employees. 2
The DDA which was introduced in 1992, has been in effect since 1993 and is
complaints based legislation, whereby individual complaints are the main means of
effecting a change. The DDA could be seen as reactive in nature, but also aims to
influence community attitudes and behaviour through its objectives and the setting
of a series of standards, including:

to eliminate as far as possible, discrimination against persons on the basis of


their disability in a range of areas including public transport, employment
education, accommodation and premises used by the public;

to ensure that as far as practicable, persons with a disability have the same
rights before the law as the rest of the community; and

to promote recognition and acceptance within the community of the principle that
persons with disabilities have the same fundamental rights as the rest of the
community.

Concern with the lack of certainty regarding practical compliance obligations under
the DDA led to amendments to Section 31 of the DDA, which came into effect in
April 2000, to allow the Australian Governments Attorney-General to formulate
Disability Standards in relation to access to premises.
With this change in 2000 came the need to review the BCA access provisions. The
need for change also stemmed from:

recognition that the technical requirements of the BCA were not considered to
meet the intent and objectives of the DDA; and

the potential for inconsistencies between two legislative requirements regulating


access for people with disability to buildings, being the DDA and through State
and Territory building law, the BCA.

Productivity Commission 2004, Review of the Disability Discrimination Act (1992), p. 41

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BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

The ABCB was requested by the Australian Government to develop proposals for a
revised BCA, to enable it to form the basis of draft Premises Standards. In 2000, the
ABCB established the BAPC to recommend changes to the BCA, to consult widely
with industry and the community and to provide advice to the ABCB on accessrelated issues.
The BAPC consisted of representatives of key stakeholders including the AttorneyGenerals Department, the Human Rights and Equal Opportunity Commission,
disability groups and industry.
Disability (Access to Premises - Building) Standards
Through the BAPC and its Technical Working Group, draft Premises Standards
were developed with wide stakeholder input. A negotiated set of proposals were
produced for public comment in 2004. The documents underwent a period of
extensive public consultation and were finally considered by the House of
Representatives Standing Committee on Legal and Constitutional Affairs (HRSC).
The HRSC sought submissions to allow it to consider, and report on, the
appropriateness and effectiveness of the draft Premises Standards in:

achieving its objects;


its interaction with other legislative schemes; and
whether the standards would have any unjustifiable impact on any particular
segment of the industry.

A series of public hearings were conducted by the HRSC where evidence was heard
from people with disability, advocates, representatives of government agencies,
business and industry and this resulted in a report titled Access All Areas (2009).
The report contained 19 recommendations relating to the scope of the Premises
Standards, possible concessions and exemptions and where these should apply,
clarification of specific provisions, matters still to be addressed and their
implementation and review.
Significantly, the report recommended:
that the Premises Standards be introduced without delay. Any issues
which cannot be finalised without causing delay should be considered at a
later date. 3
This recommendation acknowledged that there were matters that would not be
finalised in time for inclusion in the Premises Standards. These matters are
discussed in more detail in Chapter 6 of the Access all Areas report.

Commonwealth of Australia, Access All Areas (2009) 1.20 p. 6

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BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

Central to those matters not covered by the draft Premises Standards was egress
for people with disability. The HRSC heard submissions from people with disability
on the inadequacy of existing emergency egress requirements which impinged on
their dignity and their ability to work safely. 4
The HRSC concluded that the BCA requirements for emergency egress fall short
of ensuring the safety and dignity of people with a disability. These deficiencies must
be rectified as soon as possible. 5
Specific matters that were considered by the HRSC included fire stairs, lifts, visual
and other alerts and places of rescue assistance. These are discussed in Section 6
of the Access all Areas report, which recommends:
Recommendation 16
The Committee recommends that the Australian Building Codes Board
undertake further research to identify deemed-to-satisfy Provisions for
emergency egress for people with a disability with a view to making changes
to the Building Code as soon as possible.
The Australian Government, in response to the report, accepted many of the
recommendations either in full or in principle, and undertook to deal with other
HRSC recommendations as far as possible without causing delay in order to bring
the Premises Standards to fruition. The Premises Standards were launched on 15
March 2010.

4
5

Commonwealth of Australia, Access All Areas (2009) 6.1 p.123


Commonwealth of Australia, Access All Areas (2009) 6.1 p.130

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BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

Disability Egress
Prior to the development of the Premises Standards, the ABCB undertook work
towards a national approach to access to buildings for people with disability. An
ABCB Discussion Paper and Regulation Document RD97/01 titled Provisions for
People With Disabilities were released in 1998 to consult on proposals for changes
to the BCA.
RD097/01 proposed provisions to enhance both access and egress for people with
disability, but significantly proposals for egress were limited to emergency
notification and accessible evacuation refuge areas. It recognised that occupants
who were unable to use exit stairways required assistance to evacuate and
proposed provisions requiring places of refuge utilising lift lobbies or toilet blocks.
These were designed specifically to provide separation from the effects of fire and
smoke and intended to be used temporarily while occupants awaited assistance to
evacuate.
Feedback received on the Discussion Paper and RD97/01 revealed polarised views
on the refuge proposals. Some viewed the move to provide these areas as a
positive step, and others suggested that this approach was less equitable than
alternatives such as suitably designed lifts. A number of assumptions were also
challenged through the subsequent Regulation Impact Statement, which concluded
that the provision of emergency evacuation would not significantly contribute to
participation in socioeconomic activities such as employment, recreation, tourism
and education.
Despite attempts to address egress through the Premises Standards, the BAPC
acknowledged that solutions were either not currently available or were underdeveloped. It requested the ABCB to review international research and if necessary,
undertake additional research in the area of egress for all occupants.
Research
In order to progress this objective, a three stage research program was proposed:
Stage One: To develop context and alternatives;
Stage Two: To consider and refine preferred options; and
Stage Three: To develop D-t-S Provisions.
Research was undertaken as part of Stage One to analyse the various egress
strategies available for occupants with disability in a building, which took into
consideration aspects of occupant warning, path identification and egress. While the
research discussed the need for amendments to also cater for people with hearing
and vision impairments, the main findings of this study related to the barriers to
emergency egress for people with a mobility disability, in particular the inability to
independently manoeuvre when using stairs.
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BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

The research noted that the practicality of alternatives diminished in tall buildings
and examined the potential for people with disability to either independently, or with
assistance from fire wardens or assistants, use a fire-isolated stair. It was
acknowledged that this approach and other similar strategies failed to address the
dignity and equity issues the DDA seeks to influence.
The research suggested a more accessible and dignified option would be to provide
evacuation lifts that are specifically designed to operate under fire conditions.
However, the research acknowledged that evacuation lifts were more expensive to
install, support and maintain as well as requiring more resources to operate
effectively during an emergency. In addition, they had not been fully tried and tested
at that time. 6 Noteworthy disadvantages of a solution incorporating a lift or liftrefuge strategy were listed as:

potentially very costly;


human behavioural considerations such as time spent waiting anxiety, order
and priority of use, crowding;
implications for lift operation and control e.g. doors opening on a fire floor; and
the complexity of sophisticated lift control. 7

Like an earlier report undertaken on behalf of the Victorian Building Commission by


Lincolne Scott Consulting Engineers, the examination of the use of lifts as a strategy
for evacuation in this research revealed the importance of reliance on building
management procedures. Trained assistance or intervention by designated people
in the evacuation of people with disability was recognised as central to the success
of such a strategy. Procedures which are administrative in nature were
acknowledged as being fundamentally unsuitable for inclusion in the BCA which is
primarily a construction code.
In 2005 when considering the outcomes of this research, the ABCB recognised that
potential D-t-S Provisions were likely to be very complex considering the numerous
buildings, systems and configuration scenarios. It was agreed that further
consideration should await international developments subsequently Stages Two
and Three of this research were not pursued. However, the ABCB continued to
monitor and review research into the use of lifts for evacuation, including that being
undertaken by the US National Institute of Standards and Technology and the
International Organization for Standardization

Warrington Fire Research, Emergency Evacuation for Occupants with Disabilities, 2004 Prepared for the
Australian Building Codes Board.
7
Warrington Fire Research, Emergency Evacuation for Occupants with Disabilities 2004 Prepared for the
Australian Building Codes Board - 7.2.1

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BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

