Recently we conducted a well attended webinar on the subject of the NSW AS1851 mandate that comes into effect in NSW on February, 2025.
Over four hundred attendees signed up and many offered up a variety of questions at the conclusion of the presentation portion of the webinar. Many of these are representative of the overall curiosity about the upcoming changes. As a result, we are publishing them here for the edification of those who will have to meet the mandate’s regulations.
If you have any further questions, don’t hesitate to reach out to us at RedMen and we will endeavour to help you as best we can. With decades of experience, there is little that we haven’t encountered.
AS1851 questions and answers from our webinar
AS1851 Questions | AS1851 Answers |
| What is the specific law relevant to this ‘mandate’? | |
| Why 2012? That was 12 years ago. Have any changes been made since then? | There is a project by Standards Australia Committee FP-001 to review the AS1851-2012 standard, and that will commence soon. However, this will take some time, and all owners and fire companies will need to use the Legislated 2012 version |
| Is this only applicable for NSW? | This is an Australian Standard, however this specific Legislation that requires AS1851 – 2012 is NSW ONLY. Other states such as QLD also legislation. |
| AS1851 requires baseline data to establish the performance benchmark. What if there is no baseline data? | Baseline data is a very important part. However we do encourage people to ensure they have the newest copy of AS1851 -2012 – with most recent amendments, which includes changes to use of baseline data. IF you don’t have baseline data, we can assist you to develop it, and seek out as much information as can be found. In most cases we can find enough information to answer most questions of Baseline Data. Feel free to reach out and we can assist. |
| How do you know what class of building you have? | The Building Class definition is in the front part of the Building Code of Australia BCA, now called the National Construction Code NCC. If in doubt reach out to your local council for a determination or give us a call and we are more than happy to assist. https://www.bcaperformance.com/post/understanding-bca-building-classifications |
| Is FRNSW fire brigade – being a key stakeholder are they involved in the new AS1851 standard? | Fire+Rescue NSW are key important stakeholders in the AS1851 standard development or amendments. However they are generally not involved after the standard is Gazetted. However where poor maintenance can directly involve Fire and Rescue NSW is FALSE Alarms, as Poor Maintenance may be one reason for expensive False Alarms, where Fire and Rescue send Invoices to the Building Owner, for attending False Alarms (Refer the FRNSW Billing terms please). |
| Just a comment. Silent testing should not be done and if done must be recorded that it was customer’s request and that test should not be a pass. Arranging a time that suits all should be made in advance, Silent tests also may affect buildings in many ways including OHS/WHS | Hi Scott- Yes correct – The legislation relates to Building owners and the Service methodology that must be adopted by Fire Protection Companies. The Building owner and Fire Protection company must communicate re the specific site Challenges to be compliant to the legislation, and its requirement of AS1851 – such as EWIS system testing in Health Care Facilities. Records are Critical. We always use a site specific discussion with our valued clients. |
| With the non conformance will they be legislated to be actioned before next AFSS? | Luke, the requirements to be able to endorse an AFSS relates to Performance NOT maintenance. The Approved Practitioner Fire Safety (APFS) will adopt a methodology with a Risk mitigation approach, to be able to determine the Essential Fire Safety Measure (EFSM) continues to perform to the Original performance standard, So you may use AS1851 to help to confirm that performance. |
| Would you issue a critical defect for a passive fire penetrations if not treated? | All defects that are critical in nature relates to the inability of the Essential Fire Safety measure to be able to operate correctly. This always depends on the circumstances. The Passive Penetration failure circumstance, we may deem as Critical, however this would be dependent on the circumstances. In short we always adopt a Fire Safety Risk approach. HOWEVER its VERY important to remember AS1851 relates to the Maintenance of EXISTING EFSM and is not a trigger to upgrade a site to current standards. So IF the penetration was NOT treated we would first try to determine the requirements at time of construction. |
| What is the role of a Work Health and Safety professional in this standard and the new legislation? | The WHS professional, is very important in assisting in receiving the appropriate records from the Fire Safety Service Company. |
| James you don’t need to drain and replace tank liners every ten years!!! Non draining inspection and cleaning is acceptable. | Hi Mark, That is correct and Redmen have a Drone Submarine we use to carry out those inspections, so we don’t have to drain the tank for inspection. |
