2.0 Audience

This Advisory Note is intended for:
(i) Regulators.
(ii) Building Certifiers.
(iii) Building Surveyors.
(iv) Builders.
(v) Form 16 Authors.
(vi) Passive Fire Protection Contractors.
(vii) Strata Managers.
(viii) Building Owners.
(ix) Insurance Companies.

3.0 Compliance in Accordance with A2.2 Evidence of Suitability for Tested Passive Fire Protection Systems.

To satisfy A2.2 it says that clause A2.3 must be met and that Specification A2.3 applies to FRL's without exception. There is no other option.

1. Regulatory Information Report or Assessment Report from a Registered Testing Authority which clearly lists which fire rated substrates the seals may be attached to, max size of aperture seal, orientation floor or wall, which services may pass through the seal if any. For instance if it only addresses the fire stopping seals on a masonry wall substrate, it cannot be used on a FR Plasterboard wall substrate or if it only addresses a floor penetration it cannot be used for walls etc.

1. The on-site application does not vary in any way, from the construction details contained in the RIR or Assessment Report.
   COMPLIANT. In accordance with Specification A2.3 PART 2 (c).

2. If the on-site application varies, from the construction details contained in the RIR or Assessment Report. NON-COMPLIANT.

2. A single Test Report or multiple Test Reports from a Registered Testing Authority where the Tested Prototype is Identical to the on-site application and does not vary in any way.
(Definition of Identical: similar in every detail, exactly alike).
COMPLIANT. In accordance with Specification A2.3 PART 2 (b).

1. A single Test Report or multiple Test Reports from a Registered Testing Authority plus a Manufacturers Technical Installation Manual which shows variations to the Tested Prototypes. NON-COMPLIANT.

2. A single Test Report or multiple Test Reports from a Registered Testing Authority plus a Manufactures glossy data sheet which show variations to the Tested Prototypes. NON-COMPLIANT.

3. A single Test Report or multiple Test Reports from a Registered Testing Authority plus a letter from a Manufactures internal engineer, commonly known as an EJ (Engineered Judgement) which shows variations to the Tested Prototypes. NON-COMPLIANT.

4. A single Test Report or multiple Test Reports from a Registered Testing Authority plus a letter from a Manufacturer which justifies or certifies variations to the Tested Prototypes. NON-COMPLIANT.

3. A Test Certificate from a Registered Testing Authority is for marketing purposes only and is not to be used for Regulatory Compliance and therefore. NON-COMPLIANT. In accordance with AS1530.4-2005 Section A2.15.4

5.0 Opinion

There is currently a lot of non-compliance in the Passive Fire Protection industry which has led to an enormous amount of costly rectification works throughout Australia. I would suggest the reason for this, is that Industry have been and still are, happy to accept Test Certificates, Manufacturers Technical Installation Manuals, Glossy Data Sheets, EJs and conformance letters from Manufacturers and Suppliers to meet Compliance, which they do not.

A Regulatory Information Report refers to a detailed Assessment Report. The Full Assessment Report includes reference to and a brief summary of all testing which it is based upon and is prepared in accordance with the requirements of NCC Spec A2.3 c). An RIR assessment report includes all of the information of the required construction specification, though not the analysis of the results. It otherwise fully meets the requirements of NCC Spec A2.3 c).

The amount of products tested and the amount of Test Reports a manufacturer can provide to the RTA, will determine how comprehensive their RIR will be, and how many compliant applications it will cover. The manufactures which provide the most Test Reports to the RTA, are the ones which are able to provide the most compliant solutions to Industry via their Regulatory Information Reports.

This Advisory Note is based upon Normative clauses which are clearly defined in the BCA, AS1530.4-2005 and AS4072.1-2005. If clarification is required on any of the Compliance or Non-Compliance points listed please do not hesitate to contact the author who will direct you to the relevant clauses.

6.0 Documents Referenced

1. AS1530.4-2005
2. AS4072.1-2005
3. BCA
4. Oxford Dictionary

9.0 Disclaimer

The opinions expressed in this correspondence reflect those of TBA Textiles Pty Ltd (Firefly Division). However, these are subject to change based upon receipt of further information regarding the subject matter. You should interpret the technical opinion or information provided carefully and consider the context of how this opinion/information will be used in conjunction with the relevant requirements outlined in regulations (State and/or Federal), standards, codes, or specifications, certification, accreditation, manufacture's documentation and advice and any other relevant requirements, instructions or guidelines. TBA Textiles Pty Ltd (Firefly Division) does not accept any responsibility or liability for the accuracy of the opinion/information provided, nor do they accept either directly or indirectly any liabilities, losses and damages arising from the use and application of this opinion/information.