Recent Developments
Further to the recommendations of the HRSC, the ABCB convened an Emergency
Egress Forum in 2011 to seek opinions on proposals to improve egress for all
occupants. The Forum was attended by representatives from industry, government
and the disability sector. This Forum and advice from the Commonwealth Attorney
Generals Department supported changes to the BCA being undertaken
progressively, rather than waiting until research and analysis on all aspects had
been completed. This incremental approach is considered to be consistent with the
Australian Governments response to the HRSC Recommendation 16 to make
changes to the BCA as soon as possible.
In examining international approaches, the ABCB found that little had been achieved
in the development of prescriptive egress solutions. The International Building Code
(IBC 2009), a model code used in the USA, had introduced requirements that, under
specified conditions, allowed the use of lifts for evacuation in large buildings (over
128 m in height) in lieu of an additional exit stairway. However, the UK had adopted
a risk management approach and provided guidance on the design, management
and use of lifts through a British Standard BS 9999 that supported the notion that life
safety is reliant on effective management and trained personnel (BS 9999 p.3).
Strategy
While there had been some developments internationally, it appeared there was a
reluctance to mandate the use of lifts for egress, and awaiting developments was no
longer considered a sustainable approach. Therefore, the ABCB has adopted a
strategy that includes amendments to D-t-S Provisions being considered
incrementally, and the development of a non-regulatory handbook for lifts used in
evacuation. A non-mandatory handbook is also considered more able to address
building management procedures, roles and responsibilities and building specific
considerations, which are unsuitable for inclusion in the BCA.
Use of Lifts
The BCA has specific exemptions for certain small buildings from the need to install
a passenger lift. 8 However, in taller buildings where access is required to a level
other than an entry level, passenger lifts are often seen as the most practical means
of entering and exiting a building under normal conditions.
Conventionally designed lifts are considered unsuitable for use as a means of
evacuation to reach a point of safety in the event of a fire (a key objective of the
BCA). A number of factors may affect the operation of lifts and their controls
including, but not limited to the effects of fire (heat/smoke/flame) and fire fighter use
8

Australian Building Codes Board, Building Code of Australia (BCA) Volume One (2013), D3.3 (f) p.222

16

BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

during fire response operations. Lifts may also be unavailable for use due to
decommissioning for maintenance, or the waiting times for a lift may be
unacceptably long when used for simultaneous evacuation.
Therefore, the BCA requires the installation of signs warning occupants not to use
lifts in the event of a fire. This is consistent with a long established policy both in
Australia and internationally. This also applies to what the BCA terms an
emergency lift which is for use by emergency services personnel.
Building emergency evacuation practices and emergency plans also reflect this
practice through training or direction from wardens. This has also conditioned
occupants to opt for means of egress other than lifts such as fire stairways or
horizontal exits (see appendix B) in an emergency.
The ABCB recognises that potential technical solutions using lifts for evacuation are
complex, reliant on building management practices and their suitability may be
influenced by human behavioural factors. However, lifts offer obvious accessibility
advantages over other options for people with disability.
Performance Requirement DP7
In 2013, Performance Requirement DP7 was included in the BCA to ensure
appropriate consideration is given to an Alternative Solution that involves using a lift
for evacuation. DP7 states:
Where a lift is intended to be used in addition to the required exits to assist
occupants to evacuate a building safely, the type, number, location and fire-isolation
must be appropriate to
(a) the travel distance to the lift; and
(b) the number, mobility and other characteristics of occupants; and
(c) the function or use of the building; and
(d) the number of storeys connected by the lift; and
(e) the fire safety system installed in the building; and
(f) the waiting time, travel time and capacity of the lift; and
(g) the reliability and availability of the lift; and
(h) the emergency procedures for the building.
DP7 lists those issues that must be considered when using a lift for evacuation in
addition to the existing required exits (used for egress) as a means of assisting in
the evacuation of all building occupants. As buildings get higher, the occupants
needing assistance will not only be people with disability but people with a health
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BACKGROUND TO ACCESS AND EGRESS FOR PEOPOLE WITH DISABILITY

condition or temporary injury, pregnancy, who are obese or who are managing small
children.
DP7 (a) to (c) require similar consideration to that required by DP4, but are
additional specific requirements where a lift is proposed to assist in evacuation.
The intent of DP7 (e) to (h) is to ensure a high level of safety and engineering
reliability in a solution that includes a lift. DP7 also requires that appropriate
consideration be given to a lifts interaction with other fire safety systems of the
building, and building evacuation procedures under evacuation conditions.
An ABCB handbook Lifts Used During Evacuation has been developed to aid
designers and regulators when developing or assessing an Alternative Solution
using lifts as a means of egress. Matters that need to be addressed to achieve
compliance with DP7 include:

reliability of the power supply;


fire resistance and smoke management;
lift car and landing controls;
communication systems; and
human behaviour.

The handbook can be downloaded from the ABCB website at www.abcb.gov.au.

18

EGRESS AMENDMENTS & PROPOSALS

EGRESS AMENDMENTS & PROPOSALS


D-t-S Amendments to BCA 2013

As the first stage of amendments to enhance the egress provisions for all
occupants, the ABCB undertook development and consultation on changes that
were considered to be logical first steps in improving the accessibility of building
exits, for inclusion in BCA 2013.
D2.21 Door handles in the path of travel to an exit

These amendments require door hardware installed on a door in a required exit,


forming part of a required exit or in a path of travel to a required exit to meet the
requirements of AS 1428.1 : 2009 Design for Access and Mobility General
Requirements for Access New Building Work . This will enable the use of
doorways by a greater number of people.
D2.23 Signs on doors, D3.6 and Specification D3.6 Braille and tactile signage
Following reports of success for similar signage measures adopted internationally 9,
consultation with stakeholders and impact assessment resulted in the inclusion of
signage provisions in the BCA. These amendments require Braille and tactile
signage to identify a doorway and the storey where it is located in a required exit or
forming part of a required exit, including horizontal exits.
D2.15 Thresholds
Amendments have been included that require exit doorways opening to a road or
open space, if from a building required to be accessible, to have a threshold or step
ramp provided in accordance with AS 1428.1. This prevents the installation of a step
within the distance of a door leaf from the threshold providing more effective and
less dangerous egress.
D2.17 Handrails
The amendments to D2.17 require handrails associated with a ramp or stairway
serving as a required exit from an area required to be accessible, to comply with
clause 12 of AS 1428.1.

International Building Code (2009), 1011.3

19

EGRESS AMENDMENTS & PROPOSALS

Proposed D-t-S Amendments for NCC 2015


Using an incremental approach, proposals for which early stage analysis revealed
would have minor cost implication have progressed through the BCA amendment
process and were included in BCA 2013 as described above. This section covers
other, more substantial amendments on notification of the presence of fire,
identification and location of exits and their suitability and use. This section outlines
a statement of the problem, the objectives of the solution and identifies the BCA
requirements potentially affected.
These amendments are intended to ensure that safe, equitable and dignified egress
from a building is available to all occupants in an emergency to complement an
increase in accessibility provided by the introduction of the Premises Standards.
Consistent with this aim, the proposals are only intended to apply in areas which are
required by the BCA to be accessible.
Proposals were developed through consultation with representatives of
governments, industry and the disability sector. Feedback on these amendments is
sought (see opportunities for stakeholder involvement Pg. 45).
As discussed earlier, the ABCB is required to undertake an assessment of all
regulatory proposals in order to determine their impacts and measure the potential
benefits and costs associated with the proposals. While this report does not
examine costs and benefits associated with these proposals in detail, it discusses
generally the practicality of proposals and impacts both positive and negative.
Proposed BCA wording is indicative of the changes proposed and is subject to
further refinement following feedback.

20

PROPOSAL ONE

EGRESS AMENDMENTS & PROPOSALS

Proposals for Active Systems


Proposal One Notification
It is proposed that visual alarms be provided where automatic smoke detection and
alarm systems are required in buildings and parts of buildings required to be
accessible.
Early detection and notification of fire will reduce the time taken by occupants to
evacuate a building in the event of an emergency, reducing exposure to the
products of fire including heat, smoke and toxic gases. Inhalation of smoke and/or
toxic gases is the main cause of fatality from a fire.
NCC Volume One, BCA Part E2 Smoke Hazard Management contains
requirements that address smoke hazard management. These requirements, in
conjunction with other active and passive fire safety systems, seek to provide early
warning to occupants of the detection of fire and maintain tenable conditions in any
evacuation route for sufficient time to allow occupants to evacuate that part of the
building.
To achieve these outcomes the BCA specifies requirements for each class of
building with regard to

the provision of fire isolated exits,


the effective height of the building,
the size of fire compartment, and
the specific use of certain classes of buildings.

Active fire safety systems required under Part E2 include

automatic smoke alarm systems


automatic smoke detection systems
zone smoke control systems
occupancy warning systems
smoke exhaust systems
automatic air pressurisation systems
sprinkler systems
automatic smoke and heat vents
natural heat ventilation
automatic shut-down of air-conditioning systems.

The Problem
The BCA, through referenced technical standards, includes provisions for
arrangement and control of automatic smoke detection and alarm systems or
occupant warning systems. These rely on audial signals produced by sounders or
21

PROPOSAL ONE

EGRESS AMENDMENTS & PROPOSALS

amplified sound systems which are required to be 10 decibels (dB) higher than
ambient noise levels and not less than 65dB(A). 10 The use of other warning signals
such as visual and tactile signals is not mandatory except where the specific
installation requires background noise greater than 95dB(A) to be overcome. For
occupants with a hearing impairment, these audial cues may be inappropriate or
insufficient.
Objectives of the Proposal
The proposed changes are intended to assist those with a hearing impairment to
receive adequate warning at the same time as other occupants. The proposal would
apply in buildings required to be accessible which require alarm systems and
intercom systems. The arrangement of these systems in common areas (not soleoccupancy units) would be broadly consistent with the requirements of the Disability
Standards for Accessible Public Transport.
Proposed BCA Wording
Note: To illustrate proposed changes, where new text is proposed for inclusion in
the BCA underline blue is used. Where text is proposed for removal from the BCA
red text with a line struck through (strikethrough) is used.
EP4.3
To warn occupants of an emergency and assist evacuation of a building, an
sound alarm system and intercom system for emergency purposes must be
provided, to the degree necessary, appropriate to
(a) the floor areas of the building; and
(b) the function or use of the buildings; and
(c) the height of the building.
Specification E2.2a Smoke Detection and Alarm Warning System
3. Smoke Alarm System
(a) A smoke alarm system must
(i)
consist of smoke alarms complying with AS 3786; and
(ii)
be powered from the consumers mains source; and
(iii)
In a Class 3 sole-occupancy unit required to be accessible, the alarm
system must also provide visual and tactile warning to building
occupants in accordance with AS 1603.17.
6. Building occupant warning system

10

SAI Global, AS 1670.1 : Fire Detection Warning Control and Intercom systems Design, Installation and
Commissioning (2004), Clause 3.22 p.27.

