Explanatory Notes
Draft Queensland Development Code (draft QDC), Mandatory
Part 3.7 – Farm buildings
Background
Building Code of Australia
The Building Code of Australia (BCA) provides the classifications and construction
standards for buildings in Australia.
When making a decision about the classification of a building, a building certifier
must consider the purpose for which the building is designed, constructed or adapted
to be used, and the extent to which people will be occupying the building. Once a
building is given a particular classification, all of the BCA requirements relevant to the
classification will apply. As the BCA is a performance-based code, alternative
solutions can also be developed to meet the performance requirements.
Farm buildings can be used for a range of purposes, such as storing farm machinery,
storing and packaging of produce and animal husbandry. Farm buildings are not
dealt with specifically under the BCA, however, most will be covered by
classifications 7a (car park), 7b (storage) or 8 (producing goods for sale). Simple
storage sheds, such as haysheds, could also be classified as class 10a
(outbuildings).
Changes in the agricultural industry in recent years, however, have created difficulty
with the BCA requirements for some farm buildings. Moves towards larger scale,
more intensive farming and production techniques plus improved technology, have
changed how these buildings are used and reduced the fire and life safety risk
associated with them. This had led to uncertainty and inconsistency in how farm
buildings are assessed.
Australian Building Codes Board
In response to concerns that the current BCA requirements may not be appropriate
for contemporary farm buildings, the Australian Building Codes Board, which
maintains the BCA on behalf of all states and territories, has committed under its
2014-15 work program to develop provisions specifically applicable to buildings used
for agricultural purposes.
The provisions are expected to be included in the 2016 edition of the BCA, at which
time Queensland may choose to adopt all or some of the BCA provisions.
Queensland requirements for farm buildings
The Building Regulation 2006 (BR) currently provides certain requirements for class
10 farm buildings. Under Schedule 2, Section 4 of the BR, class 10 farm buildings
located more than 200 metres from a property boundary or road are exempt
development. No building assessment provisions apply to such a development.
If these buildings, other than those situated within Wind Region C, are located closer
than 200 metres to a property boundary or road, they may be self-assessable
development as per Schedule 1, Section 13 of the BR, provided that:
•
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they are associated with a single detached house; and
their maximum size complies with the following limits: area 10 metres squared,
length 5 metres, and height 2.4 metres.
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Self-assessable development must meet the building assessment provisions,
however, no building development approval is required.
Building Codes Queensland (BCQ) provided guidance to industry about selfassessable and exempt farm buildings in Building and Plumbing Newsflash No. 69
and 70, issued in August 2000. The Newsflashes also included information about the
appropriate classification of farm buildings under the BCA.
Other jurisdictions
South Australia and Victoria have both taken steps to address issues relating to farm
buildings. In South Australia, a Minister’s Specification SA H3.2 – ‘Concessions and
additional requirements for farm buildings’ has been in effect since 2004.
The Minister’s Specification was developed following a court decision involving a
large chicken broiler shed which the applicant had proposed to classify as a 10a, but
was found to be a class 8. The case recognised that the BCA provisions for a class 8
building were more suitable to a large industrial factory setting, rather than farming
operations.
The Minister’s Specification provides both concessions and additional requirements
in relation to the BCA requirements for fire resistance, firefighting equipment, access
and egress, emergency lighting and exit signage. It applies to buildings used for
agriculture, cropping, grazing, animal husbandry, intensive animal keeping,
horticulture or dairy. The South Australian Government has indicated that the
Minister’s Specification has provided consistency and certainty since its introduction
and has generally served the sector well.
In January 2013, Victoria issued a Practice Note to provide guidance in classifying
and assessing farm buildings against the BCA.
Consultation to date
Key representatives from the building and farming sectors, including the Queensland
Farmer’s Federation, Agforce, Growcom and the Housing Industry Association, have
been involved in the development of the draft QDC through an industry working
group.
BCQ also sought comment from industry, local governments and the community on
the proposal in a series of public consultation sessions held at 13 locations across
the state during June and July 2014.
Policy objectives and the reasons for them
The purpose of the draft QDC is to vary specific BCA provisions considered
inappropriate or impractical for farm buildings, while maintaining minimum levels of
fire and life safety protection in these buildings.
Many farm buildings share features that inherently reduce the risk to life safety, such
as low occupancy and occupation for very short time periods. The current technical
requirements that apply to class 7 and 8 buildings generally relate to building
containing higher risk uses than those carried out in farm buildings. Nevertheless,
farm buildings with these classifications are required to provide the same level of fire
and life safety features, often at a significant cost.
