National Headquarters
Level 12
80 The Terrace
PO Box 2133
Wellington
New Zealand
s 9(2)(a)
10/09/2018
Ginny Carter
Administrator, Determinations
Ministry of Business, Innovation and Employment
PO Box 1473
WELLINGTON 6140
By email: [email address]
Copies to:
Malcolm Gray
The Building Manager
Forbes and Davies Limited
Selwyn District Council
s 9(2)(a)
PO Box 90
ROLLESTON 7643
By email: [email address]
By email: [email address]
Dear Ginny
Draft determination 3023
Regarding the compliance of a warehouse fitout, comprising storage racking and a mezzanine
floor, with the fire safety requirements of the building code at 49 Stoneleigh Drive, Rolleston
Thank you for providing Fire and Emergency New Zealand (
Fire and Emergency) with the
opportunity to review and comment on draft determination 3023.
Fire and Emergency accepts the draft determination. A copy of the formal response form is
attached accordingly. I note that the current heading to the draft determination refers to the site
address as ’49 Rolleston Drive’, which appears to be a typographic error.
Please contact me if you require any further information from Fire and Emergency in relation to
this matter. I can be reached on 04 462 4947 or [email address].
Yours sincerely,
Ashley Cornor
Senior Counsel
Stephen Lambert
NZFS Engineering Unit
National Headquarters
PO Box 2133
Wellington 6140
New Zealand
[email address]
s 9(2)(a)
Carol Caldwell
Enlightened Solutions
PO Box 8709
Christchurch 8440
19 May 2017
Dear Carol,
Re:
New Platform in Existing Warehouse, 49 Stoneleigh Drive, Rolleston
(NZFS Reference: 9571 - Rev 03)
Thank you for the additional information concerning the above project. The NZFS understands that
the project involves the construction of a new storage platform (33.5m by 13.5m at a height of 2.4m
in an existing building of area 958m2: this represents 50.2% of the warehouse area and 47.2% of the
total building’s footprint. The platform is to be access via two stairways.
The occupant load is proposed to be 20 in the warehouse/office areas and an additional 1 person in
the sleeping firecell.
A Type 4 (automatic smoke detection) system is proposed for the bulk of the building with Type 5
coverage in the sleeping firecell.
The NZFS understands that the platform is a recently-constructed but unconsented feature. The
BCA has indicated that the building’s owner has approached the Council for retrospective consent
and has taken interim measures to mitigate life risk in the building. The BCA has provide information
concerning the project and is content with the progress of the project.
The NZFS notes that local Fire Risk Management involvement has been sought and advice obtained.
The comments in this memo take into account that advice.
In the context of the indicated application for a Certificate of Acceptance, the NZFS understands that
the ‘as nearly as reasonably practicable’ (ANARP) avenue is not available to the applicant.
The FEB neither states the height of the building nor indicates the storage height in the 450m2 outside
the perimeter of the intermediate floor.
The FEB report proposes to use a fully performance-based design approach to demonstrate that the
fire design for the building will meet the performance requirements of the NZ Building Code. This
letter outlines the NZFS position as a stakeholder in the building design process.
Referenced Information
Item
Title
Date
Revision
Email from Carol Caldwell with attached
162030
minutes concerning site meeting held on
09 May 2017
n/a
01 May 2017
NZFS’s response to additional
9571
29 Nov 2016
02
information
FEB – New Platform in Existing
162030
Warehouse at 49 Stoneleigh Drive,
8 Nov 2016
1
Rolleston
Meme from Apeksha Shah to Stephen
162030
08 Nov 2016
n/a
Lambert providing additional information
9571
NZFS’s response to FEB
31 Oct 2016
01
FEB – New Platform in Existing
162030
Warehouse at 49 Stoneleigh Drive,
10 Oct 2016
0
Rolleston
As discussed, the NZFS has reviewed the FEB documentation identified above and offers the
following comments.
The following items are considered to relate to compliance with the requirements of the Building
Code:
With reference to the NZFS’s previous letter concerning the project (Response 02, dated 29 Nov
2016), the Service considers that the issues indicated in items 1 to 4 of that letter have been
addressed at the site meeting and, therefore, are not addressed further in this letter
5.
Period of Structural Adequacy Calculations - The NZFS has reviewed the calculations
provided for the period of structural adequacy (PSA) for the unprotected steel supporting
the intermediate floor, and offers the following comments:
a. The PSA calculations have employed the limiting temperature correlation and have
assumed equivalent standard fire exposure for reaching this limiting temperature. The
NZFS notes the following:
i.
The loading schematic does not appear to reflect the photographs taken on site,
and the number of storage levels contributing to the axial load on the columns.
Of particular note are the stated sizes of the columns compared to the exposed
perimeter. Also it is not clear the perforations in the columns have been fully
accounted for in the calculations. In addition, on-site observation indicated that
some columns were note of a closed section. These details would benefit from
the provision of further information
ii.
The beams supporting the floor have not been assessed for their period of
structural adequacy. Given the relatively long span and potentially more critical
three-sided exposure, the NZFS considers that the failure of beams should be
assessed.
iii.