22

PROPOSAL ONE

EGRESS AMENDMENTS & PROPOSALS

Subject to E4.9, a building occupant warning system provided as part of a


smoke hazard management system must:
(a)
Comply with clause 3.22 of AS 1670.1 to sound through all occupied
areas except
(ai) in a Class 2 and 3 building or Class 4 part of a building provided with
a smoke alarm system in accordance with Clause 3(c)(ii)
(iA) the sound pressure level need not be measured within a soleoccupancy unit if a level of not less than 85 dB(A) is provided at
the door providing access to the sole-occupancy unit; and
(iiB) (Renumber subsequent clauses)
(bii)
(ciii).(renumber clauses)
(ev)
(iA)
(iiB)
(iiiC) in areas used by residents, may have its alarm adjusted in
volume and content to minimise trauma consistent with the type
and condition of resident.
(b) If serving an area required to be accessible
(i) incorporate a visual alarm system complying with AS 1603.11, which is
visible from all points within common areas required to be accessible;
and
(ii) in a Class 3 sole-occupancy unit, provide visual and tactile warning to
building occupants in accordance with AS 1603.17.
(bc) In a Class 2 and 3 building or Class 4 part of a building provided with a smoke
detection system in accordance with Clause 4(c), the sound pressure level from
a warning system need not be measured
E4.9 Sound Alarm systems and intercom systems for emergency
purposes
(a) An alarm system comprising a sound system and intercom system for
emergency purposes complying where applicable with AS 1670.4 must be
installed
(i)
(a) in a building with an effective height of more than 25m; and
(ii)
in a Class 3 building having a rise in storeys of more than 2 and used
as
(A) (i) the residential
(B) (ii) accommodation for the aged

23

PROPOSAL ONE

EGRESS AMENDMENTS & PROPOSALS

(b) An alarm system in (a), if serving an area required to be accessible, must


incorporate a visual warning complying with AS 1603.11, which is visible
from all points within the area required to be accessible.
Discussion
The WA Deaf Society publication, Providing Accessible Services and Facilities for
People who are Deaf or Hard of Hearing, encourages the use of strobe lighting in
key areas, and visual warning interconnection with fire and smoke alarms. 11
Visual aids used as notification in buildings are intended to alert occupants who are
awake and would be otherwise unaware of an alarm, unaccompanied or unable to
hear or interpret audible alerts. Australian Standards including AS 1603.11: 2010
Automatic fire detection and alarm systems Visual warning Devices provide
additional guidance on the interconnection of these systems with those required by
the BCA. Visual alarms have been supported by advocates of people with hearing
impairments as a means of notification regardless of the building classification. 12
However, Australian Standard AS 1603.17 : 2011 Automatic fire detection and alarm
systems Warning equipment for people with hearing impairment, which specifies
requirements for the use of warning equipment for people with a hearing impairment
for use in residential accommodation, cautions against relying on visual alarms
alone to arouse sleeping occupants.
The focus of the visual alarm proposal is on accessible areas. However, their
efficacy and suitability where occupants are sleeping has been the subject of some
debate. Some sources suggest their effectiveness can be increased by using
pillow/bedshakers. The Deafness Forum of Australia (DFA) advocate that
operators of residential accommodation such as hotels, motels and serviced
apartments should provide appropriate means of alerting deaf or hearing impaired
occupants to any danger, drill or test at the same time as other occupants13. In the
built environment more broadly, the DFA advocate the use of vibro-tactile alarms
and flashing lights as appropriate means for alerting deaf or hearing impaired
occupants to danger 14. Where suitably designed, these devices interconnect to
building occupant warning systems to provide a visual and vibro-tactile alarm, and
can be used as an additional measure to arouse sleeping occupants.
The cost of domestic visual and vibrating smoke alarms for profoundly deaf people
has been subsidised under a recent initiative of most state governments (South
11

http://www.wadeaf.org.au/media/docs/Providing_accessible_services_brochure2006.pdf
Australian Deafness Forum, Draft Disability (Access to Premises Building) Standards (2008).
13
Australian Deafness Forum, Position Statement on ACCESSIBLE ACCOMMODATION, reviewed 15
October 2012.
14
Australian Deafness Forum, Position Statement on COMMUNICATIONS AND INFORMATION ACCESS IN
THE BUILT ENVIRONMENT, reviewed 15 October 2012.
12

24

PROPOSAL ONE

EGRESS AMENDMENTS & PROPOSALS

Australia, Victoria, New South Wales, Queensland, Tasmania and Western


Australia), which may have further promoted their use. Many such devices are
portable and may be used to provide warning in places other than the persons
home.

Figure 2 Example of a lithium battery powered visual and vibrating alarm. Picture Courtesy of the Deaf Society of NSW

25

PROPOSAL TWO

EGRESS AMENDMENTS & PROPOSALS

Proposals for Passive Systems


Proposal Two Identification and location of exits
It is proposed that fire-isolated stairways be co-located with lifts.
For the purpose of the following section, the BCA definitions below are provided for
information:
Exit means
(a) Any, or any combination of the following if they provide egress to a road
or open space
(i) An internal or external stairway.
(ii) A ramp.
(iii) A fire-isolated passageway.
(iv) A doorway opening to a road or open space.
(b) A horizontal exit or a fire-isolated passageway leading to a horizontal exit.
Evacuation route means
the continuous path of travel (including exits, public corridors and the like)
from any part of a building, including within a sole-occupancy unit in a Class 2
or 3 building or Class 4 part, to a safe place.
Exits are designed to provide occupants a means for egress in an emergency and
even in multi-storey buildings where lifts are installed, stairways or ramps often
serve exclusively as exits. Stairways or ramps serving as exits must be designed to
be fire-isolated, that is to provide protection for occupants from the effects of fire,
where they connect:

more than two consecutive storeys (a third may be permitted under specified
conditions) in a Class 3, 5, 6, 7, 8 and 9 building; or
2 consecutive storeys in a Class 2 building.

Distribution, proximity to other exits and dimensions are specified in Section D of


BCA Volume One.
The Problem
As identified by earlier research, stairs as a means of evacuation pose several
practical difficulties in an evacuation, particularly for those with mobility impairment.
In these circumstances other options need to be available. Generally, these options
include assistance from trained personnel, evacuation via a suitably designed lift or
assistance by emergency services. However, these options rely on the intervention
of others. This reliance poses challenges for occupants who may be visiting or
otherwise unfamiliar with the building, unaccompanied or unable to interpret or
respond to directional cues. Also, significant differences exist in the way building
management procedures might require people with disability to exit.
26

PROPOSAL TWO

EGRESS AMENDMENTS & PROPOSALS

While building management practices can be effective in buildings used as


workplaces, their effectiveness in buildings used for other purposes can vary.
Personal Emergency Evacuation Plans (PEEPs) are recognised as a necessary and
effective measure to assist people with disability respond to an emergency and are
designed to cater to the needs of the person and the specific characteristics of the
building in egress planning. However, this approach also has complexities. For
example, PEEPs are highly individual and a first time visitor to a public assembly
building may be required to make contact with building management and establish a
new PEEP on each visit. This method of evacuation management is not feasible in
all circumstances 15. The method also does not address built-in inequalities; rather it
attempts to manage the occupants interaction with the fire safety systems.
Occupants with disability are often reliant on routes with accessible features or
accessways to gain access to buildings and studies have shown that occupants
tend to exit buildings via the route used to enter the building. This observation is of
particular importance for people with vision impairment. Typical illuminated or nonilluminated exit signs incorporating the internationally standardised running man
symbol may not be detectable by people with vision impairment. Due to complexity
of the building design, occupants with vision impairment may be unable to identify
the direction to an exit in an emergency and instead, attempt to retrace their travel
on an accessway. However, an accessway may not provide sufficient protection
from the effects of fire (e.g. fire-isolated) or an appropriate escape route unless
specifically designed as an exit. Conversely an exit may not have features to enable
its use by a person with disability.
Occupants in wheelchairs who require assistance to evacuate may be forced to wait
for other occupants to evacuate before attempting to leave or to seek refuge in an
exit. Alternatively, due to the width of stairways, those assisting with their egress
may impede the egress of others leading to delay and confusion for other occupants
evacuating. Furthermore, where occupants in wheelchairs rely on evacuation using
a lift under the control of the emergency services, they may be required to assemble
at an area remote from an exit.
Evacuation to a place of relative safety may in some cases be provided through
horizontal exits as influenced by an evacuation strategy. However, a buildings
configuration or the nature of the emergency itself may mean this option is not
provided or is rendered unavailable (see Appendix B for a discussion on the role of
the egress strategy in evacuation).

