State-wide cladding audit
In the early hours of 14 June 2017, fire engulfed a 24-storey apartment block in West London’s North Kensington district known as the Grenfell Tower, causing at least 80 deaths and many injuries.
While English authorities are still investigating the cause of the fire and its rapid spread, initial indications suggest the fire started from within the building and spread both internally and externally. It also appears that a recently installed external wall cladding had contributed to the vertical and lateral spread of the fire.
The Grenfell Tower fire reinforced the need to ensure buildings are safe from the risk of rapid fire spread not only in the United Kingdom but worldwide including Australia. The tragedy put a particular focus on the installation of potentially combustible cladding products including in the refurbishment of old buildings.
In June 2017, the Prime Minister Malcolm Turnbull wrote to the Western Australian Premier Mark McGowan MLA seeking the support of all state and territory governments to ensure the necessary steps are taken to prevent a similar tragedy from occurring in Australia.
Building Commissioner Peter Gow announced on 4 July 2017 that, in response to the Grenfell Tower fire, the WA Building Commission (Building Commission) would broaden the scope of an initial audit it had been carrying out on aluminium composite panels (ACPs) into a state-wide cladding audit that would include all high-risk, high-rise buildings with cladding attached. Similar audits have been commenced or undertaken in other states including South Australia, Queensland, New South Wales and Victoria.
The initial audit of ACPs had commenced following a fire at the Lacrosse apartment building in Melbourne, Victoria on 25 November 2014. The Lacrosse fire was identified by the Victorian authorities as having spread via ACPs attached to the external walls of the building.
Working with the City of Perth and Town of Victoria Park, the initial audit assessed the fire risk from ACPs in high-rise apartment, hotel and public buildings that were over three storeys in height and constructed in the past 10 years. All of the ACPs assessed in the initial audit contained fire resistant cores.
The Building Commission will publish regular updates about the state-wide cladding audit on this webpage and will report on its findings at the conclusion of the audit.
Announcements, updates and publications
In May 2015, the Building Commission issued Industry Bulletin 54: External wall cladding – fire safety to all registered builders and building surveyors, permit authorities and other industry contacts.
A further industry bulletin, Industry Bulletin 62: Victorian Building Authority external wall cladding audit report, was issued by the Building Commission in March 2016 reminding industry on the issues around external wall cladding. The bulletin alerted industry to the valuable information and lessons learnt from the Victorian Building Authority audit report released on external wall cladding following the Lacrosse apartment building fire in Melbourne.
In April 2016, the Building Commission published its Aluminium composite panelling in high-rise buildings – interim audit report.
In August 2016, the Australian Building Codes Board released an advisory note on Fire Performance of External Walls and Cladding.
In July 2017, the Building Commission issued the media statement State-wide cladding audit underway.
What is the current status of the audit?
The audit team is close to finalising the first stage of its audit which was to compile a list of buildings that fall within the audit scope. The final list is expected to comprise around 500 buildings.
The next stage of the audit will commence shortly and will involve a desktop risk assessment of the buildings identified in stage one. This is consistent with methodologies being applied by cladding taskforces established in other jurisdictions. During this process the audit team will identify buildings that warrant further investigation. While it is anticipated the final number of buildings that warrant further review will be small compared to the original list of 500, each building will need to be carefully assessed on a case-by-case basis and this will take some time.
While a final report cannot be completed until the audit is concluded, the Building Commission expects to publish regular updates about the state-wide cladding audit on this web page.
What is the audit scope?
The state-wide cladding audit will:
- Identify buildings three storeys and over, classes 2, 3, 4 and 9 with cladding, constructed or refurbished (where a building licence/permit was issued) after 2000. These are generally buildings in which people sleep – such as apartments, hotels and other short-stay accommodation – or which accommodate vulnerable occupants or high occupancy events.
- Determine whether cladding associated with these buildings poses an unacceptable risk of fire spread.
- Apply an appropriate intervention where an unacceptable risk is found to exist.
Buildings are being assessed based on their degree of risk to public safety.