The limiting temperature calculated (887°C) is higher than the upper bound of
850°C specified in Section 11.6 of NZS 3404. This alone would reduce the PSA
to approximately 19 minutes.
b. In addition, calculations have been performed in a spreadsheet and calculations to
support some individual inputs are not supplied. Areas of uncertainty include, but are
not limited to:
i.
Derivation of the tributary area including the intermediate floor
ii.
The derivation of buckling stresses and critical stresses.
iii.
Use of the calculated effective widths in later calculations.
iv.
The calculation of the weight of the wood floor assembly.
v.
Information relating to the 400 kg storage load per level.
vi.
Assumptions relating to the mechanical properties of steel.
Given the issues and perceived lack of clarity concerning the issues above, the NZFS is
unable to place confidence in the proposed calculations.
6. Operational Response – Given that the intermediate floor is intended to support an imposed
load above floor level, the NZFS considers this to be a “structural system”.
Clause C5.6 of the Building Code indicates that the purpose of the fire protection of
intermediate floors and their means of access to is to allow firefighters to reach the scene of
a fire (whether on or beneath and intermediate floor) to conduct fire-fighting and search
operations and, if necessary, to withdraw to a place beyond the extent of the intermediate
floor prior to the floor’s structure support and access being compromised by fire.
The proposal suggests that no applied fire protection is required because the structure
inherently provides 20 minutes’ fire resistance. The NZFS observes that this implies that the
structure will be directly affected from the onset of the fire and, therefore, that the period of
fire resistance is taken to be the time between ignition and the period when the intermediate
floor is subject to structural failure.
As indicated in previous letters, the decision to enter a building to conduct firefighting or
rescue operations is a decision made by the Incident Commander at the time of the fire.
Clause C5.6 of the Code requires buildings to be designed and constructed with regard to
the safety of firefighters and does not make this provision contingent on the probability of
firefighters entering the building.
Clause C5.6 also makes the consideration of “the firefighters’ personal protective equipment
and standard training” a requirement of the design. The NZFS considers this to be relevant
to the resources available and the attendance times of those resources. Fire Service training
indicates that entry into the building would not be made until, at the very least, the crews of
two appliances are available on site. The Service has made initial investigations of responses
to incidents in the area: the initial results suggest a response time that would encompass
approximately 90% of the incidents to be approximately 800 seconds from being alerted. It
should be noted that this period is not the same as 800 seconds from ignition of the fire. The
complete results will be made available to the stakeholders once they have been compiled
and collated.
A further period is required to brief the crews and set up the safety system for the Breathing
Apparatus wearers who are to enter the building. The advice of the NZFS’s operational
officer consulted on this issue was that “3-5 minutes” would be required for the BA crew to
be formed and briefed and to reach the outer wall of the building. Taking the longer period,
this gives a cumulative time of over 18 minutes.
The following factors must then be added to the response time:
a. The alarm system’s detection period;
b. The notification time and/or time for the call to be made to the Fire Service;
c. The time for the Breathing Apparatus wearers to enter the building and locate the seat
of the fire and/or search the intermediate floor.
This is likely to bring the total time to significantly greater than 20 minutes. The NZFS
observes that both the Acceptable Solutions and C/VM2 require fire rating of intermediate
floors of at least 30 minutes’ duration.
To avoid unnecessary iterations of the FEB process the NZFS welcomes discussion on any of the
above items, however the NZFS recommends that the FEB be revised to address the items identified
above as well as any additional items identified by other stakeholders. The NZFS also observes that
the issues may be more quickly addressed by an on-site meeting.
Our review of the information provided has focused on the performance-based design elements
identified and is intended to provide guidance to reduce the consent risks associated with
undertaking performance-based design. No assessment against the requirements of the acceptable
solutions has been undertaken. Also please note that this advice does not imply a technical
verification of the information provided.
If you have any queries or questions related to the above please do not hesitate to contact either of
the signatories below
.
Sincerely,
Stephen Lambert
&
Jeremy Gall
Fire Engineering Unit
cc:
Jenny Lilley, Selwyn District Council
[email address]
Jonathan Nyman, Fire Review Solutions
[email address]
Malcom Gray
[email address]
Mike Gaskin, NZFS
[email address]
Fire Engineering Unit, NZFS
[email address]
Our Ref: 162030
6 April 2017
Selwyn District Council
P O Box 90
Rolleston 7643
Attn: Jenny Lilley
Dear Jenny,
RE: 49 Stoneleigh Drive, Rolleston - NZFS Reference: 9571 – Rev 02
Thank you for your email on 14 March requesting to address the NZFS second response
comments on FEB of dated 29 November 2016.
We are very disappointed that NZFS has added new comments in second response than the
first response comments of dated 31 Oct 2016. It is a huge time delay and expense to our
client and it has caused frustration to him about the NZFS FEB response system.
