New requirements for early childhood centres and primary schools in multi-storey buildings

NCC 2022 enhances the fire safety provisions for early childhood centres (ECCs) and primary schools located in multi-storey buildings.

The changes were initially introduced into NCC 2019 Amendment 1 Deemed-to-Satisfy (DTS) Provisions. NCC 2022 takes this further, and includes egress from primary schools too.

If you’re involved in constructing new multi-storey buildings which include a primary school as part or all of the building occupancy, or an early childhood centre on an upper floor, then these provisions apply to you.

The changes are in Sections D, E and G of Volume One. We’ve included the previous NCC 2019 references, to help you identify what’s changed.

Primary schools

In Volume One, the new requirements are:

• D2D23 (2019: D1.18): This provision now requires primary schools to be located where the school has direct egress to a road or open space.

If this is not possible, a Performance Solution must be used.

• D2D23 no longer applies to early childhood centres in high-rise buildings. These are now covered by the DTS Provisions discussed below.

Early childhood centres

• A6G1 (2019: A6.1): ECCs are excluded from the ‘10% rule’. This means they must be classified as Class 9b, even if they occupy less than 10% of the floor area of a building.
• D2D4(2) (2019: D1.3): Stairways or ramps must be fire-isolated if they are part of a required exit. The concession for non fire-isolated stairways and ramps passing through no more than 2 storeys no longer applies for ECCs, unless they are:
  • entirely contained in a storey with direct exit to a road or open space; or
  • the only occupancy in a building no more than 2 storeys high.
• D2D16(1)(b) and (6) (2019: D1.11): Horizontal exits can no longer be counted as required exits. Where a horizontal exit is provided (in addition to the required exits), the area to which the exit leads must be able to hold all of the occupants of the ECC.
• D3D22(1)(c)(ii) (2019: D2.17): An extra handrail must be provided on stairs and ramps in exits, halfway between the stair tread and the top handrail. This provides a handrail at a suitable height for children to grip whilst using the stairs or a ramp as an exit.
• D3D27 (2019:D2.22): Re-entry from fire exits must be provided unless there is fail-safe system that will unlock the door if the fire alarm goes off. This allows for re-entry in evacuations where staff carry or assist children to use the fire exit.
• E1D11 (2019: Table E1.5): Sprinklers are now required throughout a building containing an ECC. Sprinklers must comply with Specification 17 (2019: Spec E1.5). There is an exemption for buildings where the early childhood centre is:
  • entirely contained in a storey with direct exit to a road or open space; or
  • the only occupancy in a building no more than 2 storeys high.
• E2D20(3) (2019: Table E2.2b): An automatic smoke detection and alarm system complying with Specification 20 (2019: Spec E2.2a) must be provided throughout a building with an ECC. 
• G1D4 (2019: G1.3): Further details are included for barriers enclosing an outdoor play space where the floor is more than 2 m above the surface beneath. This includes outdoor play spaces located on upper floors.

Multi-storey buildings are becoming more common in cities and towns with growing populations, as they can save space and accommodate more people.

In metropolitan areas, more multi-storey buildings are being built as mixed-use, with retail and car parking on lower levels. ECCs are increasingly being incorporated as a value proposition to owners and tenants.

While most primary schools in Australia are single-storey buildings, many families live in city centres and there is increased demand for schools in these areas. This, combined with reduced availability of land to build traditional schools, is resulting in some primary schools being located in multi-storey buildings.

Children under the care of others are among the most vulnerable occupants of a building. It is important they can access and exit these buildings safely, particularly in the case of an emergency evacuation, like a fire.