| Does not AS1851 exclude the need for destructive testing? Elements are excluded if inaccessible. | According to Australian Standard AS 1851, destructive testing is generally not needed for routine maintenance unless specifically required or safely accessible. AS 1851 focuses on maintaining fire protection systems through inspection and testing without causing damage. The standard also allows for certain inaccessible components—like those within walls or structural barriers—to be excluded from maintenance unless they can be safely reached. However, it encourages property owners to ensure access where possible for full compliance. If there are suspected issues in inaccessible areas, non-destructive testing may be recommended to check for defects without compromising the structure. |
| In the case of a building having fire extinguishers, does the monthly testing require to be done by Fire Service provider. Currently we are carrying out inspection every 6 month for FE, Hose & Fire alarm panel. Do we need to change to monthly and pay extra? | There is no requirement for extinguishers to be tested monthly under AS1851. You do have to do them 6 monthly. This has to be done by a competent person. This is someone who has the insurance and preferably has a Cert 2 or 3 in Fire Protection. |
| What about fire dampers and smoke control system testing? | We recommend that you talk to your mechanical providers making sure that they are looking after the AS1851 requirements. We are not a mechanical services company but a fire protection company. We do work with a range of mechanical services providers that work with fire dampers and smoke control. |
| Do you engage the building private certifier to ensure compliance with the BCA? | No. Not a BCA related item. We don’t engage with private certifiers, maintaining an arm’s length scenario. |
| Will Exit & Emergency Lighting be adopted into AS1851? | We can’t speak to that. That is a question for the FPAA or other stakeholder in the Australian Standards creation. |
| Tell me a building owner who knows what AS1851 really means? or has read and understand AS1851? | That is understandable that you’d doubt that. That is what a good fire protection company is for. To help them remain legally compliant. |
| As part of this standard, is it the Owners responsibility to maintain a fire asset register? | Yes. This is typically done by the fire contractor. |
| If Redmen are signing off additional measures e.g…. lift, air conditioning as part of the inspections do those additional contractors need to be coordinated to be present for the tests? | That is dependent on individual situations. What they need to do for that particular testing determines this. We may need to be there is a fire panel is put into test mode. It comes down to the specific measure being addressed. |
| Surely AS2293.2 will affect the AFSS part 5 as without the EEL (emergency exit lighting) the POT (path of travel) cannot be endorsed. | 2293 is not part of AS1851. We recommend that the EEL testing occur on a 6 monthly and annual basis. |
| Is there nothing on fire doors? | They are definitely in there. It is part of the passage section. In sole occupancy units, that can be done annually rather than 6 monthly based on an exemption that you can obtain. |
| What would happen if during a test you no longer have the required flow from the street due to Sydney Water over time reducing the flow due to leaks in their system? | That has happened to several of our clients. One of them lost 50% of their flow due to a large building going in on their street. You should speak to Sydney Water or your utility in your area. They do have a minimum performance that they are supposed to provide. The street hydrant is not a measure that you are responsible for. Some clients have had to install pumps or tanks in order to bring up their pressure to what is needed. About a decade ago, Sydney Water reduced their pressure across their network because they were experiencing a range of blowouts. |
| Can you explain the mechanical systems testing? | Redmen does offer the Interface testing between the Fire System and the mechanical services. However repairs to mechanical equipment that may be required, we subcontract to others and we in fact send the COST price to our clients and they can go direct IF they wish, to save money. |
| In terms of 6 monthly emergency management training for wardens/occupants – does this now mean both sessions need to be face to face, and both sessions require a practical evacuation? As opposed to yearly under AS3745 | Yes. We can go through your requirements. We can try to resolve any clash which happens due to specification of AS3745 on you AFSS. |
| If the building does not have sprinkler system and other safety measures does that require them to have one installed? | Any requirement will be driven by a DA, a CDC or a Fire Order from FRNSW or a Notice of Intent to issue a Fire Order from Council. |
| Where do you get a copy of this AS1851 for some bedtime reading? | From the Australian Standards website. It costs about $200. Your Fire Company will be able to help you with specific questions. |
| Have had many private owners contacting us and enquiring about the requirement of fire measures to be installed and can we do and how much! Ooops. Currently they have no or very little Fire protection. | To proceed with your request, it would be best to contact our team 1300 733 636 so we can identify the necessary measures. Once we have that information, we will be able to send you an accurate quote. |
