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Fire Safety Measures Associated with Process Equipment and the Fire Safety Schedule: Where Does it Fit?

Keywords: Fire Safety Schedule (FSS), Essential Fire Safety Measures (EFSM), Annual Fire Safety Statement (AFSS), process equipment, fire safety compliance, performance solutions, fire engineering, ammonia detection systems, Building Code of Australia (BCA), NSW fire safety regulation, certification and compliance, fire safety measures, building approvals, gas detection systems, competent person certification

Introduction

With ever increasing industrial complexity and regulatory scrutiny, understanding the intent and requirements of the Fire Safety Schedule (FSS) and how process or plant equipment fits into this has become more important to avoid gaps and overreach in fire safety compliance. This article explores how and when process equipment safety measures, such as ammonia detection systems for example, become Essential Fire Safety Measures (EFSMs), and how that status affects its inclusion in the Annual Fire Safety Statement (AFSS).

The Fire Safety Schedule

The FSS is a document issued by the Council or Certifying Authority as part of the Complying Development Certificate (CDC) or Construction Certificate (CC) that lists all EFSMs applicable to a building. These requirements are generally stipulated by the Building Code of Australia (BCA) in accordance with prescriptive standards, mandated by Australian Standards, or implemented through a fire engineering solution. The schedule provides a detailed listing of each item.

The schedule not only lists each measure but also specifies the performance standard it must meet, such as compliance with AS 1670.1 for fire detection systems or AS 2419.1 for fire hydrant systems (Department of Planning and Environment, 2023). The AFSS, submitted annually, is a declaration that each measure on the FSS has been inspected and is capable of performing to its standard.

Only measures listed on the FSS are subject to the AFSS. If a system, such as a piece of process equipment, is not on the FSS, it is not legally required to be inspected or certified under the AFSS framework. This makes the FSS the critical document for determining whether process equipment is part of a building’s regulated fire safety regime.

What is an Essential Fire Safety Measure (EFSM)?

EFSMs are defined in NSW legislation as “items of equipment, forms of construction or fire safety strategies that promote the safety of building occupants in the event of fire”. In particular, a fire safety measure is considered “essential” if it meets the following:

  • It is listed on the building’s FSS,
  • It was part of an older approval or order (NSW Government, 2021).

While this definition can seem circular, in practice, the listing process is grounded in building regulations (i.e. BCA requirements) and expert approvals (usually the approval of Council or a Certifier). For example, Regulation 79 of the Environmental Planning and Assessment Regulation 2021 lists out a range of statutory fire safety measures, such as fire hydrant systems, smoke alarms, smoke doors etc, that must be included on the FSS if a building has installed them (NSW Government, 2021). However, process equipment is not typically among these statutory measures and thus is up to the discretion of the Certifier/Council to determine if it required to be included in the FSS guided by prescriptive codes and regulations.

Process Equipment and the FSS: When Does it Qualify?

Process equipment generally refers to plant, machinery or installations used in an industrial process itself. Often this equipment will have associated safety measures such as ammonia detection systems which is not automatically considered an EFSM. These systems are often installed for occupational health and safety or environmental compliance, not fire safety. However, if a Performance Solution or Development Consent Condition relies on such equipment to mitigate a fire or explosion risk, it may be listed on the FSS.

Once listed, the process equipment becomes an EFSM and must be:

  • Maintained to a defined performance standard.
  • Inspected and certified annually by an Accredited Practitioner (or Competent Person, if no accreditation exists).
  • Included in the FSS and AFSS for on-going inspection.

This listing typically occurs during the design or approval phase, when a Certifier or Council formalises the building’s fire safety strategy. The Performance Solution or Fire Engineering Report will outline the role of the process equipment, and the certifier will determine whether it should be included on the FSS.

Comparing Standard EFSMs and Process Equipment

Consider the example of a standard smoke detection system. In many commercial and residential buildings, smoke detectors are mandated by the BCA, listed on the Fire Safety Schedule as EFSMs and subject to annual testing and certification.

Now consider a process equipment example of an ammonia detection system in a plant room. These systems are designed to detect hazardous gas leaks and trigger ventilation or shutdown procedures. While they are critical for occupational health and safety, their role in fire safety is less defined. Ammonia is both toxic and flammable, but ammonia detection systems are not explicitly listed in the BCA or standard EFSM lists. Therefore, they are not automatically included in the FSS. However, if included in a Fire Engineering Performance Solution (e.g. to mitigate explosion risk), it should be listed and treated as an EFSM.

Certifying Process Equipment

Recognising the unique nature of some performance-based fire safety measures, the NSW Government has acknowledged that not all EFSMs have corresponding Accredited Practitioners. A 2020 Gazette notice (NSW Government Gazette No. 166, 31 July 2020) authorises building owners to appoint a “Competent Person” to assess such systems, provided they certify the individual’s qualifications (NSW Government, 2020). This provision is particularly relevant for specialised process equipment like ammonia detection systems, which may not fall under traditional accreditation categories but still require annual certification if listed on the Fire Safety Schedule.

Conclusion

Process equipment is not inherently an EFSM. Its inclusion in the AFSS depends entirely on whether it is listed on the FSS, which typically occurs if it is required by the BCA, a Performance Solution, or a regulatory condition.

Building Owners, Designers, and Fire Safety Practitioners should work closely with Certifying Authorities and FRNSW to determine:

  • Whether a process system is part of the fire safety strategy.
  • What standards apply to its design, installation, and maintenance.
  • How it should be documented and certified.

Failing to include a critical system in the FSS can lead to compliance gaps and increased liability. Conversely, over-inclusion can impose unnecessary burdens and confusion.

The key takeaway is that process equipment is not inherently part of the AFSS unless it is explicitly listed on the FSS. However, when such systems are integral to a building’s fire safety strategy and relied upon as part of a Fire Engineering Performance Solution, they must be treated with the same rigour as any other EFSM and follow the same procedures.

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