We already discussed the proposed approach to BCA, BCA peer reviewer and NZFS operation
officer beforehand. The alternative solution is to demonstrate the means of escape from the
existing platform under S 112 of the building code. The building is significantly upgraded
with Type 4 system which will give early warning to occupants compare to existing Type 3
system.
We are expecting the BCA to take proactive approach and resolve the issues to help client.
Please find appended below our replies to the queries relating to …
1.
Use of C/VM2 – Your response is noted. Notwithstanding the BCA’s reported agreement
to the approach, the NZFS observes that, while the building may be consented, the over-
sized intermediate floor is subject to a Certificate of Acceptance: as previously stated,
this does not allow for any ANARP consideration.
Given that the approach taken is indicated to be an alternative solution, the selective use
of C/VM2, is not considered to be appropriate given the context of the MBIE guidance
that states, “The Verification Method C/VM2 method is a complete design system with
interrelated inputs and design parameters that result in an acceptable level of risk,”
and, “Should a designer wish to vary the design inputs other than listed in C/VM2…..al
design inputs must be justified” (MBIE “Verification Method C/VM2 interpretations”
2.6). The NZFS therefore considers that reliance on a partial application of the
methodology may not result in a proposal that achieves the level of safety indicated by
the compliance documents.
Enlightened Solutions Ltd, PO Box 8709, Christchurch, 8440, New Zealand
s 9(2)(a)
Email:[email address]
www.enlightenedsolutions.co.nz
6 Apr 17
DRU Reply – 49 Stoneleigh Drive
2 of 4
Please amend the documentation to either justify all inputs used in the proposal or comply
in full with the requirements of C/VM2.
Reply: The provided alternative solution approach in FEB was discussed and
agreed by Council, Council peer reviewer and NZFS operation engineer. The
existing warehouse is recently consented so not worth to check the full
compliance with the C/VM2.
2.
Argument regarding Size of Intermediate Floor – The argument concerning the size of the
intermediate floor is not considered to address the intention of the provision. The NZFS
observes that the 35m2 value allows for a limited balcony plume and therefore, a
reasonable level of air entrainment: this may result in a small increase in the level of
smoke production but not one that exceeds the safety margins implied by conservativism
of the other factors.
The proposal involves the 450m2 platform, with none of the side located against a side
wall. This results in a potential for over 88m of balcony edge around a fire beneath the
intermediate floor. The result may be a very significant increase in the volume of smoke
and a commensurately shorter time until the visibility criterion is breached.
The FEB does not address the height of the warehouse; therefore, an assessment of the
potential for smoke production against the available smoke volume cannot be made. In
this respect, the NZFS notes that the FEB proposes ventilation to the under-floor area is
limited to the aisles.
This implies that there are walls surrounding the space beneath the intermediate floor
and that these walls are effectively smoke separations. Unless this is the case, the
potential for leakage and, therefore, smoke production may be greatly understated.
Please demonstrate that the assumptions made with regard to ventilation of the fire and
smoke production are justified.
Reply: We don’t think that the limitation of the 35m2 area in C/ASx is related to a
limited balcony plume and air entrainment concern. The 35m2 value was in the
old Acceptable Solutions C/AS1. Certainly, the intent of the 35m2 would need to
be confirmed with MBIE.
In the FEB, the 35m2 approach from C/AS5 is used only for the equivalency for
travel distance. The challenging fire is proposed to get the activation time of
proposed smoke detector and egress time for occupants. The occupant load on
the platform is very low in comparison of large volume of warehouse space.
Therefore, the above comment #2 is considered to be irrelevant.
3.
RSET – The RSET is not proposed to be assessed against a calculated ASET; rather, it is
compared to the travel distance requirements of the Acceptable Solutions. However, the
equivalence of all other aspects of the Acceptable Solutions is not addressed.
While the NZFS acknowledges that an escape distance can be inferred from a calculated
escape time, the distances cited in the Acceptable Solutions rely on a number of other
aspects that contribute to the implicit level of safety: one of these is the size of the
intermediate floor. The NZFS observes that the intermediate floor exceeds the area
allowed for a Type 4 alarm system in the Acceptable Solutions. The NZFS therefore
Enlightened Solutions Ltd PO Box 8709 Christchurch 8440
[email address]
s 9(2)(a)
G:\CAC Projects 16\162030 49 Stoneleigh Drive, Izone\Rep Corr 2017\162030 ES DRU Reply Lttr 6Apr17.doc
CopyrightEnlightened Solutions Ltd 2017
6 Apr 17
DRU Reply – 49 Stoneleigh Drive
3 of 4
considers this approach to be an incomplete assessment.
The NZFS observes that the uncertainty regarding the validity of the ASET/RSET
relationship can be readily resolved by modelling the conditions.
Please revise the FEB to include consideration of the ASET/RSET relationship.
Reply: This is a new comment compared to previous FEB comments from NZFS.
This comment is considered to be irrelevant to our proposed approach of FEB
which is approved by BCA.
4.