The regional or rural setting of many farm buildings can also make it difficult to justify
the cost of installing some fire safety features. For example, many regional and rural
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areas of Queensland are not serviced by reticulated water so a fire hydrant system, if
installed, would rely on the provision of on-site water storage for fire-fighting
purposes. Providing water storage tanks increases the cost of the hydrant system in
terms of initial installation and ongoing maintenance. Additionally, the distance for a
fire brigade to travel to attend a fire at a farm building can be extensive—by the time
a fire brigade arrives at the site of the fire, it may be well-established and have
largely consumed the building. The role of the fire brigade at this stage may simply
be to extinguish the fire.
Anecdotal evidence from industry indicates that a growing trend in Queensland is to
classify farm buildings incorrectly as class 10 buildings, in order to avoid costly fire
and life safety features. While the current BCA requirements for some farm buildings
can be impractical, there are risks in not having any consideration for these features.
The proposal is expected to cut costs and reduce red tape for expanding farm
industries by providing a more tailored approach for farm buildings. In addition, the
draft QDC will apply across the state, which will provide certainty and consistency in
the assessment of farm buildings.
Achievement of policy objectives
The draft QDC provides performance requirements and acceptable solutions for the
design and construction of all new farm buildings and significant renovations to
existing farm buildings in Queensland.
The draft QDC includes concessions for particular deemed-to-satisfy provisions for
fire and life safety in the BCA that apply to farm buildings. Some of the concessions
are presented as alternatives rather than replacements for those provisions. This
allows for the option of complying with the BCA deemed-to-satisfy provisions or the
acceptable solutions in the draft QDC which contain some less onerous
requirements.
The concessions have been developed taking into account the fire and life safety risk
associated with farm buildings. That risk is highly dependent on the use of the
building and the number of people usually present in the building at one time. Given
the wide range of purposes farm buildings can be used for, a ‘one size fits all’
approach is not appropriate.
For example, while many farm buildings used in animal keeping industries have low
human occupation for short periods of time, a farm building used for packing fruits
and vegetables may have a high number of workers occupying the building all day.
Many of the current BCA requirements are suitable for uses involving high occupancy
and it may not be appropriate to provide concessions for certain aspects such as
egress. However, a building located in a regional or rural setting may experience
issues in terms of unnecessary costs incurred as a result of impractical or ineffectual
fire safety requirements, regardless of its occupancy level.
To ensure the appropriate levels of fire and life safety protection are provided, the
draft QDC distinguishes between occupancy densities.
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Notes on provisions
Purpose
The purpose of the draft QDC is to vary some of the requirements in the BCA that
apply to farm buildings, to ensure the requirements are appropriate for those
buildings.
Commencement
Subject to approval by Government, it is anticipated that the draft QDC will
commence by late 2014.
Application
The draft QDC will apply to all new farm buildings and significant alterations to
existing farm buildings.
The draft QDC provides six Performance Requirements for farm buildings, as follows:
• egress
• water supply for fire-fighting
• fire hose reels and fire extinguishers
• emergency lighting
• exit signs
• vehicle storage farm buildings.
It should be noted that not all Performance Requirements apply to all farm buildings.
As shown in Table 1 of the draft QDC, the relevant Performance Requirements
depend on how the building is categorised i.e. as a low occupancy farm building, high
occupancy farm building, or vehicle storage building.
For a low occupancy farm building, Performance Requirements P1, P2, P3 and P4
will apply. For a high occupancy farm building P2 and P3 will apply. For a vehicle
storage farm building P6 will apply.
The requirements of the draft QDC vary some, but not all, of the requirements in the
BCA. If a requirement of the BCA has not been varied by the draft QDC, the
requirement continues to apply in full.
Definitions
Some of the important definitions in the QDC are:
agriculture means:
(a) growing, producing or harvesting:
(i) fibre, timber, foliage or the like; or
(ii) matter or things intended for human or animal consumption (whether
immediately or after a further process); or
(b) animal husbandry, aquaculture, dairy farming, floriculture, forestry, horticulture,
intensive animal keeping, apiculture, or viticulture; or
farm building means a building (being either a class 7 building or a class 8 building)
on land used primarily for agriculture.
