Daniel Sloan – video transcript – Service contractor obligations

The speaker is Daniel Sloan.

Hi, I’m Daniel Sloan, ESM Systems Advisor with the Office of the State Building Surveyor. Welcome to this practitioner education series.

Today, we’re going to walk through the obligations that building owners — and in practice, owners corporations — have for maintaining Essential Safety Measures in Victorian apartment buildings.

We’ll cover why these systems matter, what the law requires, and how to ensure a practical and compliant maintenance regime is in place.

This presentation focuses specifically on the documentation and information that service contractors must provide — because these records are the evidence that systems are being properly maintained and that occupants are protected.

By the end of today’s session, you’ll understand key definitions, mandatory pre‑service notifications, record‑keeping requirements, the types of reports that must be produced and when they are due, and exactly what information must be included in those reports.

Our goal is to make sure you can clearly identify what compliant documentation looks like, and recognise when obligations are not being met.

To begin, it’s important to understand two key definitions that underpin this standard.

The first is the Responsible Entity. This is the person or organisation responsible for the routine servicing of fire protection systems. In most cases, this will be the building owner, but it can also be the occupier or the owner’s agent.

All documentation obligations under the standard are directed to this entity.

The second is the Service Provider, or contractor. This is the organisation or person engaged to carry out routine service — including inspection, testing, preventive maintenance, and survey.

It’s important to be clear: these obligations are mandatory. If the required documentation is not provided, this is a breach of AS 1851 and can result in regulatory non‑compliance.

These records are not administrative paperwork — they are the legal evidence that your fire protection systems are being maintained.

Now that we’ve clarified those roles, let’s move into the first set of contractor obligations — pre‑service notifications.

Before any routine service is carried out, contractors must meet specific notification requirements under Clause 1.14 of AS 1851.

The first requirement is upcoming service notification. The contractor must inform the Responsible Entity — or their nominated contact — that routine service is going to take place.

This is particularly important where the work may impact building occupants or operations.

This ensures transparency and allows appropriate planning before any work begins.

There’s a second type of notification that is even more critical when systems are affected.

The second key requirement is impairment notification.

Where servicing activities will impair a fire protection system — even temporarily — the contractor must notify the Responsible Entity.

This notification must clearly state:

• Which systems are affected.
• How they are affected.
• And the expected duration of the impairment.

This is critical because while systems are impaired, the building is more vulnerable.

It allows you to implement alternative safety measures — such as a fire watch or increased patrols — until the system is fully operational again.

There are two additional requirements under Clause 1.14 that are just as critical. First, if servicing may trigger alarm signals, the contractor must notify the monitoring service provider in advance. This prevents unnecessary emergency responses and false alarms.

Secondly, and most importantly — at the completion of any service — all system controls must be returned to their normal operating state.

If anything is left impaired, disabled, or not fully restored to normal, two things must happen:

It must be recorded in the system logbook.

And the Responsible Entity must be notified immediately.

Not later — immediately.

The principle here is simple: you must always know the operational state of your fire protection systems.

Now that we understand notifications, let’s move to one of the most important obligations — service records.

Service records are your primary evidence that maintenance has been performed.

AS 1851 allows three formats:

• A hardcopy logbook.
• An electronic log, with a printed signed copy.
• Or tags and labels, supported by a summary record.

But regardless of format, one rule always applies: a hardcopy record must be left on site at the completion of every service visit.

If tags or labels are used, the supporting summary record must be provided within one week — and that is the only case where the documentation can follow the visit.

This requirement ensures there is always a physical record available onsite for inspection or audit.

Let’s now break down exactly what must be included in those records.

Clause 1.16.3 sets out mandatory requirements for service records — and every single item must be included.

These include:

• Building name and address.
• Date and frequency of service.
• Identification and location of equipment.
• All activities performed, including results and pass or fail.

Beyond logbooks, tags and labels also have strict requirements.

Additionally:

• Every defect or non‑conformance must be recorded in full detail — including classification, location, and rectification.
• The Responsible Entity must be identified.
• The service person must provide their name, signature, and date.
• And the service provider company name must be recorded.

If even one of these items is missing, the record is non‑compliant.

This is one of the most common areas where failures occur — particularly in defect recording — so records should be regularly audited.

Where tags or labels are used, Clause 1.16.4 specifies exactly what must be included.

Each tag must show:

• The title “AS 1851 Service Record”.
• A coded figure indicating service frequency.
• The date of service.
• And a carry‑forward of the previous year’s record.

That continuity is essential — it allows the tag to demonstrate historical servicing.

Without this information, the tag does not meet compliance requirements.

Tags alone don’t carry enough detail and must be supported by another document.

A summary record must be provided to the Responsible Entity within one week of service.

This record must include detailed information such as:

• Building details.
• Dates of service and scheduled service.
• Equipment serviced and not serviced.
• Reasons for anything not serviced.
• Defects and non‑conformances.
• Service personnel details and signatures.

This acts as a full record of work performed and exceptions identified.

Importantly, it provides the detail that tags cannot capture on their own.