Use of B-Risk for ASET Assessment – The NZFS observes that, unless the conditions
indicated in Figure 1 of the FEB can be confirmed to be valid, there is potential for
significant areas of overlapping smoke flows from beneath the intermediate floor. This will
complicate the assessment of smoke production and, therefore, the assessment of the
ASET.
If an ASET/RSET relationship is to be determined, please indicate how B-Risk will be
configured to assess these interacting smoke plumes.
Reply: This is a new comment compared to previous FEB comments from NZFS.
This comment is considered to be irrelevant to our proposed approach of FEB
which is approved by BCA.
5.
Fire-rating of Intermediate Floor – The FEB seeks to argue that the intermediate floor is
an existing feature and, therefore, can be assessed on an ANARP basis. The NZFS
observes that the application for a Certificate of Acceptance does not allow for
application of ANARP considerations. While the NZFS acknowledges that the BCA
may nevertheless grant Consent, the Service is obliged to offer its comments on the
proposal irrespective of any pre- determined agreement or limitations. In this case, the
NZFS considers that the intermediate floor should be considered as new work.
Furthermore, the FEB notes the opinion of the Fire Risk Management Officer that
all occupants would be able to evacuate the building and that internal fire-fighting
operations would be unlikely to occur if there is no life risk.
The NZFS observes that fire-fighting operations involve dynamic risk assessment and
that, in the circumstances described, internal fire-fighting may not take place. However,
that is a decision to be taken at the time of the incident. By not providing the protection
required by the Building Code, the outcome of the dynamic risk assessment is effectively
pre-determined and, therefore, if circumstances mean that occupants have not
evacuated, fire-fighters may be placed at significant additional hazard that would have
been addressed had the requirements of the Building Code been applied.
The NZFS therefore considers that the argument regarding whether or not fire
operations are conducted not to be relevant to the provisions required by the Building
Code.
Enlightened Solutions Ltd PO Box 8709 Christchurch 8440
[email address]
s 9(2)(a)
G:\CAC Projects 16\162030 49 Stoneleigh Drive, Izone\Rep Corr 2017\162030 ES DRU Reply Lttr 6Apr17.doc
CopyrightEnlightened Solutions Ltd 2017
6 Apr 17
DRU Reply – 49 Stoneleigh Drive
4 of 4
Please indicate how this issue is to be addressed.
Reply: We have addressed all the relevant clauses of firefighting operations in our
revised FEB rev 1 and first response to NZFS. We don’t agree with NZFS
comments. The approach put forward in the FEB is in line with the support from
Canterbury NZFS.
6.
Disapplication of ‘C’ Clauses – Section 10 of the FEB includes several comments stating
that, “This clause is not applicable for this building under S.112”.
The NZFS observes that new works must comply in full with the Building code and
that existing conditions should not be worsened by the new works. By seeking to
disregard several aspects of the Clauses without analysis, the FEB proposes that the
Consent stage documentation will not demonstrate non-worsening. The NZFS
considers that this is not appropriate given the conditions within the building have been
changed by the un-Consented addition of a non-compliant intermediate floor.
Please indicate whether the non-worsening of existed conditions is proposed to be
demonstrated.
Reply: The provided FEB adequately addresses the fire requirements and there is
no ‘worsening’ of the existing fire features in the building. There is in fact an
improvement as the existing Type 3 system is proposed to be changed to a Type 4
system.
Please contact me should you have any queries regarding this.
Yours faithfully,
Enlightened Solutions Ltd
Apeksha Shah
BE (Civil), MEFE
GIPENZ (Fire)
Enlightened Solutions Ltd PO Box 8709 Christchurch 8440
[email address]
s 9(2)(a)
G:\CAC Projects 16\162030 49 Stoneleigh Drive, Izone\Rep Corr 2017\162030 ES DRU Reply Lttr 6Apr17.doc
CopyrightEnlightened Solutions Ltd 2017
Stephen Lambert
NZFS Engineering Unit
National Headquarters
PO Box 2133
Wellington 6140
New Zealand
[email address]
s 9(2)(a)
Apeksha Shah
Enlightened Solutions
PO Box 8709
Christchurch 8440
29 November 2016
Dear Apeksha,
Re:
New Platform in Existing Warehouse, 49 Stoneleigh Drive, Rolleston
(NZFS Reference: 9571 - Rev 02)
Thank you for the additional information concerning the above project. The NZFS understands that
the project involves the construction of a new storage platform (33.5m by 13.5m at a height of 2.4m
in an existing building of area 958m2: this represents 50.2% of the warehouse area and 47.2% of the
total building’s footprint. The platform is to be access via two stairways.
The occupant load is proposed to be 20 in the warehouse/office areas and an additional 1 person in
the sleeping firecell.
A Type 4 (automatic smoke detection) system is proposed for the bulk of the building with Type 5
coverage in the sleeping firecell.
The NZFS understands that the platform is a recently-constructed but unconsented feature. The
BCA has indicated that the building’s owner has approached the Council for retrospective consent
and has taken interim measures to mitigate life risk in the building. The BCA has provide information
concerning the project and is content with the progress of the project.