15

Department for Communities and Local Government Eland House (London), The adequacy of refuges,
escape stairs and management procedures (2008), p.15

27

PROPOSAL TWO

EGRESS AMENDMENTS & PROPOSALS

Objectives of the Proposal


The following amendment is proposed to improve the opportunity for all occupants,
including those with disability to locate and use suitable exits in an emergency.
Proposed BCA Wording
D1.5 Distance between alternative exits
Exits that are required as alternative means of egress must be
(a) distributed
(i) as uniformly as practicable within or around the storey served; and
(ii) in positions where unobstructed access to at least 2 exits is readily
available from all points on the floor including lift lobby areas; and
(iii) where a lift or bank of lifts provide access to a storey the lift or bank
of lifts must be located within 6 m of an exit ; and
(b) not less than 9 m apart
Discussion
The co-location of lifts and fire-isolated exits within a specified distance, would
ensure that occupants with vision impairment seeking egress were provided with a
suitable alternative to a lift. Furthermore, should conditions deteriorate while
assembling for assistance, occupants with mobility impairments would be provided
with an alternative exit in close proximity to a suitably designed lift or an emergency
lift under the control of emergency services.
While it is currently possible for lift shafts and fire-isolated stairways to be located in
close proximity, mandating a requirement would impose limitations on potential
configurations. Alternatively co-location is cited as being important for reasons of
efficacy and design logistics 16. Configurations leading to greater intuitive and
perceptible circulation is cited by universal design guidelines a key element in
wayfinding and may already be widely adopted in practice 17.
Some international regulations recognise the potential for occupants in wheelchairs
to be unable to use stairways without assistance. In some cases options to provide
egress utilising refuges, emergency firefighting lifts (where appropriately supported
by personnel and management plans) or evacuation lifts are provided. These
measures give deliberate consideration to the proximity of stairways to lifts as
alternative means of escape.
16

Lincoln Scott, Using Lifts for Evacuation of People with Disabilities (2003), prepared for the Victorian
Building Commission.
17
NFPA, Life safety code provisions and its impact on emergency egress behaviour of people during fires
(2008).

28

PROPOSAL TWO

EGRESS AMENDMENTS & PROPOSALS

For example, the UK building regulations provide for the location of the lift shaft
within the enclosure of a protected stairway for the purposes of fire separation from
the remainder of the storey 18. Guidance on the use of evacuation lifts and refuge
areas is also provided through BS 9999 : 2008 Annex G (superseding BS 5588-8 :
1999). This standard provides options, details and figures for location of lifts and
refuges. While not mandatory, the standard suggests where evacuation lifts are
provided, that they be associated with a refuge and located close to a protected
stairway.
In specified instances, the USA International Building Code requires at least one
accessible means of egress be in the form of an elevator that is designed to ensure
emergency operation and be directly accessible from either a refuge or a horizontal
exit. Where refuges are utilised, these need to provide access to an elevator or an
accessible stairway. However, in order for a stairway to be considered accessible,
the stairway needs to incorporate a refuge or be accessible from a refuge.
Therefore, efficiencies may dictate that refuges are designed to adjoin, or be
accessible from stairways that also provide access to an elevator.
While international regulations consider the location of refuges associated with an
exit, refuges are not associated with this proposal and are explored as a potential
future regulatory proposal in this report.
This proposal tests the role and importance of intuitive building design in the location
of a place of safety forming part of the every-day building circulation space. It has
been suggested, in proposing enhancements to building egress requirements, it is
easier to design a building with evacuation lifts in the normal circulation paths19.
However, the proposal is considered an effective means of providing a suitable exit,
or place of relative safety (suitably designed lift, refuge or accessible exit
stairway/ramp or horizontal exit) which can be located through wayfinding.

18

UK Building Regulations, Approved Document B Volume Two Buildings Other than Dwelling Houses
(2010), Clause 5.42.
19
W Bretherton, Everybody Out Emergency Evacuation for Persons with a Disability (2003) p. 62.

29

PROPOSAL THREE

EGRESS AMENDMENTS & PROPOSALS

Proposal Three Suitability for Use Dimensions


It is proposed to apply the accessibility requirements of AS 1428.1 to doors and
circulation spaces and ramps in exits and paths of travel to an exit.
To enable buildings to be accessible for occupants with disability, Part D3 of the BCA
describes where an accessway (a continuous accessible path of travel as defined in
AS 1428.1) needs to be provided. AS 1428.1 contains the technical details to
achieve an accessible path of travel in order to comply with the BCA and the
Premises Standards. Therefore, applying the requirements AS 1428.1 to egress
routes is a logical method to ensure accessibility for egress purposes.
The Problem
The current BCA requirements allow for the design and construction of egress paths
which may not be suitable for use by people with disability. Specifically,

paths of travel to an exit do not require turning spaces and circulation space at
doorways to allow their use by occupants in a wheelchair
luminance contrast of doors and doorframes with adjacent walls may not be
sufficient to enable an occupant with vision impairment to identify an exit
exit door controls may impede the egress of occupants with gripping impairments.

Paths of Travel to an Exit


Changes to D2.15 were introduced in BCA 2013 in buildings required to be
accessible, to prevent doorways leading to roads or open spaces from incorporating
a step at any point closer to the doorway than the width of the door leaf. The
installation of a threshold ramp or step ramp in accordance with AS 1428.1 is
required to overcome a change in level at the threshold of a door within this specified
distance. This enables the doorway to be used by occupants with disability However,
where a landing is provided, steps may be used to achieve changes in level outside
of this zone without the need for the installation of a threshold ramp or a step ramp.
Where this occurred on a path of travel to an exit, the egress of a person with a
mobility impairment may be impeded.

Figure 3 Illustration of where a step is currently not allowed in a doorway

Doors and Circulation Space


30

PROPOSAL THREE

EGRESS AMENDMENTS & PROPOSALS

The BCA requires a minimum exit width for a path of travel to a required exit
(excluding doorways) of 1 m. Additional exit width is required in certain
circumstances due to the use of the building and the number and characteristics of
occupants. This dimension is consistent with the minimum required for accessibility.
However, accessways require additional circulation space at doorways and at
changes in direction greater than 60 degrees, luminance contrast between doors and
doorframes and adjacent walls and limitations on opening forces.
Turning Spaces
A corridor serving an exit is not required to accommodate room for wheelchairs to
turn. Consequently, occupants in wheelchairs may be forced to retrace their journey
in reverse when faced with an obstruction potentially delaying their own egress or
that of others.
Objectives of the proposal
The objective of the amendments is to improve the accessibility of exits and paths of
travel to exits to places of safety for all occupants. Specific changes to the BCA text
have not been developed for these proposals. Instead, Table 1 below contains a
summary of the intent of proposed changes to egress elements for Proposals 3 and
4.

31

PROPOSAL THREE

EGRESS AMENDMENTS & PROPOSALS

Table 1. Summary of the Intent of Proposed Changes to Achieve the Objectives of Proposals 3 & 4.
Egress element

Current access requirements in areas required to be accessible

Proposed additional egress requirements in areas required to be


accessible

Corridor in path of travel to


exit

Part D3 Accessway provisions generally apply.

No additional requirements

Door in a path of travel

Part D3 Accessway provisions generally apply.


D2.21 Accessible operation of latch.

No additional requirements

Non-fire isolated stairway

D3.3(a) Clause 11 of AS 1428.1

No additional requirements

Non-fire isolated ramp

D3.3(a) Clause 10 of AS 1428.1

No additional requirements

Step in a path of travel

D2.15(c)

Apply accessway requirements to the path of travel to an exit

Fire-isolated stairway

D3.3(a)Clause 11(f) and (g) of AS 1428.1

Clause 11 of AS 1428.1 for handrails, TGSIs at commencement of stairs and


landings

Fire-isolated ramp

D3.3(a)Clause 10(f) and (g) of AS 1428.1

Clause 10.3 of AS 1428.1 for handrails, TGSIs, handrails, ramp gradients,


kerb rails and landings

Fire-isolated passageway

D2.21 Accessible operation of latch

Apply accessway requirements

Horizontal exit door

Accessway requirements apply

No additional requirements

Entrance door to fire


isolated stairway or
passageway

D2.21 Accessible operation of latch

AS 1428.1 Clause 13 requirements for luminance contrast, door controls

Exit door from a fireisolated stairway, fireisolated ramp or fireisolated passageway to


open space

D2.21 Accessible operation of latch.


D2.15(c)Step or threshold ramp in lieu of step within width of
swing of door.