The audit scope has been developed in partnership with other regulatory and advisory bodies assisting in the audit under a newly-formed Audit Regulator Group (ARG). The ARG includes representatives from the Department of Fire and Emergency Services, the Western Australian Local Government Association (on behalf of local government), representatives of the three permit authorities of Perth, Victoria Park and Cockburn, and members of the Building Commission audit team.
The audit scope is consistent with the approach being taken nationally. The Building Commission is collaborating with regulators in other jurisdictions that are similarly auditing buildings with cladding attached.
What types of cladding will be assessed?
The state-wide cladding audit will assess buildings with any type of cladding attached that fit within the audit scope.
Cladding is not limited to aluminium composite panelling during this audit and the audit may carry out testing of a cladding to ensure that what was specified was in fact installed.
Who is carrying out the state-wide cladding audit?
The Building Commission is coordinating the state-wide cladding audit of private buildings, state housing and publically owned buildings.
The audit team will include a range of building and fire experts and is collaborating with several agencies to carry out the audit. This may result in the appointment of additional staff to assist with the execution of the audit.
The Building Commission wrote to all Western Australian permit authorities on 4 July 2017 asking for their assistance with the state-wide cladding audit for buildings within their jurisdictions.
Permit authority certification records and Department of Fire and Emergency Services building records will be used to identify buildings that require further assessment.
The Department of Communities is responsible for assessing state housing buildings. The Department of Finance – Building Management and Works is assisting other government agencies with the assessment of publically-owned buildings.
Through the newly-established Audit Regulator Group (ARG), the Building Commission worked collaboratively with three local government representatives and the Department of Fire and Emergency Services to finalise the scope of the audit and to identify buildings with cladding attached.
An Audit Stakeholder Group (ASG) also met for the first time on 6 July 2017 and will assist with the facilitation of information about the audit. The ASG includes representatives from (in alphabetical order):
- Australian Institute of Architects
- Australian Institute of Building
- Australian Institute of Building Surveyors
- Building Commission (WA)
- City of Cockburn
- City of Perth
- Construction, Forestry, Mining and Energy Union (CFMEU)
- Department of Fire and Emergency Services
- Housing Industry Association
- Local Government Insurance Services Western Australia
- Master Builders Association
- Property Council of Australia
- Society of Fire Safety
- Strata Community Australia
- Town of Victoria Park
- Western Australian Local Government Association
It is possible that the audit will also identify buildings within the scope of the audit that require further investigation and the Building Commission and relevant permit authority will work with building owners to ensure the cladding attached to their buildings meets the performance requirements of the Building Code of Australia.
Foyer Oxford Building, Leederville
The Foyer Oxford building in Leederville was recently found to contain cladding of an unacceptable risk (this was identified outside the state-wide audit).
Foundation Housing and the Department of Communities are working to ensure the building is safe from the risk of rapid fire spread.
The Department of Communities is the primary State Government contact for enquiries about the Foyer Oxford building.
How long will the audit take?
The assessment of cladding on Western Australian buildings will continue for as long as it takes to be satisfied the cladding meets the fire safety requirements.
The Building Commission is working collaboratively with local government permit authorities and the Department of Fire and Emergency Services to identify buildings with cladding attached. An assessment of these buildings will take place as soon as possible as part of the state-wide cladding audit.
The time it will take to complete the audit will depend on the number of buildings found to have cladding attached and the overall fire safety of the buildings.
Every building is unique and will need to be assessed on a case-by-case basis. Until we know how many buildings need to be assessed and the nature of the products used it is too early to know how long the audit will take.
How many buildings will be checked?
The Building Commission is working with local government permit authorities, the Department of Fire and Emergency Services, Department of Communities and public agencies to identify and assess buildings that fall within the scope of the state-wide cladding audit.
The task of identifying buildings within the audit scope is quite arduous and is likely to take some time.
The Building Commission has identified buildings that fit within the audit criteria of class, height and age. The number of buildings to be assessed cannot be determined until this process is concluded.
