COVID-19 – Maintenance of Fire Protection, Mechanical Services and Electrical Assets
The LFRA has been strongly advocating that Large Format Retailers should remain open for trade during the COVID-19 crisis should they choose to do so. Despite this, property owners and managers may be faced with the possibility of some building closures. Grosvenor Engineering Group has put together this fact sheet setting out how best to continue with the required maintenance tasks applicable to a buildings essential services. These tasks are considered the minimum required to be able to meet the state by state legislative obligations e.g. submission of an AFSS (Annual Fire Safety Statement) as is required in NSW.
By definition: An essential service……
Prior to the COVID-19 pandemic, fire protection, mechanical services and electrical assets installed, tested and maintained were known as essential services. These systems and equipment, as specified in the National Construction Code and in turn numerous Australian Standards, is required to be installed (and in turn maintained) in commercial, retail and industrial buildings around Australia. They are there to ensure the occupants, along with the property are protected from, alerted to any potential fire risk. Most of these systems are automated, meaning that specific and targeted maintenance is required to ensure correct and compliant continued operation. Furthermore, non-completion of essential maintenance leading to a prospective insurable event would be significantly damaging for both property and reputation.
Your continued obligations. A State by State guide for property owners and occupiers – Annual compliance sign off
NSW: Annual Fire Safety Statement
QLD: Occupiers Statement
VIC: Annual Essential Safety Measures Report
SA: Form 3
WA: Expected the owner manages maintenance obligations
TAS: Expected the owner manages maintenance obligations
NT: Yearly Condition Report
ACT: Expected the owner manages maintenance obligations
Your maintenance position: A minimum requirement for Essential Services
Fire Protection Services
AS1851 is the maintenance obligation nationally. Be it in line with 2012 or 2005 per AESMR in VIC, or per client contractual obligations nationally.
Grosvenor Engineering Group recommends all fire protection systems are maintained as per existing agreements and in line with all relevant Australian Standards which are further governed by state and territory legislation.
Detail below are the required obligations – A State and Territory guide for property owner’s Legislative responsibility
- NSW Environmental Planning and Assessment Regulation 2000
- Queensland Building Fire Safety Regulation 2008
- Tasmanian Building Regulation 2004 amended 2013
- Regulation 48A WA Building Regulations 2012, amended 2014 WA
- Building Act 1993 and Building Regulations 2018, Regulations 223 and 224 Victoria
- Development Regulations 1993 and Ministers Specifications South Australia 76
- Northern Territory Fire and Emergency Act and Regulations
- Emergencies Act 2004/ ACT Fire Brigade Policy FS-05 ‘Essential Safety Maintenance’ ACT
Grosvenor Engineering Group also recommends taking this opportunity to complete any major fire compliance works that would normally severely impact on tenant’s business operations if these areas are now vacant.
Mechanical Services
It is recommended that all mechanical services systems that includes Heating, Ventilation and Air Conditioning Equipment should be continued to be maintained to ensure building internal environments remain well ventilated and ‘fresh’, and run regularly to ensure equipment life is maximised.
With reference to Essential ‘Mechanical’ Services, AS1851 and AS 1668 Part 1 are the applicable maintenance and testing Australian Standards for HVAC Equipment normally referred to as the Smoke Hazard Management Systems. These systems are designated as Essential Services and must be maintained and tested in line with Authority requirements.
Property Owners / Managers should be aware that under the Public Health Act, the routine monthly maintenance and servicing of cooling water systems (includes cooling towers, evaporative coolers, associated pumps and other water-based systems) must continue to ensure compliance with the Public Health Act 2010, Public Health Regulation 2012 and AS/NZS 3666.3. If maintenance does not continue on these systems, there is a further risk of a legionella outbreak.
Split Systems / Package Units / VRV Systems – all these system types can be isolated where areas are not occupied provided they do not form part of smoke hazard management systems. Grosvenor recommends that these systems be programmed to run for a few hours per day to keep the areas they serve ‘fresh’ but this is not mandatory.
CRAC Units – considered an essential service given that these systems run 24 hours per day, 365 days per year serving Data Centres / Computer Rooms. CRAC units can be connected to cooling towers, chillers and can be standalone air-cooled type. Maintenance of CRAC units and systems providing heat rejection must be serviced to ensure set-point temperatures and humidity levels are maintained.
Chillers – Chiller strategies can be altered to ensure low load efficiencies are maximised especially where occupancy in buildings has decreased. It is also recommended that any mothballed chillers are run regularly to ensure oil circulation and seal lubrication that forms part of chiller longevity.