Next, we move into defect reporting which is arguably the most critical obligation under the standard, with strict timeframes based on severity.

A critical defect is one that renders a system inoperative.

Examples include:

• A sprinkler system without water supply.
• An inoperative fire indicator panel.

When a critical defect is identified:

• The Responsible Entity must be notified before leaving site.
• It must be confirmed in writing within 24 hours.
• And it must be reconfirmed every time it is identified.

For other issues:

• Non‑critical defects, within one week.
• Non‑conformances, within one week.
• Out‑of‑tolerance activities, within one week after the tolerance period.

The rule of thumb is simple:

Critical means 24 hours, everything else means one week.

Now let's look at the most common asset, Extinguishers.

There are special requirements for fire extinguishers under Clause 10.2.10.

If an extinguisher is defective and must be removed:

• A replacement must be installed immediately — never leave an empty bracket.
• A defect report and an action required report must both be provided.
• All actions must be recorded in the service record.
• And if disposal is required, it must be approved by the owner.

The extinguisher is an asset of the building — it cannot simply be removed without accountability.

Moving on to yearly condition reporting.

The Yearly Condition Report is the principal compliance document under AS 1851.

It must be issued annually by the service contractor to the Responsible Entity — without exception.

This report includes:

• Full system identification.
• Applicable design standards.
• All outstanding defects and non‑conformances.
• A summary of service activity.
• And a formal statement of system condition

This document is the formal evidence of compliance and supports regulatory obligations across jurisdictions.

In addition:

• Any missed service must be acknowledged.
• Any system rendered non‑operational must be clearly stated.
• And any involvement of multiple service providers must be disclosed.

This is the document regulators will ask for first — and it must be complete, accurate, and signed.

To bring this together, let’s now look at a simple checklist of what must be provided.

Clause 1.17.2 sets ten mandatory items for the Yearly Condition Report.

1. Building name and address.
2. The period covered.
3. Description and location of every system in scope.
4. The approved design standard for each.
5. Outstanding defects — every unrectified critical defect lives here, so if you don't receive it, request it.
6. Outstanding non-conformances.
7. A summary of the year's service records.
8. A statement of system condition and whether it's in line with the approved design — a professional opinion the contractor signs.
9. The Responsible Entity's name and address.
10. And the representative's name, signature, date and company.

All ten, every year.

Beyond the mandatory content, three additional requirements apply to the Yearly Condition Report.

First, it must acknowledge any missed service during the year — hiding it isn't an option.

Second, if outstanding defects make a system non-operational, that must be stated plainly so you know.

Third, where different parties did portions of the service, that must be acknowledged.

In Victoria and most jurisdictions this report supports your Annual Essential Safety Measures Report or equivalent — your statutory compliance and occupant safety depend on it being accurate and on time.

This all ties in with the System interface testing.

Where fire systems interface with other building systems — lifts, smoke fans, doors, HVAC — end-to-end interface tests must be done and records provided to you, under Clause 1.12 and Appendix D.

Each record must include:

• each interface tested in cause-and-effect terms.
• The name and signature of who verified it.
• Date and time.
• The acceptance signature of your representative, and
• any defects found.

Pass/fail results also go in the relevant system records, and a hardcopy must be kept on site at all times.

The contractor runs and documents the tests. Defects found also go on the Yearly Condition Report.

Let’s now review a quick reference for complete notification and document checklist.

What to provide and when, for each visit:

Pre-service impairment notice (Cl. 1.14): before work.

Monitoring provider notice (Cl. 1.14): before work, where signals may transmit.

Completed service record (Cl. 1.16.2): on the day, left on site.

Service tag or label (Cl. 1.16.4): on the day, attached to equipment.

Summary record where tags used (Cl. 1.16.5): within one week.

Notice of impairment not restored to Normal (Cl. 1.14): before leaving site.

Verbal critical defect report (Cl. 1.17.1): before leaving site.

Written critical defect confirmation: within 24 hours.

Non-critical defect or non-conformance: within one week.

Out-of-tolerance activity: within one week of the tolerance period ending.

The Yearly Condition Report — issued annually, covering all services, outstanding defects and non-conformances; complete, accurate, signed and dated.

Systems interface test records — hardcopy kept on site, with any defects also flagged in the Yearly Condition Report.

Two annual obligations — the Yearly Condition Report is the one a regulator or auditor asks for first, so be ready to produce it.

The key takeaways from this presentation are that:

• Hardcopy records must always be left onsite.
• Critical defects require immediate escalation.
• Most other issues must be reported within one week.
• The Yearly Condition Report is mandatory every year.
• Tags must be supported by summary records.
• And all records must be retained for at least seven years.

Your documentation is not just administrative — it is the legal evidence that systems are maintained and occupants are protected.

If the documentation is incomplete, delayed, or missing, then from a regulatory perspective, the compliance does not exist.

Today we’ve covered the full set of documentation obligations under AS 1851 — including notifications, service records, defect reporting, and annual compliance documentation.

To close, I’ll leave you with one final message.

If it isn’t documented, it didn’t happen. Thank you.