NCC Queensland variation: bonded laminate

19 October 2018

The government was expected to introduce a Queensland variation to the National Construction Code to remove the deemed-to-satisfy concession for bonded laminated materials.

***UPDATE***

Removal of the concession is also being debated nationally as part of the amendments to the NCC, which will take effect from May 2019. Despite this, the Queensland variation was expected to go ahead within two to three weeks.

Master Builders, along with other industry groups, raised concerns with government as to the scope and the timing of the change.

And they've listened. 

We've just received an update that the change has been put on hold until the outcomes of the national debate are known. 

Given that the change is still likely to go ahead at some point over the next six months we are continuing to recommend that you take action now to understand where bonded laminate materials are used in your projects.

If they are used on a Type A or Type B construction where a non-combustible material is required, look to the ‘evidence of suitability’ provided for the product. If the evidence relies on Volume 1 Section C1.9 (e)(vi) of the NCC then expect to need a performance solution for the continued use of the material as a non-combustible material. There are likely to be some exceptions for sarking, laminated glass and glazing films but the details are not yet confirmed.

More information will be available in the new year and we will continue to keep you in the loop.


Currently, the deemed-to-satisfy concession allows certain bonded laminated materials to be regarded as non-combustible (Volume 1 Section C1.9 (e)(vi)). However, we have been advised to expect this concession to be removed in a Queensland variation to the NCC in the next 2-3 weeks.

This will mean that it will be necessary to prove that bonded laminated materials are a non-combustible when used where a non-combustible material is required. To do this will require a performance solution, resulting in a more costly and time consuming approval process.

For existing buildings captured under the combustible cladding regulation (Type A & B, Class 2 -9 built or significantly altered after 1994), this change is already in place.  Fire Engineers have already been directed to not rely on the concession in their fire risk assessments.

Removal of the concession is also being debated nationally as part of the amendments to the NCC to take effect from May 2019. However, the Queensland variation will go ahead regardless of the outcome of the national debate and is expected to take effect within two to three weeks.

Our concerns

Timing

While the normal transitional arrangements will apply, two to three weeks is an unrealistic time frame to introduce such a significant change, as supply arrangements and contracts will already be in place. Projects which are underway, and therefore exempt under transitional arrangements, will be compromised nonetheless, as owners, insurers and certifiers are unlikely to accept a building which does not meet regulations current at handover.

Scope

In making the change the government is seeking to address the problem of combustible cladding in commercial buildings. However, a large range of products can be considered bonded laminated materials from aluminium composite panels, to safety glass and timber products, such as plywood. They can also have a wide range of uses beyond external cladding – common walls, flooring, internal walls, etc.

Our concern is that it is currently not clear what the full impact of this change will be. The government has also not yet provided any analysis of the scale and scope of the likely impact.

Our recommendations

While we support all efforts to strengthen the fire performance of buildings, we are keen to ensure the government follows a prudent process that assesses the full scale and scope of the change. The potential for unintended consequences with this change is high.

We’ve recommended the government should delay the implementation of the Queensland variation until the full implications are understood and industry is given time to adjust. We strongly recommend utilising the timeline already in place for National Construction Code amendments of May 2019.

What you should do now

Given the potentially short timeframe for this change, we recommend that you take action immediately to understand where bonded laminate materials are used in your projects. If they are used on a Type A or Type B construction where a non-combustible material is required, look to the ‘evidence of suitability’ provided for the product. If the evidence relies on Volume 1 Section C1.9 (e)(vi) of the NCC then it will be necessary to use a performance solution for the continued use of the material as a non-combustible material.

Questions?

Contact us on 1300 30 50 10 or email us.

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