The Western Australian starting point is approximately 6,000 buildings. This includes buildings for which early records do not detail the class or height of the building and the Building Commission is diligently working its way through this list to identify the buildings with cladding that are high-risk.
What should building owners, managers and occupiers do if they have concerns about cladding?
Fire events in Australia and around the world highlight the need for building owners and occupants to remain vigilant about maintaining safety and knowing their emergency response in the case of a building fire.
In some of these cases, the use of certain types of external wall cladding was found to contribute to the rapid fire spread across the façade of the building.
Aluminium composite panels (ACPs) were found to have contributed to the spread of fire in the Lacrosse apartment building in Melbourne in 2014, however not all ACPs is dangerous. Such products are usually manufactured in a range of grades that can be used appropriately in some circumstances.
Identifying ACPs on a building, including the combustible version of the product, is not necessarily cause for concern. It depends on whether the cladding is used in accordance with the applicable codes and standards.
Home owners with concerns about cladding should contact their building manager in the first instance.
Building managers should raise any concerns about a building’s cladding with the builder. If building managers are unsure who the builder was they should contact the relevant local government.
If dissatisfied with their builder’s response the building manager or owner may wish to speak to the building surveyor who certified the building or engage a suitably qualified fire engineer to carry out a performance assessment of the cladding to ensure it does not pose an unacceptable risk of fire spread.
Building managers may arrange to have any necessary rectification works carried out. A building permit may be required for such building work.
If their building has been completed in the past six years, home owners may be able to lodge a building services complaint with the Building Commission. They will need to provide evidence to support their complaint.
Anyone associated with an apartment building who is concerned that the building managing body (often referred to as the body corporate) is not taking these fire safety concerns seriously is asked to contact the Building Commission on email@example.com or phone 1300 489 099.
What did the initial audit of aluminium composite panels find?
Following the 2014 Lacrosse apartment building fire in Melbourne, the Building Commission, City of Perth and Town of Victoria Park carried out an assessment of high-rise buildings that incorporate aluminium composite panels (ACPs).
The criteria for the initial audit were apartment, hotel and public buildings that were over three storeys in height and constructed in the past 10 years.
Ninety-one buildings (70 in City of Perth and 21 in the Town of Victoria Park) initially met the criteria for the initial audit (in regards to use and size of the building). Nine of those buildings in City of Perth and seven in the Town of Victoria Park were found to contain ACPs and were further examined in the initial audit.
The initial audit found no buildings in which the use of ACPs gave cause for concern – all of the ACPs assessed in these audits had fire resistant cores. It should be noted that the initial audit specifically targeted fire risk from ACPs without fire-resistant cores.
The type of product used on the Lacrosse apartment building was not identified in any of the Western Australian buildings audited in the initial audit.
Further information is provided in the interim audit report.
What advice does the WA Building Commission have for members of the building industry?
Fire safety concerns have been raised about the use of external wall cladding where that product had not been tested or demonstrated to meet the requirements of the Building Code of Australia (BCA) for that use.
Such products can lead to a rapid vertical and lateral spread of a fire via the façade of the building which raises serious safety concerns.
Western Australian building legislation requires buildings to comply with the BCA which includes requirements on fire safety. In general the BCA Volume 1 contains provisions for external walls of buildings falling under type A and type B construction (typically medium rise and high-rise commercial buildings including residential apartment buildings) to be non-combustible.
Further information for building surveyors, builders, designers and owners is provided in Industry Bulletin 54: External wall cladding – fire safety.
Any non-compliant use of cladding should be reported to the Building Commission in the first instance.
How is compliance with the building legislation enforced?
All building work in Western Australia must comply with the applicable building standards. The Building Act 2011 adopts the Building Code of Australia (BCA), which forms part of the National Construction Code as the primary applicable building standard.
The BCA is produced and maintained by the Australian Building Codes Board (ABCB) on behalf of the Australian Government and each state and territory government.
The BCA is a performance-based document with nationally consistent, minimum necessary standards for relevant safety (including structural safety and safety from fire), health, amenity and sustainability objectives.