AS1428.1 Clause 13 requirements for luminance contrast, door controls

Path of travel after


discharging from an exit to
road or open space
32

D1.7(b)(B)

Apply accessway requirements apply from the point of discharge from an


exit along the route to a safe place

PROPOSAL THREE

EGRESS AMENDMENTS & PROPOSALS

Discussion
Turning Spaces on Paths of Travel to an Exit
The BCA requires passing and turning spaces at 20 m intervals on those parts of an
accessway where a direct line of sight is not available; or within 2m of the end of an
accessway, where it is not possible to continue along the path. This requirement
recognises that it is not appropriate to require a person in a wheelchair to reverse
over long distances.
Despite long unbroken corridors being relatively uncommon in designs, the ABCB
Access RIS assessed the provision of passing and turning spaces in buildings for
accessibility as being a proposal which would have a moderate impact. 20 This was
due to the range of buildings that the requirements would apply. It might be
assumed that the effect of requiring the installation of these spaces for access would
have diminished to a large extent the number of potential instances where these
would be required for egress purposes.
Accessways
Designing a path of travel to an exit as an accessway requires compliance with AS
1428.1 requirements for door opening forces, circulation space at doorways,
luminance contrast of doors and restrictions on the use of steps in paths of travel.
The requirement is intended to prevent features which might impede the egress of
occupants with disability in paths of travel from areas required to be accessible, and
upon discharging from an exit, on the route to open space. An increase in initial
construction costs is anticipated for this proposal associated with:

the additional materials required for an accessible ramp, or a step ramp in lieu of
providing a landing served by steps; and
increases in door widths, circulation space.;

However, the degree costs will be increased will depend on the number of exits in a
building, and the slope of the site. It is important to note that most buildings will
require at least one accessible entrance to be provided, so for these entrances
(exits) there will be no associated cost increases. Impacts would be limited to fireisolated passageways, fire-isolated ramps used as required exits and the route from
required exits which do not discharge directly to open space.
Doors and Circulation Space
The increases in widths at doorways and circulation spaces in order to provide
access for people with disability would have captured some doorways in the path of
20

Australian Building Codes Board, Final Regulation Impact Statement for Decision (RIS2009-05) Proposal to
Formulate Disability (Access to Premises Buildings) Standards and Amend the Access Provisions of the
Building Code of Australia ( RIS 2008-02 as amended) pg33.

33

PROPOSAL THREE

EGRESS AMENDMENTS & PROPOSALS

travel to exits. However, an area not likely captured by changes for access would be
the entrance and exit doors serving a fire-isolated exit and would be subject to the
circulation requirements, luminance contrast and door controls requirements of
AS1428.1 to allow the exit to be identified and used by occupants with disability. The
ABCB Access RIS (pg. 133), attributed an additional $100 as a cost of compliance
with the door widths and $1,250 allowance for an additional 1m2 average circulation
space.

34

PROPOSAL FOUR

EGRESS AMENDMENTS & PROPOSALS

Proposal Four Suitability for Use Accessibility of Stairs and


Ramps
It is proposed to extend the requirements of AS 1428.1 for stairs and ramps to those
used in an exit.
The Problem
Current access requirements exempt fire-isolated stairs and ramps from compliance
with the requirements of AS 1428.1. The Australian Standard requires stairs leading
to an area required to be accessible, (serving as a means of access) to have:

opaque risers;
two accessible handrails; and
tactile ground surface indicators.

Ramps are required to have similar accessible features with the addition of kerb
rails. The standard also places limitations on gradients and intervals for landings to
assist in their use by a greater number of occupants including those with vision
impairment.
However, there is the potential that some occupants will still be unable to use an
accessible stairway for egress in a manner which is considered safe, equitable and
dignified. This issue is considered separately as a future regulatory proposal in this
report.
In considering the draft Premises Standards, the HRSC recommended exemptions
for fire-isolated stairs be reconsidered and narrowed. Apart from improving the
general access to buildings, the effect of installing these features on fire-isolated
stairways or ramps was recognised by the HRSC as improving the overall safety of
these exits for ambulant people who are blind or have vision impairment. 21
Changes to BCA 2013 require the size, configuration and location of handrails
associated with a ramp or required exit stairway, from an area required to be
accessible, to comply with clause 12 of AS 1428.1. However, these requirements do
not require handrails to be provided on both sides of a stairway, or include other
accessible features such as handrail extensions and returns.
Objectives of Proposal Four
The objective of the proposal is to improve the accessibility of fire-isolated stairs or
ramps for use by occupants with a mobility impairment, a gripping impairment or
vision impairment. (Note: Table 1 contains a summary of the intent of proposed
changes to achieve the objectives of Proposals 3 and 4)
21

Commonwealth of Australia, Access All Areas (2009), Recommendation 10, p.69

35

PROPOSAL FOUR

EGRESS AMENDMENTS & PROPOSALS

Proposed BCA wording


D2.17 Handrails
(a) Except for handrails referred to in D2.18, handrails must be
(v)

(vi)

in a required exit serving an area required to be accessible, designed


and constructed to comply with clause 12 of AS 1428.1, except that
clause 12(d) does not apply to a handrail required by (a)(iii)(B).

D3.3 Parts of buildings to be accessible


In a building required to be accessible
(a) every ramp and stairway, except for ramps and stairways in areas exempted by
D3.4, must comply with
(i)

for a ramp, except a fire-isolated ramp, clause 10 of AS 1428.1; and

(ii)

for a stairway, except a fire-isolated stairway, clause 11 of AS 1428.1;


and

(iii)

for a fire-isolated stairway, clause 11.1(f) and (g) of AS 1428.1; and

(h)
(j) clause 12(d) of AS 1428.1 does not apply to a second handrail in a Class 9b
primary school required by D2.17(a)(iii)(B).
Discussion
By removing exemptions in D3.3 for fire-isolated stairs and ramps as well as
reference to Clause 12 of AS 1428.1, the changes would require all features of AS
1428.1 for stairways and ramps used in exits. These measures while small in
nature, together are considered essential to providing the necessary sensory
information to enable an occupant with a vision, mobility or dexterity impairment to
use a ramp or stairway in an emergency.
Stairs
This proposal would result in the following changes to the requirements for stairs in
areas required to be accessible:

increased set backs on property boundaries and internal corridors to


accommodate accessible features such as handrail returns;
changes to nosing arrangement and profile requirements;
opaque risers; and
inclusion of Tactile Ground Surface Indicators (TGSIs).

The major costs associated with this proposal relate to the increased set-backs to
avoid the enhanced features encroaching on the transverse path of travel. This
36

PROPOSAL FOUR

EGRESS AMENDMENTS & PROPOSALS

potentially affects a buildings lettable area (the proportion of the usable floor area
available for lease) which excludes the lift and stair cores. A commercial buildings
lettable area may influence the value of its lease.
Costs associated with potential changes would however, be building specific and
depend upon the options used to achieve compliance.
Open risers present a particular difficulty for occupants with vision impairment when
negotiating a stairway. The presence of light behind a stairway with an open riser
can reduce the visibility of a stair and the gap between treads poses a hazard for
those using mobility aids, or with prosthesis. Off-form concrete stairs as typically
used in high rise construction are an example of those which would generally meet
the proposed requirement. That is, the vertical element of the stair is solid and not
prone to entrapment although this is considered achievable with most commonly
used stair materials.
While the main benefit in respect of opaque risers is to users ascending a stair, the
direction of travel in an emergency will depend on the occupants location relative to
the place of safety and the fire safety strategy adopted, i.e. some egress routes
involve ascending rather than descending stairs.

Figure 4 Closed risers (left) and open risers (right) in stairways

Handrails
The proposals would result in the following changes to handrails in areas required to
be accessible:

accessible handrails on both sides in accordance with AS 1428.1 in fire-isolated


stairs and ramps
The extension of handrails and requirements for the return configurations

There are numerous benefits in providing handrails in stairs. Where designed for
access they are used as a disruptive anchor in the event of a fall. They also
provide an important visual cue to a change in level and stability and confidence
when using a stair.

37

PROPOSAL FOUR

EGRESS AMENDMENTS & PROPOSALS

The primary function of a fire-isolated exit stairway or ramp is to provide a means for
escape by descent in an emergency (depending on strategy; see Appendix B).
Recent research cited studies in the UK and US that found approximately two-thirds
of stair accidents were found to have occurred during stair descent. Furthermore,
descent accidents were likely to result in more severe injuries than falls which
occurred on stair ascent 22.
The BCA does not require the installation of two handrails unless the width of the
stairway or ramp is greater than 2m. Therefore current BCA requirements assume
occupants have use of either hand. The inclusion of two suitably designed handrails
on stairways and ramps is a measure intended to assist those occupants with
mobility or vision impairment or where an occupant only has the use of one hand, in
negotiating a stair.
It is noted that aside from the cost of the handrail itself, the main cost associated
with the proposal to provide an additional handrail is the additional width required for
the stairway core or ramp, potentially at the expense of the lettable area.
Ramps
The proposals would result in the following changes to ramps in an area required to
be accessible:

circulation space inclusions;


gradient limitations;
increased set-backs on property boundaries and internal corridors so as not to
encroach on the transverse path of travel;
installation of kerb rails; and
installation of TGSIs.

A ramp or a step ramp must be provided to accommodate changes in level. Step


ramps can accommodate changes in level up to 190mm, and for changes greater
than 1900mm in length a reduction in rise to run slope ratio from 1:8 to 1:14. Also
the inclusion of an additional handrail would be required to enable a ramp to be
used by people with disability as a required exit. Where these longer ramps are
proposed, the requirement would result in an increase in the required footprint of a
ramp to achieve the same change in level (height). However, the practicality of using
ramps over long distances for relatively small changes in level are likely to be a
greater influence on their use. This would confine the impact of the changes to
medium rise installations, or where a fire-isolated ramp is installed for other reasons.