| If the hydrant does not provide the pressure, then we are seeing that councils are requiring on site tanks. | That is correct. Some clients have had to install pumps or tanks in order to bring up their pressure to what is needed by Council. |
| What about lightweight construction, services penetration, structural steel elements, and ductwork protected with fire protection coatings (passive)? | The challenge here is baseline data. Easy for a newer building |
| When interconnected fire alarms are needed under a council fire order are wirelessly interconnected alarms acceptable? | Under Australian Standard AS 1851, when a council fire order requires interconnected fire alarms, wirelessly interconnected alarms can be acceptable, provided they meet specific performance criteria and are approved by relevant authorities. Wireless interconnection is permitted as long as the alarms comply with AS 3786, which covers smoke alarms, or other applicable standards governing fire detection systems. The wireless system must ensure reliable communication between devices, activating all alarms simultaneously in the event of a fire. It’s essential to confirm with the local council or fire authority to ensure wireless interconnection aligns with their requirements, as some jurisdictions may have specific guidelines on the types of interconnection methods that are acceptable. Additionally, regular maintenance and testing in accordance with AS 1851 should be conducted to ensure all interconnected alarms are functioning properly and maintain compliance. |
| Is it law to have a sign for Emergency Assembly location? | Not sure but we recommend it to demonstrate accountability, and it doesn’t cost a lot. We’re glad to help you here. You will be required under AS3745. |
| Testing of sprinkler heads in a 24 year old building will this need to be carried out next year? | Yes. You don’t get to wait another 25 years. |
| Does any authority responsible for building inspection like civil defence or any fire departments who will impose penalties in case building is not complied by AS1851 | We believe it will be councils and FRNSW. As FRNSW go into buildings on fire, they want hydrants and fire panels working. Civil Defence is not a term we use here. You may find it more in use in the Middle East. |
| Where is AS1851 endorsed by the owner/contractor, will this be referenced within the AFSS or a separate document? | Not on the AFSS currently. It is a separate form. The building owner is responsible to make sure it is endorsed correctly. |
| AS1851 precludes any audit if original certification of passive elements in an building, and precludes any elements not accessible… many inspectors don’t realise this… comments? | Australian Standard AS 1851 focuses on maintaining accessible fire protection systems, not certifying or auditing passive elements (like fire-rated walls) without original documentation. It excludes inaccessible elements unless they can be safely reached without damage. Inspectors should understand that AS 1851 doesn’t cover auditing passive systems without prior certification, and original compliance documents are needed for verification. |
| In a building of 154 apartments would the sprinkler heads be tested in each apartment? | No. A sampling process is done. The physical sprinkler in each apartment does not get tested. The main array in the fire room is where the testing would take place . A good contractor would do this in the common areas. |
| (refer section 12.1 and C12.2.4.1) | |
| In the case of Strata, I assume the person appointed to sign the AFSS is the person ultimately responsible (as the Owner’s Agent) for ensuring all the standards are met for AS1851-2012? | Yes. That is a logical assessment of where it will fall. Typically it would be the owner’s agent. We’d advise that you have plenty of documentation. It is tough for the strata management industry. |
| Please tell us a bit more regarding 5 yearly test? | There is a whole range of different 5 yearly tests. Have a talk to your fire protection specialists. Sprinklers, detection, hydrants, extinguisher, mechanical etc. Hydrostatic testing is the one we get most asked about. |
| Is monthly test for FIP required for non monitored system? | Yes it is. Fire panels fall under AS1851. |
| Is there any change to smoke detectors in SOUs (single occupancy units) that are not connected to a FIP? | Smoke alarm vs smoke detectors (which go back to a FIP). Smoke alarm is both an alarm and detector and those go back to the fire panel. All makers of smoke alarms say that they have a 10 year life. |
| sCan we continue doing silenced monthly test after 13 February? | Case by case basis. Please reach out and we will try to accommodate you. |
| The 10 yearly fire detection test is not on the schedule, why would this be? | It should be in AS1851. |
I guess Fran is asking for standalone battery operated smoke sensors which is not connected to FACP | |
| What about the items stated in AFSS are not one of that 36 modules listed by FPAS? Should they be maintained by APFS and signed off by competent persons? | AFSS is about performance. Building owner needs to ensure competent person. |
If you have any further AS1851 questions, just contact us here at RedMen.