In order to comply with the BCA the building must meet the mandatory performance requirements of each part of the BCA that is relevant to the building.
When designing a building solution to satisfy compliance with the BCA, a choice can be made to use the deemed-to-satisfy (DTS) provisions or to develop a performance solution.
A performance solution can be developed in accordance with the BCA that suits a particular building and gives the flexibility to design and build contemporary buildings while still achieving compliance with the minimum performance requirements.
The BCA performance requirement CP2 requires buildings to have elements that avoid the spread of fire. In order to meet the DTS solution for high-rise buildings, an external wall is required to be non-combustible. The DTS permits the use of certain materials with combustible elements provided that it does not expose the building to unacceptable risk of the spread of fire.
ACPs generally come in three types, each with differing amounts of combustibility. Certain ACP attachments may be able to comply with the DTS provisions of the BCA. However, the use of an ACP will generally require consideration under performance to demonstrate that it will not constitute an undue risk of fire spread via the façade of the building and meets the performance requirements of the BCA.
Building surveyors have a role in certifying buildings’ compliance with applicable building standards. This includes checking compliance with applicable building standards when issuing a certificate of design compliance (CDC) for the purpose of obtaining a building permit before building work can commence and issuing a certificate of building compliance or construction compliance when applying for an occupancy permit.
The builder’s role includes ensuring that the correct materials have been used in the construction. The builder must ensure that on completion the building complies with the plans and specifications that are specified in the applicable CDC and applicable building standards.
The Building Commission, through the Building Services Board, registers builders and building surveyors.
As part of its proactive measures, the Building Commission conducts audits of building service providers on a random and targeted basis.
The Building Commission’s audits schedule is developed having regard to information arising from its disputes, auditing, enforcement and intelligence monitoring activities.
Should a builder or building surveyor be found to have failed to meet their obligations under the Building Services (Registration) Act 2011, the Building Services Board or State Administrative Tribunal have a range of disciplinary actions/outcomes available to them, which include a caution, reprimand, fines, requiring further training to be undertaken, placing conditions on a builder’s registration or deregistering the builder or building surveyor. There are also offences under the Building Act 2011 for failure to comply with applicable building standards, which may result in fines or imprisonment for repeated offences.
Permit authorities, usually the local government, have powers under the building legislation to enforce the compliance, maintenance and safety of buildings within their jurisdiction. In the event a building’s cladding is found to be dangerous the permit authority can issue a building order requiring that it brought to a safe state.
The ABCB is examining the use of non-compliant external cladding products on buildings in Australia to find ways to improve product use and compliance.
What is being done to address issues around non-conforming and non-complying building products?
Nationally, Building Ministers in conjunction with the Australian Building Codes Board (ABCB) are working to deliver a comprehensive package of improvements to tackle the challenges associated with product compliance.
Through the national Building Ministers’ Forum (BMF), Building Ministers including the Western Australian Minister for Commerce and Industrial Relations Bill Johnston MLA are working cooperatively to address safety issues associated with non-conforming and non-complying building products.
A Senior Officers’ Group consisting of representatives from all jurisdictions has been established to report on ways to minimise the risk to consumers, businesses and the community.
At its meeting of December 2016, the BMF agreed to a comprehensive package of measures to improve fire safety in high-rise buildings.
The comprehensive package of measures, which includes measures that Ministers previously requested the ABCB to implement, seek to:
- Reference a contemporary and rigorous testing standard, developed based on international best practice, for full scale testing of the fire performance of external façade systems, which is particularly relevant for new and innovative systems.
- Provide rigorous, contemporary and clear Code requirements to improve application and compliance.
- Provide practitioners with the tools and supporting material to support Code compliance.
- Increase industry awareness of the need to be cognisant to the potential risks associated with non-compliance.
- Enhance on-site checking, auditing and enforcement.
The BMF communiqué is available from the Commonwealth Department of Industry, Innovation and Science website.
The Australian Building Codes Board website contains information about product certification and the reporting of non-conforming building products.
Information including recent developments in regards to non-conforming building products is on the Building Commission website.
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