22

38

Monash University Accident Research Centre, The relationship between slips, trips and falls and the design
and construction of buildings 2008, funded by the ABCB p.22.

PROPOSAL FOUR

EGRESS AMENDMENTS & PROPOSALS

TGSIs
The installation of TGSIs on landings at stairways and ramps used as exits will
assist vision impaired occupants in independently exiting a building. TGSIs are
required where a hazard is present, such as at the commencement of a stairway.
They are intended to be interpreted by a person with a vision impairment either
under the foot, by the tip of a seeing cane or by their visual contrast. Their location
and dimensions is intended to provide a tactile cue to a vision impaired occupant to
their location and impending interaction with a stair or ramp. The consistent
application of TGSIs will provide predictability for these occupants when moving in
the built environment. 23
The installation of TGSIs would be required at the top and bottom of stairways and
ramps on landings greater than 3 metres not bounded on both sides by a handrail.
Typically this would be where doorways penetrate a fire-isolated stairway or ramp.
The top surface of a TGSI and the bottom of a door leaf have the potential to
overlap leading some to suggest a TGSI will obstruct the operation of a door.
However, a typical clearance between a door leaf and a threshold of 10mm would
provide a residual clearance for free operation over TGSIs. Furthermore, the
favourable difference in level due to the absence of floor finishes in fire-isolated
exits, suggests design solutions will overcome the need for an increase in landing
size. Therefore, current landing dimensions are considered unchanged, and costs
are assumed to stem from the supply and installation of TGSIs only.

23 Blind Citizens Australia Submission to House of Representatives Legal and Constitutional Affairs
Committee Inquiry into Draft Disability (Access to Premises Buildings) Standards (March 2009), p. 15.

39

FUTURE PROPOSALS

FUTURE PROPOSALS
Places of Refuge

Unlike proposals 1-4 which, subject to feedback and impact assessment, are
proposed for consideration in NCC 2015, places of refuge are not intended for
consideration in 2015. Feedback on this report will instead inform the
development of any future changes.
Questions 5 to 7 of the report specifically address opinions on the use of places
of refuge in egress.
Discussion
The use of spaces in buildings to provide protection to occupants from the effects
of fire is not a new concept and is recognised in the use of horizontal exits and
compartmentation (e.g. in health-care buildings). Internationally, places of refuge
may be used as a solution to provide occupants with disability with a place of
relative safety in an emergency.
Refuges are spaces which are fire and smoke separated from the remainder of a
building in a similar manner to a fire-isolated stairway. However, other
considerations such as signage, minimum sizes, means of communication, and
access for assistance are cited by research and embodied in codes
internationally as essential features of refuges.
The ABCB developed proposals for egress to assist people with disability in
Regulation Document RD97/01(circa 1997). The proposals focus was limited to
visual alarms and places of refuge as a means for meeting obligations expressed
under the DDA. RD97/01 contained detailed proposals for places of refuge
defined as a place which offers protection from a fire hazard for people with
disabilities while awaiting assistance to evacuate.
RD97/01 explained that the intention was to provide spaces where a continuously
accessible path of travel was not available, or make use of existing spaces (e.g.
lift lobbies or toilet blocks) as temporary places of refuge form which rescue
personnel can later evacuate occupants. Proposed provisions applied the
requirements to buildings other than Class 2, Class 4 parts or Class 9a buildings
and proposed all exits be accessible or supplemented by a place of refuge.
Requirements developed as part of this work applied restrictions to the following
elements to assist with egress

40

fire and smoke separation utilising smoke proof walls where sprinklers were
provided, or providing a level of protection equivalent to a fire-isolated stair or
ramp and in other cases a minimum fire resistance level for walls and
ceilings;

FUTURE PROPOSALS

fire resistance and fire hazard properties of linings and finishes;


restrictions to openings and service penetrations;
minimum dimensions for doorways and minimum floor areas;
access for and communications with emergency personnel; and
signage to identify and direct occupants to refuges.

Feedback on RD97/01 Proposals


Feedback received in response to consultation on the refuge proposal included a
number of suggestions to improve structure and clarity. Feedback also revealed
some respondents preferred solutions which were perceived to provide a greater
level of equity, such as the use of suitably designed lifts.
Subsequently, research was undertaken examining strategies for evacuation of
occupants with disability in 2004. It discussed criticisms that areas of refuge were
not equitable, undesirable and inefficient uses of space and that they would be
located in remote parts of buildings leading to them being ignored as an option. In
comparing international approaches the research noted the significance of the
British Standard BS 5588-8 1999 (superseded by BS9999: 2008) definition of a
refuge (since amended) which is considered similar to that proposed by
RD97/01
places of relative safety where people whose abilities or impairments
might result in delayed evacuation can await assistance from building
management with the next part of their movement to a place of ultimate
safety.
The definition recognises the potential for increased waiting times occupants with
disability face when evacuating due to the need to await assistance from trained
personnel. Recognising this, places of refuge become necessary to provide an
equivalent level of temporary safety under either an emergency lift or stairway
evacuation scenario. Furthermore, requiring that they be associated with a fireisolated stairway or lift lobby would address concerns with familiarity of their
location and reduce the loss of space. 24 Research noted that adequate provision
of evacuation lifts would provide the most dignified and independent means of
egress from buildings. Also, where these were not designed for use in an
emergency, refuge areas near stair entrances were the only viable means of
providing egress. 25 However, research did not proceed to Stages Two and Three
to examine potential solutions since, like lifts, it was recognised that a strategy of
providing places of temporary refuge was equally reliant on assistance for the
ultimate evacuation of occupants.

24

Warrington Fire Research, Emergency Evacuation for Occupants with Disabilities 2004, Prepared for the
Australian Building Codes Board - 4.2
25
Warrington Fire Research, Emergency Evacuation for Occupants with Disabilities 2004, Prepared for the
Australian Building Codes Board - 4.7

41

FUTURE PROPOSALS

Considerations on a Future Model for Refuges


A key consideration of the inclusion of refuges will be in the acceptance of the
option in meeting the objectives of the DDA, as related issues have dominated
debate since the initial proposals were developed.
This report, in seeking to explain previous approaches for refuge areas,
concludes refuges which provide protection (an equivalent level of safety from
fire) for occupants are technically achievable. However, debate over user
acceptance and the reliance on building management are symptomatic of
concerns over the dignity and equity of this solution.
Furthermore, best practice regulation principles require that solutions be
commensurate with a clearly demonstrated problem and the most effective and
efficient of the options available.
Discussion included below is intended to inform feedback which will contribute to
consideration of any future model for consultation and impact assessment.
Triggers for Application
In recognition of the particular needs of occupants likely to use refuges, there is a
need to discuss triggers for the installation of refuges, in addition to those
technical requirements discussed as being essential elements of places of
refuge.
The approach considered most appropriate as a starting point are buildings
required to be accessible under D3 of BCA Volume One where the BCA also
requires the installation of a fire-isolated stairway (See Appendix C). Previous
refuge proposals also provided exemptions to Class 9a buildings in recognition of
the high degree of compartmentation in these buildings, an option still considered
viable.
The BCA currently provides exemptions to areas under D3.3 (f) and D3.4 from
the requirements for accessibility to areas
a) In buildings of Class 5, 6, 7b or 8 containing not more than 3 storeys; and
with a floor area of each storey excluding the entrance storey, of not more
than 200m2.
b) Where access would be inappropriate because of a particular purpose for
which the area is used.
c) That would pose a health and safety risk to people with a disability.
d) Which is a path of travel providing access only to an area exempted by (c)
or (d).
The above small building exemptions are proposed to apply to future egress
requirements.
Guidance developed by the ABCB in response to solutions which include the use
of suitably designed lifts as an exit, highlights that of primary consideration in
42

FUTURE PROPOSALS

their design is the fire and smoke protection of assembly areas such as lift
lobbies to serve the lifts. Concessions from providing places of refuge, where a
suitably designed lift lobby is provided, may also be appropriate.
User Acceptance
Central to further consideration of the inclusion of a place of refuge will be
accounting for user perceptions of how equitable the option is compared to other
options such as lifts. A suggested common view is that for occupants with
mobility impairments, a reliance on trained assistance to egress via a stairway is
less dignified and equitable than exiting via a lift. This is despite both alternatives
requiring the assistance of trained personnel and a period of assembly (in a
protected area) while awaiting assistance. While perceptions are individual, it
should be recognised that the BCA proposals are designed to provide safe,
equitable and dignified egress solutions for all occupants in an emergency.
A more complex debate when discussing the merits of the use of refuges in
association with strategies to protect-in-place or evacuate using suitably
designed lifts is highlighted by Bretherton 2003. His thesis Everybody Out points
to research indicating that refuges, unlike traditional evacuation, requires
occupants (perceptively at least) to remain in the proximity of the initial danger
from fire 26. Therefore the success of refuge areas is likely to ultimately hinge on
the willingness of the occupants to use these areas as a safe place 27.
Regardless of the strategy adopted, research argues that the success of
emergency evacuation for people with disability is dependent upon the familiarity
of the occupants with evacuation procedures. Consultation with users of places of
refuge in the United Kingdom revealed concerns over their use and the
procedures which support them 28, highlighting the importance of supporting
systems to any solution.
Building Emergency Management
Building management obligations require administrative practices and procedures
to be in place in order to respond as needed for coordinated and orderly
management of evacuation for all occupants. However, it is possible that an over
reliance on assistance by trained personnel may perversely entrench inequity in
egress routes.
In proposing requirements for either protect in place or everybody out (full
evacuation), Bretherton (2003) recognises the importance of building specific

