Is an air-conditioning system an safety measure?

Once again the question "is an air-conditioning system an essential safety measure?" has popped up and I thought I would take a fresh look at what I have written on air-conditioning systems in the past.

To kick things off, here is the question I received from an industry professional (Julie)...

On Fri, Oct 5, 2012 at 10:40 AM, Julie wrote:

If you install, modify or remove ANY ESMs you need a building permit.

Logically, if you don’t need a BP for an A/C package unit then it could not possibly be an ESM

Also if its not hooked into the fire services then its not an ESM

Can you please confirm ?


Julie | Division Manager

This question is typically poorly handled by building surveyors, engineers, industry professionals, property managers, facility managers and just about everyone for that matter!

The phrase safety measure is clearly defined in the Building Code of Australia ("BCA") as follows;

Safety measure
means any measure (including an item of equipment, form of construction or safety strategy) required to ensure the safety of persons using the building.1

For the purpose of completeness, here is the definition of air-conditioning also from the BCA.

for the purposes of Section J, means a service that actively cools or heats the air within a space, but does not include a service that directly cools or heats cold rooms or hot rooms.

By this definition, we can exclude any measure, item of equipment, form of construction or safety strategy that is not specifically to ensure the safety of persons using the building. To understand this, you also need to understand the goal of the BCA...

The goal of the BCA is to enable the achievement of nationally consistent, minimum necessary standards of relevant health, safety (including structural safety and safety from fire), amenity and sustainability objectives efficiently....

Following this line of thought, an air-conditioning system is generally installed in a building for the amenity of the occupants, i.e. to heat and cool the building to satisfy the needs of the people using the building.

Interesting the term amenity is not defined in the BCA however it is referenced over 100 times throughout Volume One alone.

When is an air-conditioning system a required safety measure?

We are now into the nitty-gritty of this question, because there are some occasions where an air-conditioning could form part of the safety measures of the building.

One of the first clues for this comes again form the BCA in Table 1 with a reference to Australian Standard AS 1668 ("AS1668") for "the use of mechanical ventilation and air-conditioning in buildings".

Another clue exists in Table I1.6 SAFETY MEASURES - AIR HANDLING SYSTEMS

Safety measure BCA provisions for determining standard of performance
Smoke hazard management systems—
  • automatic air pressurisation systems for fire- isolated exits
  • zone smoke control system
  • automatic smoke exhaust system
  • automatic smoke-and-heat vents
  • air-handling systems that do not form part of smoke hazard management system and which may unduly contribute to the spread of smoke
  • miscellaneous air-handling systems covered by Sections 5 and 11 of AS/NZS 1668.1 serving more than one fire compartment
  • other air-handling systems
Carpark mechanical ventilation system F4.11
Atrium smoke control system Specification G3.8

This list of safety measures related to "Air Handling Systems" (an air-conditioning systems is a type of air handling system) is dealing with the safety not amenity.

You can get further clarification throughout the BCA on the definition of a required safety measure and it essentially boils down to the definition of what a safety measure is in the first place..

An air-conditioning system may be used as part of the heat and smoke control systems in a building, in which case it is likely to be a required safety measure! In this case, its purpose is likely clearly defined in the BCA and AS1668.

Split System Air-Conditioners

In all likelihood, a split system air-conditioner exists for occupant amenity only and is not likely to be a required safety measure of a building. In these cases, it is questionable that there is any requirement in Australian Standard AS 1851 - Maintenance of Fire Protection Systems and Equipment ("AS1851") for periodic maintenance.

The only grey area I can foresee in these arguments is when there is an air-conditioning system that exists only for amenity but incorporates a fire-mode relay for shut down in an emergency purpose.. In this case, the relay is clearly required to operate and is a safety measure, but is the air-conditioning system? I suggest not, but thats up to the engineers and building surveyors to debate!

Summarising the discussion...

I have made a few statements here including importance references to the BCA and Australian Standards that might get up the nose of some people. The intention is to address very common misconceptions regarding air-conditioning systems as safety measures.

To assist readers, I have created the following table as a general guideline for discussion with your building surveyor or fire safety engineer.

Example Fire mode interface Safety
Air-conditioning system exclusively for occupant amenity. No interface to other safety systems No
Air-conditioning system for occupant amenity Fitted with a shutdown or fire mode interface Possibly
Air-conditioning system for occupant amenity incorporating heat and smoke control features Operates in fire mode Yes
Stairwell pressurisation fan Operates in fire mode Yes
Smoke spill fan Operates in fire mode Yes


Given the nature of this subject, it is important to note the information and material in this article is intended as general reference information only. Specific facts and circumstances may alter the concepts or applications of materials and information described herein. The information provided is not a substitute for professional advice and should not be relied upon in the absence of such professional advice specific to whatever facts and circumstances are presented in any given situation.

More information...

I have written about this subject in various forms on this website previously and will likely continue to do so. In that regard, you can search for similar articles using key words that best describe your questions.

Feel free to send me a message if you have specific questions or would like more information about the services provided by Firewize.


  • 1. NCC 2012 BCA Volume One
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