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This document provides Municipal Building Surveyors (MBS) a guidance framework to follow when reviewing and considering cancelling enforcement issued on buildings that may have Expanded Polystyrene (EPS) concrete used as a cladding to the external walls. It also presents a general process to provide guidance to owners in providing show cause representation to the enforcement action by an MBS.
In this document:
The Statewide Cladding Audit (SCA) has identified some buildings that have been constructed with a mixture of both EPS concrete and EPS cladding external wall systems. The guidance framework in this document only applies to buildings that have EPS concrete cladding that have a bulk density greater than 345 kg/m3. If EPS cladding or other highly combustible cladding material is present, or the bulk density of the EPS concrete is less than 345 kg/m3, the direct guidance framework in this document is not applicable.
The framework comprises a 4-stage process:
Stages 1 and 2 are to be undertaken by the building owner and Stages 3 and 4 by the MBS. These stages are to ensure a consistent approach is taken in order to validate the presence of EPS concrete when the owner intends to retain this cladding material.
The VBA engaged CSIRO to undertake a technical advice report on the fire performance of EPS concrete cladding panels based upon a review of available fire test reports and other information. The report can be found here.
The CSIRO review of EPS concrete demonstrated that, based on the testing available, the QT Eco Series wall system Conpolcrete may present a lower risk of fire spread. This EPS concrete material has a density greater than 345 kg/m3.
Based on the CSIRO review, the VBA has concluded that if a building is validated via an appropriate analysis to be entirely EPS concrete of density greater than 345 kg/m3 (without other combustible external wall materials) it may be reasonable to consider the cancellation of relevant enforcement relating to cladding.
Where a building’s external wall cladding includes other combustible products, including Aluminium Composite Panels (ACP), the MBS will need to consider any additional risks posed by these products in determining appropriate action. Consideration of potential risks posed by combustible insulation in the wall system should also be considered. It is recommended that the MBS familiarise themselves with the CSIRO report to understand other products that may be used, and the background information to this validation process.
It is recommended to review the available documentation, such as the Building Permit endorsed documents for the building, to determine whether EPS cladding (or another material) was nominated in addition to EPS concrete. Other documentation may also be used for the review, such as technical investigation and audit reports from appropriate professionals.
Where documentation indicates that EPS cladding (or another material) could have been used, these locations should be investigated on site (see step b).
Due to the potential for undocumented product substitution during the construction phase, additional precautions are recommended rather than relying solely on the building permit endorsed documentation.
It is recommended that an inspection of the building should be undertaken to conduct a series of minimally invasive tests and take samples of the cladding material.
The testing can be achieved via drilling small pilot holes to reveal the external wall material. Visually, EPS cladding will typically swarf out of the hole as fluffy loose EPS beads, whereas EPS concrete will come out as a cementitious EPS mixture.
The MBS should work with the Owners Corporation (OC) to determine and agree on the extent and the locations of proposed testing holes and sampling. As every building is unique, the MBS should use their judgement to guide owners on the number of pilot holes and samples required, as such, the above are recommendations only. The locations of test holes and sampling taken during the inspection should be clearly documented on plans with relevant supporting information of the tests carried out and samples taken. The MBS should be satisfied that sufficient evidence of material type is provided. It is recommended to target areas for pilot testing where EPS cladding is likely to have been used.
Examples include:
If EPS cladding (or other combustible materials) are identified during the inspection, the guidance framework is no longer directly applicable for the building. This guidance framework has been prepared on the basis that the building contains, or will contain, no combustible external wall cladding other than EPS concrete.
Material product samples of EPS concrete should be taken at selected locations for both visual inspection and either density or laboratory testing to indicate the properties of the EPS concrete are similar to those of QT Eco Series wall system Conpolcrete.
Two measurement options are recommended per the CSIRO technical advice report:
There have been three major formulations of QT EPS Concrete over the years including:
White core EPS concrete can resemble EPS cladding and requires careful inspection and checking for cementitious mixture.
The EPS concrete sample should be photographed and visually checked/compared against visual examples of QT EPS Concrete (pink, white or grey) provided in the CSIRO report.
Other aspects that should be considered for documentation and review at sample hole locations to confirm alignment with the QT installation manual where possible, include:
It is recommended EPS concrete is sampled for density measurement or laboratory testing in at least three different locations in the building, and preferably at different locations to where the drill holes of Stage 1b were drilled.
The MBS should use their judgment to guide owners on the number of sample locations required, as such the above are recommendations only.
Cutting a ~100 x 100 mm square section sample using a reciprocating saw is recommended to ensure accuracy of the density measurement. Alternatively, a core sample using a hole saw at least ~ 100 mm in diameter is recommended.
The following should be considered:
For laboratory test samples a hole saw sample using a 40-50mm diameter hole saw at least 50mm in depth is sufficient. A hole saw with arbor bit can be used.
The density of the core samples should be measured and calculated based on Appendix B of the CSIRO report. It is recommended that a suitably qualified person undertake this work, to the MBS’s satisfaction, such as a builder, building surveyor, or engineer.
Render must be neatly removed from the sample, ensuring the faces of the sample remain flat and clean of crumbling elements to ensure accuracy.
A minimum calculated density for the sample of 345 kg/m3 and above is considered to be EPS concrete aligning with the CSIRO report’s conclusion. If there is any concern regarding the composition of the EPS concrete, samples should be sent for lab testing in accordance with the CSIRO report.
Where EPS concrete samples indicate a density greater than 345 kg/m3, no combustible insulation is identified, and reasonable evidence, such as drill testing, is provided that there is no EPS cladding or other combustible cladding types on the building, consideration can be given to cancelling relevant enforcement issued in relation to combustible cladding.
The MBS should be confident the testing and sampling has been appropriate for the building in question (i.e., sufficient testing has been undertaken).
If the density of samples is measured to be less than 345 kg/m3, this guidance note is no longer applicable, and it is recommended the MBS requests further review of fire spread risks by appropriately qualified people. Further laboratory materials characterisation testing of samples may be required.
Judgement may need to be made if the material density is lower, but within close range of 345 kg/m3, and appears to be visually similar to QT Eco Panel wall system (refer to the CSIRO report). The MBS may need to review samples for possible measurement errors but may also review the extent of EPS concrete on the building, its height, and other features, such as sprinkler protection when making a decision.
It is recommended that the MBS be satisfied the building does not have any major safety concerns, having inspected the site.
Enforcement for building issues not directly interrelated with the external wall material, may be addressed by separate consideration and enforcement. It is recommended that the MBS review available audit and inspection reports to inform themselves of the buildings fire safety characteristics.
Where the MBS forms the opinion that the building is not a danger to life or safety the MBS may cancel enforcement relating to cladding.
The intention is to provide this guidance as a tool to support an MBS in their decision-making process following the release of the CSIRO report findings and recommendations on EPS concrete. It remains with the MBS in their function and powers under the Act to be satisfied in any decision they make for each individual building, when using this guidance or any other relevant and available tools and information at their disposal.
The following details should be reported.