Maintenance of Fire Safety Installations in Queensland

AS1851-2005 has not had the success anticipated by both Standards Australia and the FPAA. Only one of the state regulators has legislated for use of AS1851-2005. There has been a lot of discussion in the industry about AS1851-2005 being "mandatory" in Queensland. From our review of the legisaltion this is not strictly true. Practically this may be the case but there is a basis for adoption of other maintenance standards.

Under the Regulations the application of maintenance standards varies according to whether it is a:

1. relevant current Australian Standard (AS1851-2005); or
2. relevant former Australian Standard (e.g. AS1851.3-1997); or
3. there is no relevant or appropriate Australian Standard.

Two criteria must be met for "a relevant former AS" to be applicable:

1. carrying out the maintenance in compliance with the relevant current standard would adversely affect the installation; and
2. a previous maintenance standard applies (in accordance with Column 3 in the table in Schedule 1 to the Building Fire Safety Regulation 2008).

It is not clear what or how qualifies something to "adversely affect the installation".

The third case - "no relevant or appropriate AS" has 2 similar pre-qualifying criteria:

1. there is no relevant former standard for the installation;
2. there is a relevant former standard for the installation but carrying out the maintenance in compliance with the standard would adversely affect the installation.

Where this applies there are two possible outcomes:

1. in accordance with the manufacturer's recommendations; or
2. "in a way that is reasonably appropriate in the interests of safety"

We are doing some more research into the practical application of these requirements and will post more analysis soon.

The legislative requirement for the adoption of the standard comes from the Fire and Rescue Service Act and the Building Fire Safety Regulation.