The NZFS notes that local Fire Risk Management involvement has been sought and advice obtained.
The comments in this memo take into account that advice.
In the context of the indicated application for a Certificate of Acceptance, the NZFS understands that
the ‘as nearly as reasonably practicable’ (ANARP) avenue is not available to the applicant.
The FEB neither states the height of the building nor indicates the storage height in the 450m2 outside
the perimeter of the intermediate floor.
The FEB report proposes to use a fully performance-based design approach to demonstrate that the
fire design for the building will meet the performance requirements of the NZ Building Code. This
letter outlines the NZFS position as a stakeholder in the building design process.
Referenced Information
Item
Title
Date
Revision
FEB – New Platform in Existing
162030
Warehouse at 49 Stoneleigh Drive,
8 Nov 2016
1
Rolleston
Meme from Apeksha Shah to Stephen
162030
08 Nov 2016
n/a
Lambert providing additional information
9571
NZFS’s response to FEB
31 Oct 2016
01
FEB – New Platform in Existing
162030
Warehouse at 49 Stoneleigh Drive,
10 Oct 2016
0
Rolleston
As discussed, the NZFS has reviewed the FEB documentation identified above and offers the
following comments.
The following items are considered to relate to compliance with the requirements of the Building
Code:
1. Use of C/VM2 – Your response is noted. Notwithstanding the BCA’s reported agreement to
the approach, the NZFS observes that, while the building may be consented, the over-sized
intermediate floor is subject to a Certificate of Acceptance: as previously stated, this does
not allow for any ANARP consideration.
Given that the approach taken is indicated to be an alternative solution, the selective use of
C/VM2, is not considered to be appropriate given the context of the MBIE guidance that
states, “The Verification Method C/VM2 method is a complete design system with interrelated
inputs and design parameters that result in an acceptable level of risk,” and, “Should a
designer wish to vary the design inputs other than listed in C/VM2…..all design inputs must
be justified” (MBIE “Verification Method C/VM2 interpretations” 2.6). The NZFS therefore
considers that reliance on a partial application of the methodology may not result in a
proposal that achieves the level of safety indicated by the compliance documents.
Please amend the documentation to either justify all inputs used in the proposal or comply in
full with the requirements of C/VM2.
2. Argument regarding Size of Intermediate Floor – The argument concerning the size of the
intermediate floor is not considered to address the intention of the provision. The NZFS
observes that the 35m2 value allows for a limited balcony plume and therefore, a reasonable
level of air entrainment: this may result in a small increase in the level of smoke production
but not one that exceeds the safety margins implied by conservativism of the other factors.
The proposal involves the 450m2 platform, with none of the side located against a side wall.
This results in a potential for over 88m of balcony edge around a fire beneath the intermediate
floor. The result may be a very significant increase in the volume of smoke and a
commensurately shorter time until the visibility criterion is breached. The FEB does not
address the height of the warehouse; therefore, an assessment of the potential for smoke
production against the available smoke volume cannot be made. In this respect, the NZFS
notes that the FEB proposes ventilation to the under-floor area is limited to the aisles.
This implies that there are walls surrounding the space beneath the intermediate floor and
that these walls are effectively smoke separations. Unless this is the case, the potential for
leakage and, therefore, smoke production may be greatly understated.
Please demonstrate that the assumptions made with regard to ventilation of the fire and
smoke production are justified.
3. RSET – The RSET is not proposed to be assessed against a calculated ASET; rather, it is
compared to the travel distance requirements of the Acceptable Solutions. However, the
equivalence of all other aspects of the Acceptable Solutions is not addressed.
While the NZFS acknowledges that an escape distance can be inferred from a calculated
escape time, the distances cited in the Acceptable Solutions rely on a number of other
aspects that contribute to the implicit level of safety: one of these is the size of the
intermediate floor. The NZFS observes that the intermediate floor exceeds the area allowed
for a Type 4 alarm system in the Acceptable Solutions. The NZFS therefore considers this
approach to be an incomplete assessment.
The NZFS observes that the uncertainty regarding the validity of the ASET/RSET relationship
can be readily resolved by modelling the conditions.
Please revise the FEB to include consideration of the ASET/RSET relationship.
4. Use of B-Risk for ASET Assessment – The NZFS observes that, unless the conditions
indicated in Figure 1 of the FEB can be confirmed to be valid, there is potential for significant
areas of overlapping smoke flows from beneath the intermediate floor. This will complicate
the assessment of smoke production and, therefore, the assessment of the ASET.
If an ASET/RSET relationship is to be determined, please indicate how B-Risk will be
configured to assess these interacting smoke plumes.
5. Fire-rating of Intermediate Floor – The FEB seeks to argue that the intermediate floor is an
existing feature and, therefore, can be assessed on an ANARP basis. The NZFS observes
that the application for a Certificate of Acceptance does not allow for application of ANARP
considerations. While the NZFS acknowledges that the BCA may nevertheless grant
Consent, the Service is obliged to offer its comments on the proposal irrespective of any pre-
determined agreement or limitations. In this case, the NZFS considers that the intermediate
floor should be considered as new work.
