Shopping Centre: Do my external facing shops require occupant warning?

Earlier today, I received a telephone call from the Centre Manager for a Shopping Centre asking for advice in regard to emergency warning. The questions went along the lines of;

"Do I need to install additional speakers outside the outward facing retailers on the perimeter of the shopping centre?"

To answer this question, we need to refer to the National Construction Code / Building Code of Australia (BCA) and any related Australian Standards.

We need to consider the options for a Shopping Centre which is a "Class 6" building.

For the purposes of this article, we are only going to consider the Deemed-to-Satisfy (DtS) Provisions of the BCA. Specification E2.2A - Smoke Detection & Alarm Systems provides the DtS solution we are looking for;

1. Scope
This Specification describes the installation and operation of automatic smoke detection and alarm systems.

2. Type of system
A required automatic smoke detection and alarm system must comply with the following:

(b) Class 5, 6, 7, 8 and 9b buildings: A smoke detection system complying with Clause 4

Clause 4 sets out the requirements for a Smoke Detection System as follows;

4. Smoke detection system
(a) A smoke detection system must—
(i) subject to (c) and (d), comply with AS 1670.1 except for the provisions of—
(A) Clause 3.26(f); and (B) *****
(C) *****
(ii) activate a building occupant warning system in accordance with Clause 6.

Clause 6 describes the requirements for a Building occupant warning system

6. Building occupant warning system
Subject to E4.9, a building occupant warning system provided as part of a smoke hazard management system must comply with clause 3.22 of AS 1670.1 to sound through all occupied areas except -

The "except" here refers to a range of building classifications, but does not include Class 6.

We can draw from this then that a Class 6 building requires an occupant warning system throughout all occupied areas in accordance with Australian Standard AS1670.1


Australian Standard AS1670.1-2004 sets out the requirements for a Fire detection, warning, control and intercom systems - System design, installation and commissioning.

Clause 3.22 in particular deals with the requirements for Occupant Warning. The opening clause sums up the requirements fairly well;

Occupant warning shall be provided to alert all building occupants to a fire alarm situation.

This clause goes on to st out the requirements in more detail however for the sake of not breaching copyright, its probably best if we summarise the requirements. Warning systems can be one of a number of methods including;

  1. Sound system for emergency purposes as described in Australian Standard AS1670.4
  2. Electronic sounders or amplified sound systems producing the evacuation signal;
  3. Additional visual & tactile signals to augment the audible emergency evacuation signal

For this particular retail facility, the building is fitted with a background music system which has been modified to also transmit audible warning system tones throughout the public areas of the building. This is consistent with item (2) above.

This music is overridden in an alarm situation and the background music system is disabled and evacuation tones are produced.


This particular property is fitted with a minimal background music system, never designed to meet the "all occupied areas" of the building requirements of the BCA or AS1670.

To meet this requirement, the building owner would need to substantially extend the existing background music / occupant warning system to include additional speakers throughout all occupied areas of the building (including externally facing tenancies) to comply with the BCA and AS1670.

Unfortunately this building has been through a substantial extension and renovation in the last 5 years, and the relevant building surveyor did not pick this issue up during any of their mandatory inspections.

So moving along from here, our advice will be to undertake a comprehensive review of the sound pressure levels throughout the property and review the findings against the Objective, Functional Statement & Performance Requirements of Part E1 - Fire Fighting Equipment of the Building Code.

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