The significance of the definitions of ‘farm building’ and ‘agriculture’ is to specify the
type of farm buildings the draft QDC applies will apply to. A farm building is a class 7
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or 8 building that is located on land primarily used for any of the range of activities set
out in the definition of agriculture.
The use of the qualifier “used primarily” in the definition of farm building recognises
that other activities may also be carried out on agricultural land. Some working farms,
for example, also provide tourism accommodation to the public and offer tours,
activities and entertainment to guests. However, the land must be used primarily for
the activities and uses outlined in the definition of ‘agriculture’ in order for the draft
QDC to apply.
It is understood that many smaller farming operations nowadays are self-contained,
both growing and packaging their own products on-site. The requirement for a farm
building to be located on agricultural land is designed to exclude large-scale
operations that may deal with agricultural products, such as eggs or livestock, but are
only concerned with processing, treating or packaging these products, for example,
an abattoir or sawmill. This is because the current requirements under the BCA are
more suited to the intensive assembly or manufacturing processes that tend to be
carried out in these buildings. Additionally, these buildings are more likely to be
located in an area where a fire brigade is able to attend quicker.
Conversely, in the case of a produce farm where vegetables are grown, harvested
and washed and packed on-site before being transported to another location for sale,
the building used for packing the produce would considered a farm building.
high occupancy farm building means is a farm building where the number of
persons usually working in the building is greater than for a low occupancy farm
building.
low occupancy farm building means is a farm building where the number of
persons usually working in the building is no more than the greater of the following:
(a) 1 person per 200 metres squared of the total floor area of the building; or
(b) 6 persons.
vehicle storage farm building means a farm building that is used primarily for the
parking of motor vehicles.
The significance of these definitions is to distinguish farm buildings based on their
occupancy and use. These are the factors that influence the fire and life safety risk of
a building. Providing different categories of farm building ensures that the acceptable
solutions applied to them are appropriate to the building’s risk.
The definition of ‘low occupancy farm’ building limits the maximum occupancy of the
building. The total number of people working in a low occupancy farm building cannot
exceed 1 person per 200 metres squared of the total floor area, or 6 people—
whichever of these numbers is greater.
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Example 1
For a farm building with an area of 800 metres squared, 1 person per 200 metres
squared equates to 4 people. The greater of 4 and 6 is 6; this is the maximum
number of people who can work in the building for it to be considered a low
occupancy farm building.
Example 2
For a farm building with an area of 1600 metres squared, 1 person per 200
metres squared equates to 8 people. The greater of 8 and 6 is 8; this is the
maximum number of people who can work in the building for it to be considered a
low occupancy farm building.
Once the number of people working in the building exceeds the maximum occupancy
determined by this formula, it becomes a high occupancy building. If in Example 2
above, there were usually 11 people working in the building that has an area of 1600
metres squared, it would become a high occupancy farm building. This is unless the
farm building is used primarily for the parking of motor vehicles, in which case it
becomes a vehicle storage farm building and acceptable solutions are applied
appropriate to its specialised use.
Similar to the definition of ‘farm building’, the definition of ‘vehicle storage farm
building’ refers to the building’s primary use. A large shed used to store farm vehicles
may also be used to store machinery, fuel or feed—this use may still be acceptable if
the majority of the shed’s space was designated for the parking of vehicles. However,
if part of the building also serves as a workshop or similar where there is a consistent
level of human occupation, it would not be appropriate for it to be considered a
vehicle storage farm building.
Performance requirements (P) and Acceptable Solutions (A)
P1 and A1
P1 is designed to vary certain egress provisions under the BCA. The acceptable
solutions recognise that the design of some low occupancy farm buildings and
configuration of machinery can make it impractical to provide exits in the BCA
required locations.
For example, A1(1) allows a maximum travel distance to an exit of 40 metres. Where
a person can, within 20 metres, reach a point where alternative routes to an exit are
available, the maximum travel distance to the exit can be 60 metres.
To complement A1(1), the distance between exits that are required as alternative
means of egress is increased to not more than 80 metres apart under A1(2).
Figure 1 (on the following page) illustrates an example of the required distances to
and between exits in a farm building.
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Figure 1
Single exit
Alternative exits
For a going and riser, landing, balustrade or other barrier, handrail, fixed platform,
walkway, stairway or ladder in a farm building, A1(3) provides the choice to comply
with the relevant provisions of the BCA or with Australian Standard 1657.