Furthermore, the FEB notes the opinion of the Fire Risk Management Officer that all
occupants would be able to evacuate the building and that internal fire-fighting operations
would be unlikely to occur if there is no life risk.
The NZFS observes that fire-fighting operations involve dynamic risk assessment and that,
in the circumstances described, internal fire-fighting may not take place. However, that is a
decision to be taken at the time of the incident. By not providing the protection required by
the Building Code, the outcome of the dynamic risk assessment is effectively pre-determined
and, therefore, if circumstances mean that occupants have not evacuated, fire-fighters may
be placed at significant additional hazard that would have been addressed had the
requirements of the Building Code been applied.
The NZFS therefore considers that the argument regarding whether or not fire operations
are conducted not to be relevant to the provisions required by the Building Code.
Please indicate how this issue is to be addressed.
6. Disapplication of ‘C’ Clauses – Section 10 of the FEB includes several comments stating
that, “This clause is not applicable for this building under S.112”.
The NZFS observes that new works must comply in full with the Building code and that
existing conditions should not be worsened by the new works. By seeking to disregard
several aspects of the Clauses without analysis, the FEB proposes that the Consent stage
documentation will not demonstrate non-worsening. The NZFS considers that this is not
appropriate given the conditions within the building have been changed by the un-Consented
addition of a non-compliant intermediate floor.
Please indicate whether the non-worsening of existed conditions is proposed to be
demonstrated.
To avoid unnecessary iterations of the FEB process the NZFS welcomes discussion on any of the
above items, however the NZFS recommends that the FEB be revised to address the items identified
above as well as any additional items identified by other stakeholders. The NZFS also observes that
the issues may be more quickly addressed by an on-site meeting.
Our review of the information provided has focused on the performance-based design elements
identified and is intended to provide guidance to reduce the consent risks associated with
undertaking performance-based design. No assessment against the requirements of the acceptable
solutions has been undertaken. Also please note that this advice does not imply a technical
verification of the information provided.
If you have any queries or questions related to the above please do not hesitate to contact me.
Sincerely,
Stephen Lambert
Fire Engineering Unit
cc:
Jenny Lilley, Selwyn District Council
[email address]
Jonathan Nyman, Fire Review Solutions
[email address]
Graton Holding Warehouse
TBN
Mike Gaskin, NZFS
mike [email address]
Fire Engineering Unit, NZFS
[email address]
Our Ref: 162030
8 November 2016
NZFS Engineering Unit
PO Box 2133
Wellington 6140
Attn: Stephen Lambert
Dear Stephen,
RE: 49 Stoneleigh Drive, Rolleston - NZFS Reference: 9571 – Rev 1
Please find appended below our replies to the comments dated 31 October 2016.
1. Use of C/VM2 – Sections 11.1 and 11.2 propose the use of C/VM2 parameters in both
the modelling and the ASET/RSET analysis.
The NZFS observes that both MBIE guidance and Determination 2015/058 indicate
that C/VM2 is a complete system that should be applied in its entirety. Therefore,
selective use of parameters from the methodology may undermine the safety margin
implied by its application.
While C/VM2 may be valid as a comparator to demonstrate equivalence, the proposed
approach does not identify or compensate for departures from C/VM2. The use of
elements of C/VM2 therefore does not demonstrate equivalence with C/VM2.
Where references to factors included in C/VM2 are made, please amend the FEB to
provide the justification for their use and, if applicable, the source material.
In addition, given the simplified RSET analysis permitted in C/VM2, please
demonstrate that the travel speeds applied are justified. In this respect, the NZFS
observes that C/VM2 explicitly refers to its limitations in respect of egress analysis and,
in the comments following paragraphs 3.2 and 3.2.5, refers to Section 3 of the SFPE
Handbook for further details.
Reply: The warehouse is recently consented and proposed approach was discussed and
agreed by Council and Council reviewer and NZFS operation engineer.
2. Fire-fighting Access and Facilities - Section 10.4 of the FEB proposes that
consideration is not to be given to the requirements of Clause C5 because the project
is proposed under s112 of the Building Act.
Notwithstanding this opinion, there is a record of communications between the Fire
Service’s Operational representative and the design team appended to the report. The
statement and the evidence are therefore contradictory.
The NZFS observes that the provision of the storage platform represents new works
and that s17 of the Building Act requires new works to comply in full with the Building
Code. Consequently, the operational needs and safety of firefighters should be
considered as part of this project.
Please indicate how this issue is to be addressed.
Enlightened Solutions Ltd PO Box 8709, Christchurch, 8440, New Zealand Email: [email address]
www.enlightenedsolutions.co.nz
s 9(2)(a)
8 Nov 2016
49 Stoneleigh Drive, Rolleston
2 of 3
Reply: We have included the compliance with C5 in the FEB. Please refer attached updated
FEB.
3. Sleeping Area – The FEB refers to a sleeping firecell in the building. However, this is
not apparent in the provided drawings. Please indicate where the firecell is located
and show the means of escape from this space.
