LETTER TO THE EDITOR: We write in response to a published article in The Fifth Estate regarding the proposal to install home fire sprinklers in residential accommodation for people living with a disability.
While we welcome open public discourse on residential building standards, the article in question contains key factual inaccuracies, misinterprets statutory regulatory frameworks and fundamentally misrepresents both the purpose and broad-based coalition behind the Class 1c Proposal for Change.
We request that The Fifth Estate publish this response in full to ensure your readers receive an accurate, evidence-based account of the regulatory landscape, safety data and cost frameworks surrounding fire protection for vulnerable Australians.
The article incorrectly asserts that “Schedule 1 of the NDIS Specialist Disability Accommodation (SDA) Rules sets out which NCC class applies to each SDA Classification”.
This is incorrect. Schedule 1 of the NDIS SDA Rules 2020 defines SDA Building Types (such as apartments, villas, houses, group homes) based on dwelling design, resident count and functional layout.
It does not define or mandate National Construction Code (NCC) building classes (such as Class 1a, 1b, 2, 3, or 9c). The determination of an NCC building class rests entirely with the registered building certifier or surveyor under relevant state and territory legislation, based on the intended purpose for which it is designed, constructed or adapted to be used.
In practice, SDA dwellings for two or more unrelated residents with disability are frequently classified as NCC Class 3 (residential care) by building certifiers. This imposes complex institutional/commercial fire protection requirements – such as commercial-grade sprinkler installations, fire doors, and commercial emergency lighting – on what is meant to be a residential home. The over engineering and high cost of these commercial requirements have led to projects being scrapped at a time when housing affordability is critical.
The article frames our advocacy as an attempt to “restrict Class 1 buildings” and “force all SDA to comply with an institutional standard”.
This completely flips the reality of the proposal. The proposal put forward by Housing Industry Association and strongly supported by the Home Fire Sprinkler Coalition Australia (HFSCA), SDA Alliance and key industry stakeholders creates a new domestic sub-classification: “Class 1c”.
Rather than forcing participants into institutional Class 3 facilities, Class 1c is designed to ensure participants can safely choose to live in domestic Class 1 homes, with appropriate protection.
Class 1c retains all the accessibility, amenity and domestic features of a standard Class 1 family home, but adds two essential life-saving domestic fire safety measures: multiple interconnected smoke alarms throughout the dwelling for early warning; and a fit-for-purpose, cost-effective home fire sprinkler system.
This compromise removes the legal ambiguity faced by certifiers, avoids forcing residential homes into Class 3 commercial classifications, and protects participant choice while delivering appropriate safety.
The article attempts to characterise this initiative as a narrow, industry-backed campaign. This ignores the broad consensus supporting the proposal. HFSCA is a non-profit, strategic alliance comprising the Australasian Fire and Emergency Services Authorities Council (AFAC) – representing all fire brigades in Australia – partnered with the Fire Protection Association Australia and the Fire Industry Alliance, the national leaders in the fire protection industry.
HFSCA earns no commercial revenue from its activities and relies entirely on grants and voluntary contributions to advance public safety. The Class 1c proposal has earned widespread backing across public safety agencies, disability sector advocates, industry subject-matter experts and regulatory authorities.
The article cites high figures, ranging up to about $60,000 plus annual inspection fees, claiming these represent the cost of residential fire sprinklers. These figures reflect high-end commercial/industrial systems (Class 3 solutions), not the domestic systems proposed under Class 1c.
HFSCA and its partners are acutely aware that commercial fire systems are economically unfeasible for smaller SDA dwellings. The proposed Class 1c standard leverages fit-for-purpose domestic sprinkler systems similar to the FPAA101D/H designs: standards that are referenced in the NCC as Deemed to Satisfy solutions for mandatory sprinklers in specific shared residential buildings.
These tap directly into existing domestic water supplies, leveraging off the existing water infrastructure and eliminating costly dedicated commercial mains and heavy ongoing maintenance.
During the Australian Building Codes Board’s proposal for change process for NCC 2019, which successfully introduced mandatory fire sprinkler systems into identified mid-rise residential buildings, the required cost-benefit analysis demonstrated net cost savings for builders and occupants through regulatory concessions and trade-offs.
We fully support a similar approach for Class 1c, where the inclusion of domestic sprinklers is matched with regulatory trade-offs against onerous commercial/industrial requirements.
Australia records an average of 64 preventable residential fire fatalities each year. National and international research consistently demonstrates that automatic fire sprinklers cut fire fatalities by more than 80 per cent and property damage by more than 70 per cent.
The article’s claim that the Class 1c proposal “offers no proof a mandate would save a single life” is patently untrue. The article’s author has been provided with examples of international research that consistently demonstrates the life-saving benefits of fire sprinklers.
While early detection tools such as interconnected smoke alarms are critical, they only provide a warning; they do not suppress, control or extinguish a fire.
For NDIS participants or individuals with mobility or cognitive impairments who face delayed evacuation capacity, smoke alarms alone do not represent an occupant’s best chance of survival. Automatic sprinklers act immediately and extremely effectively to control or extinguish the fire at its source, regardless of the occupant’s physical capability.
Fatalities in residential fires are preventable tragedies. Dismissing life-saving technology based on mischaracterised cost data or distorted claims regarding participant choice undermines both public safety and common sense.
The Class 1c proposal offers a pragmatic, cost-effective and life-saving compromise that allows Australians living with a disability to reside safely in authentic home-like environments. We are concerned to correct the record and ensure future coverage reflects the facts of this critical safety initiative.
Mark Whybro AFSM
Chair
Home Fire Sprinkler Coalition Australia