26

W. Bretherton, Everybody out Emergency Evacuation for Persons with a Disability (2003), p.44.
W. Bretherton, Everybody out Emergency Evacuation for Persons with a Disability (2003), p.59.
28
Department for Communities and Local Government Eland House (London), The adequacy of refuges,
escape stairs and management procedures (2008), p. 3.
27

43

FUTURE PROPOSALS

management procedures and recommends the BCA be amended to include


some human behavioural aspects such as management practices and fire drills 29.
The BCA contains a number of systems which currently rely on the intervention of
others. These include the provision of fire hydrants for the use of emergency
services, fire extinguishers, and emergency warning and intercommunication
systems for coordination of evacuations. However, obligations for their use and
training in their use is supported by other legislation or administrative
requirements.
The highly specific nature of solutions adopted for the use of lifts, including
reliance on other systems and personnel, meant this was considered a solution
unsuitable for adoption as a D-t-S provision through the BCA. A place of refuge
model should also consider the role of other instruments such as legislation,
standards or guidance material to enforce/discuss matters unsuitable for
regulation. This would enable a final building management system to be tailored
to support a place of refuge strategy rather than attempt to overcome built-in
inequalities and provide greater certainty to industry and users on the safety,
dignity and equity of the solution adopted.

Management
Procedures

- Emergency procedures
- Risk minimisation
- Training

Fire and
Life Safety
Built Structure
and
Systems
including Community
and Utility Services

Emergency drills
Maintenance
Familiarity
Organisation
structure

Egress/Circulation
Compartmentation
Suppression systems
Detection systems
Alarm systems

Occupant
Behavioural
Systems

Figure 5 Essential Elements of Fire Safety - Taken From Feasibility of Using Lifts for Emergency Egress Lincolne Scott, 2000

29

W. Bretherton, Everybody out Emergency Evacuation for Persons with a Disability (2003), p.144.

44

OPPORTUNITIES FOR INVOLVEMENT

OPPORTUNITIES FOR INVOLVEMENT


The ABCB intends to undertake public consultation through three stages of the
proposals development.
Stage One: This Report
Feedback may be submitted in response to this report. This will assist in informing
and refining the proposals as they progress to formal impact analysis.
Stage Two: Regulation Impact Statement
The ABCB applies COAG Best Practice Regulation Guidelines in the consideration
of regulatory proposals. Public consultation will also be invited during the
development of a Regulation Impact Statement which will be a key element in the
examination of the costs and benefits of the proposals.
Stage Three: NCC Public Comment Draft
The ABCBs amendment process also seeks feedback from practitioners and
industry on a draft of the following years edition of the NCC through a public
comment period.

Timeframes for Amendments


An indicative timeline for consultation and consideration of amendments is included
below
Late 2013:

Release of Directions Report for public consultation (8 weeks)

Early 2014:

Release of Consultation RIS for public comment (6 weeks)

Mid

Release of public comment draft of BCA 2015 (8 weeks)

2014:

Late 2014:

Development of Final RIS

May

Adoption by States and Territories of BCA 2015

2015:

How You Can Make Comments


The Directions Report discusses a number of Regulatory Proposals for
consideration in NCC 2015, and in future amendments. These are intended to
improve the existing BCA requirements to ensure safe, equitable and dignified
egress is available for all occupants in an emergency. While general comments are
welcome, please also consider how your feedback might inform the questions set
out in the Directions Report Response Form.
45

APPENDIX A BCA 2013 CLASSIFICATIONS


A3.1 Principles of classification
The classification of a building or part of a building is determined by the purpose
for which it is designed, constructed or adapted to be used.
A3.2 Classifications
Buildings are classified as follows:
Class 1:
one or more buildings which in association constitute
(a) Class 1a a single dwelling being
(i)
a detached house; or
(ii)
one of a group of two or more attached dwellings, each being a
building, separated by a fire-resisting wall, including a row house,
terrace house, town house or villa unit; or
(b) Class 1b
(i)

(ii)

a boarding house, guest house, hostel or the like


2
(A)
with a total area of all floors not exceeding 300 m measured
over the enclosing walls of the Class 1b; and
(B)
in which not more than 12 persons would ordinarily be
resident; or
4 or more single dwellings located on one allotment and used for
short-term holiday accommodation,

which are not located above or below another dwelling or another Class of
building other than a private garage.
Class 2:

a building containing 2 or more sole-occupancy units each being a


separate dwelling.

Class 3:

a residential building, other than a building of Class 1 or 2, which is


a common place of long term or transient living for a number of
unrelated persons, including

(a)
(b)
(c)
(d)
(e)
(f)

a boarding house, guest house, hostel, lodging house or backpackers


accommodation; or
a residential part of a hotel or motel; or
a residential part of a school; or
accommodation for the aged, children or people with disabilities; or
a residential part of a health-care building which accommodates members
of staff; or
a residential part of a detention centre.

Class 4:

a dwelling in a building that is Class 5, 6, 7, 8 or 9 if it is the only


dwelling in the building.

Class 5:

an office building used for professional or commercial purposes,


excluding buildings of Class 6, 7, 8 or 9.

Class 6:

a shop or other building for the sale of goods by retail or the supply
of services direct to the public, including

46

(a)
(b)
(c)
(d)

an eating room, caf, restaurant, milk or soft-drink bar; or


a dining room, bar area that is not an assembly building, shop or kiosk
part of a hotel or motel; or
a hairdressers or barbers shop, public laundry, or undertakers
establishment; or
market or sale room, showroom, or service station.

Class 7:

a building which is

(a) Class 7a a carpark; or


(b) Class 7b for storage, or display of goods or produce for sale by wholesale.
Class 8:

a laboratory, or a building in which a handicraft or process for the


production, assembling, altering, repairing, packing, finishing, or
cleaning of goods or produce is carried on for trade, sale, or gain.

Class 9:

a building of a public nature

(a) Class 9a a health-care building, including those parts of the building set
aside as a laboratory; or
(b) Class 9b an assembly building, including a trade workshop, laboratory or
the like in a primary or secondary school, but excluding any
other parts of the building that are of another Class; or
(c) Class 9c an aged care building.
Class 10:

a non-habitable building or structure

(a) Class 10a a non-habitable building being a private garage, carport, shed,
or the like; or
(b) Class 10b a structure being a fence, mast, antenna, retaining or freestanding wall, swimming pool, or the like; or
(c) Class 10c a private bushfire shelter

47

APPENDIX B BUILDING EVACUATION


Obligations for building evacuation management are contained in model Work
Health and Safety Regulations (2011) produced by Safe Work Australia and
adopted as similar instruments in each State and Territory. These contain the
duty to prepare and maintain an emergency plan in a workplace. This is the
legislative basis for Persons Conducting a Business or Undertaking to establish
procedures for an effective response to an emergency, medical treatment and
assistance, and communication between the responsible workplace
representatives and all persons at the workplace.

Strategies
An evacuation strategy to manage the evacuation of building occupants is a
critical component of an overarching emergency management plan to meet the
above obligations. Such strategies are integral in the effective management of
buildings during emergencies, and as such are developed specifically for the
particular characteristics of the building, the types of emergency, the fire safety
systems installed in the building, and reflect the level of coordination involvement
of trained personnel such as fire wardens. The various strategies are discussed
briefly below.
Personal Emergency Evacuation Plans
Personal Emergency Evacuation Plans (PEEPs) and to some extent the
assistance of trained personnel or other occupants in an emergency, are borne
from a practical recognition that building occupant warning systems and egress
routes may prevent people with hearing, vision or mobility impairment evacuating
independently.
PEEPs are recognised as a necessary and effective measure to assist people
with a disability respond to an emergency. PEEPs are highly individual and
designed to cater to the needs person and the specific characteristics of the
building. Australian Standard AS 3745: 2010 Planning for Emergencies in
Facilities suggests the development of PEEPs be considered during the
development of emergency procedures, in consultation with occupants with
disability from the facility.
Full or Staged (Phased)
Australian Standard AS 3745: 2010 Planning for Emergencies in Facilities
advises that full evacuation would normally be carried out in response to a
potentially catastrophic, life threatening situation or where the building cannot
function due to a severe services malfunction. As implied by this description, this
would involve simultaneous or phased evacuation of all building occupants
typically utilising fire-isolated stairways.
48

In large buildings, full evacuation would be phased or staged to avoid delaying


those occupants most under threat should all floors be simultaneously
evacuated. The floor of fire origin, the floor immediately above and immediately
below are generally given priority.
Partial Evacuation
A localised emergency may result in the need for a partial evacuation to take
place via fire-isolated exits. This strategy may be the preferred option for a tall
office building, due to the fire separation afforded by floors of fire compartments
in different storeys and the large number of occupants they potentially
accommodate.
Horizontal Evacuation (exits)
This type of evacuation utilises exits leading to safe places afforded by fire
resisting construction such as fire walls and fire doors. The degree that this
strategy is adopted will depend on a number of building specific factors. For
example, it is recognised that in a health-care building occupants may be nonambulatory and unable to evacuate without assistance from staff and a high level
of fire compartmentation between adjoining areas is required. In these buildings
horizontal evacuation is suited to the needs of the occupants, and supported by
trained staff. Shopping malls provide similar flexibility. However, a typical multistorey office building design does not require this level of compartmentation
often being constructed in open-plan (without walls), nor is constant dedicated
assistance available to alert and assist in evacuation.
Protect in Place
AS 3745: 2010 notes the importance of this measure as a means of protecting
occupants from risks external to the building to which evacuated people would
otherwise be exposed. As this strategy requires occupants remaining in place it
poses no inequity to people with a mobility disability. However, as occupants with
hearing impairments may be unaware of the existence of a greater remote
emergency, notification and intercommunication systems used in an emergency
currently require supplementing by trained assistance. Similarly, if the
emergency affected the path of travel used to enter a building, a person with
vision impairment may be unable to locate an alternative safe path without
assistance.

