Childcare facilities present unique challenges when it comes to managing fire risks and meeting the goals of fire safety within these properties. These types of facilities are used primarily for assembly use (Class 9b). However, a wide variety of hazards are often present, requiring careful consideration of the risks and mitigation measures to ensure life safety goals are met.

On 9 May 2022, the Australian Building Codes Board (ABCB) published the preview of the National Construction Code (NCC) 2022 for early childhood services. The emphasis is on mitigation measures in addressing the safety risks with evacuating children from multi-storey and mixed-use buildings. These changes will come into effect from 1 September 2022.

Section D of NCC 2019 Amendment 1 Volume 1 (NCC 2019 A1 V1) emphasises the requirements for egress provisions in the building. BCA D1.2 further notes that each storey in a Class 9b building used as an early childhood centre must be provided with access to two (2) exits.

BCA D1.18 details the one of the few additional egress requirements for early childhood centres in the current NCC, noting that direct access to a road or open space must be provided. This is primarily attributed to the extended time taken for evacuation of such facilities.

NCC 2022 Volume 1 acknowledges and emphasises the risks associated with fire safety and evacuation for Early Childhood Centres and Primary Schools in High Rise Buildings in the event of fire or other emergencies. New provisions stated in BCA 2022 Volume 1 addresses concerns of early childhood centres (ECCs) that are situated on the upper floors in multi-storey buildings dealing with very young children and potentially extended travel distances.

NCC D2D23 (formerly D1.18 in NCC 2019 A1 V1) removed the references to early childhood centres and replaced it with primary schools of up to four (4) storeys. This is due to the increasing number of early childhood centres being integrated into high-rise mixed-use developments, as opposed to being standalone buildings more akin to traditional schools.

A tabular list of the changes in relation to Sections C, D and E of NCC 2019 A1 V1 and NCC 2022 is provided below for reference.

Table 1 – NCC 2022 Changes in relation to Early Childhood Centres

NCC Clause	NCC 2019 Comments	NCC 2022 Comments	Commentary
C2.5 – Class 9a and 9c Buildings C3D6	Only applicable to Class 9a and 9c buildings.	Added new requirements for Class 9b Early childhood centres, noting that in buildings where the Class 9b is not the only use the area must be separated from the remainder of the building with walls and floors with an FRL required by a fire wall.	Additional requirements for early childhood centres in NCC 2022 to fire separate if not occupying the entire floor.
D1.2 – Number of Exits D2D3	Provision of at least two (2) exits in addition to horizontal exits.	Provision of at least two (2) exits in addition to horizontal exits. At least one (1) exit must be provided for early childhood centres divided into fire compartments in accordance with NCC C3D3 or C3D6.	Additional requirement in NCC 2022.
D1.4 – Exit Travel Distance D2D5	20m to an exit or point of choice. Travel distance to any exit cannot be greater than 40m. Travel distance in Class 9b buildings of 60 m cannot be applied to schools and early childhood centres.	20m to an exit or point of choice. Travel distance to any exit cannot be greater than 40m. Travel distance in Class 9b buildings of 60 m cannot be applied to schools and early childhood centres.	Same requirement between NCC 2019 and 2022.
D1.11 – Horizontal Exits D2D16	Horizontal exits cannot be identified as a required exit in schools and early childhood centres.	Horizontal exits cannot be identified as a required exit in schools and early childhood centres. Where horizontal exits are provided, the clear area required is to be a size that accommodates all occupants of the early childhood centre.	Horizontal exits cannot be used as required exits in Class 9b early childhood centres. Where provided as supplementary exits NCC 2022 notes that the area on the other side must be able to accommodate all the occupants.
D1.18 – Egress from Early Childhood Centres D2D23	Provides concessions to early childhood centres with a rise in storeys of no more than two (2).	No longer applicable to early childhood centres.	NCC 2022 removed the concession provided by NCC 2019.
D2.17 – Handrails D3D22	No specific requirements for Class 9b early childhood centres.	Handrails must be provided in Class 9b early childhood centres.	Added reference to Class 9b early childhood centres.
D2.21 – Operation of Latch NSW Variation D3D26	Doors in a required exit must be readily openable without a key and operable by a single hand downwards/pushing action device.	Doors in a required exit must be readily openable without a key and operable by a single hand downwards/pushing action device.	Same requirement between NCC 2019 and 2022.
D2.22 – Re-entry from fire isolated stairs D3D27	No specific requirements for Class 9b early childhood centres.	Notes that doors of a fire isolated exit must not be locked from the inside of Class 9b early childhood centres.	Added reference to Class 9b early childhood centres.
D2.24 – Protection of Openable Windows D3D29	Protection to be provided to openable windows where the floor below is greater than 2m.	Protection to be provided to openable windows where the floor below is greater than 2m.	Same requirement between NCC 2019 and 2022.
Table E1.5 – Sprinklers E1D11	No specific requirements for Class 9b early childhood centres.	Sprinklers must be provided in the Class 9b early childhood centre, unless the childhood centre is in a storey that provides direct egress to a road or open space.	Additional requirements for sprinklers to be provided in Class 9b early childhood centres.
Table E2.2b – Smoke Detection E2D20	No specific requirements for Class 9b early childhood centres.	Smoke detection must be provided in the Class 9b early childhood centre which is not wholly within a storey that provides direct egress to a road or open space, in accordance with Specification 20 throughout the entire building.	Additional requirements for smoke detection to be provided in Class 9b early childhood centres.
S17C14 – Early Childhood Centres	Not Applicable.	Notes that quick response sprinklers must be used in Class 9b early childhood centres.	Additional requirements for sprinklers to be provided in Class 9b early childhood centres.

In summary, NCC 2022 outlines additional requirements that need to be adhered to in order to design a Class 9b early childhood centre that is compliant with the requirements of the NCC DtS Provisions. Whilst from a design perspective these may look onerous, in terms of a fire and life safety perspective based on the prolonged evacuation time typically noted in Class 9b early childhood centres these additional measures provide an effective means to mitigate this risk.