In an emergency situation emergency lights should run on their backup battery for at least 90-minutes. Australian Standards require that exit & emergency lights be tested every 6 months. Exit and emergency lights have a shorter lifespan when compared to non-emergency lights.
Paths of travel & safe passage
Maintaining exits, and clear paths of travel to exits is critical in ensuring occupants can escape in the event of an emergency.
For fire safety purposes the requirements for safe passage come from:
- Environmental Planning and Assessment Regulation 2000 Part 9 Division 7, and
- Part D of the Building Code of Australia.
Section 5 of the Annual Fire Safety Statement (AFSS) requires an Accredited Practitioner (Fire Safety) to sign off on the inspection fire exits and paths of travel to fire exits, (Part 9 Division 7).
This division is broken into 4 clauses:
- 183 Fire safety notices
- 184 Fire exits
- 185 Doors relating to fire exits
- 186 Paths of travel to fire exits
This legislation is applicable to all buildings and its intention is to ensure that nothing is placed in an exit, exit door or path of travel to an exit that may impede the free passage of persons in any way.
Clause 186 places the onus on the building owner to ensure any stairway, passageway or ramp serving as or forming part of a building’s fire exit AND any path of travel to the buildings fire exit is kept clear.
This legislation is relatively straightforward, an excerpt is below but we recommend reading it in full here.
The Environmental Planning and Assessment Regulation is NOT prescriptive. That is, it doesn’t tell us exactly how much clearance there must be in exits, or paths of travel to exits. This is where we defer to the Building Code of Australia, which goes on to specify not only the required clearances, but also things like the number of required exits, the construction of exits, and many other things besides. We’ve only selected a handful of the most relevant clauses to elaborate on in this article.
Dimensions of exits and paths of travel to exits
For most buildings, BCA D1.6 tells us the width of an exit, or path of travel to an exit (excluding doorways) must not be less than 1m.
Roller shutters over exit doors for extra security
BCA D2.19 prohibits the use of roller shutters or tilt-up doors on required exits UNLESS
- It serves a Class 6, 7 or 8 building or part with a floor area not more than 200 m2; and
- The doorway is the only required exit from the building or part; and
- It is held in the open position while the building or part is lawfully occupied
We often see this clause breached in warehouse / industrial properties where occupants install a roller door OVER the existing entry/exit door.
Locks on exit doors, or on doors in paths of travel to an exit
Generally speaking, BCA D2.21 requires that a door in a required exit, forming part of a required exit or in the path of travel to a required exit must be readily openable without a key from the side that faces a person seeking egress, by a single hand downward or pushing action on a single device which is located between 900 mm and 1.1 m from the floor
There are exclusions to the above such as Sole Occupancy Units (SOUs) in Class 2 & 4 parts of building for example
There are also some alternatives that may be able to be applied in some circumstances such as having automatic fail-safe devices that can automatically unlock the door on power failure or activation of a fire alarm in the building.
Warehouse, storage & industrial properties
Paths of travel & safe passage is major concern in warehouses, storage facilities & light industrial properties.
We often come across suites/units where the occupants have erected warehouse shelving along every wall, or where every square inch of floor space is stacked with boxes or stored goods. In some cases, this drastically reduces the width of the path of travel to well under 1m (required under BCA D1.6).
We also often see fire exits, exit doors and fire equipment obstructed or completely blocked by storage and shelving and fire isolated passageways being used for storage.
Whist the fire contractor has an obligation to report on these breaches ahead of signing Section 5 of the AFSS, it is the owners of the building, who have a year-round obligation under clause 186 of the EPAR to ensure safe passage is not compromised in these buildings.
It is vital that exits, paths of travel to exits and access to fire equipment is kept clear and unobstructed at all times.
Some photos below show actual paths of travel breaches identified by Civil Fire in warehouse type properties.
Fire fighting equipment obstructed
When paths of travel are comprised, we often also find that fire fighting equipment is obstructed, or difficult to access. Not surpassingly, this is not allowed under the fire safety standards.
AS2441 2005 – Section 10.1
Access to fire hose reels shall not be obstructed, e.g., from items such as furniture.
Occasionally, we see issues with restricted paths of travel due to the storage of goods in common area’s of the property these items often include indoor plants, shoe racks, side tables and baby strollers.
Mostly however, paths of travel issues arise when owners install additional locks on common area doors in order to make their building more secure. For example, after possessions are stolen from a basement garage, the owners might install locks on all doors into and out of the basement garage. This is a clear breach of the legislation.
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