Ideally all HVAC equipment should be continued to be maintained and run regularly to ensure equipment life is maximised. In practical terms, there are also serious issues that can arise if buildings are not maintained, particularly in water systems. These include corrosion cells and stagnant water in piping (dead legs) that can subsequently lead to further health issues such as Legionella. Today’s buildings are simply not designed to be shut down for extended periods.
Electrical Services
AS2293.2 is applicable to Exit/Emergency lighting maintenance.
AS3000 – 2018 for electrical testing including RCD’s.
Grosvenor recommendations for equipment and technical reasons for continued maintenance:
RCD testing: is an important factor in providing a safe workspace. Property owners/managers do have an obligation to ensure that RCD testing is carried out, and the ease of conducting this type of testing in unoccupied buildings is a time benefit to maintenance companies and a cost saving to owners / managers.
Thermographic scanning: Electrical switchboard inspection and maintenance, inclusive of thermographic scanning is essential to the reliable and risk-free operation of electrical switchboards. Whilst not better suited to unoccupied buildings as operating loads will not be at a maximum, extra freedom access wise, will ensure cost savings can be passed on to owners.
Current Stance. The Government, Industry Bodies, Fire Brigades, Insurance Companies, Building Owners and Grosvenor Engineering Group
The Government: is yet to make any concessions or further consider how this pandemic will affect building owners and their ability to achieve the required compliance as set out in state by state legislation.
Industry Bodies: The FPAA for example have written to Governments at both state and federal levels, suggesting an easing of annual compliance obligations in the form of extensions for compliance submission. An excerpt from the FPAA’s letter to each relevant state minister is below:
Option A: The Government should issue a declaration that routine maintenance requirements and/or the issue of annual fire safety statements can be delayed up to four (4) months; and: Routine servicing and fire safety assessment would continue to be carried out on relevant buildings where possible but without entering SOUs or areas of designated restriction.
Option B: The Government should empower local government to grant extensions on the issue of annual fire safety statements for up to four (4) months without incurring a fine; and: Routine servicing and fire safety assessment would continue to be carried out on relevant buildings where possible but without entering SOUs or areas of designated restriction.
Further to the above, The FPAA states: this would be mostly applied for residential, health care, aged care, education or buildings with designated restrictions. At this stage we expect maintenance and annual assessment would generally continue on commercial and industrial type facilities.
Fire Service Providers (Authorities): Below is a statement from the QFES highlighting their position regarding continued essential services maintenance.
Queensland Fire and Emergency Services (QFES) acknowledges the challenge you have identified, however, QFES does not have jurisdiction to endorse the breeching of a legislative requirement.
Smoke alarm and detection systems provide critical early warning to occupants. Their activation initiates investigation and responsive action. In many cases, this early intervention is relied upon to support evacuation. Where these systems are monitored by QFES, they trigger automatic attendance by firefighters who have been advised to take additional care and wear appropriate personal protection.
The function and integrity of fire safety systems should be considered essential and the service and maintenance of these should remain a priority.
QFES will consider mitigating circumstances when assessing building fire safety compliance matters and a pragmatic approach will be taken in relation to enforcement action where external factors significantly impact on regulatory compliance.
Should you require any further assistance, please contact Community Safety Office on 3635 1500.
Building Owners: In liaison with our key clients, the current situation is being seen through their eyes as an opportunity to conduct maintenance routines that are usually difficult given tenant occupation, noise restrictions and impaired contractor access.
Insurance Companies: Have broadly declared that they expect that all maintenance obligations relating to essential services must be met, and annual compliance documentation submitted as required per relevant legislation.
Grosvenor Engineering Group: As the industry’s most dynamic service provider, Grosvenor are always considering ways to ensure its clients’ interests are best managed. As each building is different when it comes to plant/equipment type, Grosvenor’s suggestions for cost savings, more efficient plant operation, skeleton staff plant operation and reduced maintenance obligations are available but will be tailored per building.
Force Majeure: There is some consideration to be placed on the potential to rely on Force Majeure given the impediments that an owner or landlord may face in these ever-changing times. Whilst the entire contract may not be affected, part of a landlord or owners responsibility through a lease agreement is to provide clients / tenant a compliant space in which they lease. Should essential services not be delivered to the client/tenant this may impart the execution of a Force Majeure claim. We encourage our customers to investigate this item when considering Essential Services maintenance.
In Summary: Whilst there may be certain plant/equipment operation that can be cycled down or turned off during this pandemic, Essential Services maintenance is still required to ensure correct system operation if and when it is required. The goal posts are constantly moving, so this article will be re-considered by the Grosvenor team on a weekly basis, and will be updated as required.
Michael Brooker, National Business Development Manager
Grosvenor Engineering Group