Reply: Please refer attached TM Consultants - Fire Design Report in Appendix A of FEB. The
drawings at the back of the report shows fire separated sleeping room and its final
exit door.
4. Route Shown on Drawing Fire#3 – Drawing Fire#3 shows a route with an associated
distance of 63.7m. Given the presence of other doors in the plan north elevation of the
building, please clarify whether this is intended to represent a maximum open path
travel distance rather than a dead-end travel distance.
Reply: On the drawing of Fire #3, 63.7 m is the maximum open path travel distance. There
are two means of escape available from the remote corner of the warehouse.
5. DEOP Calculation – Drawing Fire#2 shows a calculation comparing the DEOP travel
distance from a hypothetical platform of area 35m2 with travel distance from the
proposed platform.
In the context of a scenario involving consideration of RSET, please clarify the
relevance of this assessment.
As indicated above, the NZFS considers equivalence to an element of a compliance
methodology is not the same as demonstrating compliance with that methodology. In
particular, given the reference is in the context of an intermediate floor that has an
area more than 11 times greater than that permitted for storage greater than 3m by
C/AS5, paragraph 4.13.7, the argument for equivalence is considered to be
significantly undermined.
Reply: The travel distance from 35m2 from a complying C/AS5 mezzanine floor and for this
mezzanine floor are same and this is relevant to the discussion building code
compliance. It demonstrates that the time on this platform and potential exposure to
a fire is the same or less exposure in this case then in the C/AS complying case.
6. Modelling – Challenging Fire – Section 11.0 of the FEB proposes that a “challenging
fire” will be modelled to determine the alarm activation time and will be limited to the
extent of the platform only. The NZFS considers that this cannot be represented as a
Challenging Fire as there is no assessment of tenability conditions in other parts of the
warehouse. Furthermore, given that explicit consideration if either ASET or RSET is
beyond the scope of the Acceptable Solutions, any reference to these factors requires
tenability to be modelled. The terms of the FEB do not suggest that this is proposed.
Consequently, the NZFS considers that the proposal neither demonstrates compliance
with a recognised Compliance Document nor demonstrates compliance with the
tenability criteria given in Clause C4.3 of the Building Code.
Please indicate how this issue is to be addressed
Reply: The warehouse is recently consented in 2015 under consent number BC150389 so it
complies with the current code requirements.
It has been agreed with Council that the new platform requires compliance with
means of escape form fire under S112 of the building code.
Enlightened Solutions Ltd PO Box 8709 Christchurch 8440
[email address]
s 9(2)(a)
G:\CAC Projects 16\162030 49 Stoneleigh Drive, Izone\Rep Corr FEB\NZFS & Cncl\162030 NZFS reply ltr 8nov16.doc
8 Nov 2016
49 Stoneleigh Drive, Rolleston
3 of 3
The fire under the platform is considered appropriate for the contents located under
the platform.
The building is to be upgraded with the Type 4 system. The design approach is
equivalency with the C/AS5 travel distance requirements, hence the Challenging Fire is
proposed only underneath the platform to check tenability of occupants on the
platform.
Please contact me should you have any queries regarding this.
Yours faithfully,
Enlightened Solutions Ltd
Apeksha Shah
BE (Civil), MEFE
GIPENZ (Fire)
Enlightened Solutions Ltd PO Box 8709 Christchurch 8440
[email address]
s 9(2)(a)
G:\CAC Projects 16\162030 49 Stoneleigh Drive, Izone\Rep Corr FEB\NZFS & Cncl\162030 NZFS reply ltr 8nov16.doc
Stephen Lambert
NZFS Engineering Unit
National Headquarters
PO Box 2133
Wellington 6140
New Zealand
[email address]
s 9(2)(a)
Apeksha Shah
Enlightened Solutions
PO Box 8709
Christchurch 8440
31 October 2016
Dear Apeksha,
Re:
New Platform in Existing Warehouse At 49 Stoneleigh Drive, Rolleston
(NZFS Reference: 9571 - Rev 01)
Thank you for the opportunity to be involved in the above project. The NZFS understands that the
project involves the construction of a new storage platform (33.5m by 13.5m at a height of 2.4m in
an existing building of area 958m2: this represents 50.2% of the warehouse area and 47.2% of the
total building’s footprint. The platform is to be access via two stairways.
The occupant load is proposed to be 20 in the warehouse/office areas and an additional 1 person in
the sleeping firecell.
A Type 4 (automatic smoke detection) system is proposed for the bulk of the building with Type 5
coverage in the sleeping firecell.
The NZFS understands that the platform is a recently-constructed but unconsented feature. The
BCA has indicated that the building’s owner has approached the Council for retrospective consent
and has taken interim measures to mitigate life risk in the building. The BCA has provide information
concerning the project and is content with the progress of the project.
The NZFS notes that local Fire Risk Management involvement has been sought and advice obtained.
The comments in this memo take into account that advice.
