The Royal Commission into Aged Care Quality and Safety, announced by Prime Minister Scott Morrison on the 9th of October 2018, has peaked my interest in the subject of ‘at-risk’ housing developments and accommodation.
As a former senior officer in the Western Australian Fire Services and, more recently, a consultant in the fire safety and emergency management industry, I believe that the aged care sector—and other facilities which offer high-density living—can improve their approach to fire safety.
Many facilities in various jurisdictions implement good practices, but others do not meet the modern fire safety standards expected of them by their communities. These shortcomings are caused by a number of factors. Regulatory requirements, which differ from state to state, represent hurdles to compliance. Furthermore, recent developments within the sector, such as external cladding, short-term residential accommodation, and independent aged care buildings with multiple storeys, pose further emergent risks.
In the aged care sector, the relevant Australian Standards are AS 3745—2010: Planning for Emergencies in Facilities and AS 4083—2010: Planning for Emergencies—Health Care Facilities. These standards outline the emergency control structures and procedures to be implemented by facilities. I am often perplexed, however, by key staff in these facilities who, when asked about their responsibilities, demonstrate a lack of training and confidence. Given the vulnerability of the residents they care for, it is paramount that staff turn up to work each shift knowing what actions they will take in an emergency.
The expectation that the Fire Service will be there to assist should not be a fall-back position. Fire service initial responses are often not at the level required to take care of residents and occupants that are unable to self-evacuate. In smaller jurisdictions and regional centres an escalated emergency response will take some time.
My experience in the industry is that the majority of residents will not be able to self-evacuate. This is well understood in the industry with up to 80% of residents in facilities requiring assistance in the initial stages of an emergency. While low staff numbers has been flagged by the Royal Commission, I believe that fire safety measures are the predominant factor in the survival of residents, particularly for emergencies occurring at night.
In the case of an emergency, facilities rely upon safety measures including direct brigade alarms; effective sprinkler operation; fire & smoke compartmentation; and responding emergency services to undertake any required rescues. Lateral evacuation and ‘protect in place’ strategies are applied in these facilities as the initial focus of staff in developing emergencies. The requirements for a stage two (a lower floor) or stage three evacuation (externally) is often not practiced or not anticipated to occur. However, should a smoke compartment be compromised by poorly maintained doors, hose lays, continual opening of doors by entering firefighters and evacuees-the safety of residents will be compromised.
Furthermore, in 2012, a Western Australian study found that 87% of smoke doors in aged care facilities were defective. In my own experience, this is indeed a problem: I have encountered many doors with malfunctioning dropper seals, incorrect sequencing and faulty closing mechanisms.
Compliance with modern fire safety standards, including relevant building codes, fire safety regulations, sector-specific guidelines and the AS 1851—2012 Routine service of fire protection systems and equipment, are, therefore, linked to better safety outcomes.

As mentioned earlier, each Australian jurisdiction has slightly different requirements, and national aged care operators are required to adapt their approach to Fire Safety measures in each State. Whilst by no means an exhaustive list, some notable differences are as follows:
- Victoria
- mandatory sprinklered aged care facilities
- BCA allows locally monitored smoke detectors (not connected to the State Fire Services) if the building is sprinklered
- Queensland
- mandatory sprinklered aged care facilities
- fire safety advisers appointed for facilities
- state Fire Regulations covering specified facilities
- NSW
- retrospective and mandatory fitting of sprinklers
- healthcare sector guidelines
- appointment of fire safety manager and fire safety officers
- Western Australia
- Facilities are not subject to retrospective fitting of sprinklers
- no specific codes or guidelines for the sector
- Tasmania
- sprinklers not subject to retrospective fitting
- evacuation plans to be submitted to the Tasmanian Fire Service for approval
- evacuation drill to be observed prior to the acceptance of the plan
- plans resubmitted every five years;
- South Australia
- sprinklers not subject to retrospective fitting
- fire indicator panel instructions limiting occupant operation prior to the fire brigade arrival
- Minister specifications for essential safety provisions.
Interestingly, New South Wales, Queensland and Victoria all acted upon mandatory sprinklers following significant multiple fatality incidents: Quakers Hill Nursing Home (NSW), Childers Backpacker Hostel (Qld) and Kew Cottages (Vic).
An issue that arises in new developments, particularly with multi-storey buildings, are fire engineering reports that enable alternative solutions and lead to worse fire safety outcomes for residents. This includes ‘deemed to satisfy’ examples such as smoke compartments areas greater than the BCA allowance, longer distances of travel, construction type and fire isolated stair concessions. Aesthetic or design features, including multiple narrow paths, gardens, elevated blocks and stairs (in lieu of ramps) are also matters that, I believe, warrant inclusion in the design approvals-we should be planning for every advantage should an emergency occur.
High density living and apartments including class three occupancies and independent living accommodation for aged care occupants, are also areas in need of improvement. The lack of properly designed evacuation procedures, no emergency control structures, deficient evacuation diagrams and fire zone plans further contribute to the vulnerability of these facilities and their occupants.
Whilst the Royal Commission will no doubt focus on many aspects of residential aged care, it would be wise to consider the safety of residents during an emergency. I trust fire safety practitioners in the region to continue to do their best to improve the standard of fire and emergency preparedness, particularly during circumstances described above.
For more information, email craig@executiverisksolutions.com.au
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