49

APPENDIX C D3 BUILDING ACCESS REQUIREMENTS


D3.0
(a)

Deemed-to-Satisfy Provisions
Where a Building Solution is proposed to comply with the Deemed-to-Satisfy Provisions,
Performance Requirements DP1 to DP6, DP8 and DP9 are satisfied by complying with
(i)

D1.1 to D1.16, D2.1 to D2.24 and D3.1 to D3.12; and

(ii)

in a building containing an atrium, Part G3; and (iii)


for theatres, stages and public halls, Part H1; and

(iv)
(b)

for public transport buildings, Part H2.

Where a Building Solution is proposed as an Alternative Solution to the Deemed-toSatisfy Provisions of


(i)

D1.1 to D1.16, D2.1 to D2.24 and D3.1 to D3.12; and

(ii)

in a building containing an atrium, Part G3; and (iii)

(iii)

for theatres, stages and public halls, Part H1; and

(iv)

for public transport buildings, Part H2,

the relevant Performance Requirements must be determined in accordance with A0.10.

D3.1

General building access requirements

Buildings and parts of buildings must be accessible as required by Table D3.1, unless
exempted by D3.4.
Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY
Class of building

Access requirements

Class 1b
(a) Dwellings located on one allotment(1) and used
for short-term holiday accommodation,
consisting of
(i)

50

4 to 10 dwellings

To and within
1 dwelling

(ii) 11 to 40 dwellings

2 dwellings

(iii) 41 to 60 dwellings

3 dwellings

(iv) 61 to 80 dwellings

4 dwellings

(v) 81 to 100 dwellings

5 dwellings

(vi) more than 100 dwellings

5 dwellings plus 1 additional dwelling for


each additional 30 dwellings or part thereof
in excess of 100 dwellings.

Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY continued

Class of building

Access requirements

(b) A boarding house, bed and breakfast, guest


house, hostel or the like, other than those
described in (a)

To and within
1 bedroom and associated sanitary
facilities; and
not less than 1 of each type of room or
space for use in common by the residents
or guests, including a cooking facility,
sauna, gymnasium, swimming pool,
laundry, games room, eating area, or the
like; and

rooms or spaces for use in common by all


residents on a floor to which access by
way of a ramp complying with AS 1428.1
or a passenger lift is provided.
(1)
A community or strata-type subdivision or development is considered to be on a single
allotment.
Class 2
Common areas

From a pedestrian entrance required to be


accessible to at least 1 floor containing
sole-occupancy units and to the entrance
doorway of each sole-occupancy unit
located on that level.
To and within not less than 1 of each type
of room or space for use in common by
the residents, including a cooking facility,
sauna, gymnasium, swimming pool,
common laundry, games room, individual
shop, eating area, or the like.
Where a ramp complying with AS 1428.1
or a passenger lift is installed
(a)

to the entrance doorway of each


sole-occupancy unit; and

(b)

to and within rooms or spaces for


use in common by the residents,

located on the levels served by the lift or


ramp.

51

Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY continued

Class of building

Access requirements

Class 3
Common areas

From a pedestrian entrance required to be


accessible to at least 1 floor containing soleoccupancy units and to the entrance doorway of
each sole-occupancy unit located on that level.
To and within not less than 1 of each type of
room or space for use in common by the
residents, including a cooking facility, sauna,
gymnasium, swimming pool, common laundry,
games room, TV room, individual shop, dining
room, public viewing area, ticket purchasing
service, lunch room, lounge room, or the like.
Where a ramp complying with AS 1428.1 or a
passenger lift is installed
(a)

to the entrance doorway of each


sole-occupancy unit; and

(b)
to and within rooms or spaces for
use in common by the residents,
located on the levels served by the lift or
ramp.

Sole-occupancy units

Not more than 2 required accessible soleoccupancy units may be located adjacent to
each other.
Where more than 2 accessible soleoccupancy units are required, they must be
representative of the range of rooms
available.

52

Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY continued

Class of building

Access requirements

If the building or group of buildings contain

To and within

1 to 10 sole-occupancy units

1 accessible sole-occupancy unit.

11 to 40 sole-occupancy units

2 accessible sole-occupancy units.

41 to 60 sole-occupancy units

3 accessible sole-occupancy units.

61 to 80 sole-occupancy units

4 accessible sole-occupancy units.

81 to 100 sole-occupancy units

5 accessible sole-occupancy units.

101 to 200 sole-occupancy units

5 accessible sole-occupancy units plus 1


additional accessible sole-occupancy unit
for every 25 units or part thereof in excess
of 100.

201 to 500 sole-occupancy units

9 accessible sole-occupancy units plus 1


additional accessible sole-occupancy unit
for every 30 units or part thereof in excess
of 200.

more than 500 sole-occupancy units

19 accessible sole-occupancy units plus 1


additional accessible sole-occupancy unit
for every 50 units or part thereof in excess
of 500.

Class 5

To and within all areas normally used by


the occupants.

Class 6

To and within all areas normally used by


the occupants.

Class 7a

To and within any level containing


accessible carparking spaces.

Class 7b

To and within all areas normally used by


the occupants.

Class 8

To and within all areas normally used by


the occupants.

Class 9a

To and within all areas normally used by


the occupants.

Class 9b
Schools and early childhood centres

To and within all areas normally used by the


occupants.

An assembly building not being a school or an


early childhood centre

To wheelchair seating spaces provided in


accordance with D3.9.
To and within all other areas normally
used by the occupants, except that
access need not be provided to tiers or
platforms of seating areas that do not
contain wheelchair seating spaces.

53

Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY continued

Class of building

Access requirements

Class 9c
Common areas

From a pedestrian entrance required to be


accessible to at least 1 floor containing soleoccupancy units and to the entrance
doorway of each sole-occupancy unit
located on that level.
To and within not less than 1 of each type
of room or space for use in common by
the residents, including a cooking facility,
sauna, gymnasium, swimming pool,
common laundry, games room, TV room,
individual shop, dining room, public
viewing area, ticket purchasing service,
lunch room, lounge room, or the like.
Where a ramp complying with AS 1428.1
or a passenger lift is installed
(a)

to the entrance doorway of each


sole-occupancy unit; and

(b)

to and within rooms or spaces for


use in common by the residents,

located on the levels served by the lift or


ramp.
Sole-occupancy units

Where more than 2 accessible soleoccupancy units are required, they must
be representative of the range of rooms
available.

If the building or group of buildings contain

To and within

1 to 10 sole-occupancy units

1 accessible sole-occupancy unit.

11 to 40 sole-occupancy units

2 accessible sole-occupancy units.

41 to 60 sole-occupancy units

3 accessible sole-occupancy units.

61 to 80 sole-occupancy units

4 accessible sole-occupancy units.

81 to 100 sole-occupancy units

5 accessible sole-occupancy units.

101 to 200 sole-occupancy units

5 accessible sole-occupancy units plus 1


additional sole-occupancy unit for every
25 units or part thereof in excess of 100.

201 to 500 sole-occupancy units

9 accessible sole-occupancy units plus 1


additional sole-occupancy unit for every
30 units or part thereof in excess of 200.

more than 500 sole-occupancy units

19 accessible sole-occupancy units plus 1


additional sole-occupancy unit for every
50 units or part thereof in excess of 500.

54

Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY continued

Class of building

Access requirements

Class 10a
Non-habitable building located in an accessible
area intended for use by the public and containing
a sanitary facility, change room facility or shelter

Class 10b
Swimming pool

55

To and into swimming pools with a total


perimeter greater than 40 m, associated with
a Class 1b, 2, 3, 5, 6, 7, 8 or 9 building that
is required to be accessible, but not
swimming pools for the exclusive use of
occupants of a Class 1b building or a soleoccupancy unit in a Class 2 or Class
To and within
(a)

An accessible sanitary facility; and

(b)

a change room facility; and

(c)

a public shelter or the like