A1(4) allows the use of a 700 millimetre step in the threshold of an exit. Farm
buildings used for the keeping of pigs and chickens often incorporate low-height
concrete walls along the sides of the building which are used for cleaning, clearing
and pest control. This variation can only be applied, however, in cases where BCA
Volume 1, clause D3.4 – ‘Exemptions’ is applicable. This clause provides an
exemption from the disability access requirements of the BCA and can be applied, for
example, where activity within a building would pose a health or safety risk for people
with a disability.
P2 and A2
P2 is designed to ensure a farm building has adequate water to allow a fire brigade
to undertake fire-fighting operations.
To achieve this, a farm building may comply with E1.4 of the BCA, which relates to
the provision of a fire hydrant system. E1.4 requires the installation of a fire hydrant
system to be in accordance with AS 2419.1:2005. A2(1) varies AS 2419.1 so that this
clause is amended to require 2 hours’ water supply for a fire hydrant installation
instead of 4.
Alternatively, a farm building may comply with A2(2), which allows the use of an onsite storage tank to provide adequate water. This solution ensures the needs of the
fire brigade are met by providing specific requirements for the water storage tank. For
example, the water storage tank must have, to be compatible with the equipment of
the fire brigade, a hard suction outlets comprising of a female coupling of British
Coventry type, 125 millimetre diameter and a thread size of 3 threads per inch, and a
50 millimetre ball valve and male camlock coupling. Where the building is not within a
40 minute response time from the nearest QFES urban or auxiliary fire station,
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however, the 125 millimetre British Coventry coupling is not required. This is because
rural fire brigades use only small suction connections.
P3 and A3
P3 ensures that fire-firefighting equipment is provided in a farm building to allow
occupants to undertake initial attack on a fire.
P3 can be achieved by installing fire hose reels and fire extinguishers in accordance
with the relevant BCA provisions (E1.4 and E1.6 respectively).
Alternatively, A3(2) allows a farm building to forgo the installation of fire hose reels
and instead details specific requirements about the type, size and installation of
portable fire extinguishers that must be provided in the building. The location and
distribution of extinguishers varies depending on whether the building has required
exits or is open-walled. This solution also prescribes a fire extinguisher for any room
containing flammable materials or electrical equipment that is attached to a farm
building.
To ensure that occupants are aware of the location of fire extinguishers, A3(2)
requires the installation of extinguisher location signs, which must be done in
compliance with certain clauses of Australian Standard 2444:2001.
P4 and A4
P4 does not amend the BCA provisions relating to emergency lighting. However, it
does provide an avenue for some low occupancy farm buildings to use alternative
lighting commensurate with their function and use.
In some farm buildings, no artificial lighting is provided and the operations are all
carried out under natural lighting conditions. Additionally, some farm buildings are
connected to back-up generator systems that will ensure sufficient light is
automatically provided in the event of a power failure. In both cases, emergency
lighting is not considered necessary.
P5 and A5
P5 varies the BCA to allow the use of non-illuminated exit signs in certain cases. In
some farm industries which involve the keeping of animals in a building, the animals
kept are sensitive to the level of light to which they are exposed, and the duration of
exposure. The use of illuminated or photoluminescent exit signage in these buildings,
as is currently allowed under the BCA, can have a potentially profound impact on
animals.
A non-illuminated exit sign that may be provided in a low occupancy farm building
must consist of white symbols on a green background, with Australian Standard
2293.3:2005. providing further specific requirements for the appearance of the exit
sign face. Non-illuminated exit signs must be installed in compliance with parts of
Australian Standard 2293.1:2005.
P6 and A6
Many farms use a number of vehicles in their daily operations, such as tractors, quad
bikes and harvesters, which are stored in large sheds or carports. These buildings
have limited occupancy and are used in a similar manner to a private garage.
However, under the BCA, a building used for storing more than three vehicles that is
not associated with a residence (class 1 building) is classified as a class 7a. The
requirements under the BCA that apply to class 7a buildings are more aligned with
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buildings used as car parks, a higher risk use than that of a vehicle storage farm
building.
P6 applies the same standards to vehicle storage farm buildings that apply to class
10a buildings (non-habitable buildings and structures). As some vehicle storage farm
buildings can be quite large, the draft QDC applies additional requirements where the
building is not open-walled, those requirements being for:
• egress, in accordance with A1(1) and A1(2) of the draft QDC; and
• fire extinguishers, in accordance with A3(2) of the draft QDC; and
• exit signs, in accordance with A5(2) of the draft QDC.
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