In the context of the indicated application for a Certificate of Acceptance, the NZFS understands that
the ‘as nearly as reasonably practicable’ (ANARP) avenue is not available to the applicant.
The FEB report proposes to use a fully performance-based design approach to demonstrate that the
fire design for the building will meet the performance requirements of the NZ Building Code. This
letter outlines the NZFS position as a stakeholder in the building design process.
Referenced Information
Item
Title
Date
Revision
FEB – New Platform in Existing
162030
Warehouse at 49 Stoneleigh Drive,
10 Oct 2016
0
Rolleston
As discussed, the NZFS has reviewed the FEB documentation identified above and offers the
following comments.
The following items are considered to relate to compliance with the requirements of the Building
Code:
1. Use of C/VM2 – Sections 11.1 and 11.2 propose the use of C/VM2 parameters in both the
modelling and the ASET/RSET analysis.
The NZFS observes that both MBIE guidance and Determination 2015/058 indicate that
C/VM2 is a complete system that should be applied in its entirety. Therefore, selective use
of parameters from the methodology may undermine the safety margin implied by its
application.
While C/VM2 may be valid as a comparator to demonstrate equivalence, the proposed
approach does not identify or compensate for departures from C/VM2. The use of elements
of C/VM2 therefore does not demonstrate equivalence with C/VM2.
Where references to factors included in C/VM2 are made, please amend the FEB to provide
the justification for their use and, if applicable, the source material.
In addition, given the simplified RSET analysis permitted in C/VM2, please demonstrate that
the travel speeds applied are justified. In this respect, the NZFS observes that C/VM2
explicitly refers to its limitations in respect of egress analysis and, in the comments following
paragraphs 3.2 and 3.2.5, refers to Section 3 of the SFPE Handbook for further details.
2. Fire-fighting Access and Facilities – Section 10.4 of the FEB proposes that consideration is
not to be given to the requirements of Clause C5 because the project is proposed under s112
of the Building Act.
Notwithstanding this opinion, there is a record of communications between the Fire Service’s
Operational representative and the design team appended to the report. The statement and
the evidence are therefore contradictory.
The NZFS observes that the provision of the storage platform represents new works and that
s17 of the Building Act requires new works to comply in full with the Building Code.
Consequently, the operational needs and safety of firefighters should be considered as part
of this project.
Please indicate how this issue is to be addressed.
3. Sleeping Area – The FEB refers to a sleeping firecell in the building. However, this is not
apparent in the provided drawings. Please indicate where the firecell is located and show
the means of escape from this space.
4. Route Shown on Drawing Fire#3 – Drawing Fire#3 shows a route with an associated distance
of 63.7m. Given the presence of other doors in the plan north elevation of the building,
please clarify whether this is intended to represent a maximum open path travel distance
rather than a dead-end travel distance.
5. DEOP Calculation – Drawing Fire#2 shows a calculation comparing the DEOP travel
distance from a hypothetical platform of area 35m2 with travel distance from the proposed
platform.
In the context of a scenario involving consideration of RSET, please clarify the relevance of
this assessment.
As indicated above, the NZFS considers equivalence to an element of a compliance
methodology is not the same as demonstrating compliance with that methodology. In
particular, given the reference is in the context of an intermediate floor that has an area more
than 11 times greater than that permitted for storage greater than 3m by C/AS5, paragraph
4.13.7, the argument for equivalence is considered to be significantly undermined.
6. Modelling – Challenging Fire – Section 11.0 of the FEB proposes that a “challenging fire” wil
be modelled to determine the alarm activation time and will be limited to the extent of the
platform only.
The NZFS considers that this cannot be represented as a Challenging Fire as there is no
assessment of tenability conditions in other parts of the warehouse.
Furthermore, given that explicit consideration if either ASET or RSET is beyond the scope of
the Acceptable Solutions, any reference to these factors requires tenability to be modelled.
The terms of the FEB do not suggest that this is proposed. Consequently, the NZFS
considers that the proposal neither demonstrates compliance with a recognised Compliance
Document nor demonstrates compliance with the tenability criteria given in Clause C4.3 of
the Building Code.
Please indicate how this issue is to be addressed.
To avoid unnecessary iterations of the FEB process the NZFS welcomes discussion on any of the
above items, however the NZFS recommends that the FEB be revised to address the items identified
above as well as any additional items identified by other stakeholders.
Our review of the information provided has focused on the performance-based design elements
identified and is intended to provide guidance to reduce the consent risks associated with
undertaking performance-based design. No assessment against the requirements of the acceptable
solutions has been undertaken. Also please note that this advice does not imply a technical
verification of the information provided.
If you have any queries or questions related to the above please do not hesitate to contact me.
Sincerely,
Stephen Lambert
Fire Engineering Unit
cc:
Jenny Lilley, Selwyn District Council
[email address]
Jonathan Nyman, Fire Review Solutions
[email address]
Graton Holding Warehouse
TBN
Mike Gaskin, NZFS
mike [email address]
Fire Engineering Unit, NZFS
[email address]
Document Outline
