Summary of Items Discussed in APSEC Discussion Forum on 16 March 2012

Items proposed by Convenors for Discussion Summary of Discussion and BD’s Responses

Items raised by HKIA

1. Application of FS Code 2011
PNAP APP-153 regarding the application of the new Fire BD advised that para. 2(i) of PNAP APP-153 is to cater for situations where
Safety Code stipulates that the use of the old codes may be the foundation has been designed based on a set of approved GBP for a
allowed for a project for which the first consent (foundation proposed building designed to comply with the MOE/ FRC/ MOA Codes
or site formation) has been obtained before 1.4.12. and such foundation works have already been commenced when the new FS
However, BD has recently imposed an additional Code comes into effect on 1.4.2012. The rationale being that there would
requirement that the first approval of building plans has be constraints in re-designing the proposed building to comply with the new
also to be obtained. This has caused problem to some FS Code as the corresponding foundation works have already been
projects where the foundation has been designed and commenced. If a development site does not has a set of GBP approved
implemented based on building plans designed in before 1.4.2012, the early commencement of foundation works is solely at
accordance with the old codes but for some reason the the applicant’s own risk and should not and would not be accepted as an
building plans have not been approved before 1.4.12. excuse for not able to comply with the new FS Code. That said, BD would
HKIA members find this additional requirement unfair and consider any request for relaxation upon receipt of full substantiations of the
would request BD not to impose this, especially when this circumstances of individual cases.
has not been stated in the PNAP before.

2. Requirement for Plant Rooms under FS Code 2011

The new Fire Safety Code requires the assessment of BD advised that pursuant to Table B1, a plant room exceeding 100m2 in net
occupancy for plant rooms larger the 100 sqm. in size. floor area (i.e. area within the enclosing walls of the plant room) should be
However, it does not further expand on whether the other assessed for its occupant capacity. Persons who are expected to be present
MOE requirements in the code have to be applied to such in plant rooms would be authorized/ maintenance personnels, the AP could
plant rooms. This may be open to interpretation and may exercise his professional judgment in providing suitable means of exit
have a lot of implications. For example (1) should the therefrom for such personnels.
plants/equipment in the plant rooms be shown on the plans
to demonstrate escape paths of adequate width and
headroom are provided? (2) Plant rooms are generally full
of pipe runs across the room (at floor or high levels) – will
these be considered obstructions to escape paths?

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3. Definition of Hangers under Element of Construction
Catwalks and overhead maintenance corridors of steel BD advised that catwalks and overhead corridors are sometimes provided to
construction are common in some buildings such as effect maintenance to plant and services, they are not performing the
theatres, halls, public transport terminus, etc. Are these function as floor/ beam/ column, which together with hanger are grouped as
construction considered as “hanger” under the definition of “Element of Construction”, hence they are not required to have FRP/ FRR.
“Element of Construction”, thereby requiring FRP in the old Whilst such catwalks and overhead corridors offer exit for authorized/
FRC Code or FRR in the new Fire Safety Code? It has been maintenance personnels thereon, there is no requirement for such exit routes
hard to draw a line between more extensive hanger to have FRP/ FRR.
construction such as catwalks and less extensive hanger
construction such as false ceilings but the requirements on
FRC/FRR can be of great implications to construction
method and cost. Can BD provide more guidelines on the
differentiation?

4. MOE for Car Ramps

Are the areas of the car ramps considered occupied spaces BD advised that when shutters are deployed to form fire compartments in
requiring means of escape? There may be difficulties in carparks for Table C1 purpose, in case the dispositions of the shutters would
complying with dead end and gradient requirements for result in portions of the car ramps being dead-locked upon activation of the
MOE. Will there be a difference in requirements in the shutters, it would be necessary to provide means of exit to the required
case of an aboveground ramp as opposed to an underground staircases / open area / ultimate place of safety to cater for any person who
ramp? might be trapped within such dead-locked portions of the car-ramp.

5. Calculation of Percentage of Opening Protected by Shutters

Following BD’s clarification on the denominator for the BD advised that in light of comments received, BD in liaison with the
total length of the perimeter of a fire compartment regarding Consultant have holistically reviewed the requirement under Clause C8.1,
the 25% calculation for opening protected by shutters the outcome has been incorporated in the final version of the FS Code
without insulation properties, can BD further consider the promulgated on 2.4.2012. Relatedly, para.2(i) of PNAP APP-83 on FRC
inclusion of external walls of an aboveground compartment Code 10.1 will be similarly revised to reflect the same outcome.
not requiring FRR into the denominator as well, with the
understanding that such a wall (being on the exterior of a
building and not requiring FRR) poses no additional fire
risk compared to one in an underground compartment
situation where FRR is required?

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6. Minor Works
There have been difficulties faced by AP/RMWC Members raised that, for minor works, especially those requiring only
submitting minor works completion records where BD after notification to BD upon completion, it would be difficult to comply with
audit checking in a few months from the works completion BD’s comments to the works if they were given a few months after the
issue major comments on the submitted records for Minor notification. Further, members requested for a contact point for enquiry on
Works or even objection to the works classification. Can minor works, especially on the structural aspect.
BD commit to a period within which objection or comment
may be issued so that rectification work can be made within BD requested HKIA to give examples on enquiry issues for review. Besides,
reasonable time but not after user-occupation or long into BD advised that MWCS is a self-regulating control system which allows
license application procedures, etc.? “minor works” to be commenced or carried out under the “simplified
requirements” by prescribed building professionals (PBP)/prescribed
registered contractors (PRC). Bearing in mind that the PBP/PRC have the
obligation to ensure the subject works are in compliance with the BO and
other enactments and should not rely on BD’s audit check on the
documents/works engaged by them. Minor Work Unit has advised that
taking into account of large number of minor works submissions received by
BD and the limited resources currently available for handling of the
submissions, BD is not yet ready to commit a pledge on replying PBP/PRC.
If PBPs have queries relating to minor works, they are welcome to screen
the cases involved and outline the scope before raising the example cases for
the enquiry services. The general enquiry relating to minor works may be
sent to e-mail address pkleung@bd.gov.hk .

7. Distances in SBD Guidelines

In PNAP APP-151 & 152, the SBD Guidelines, a lot of Regarding the requirements on distances in PNAP APP-152 (SBD
distance requirements have been imposed say on the width Guidelines), members enquired whether the distances were to be measured
of set back and building separation. However, it is not from the structural or the finished surface of buildings, and whether there
specified whether these distance requirements are measured was any allowance for finishes similar to those traditionally given in the
from the structural face or the finished face of buildings. case of Open Air and Prescribed Window calculations under the B(P)R.
Can BD clarify on this? Is there any finishes allowance
similar to those traditionally given in the case of Open Air In response, BD advised that PNAP APP-151 regarding the overall cap on
and Prescribed Window calculation under the B(P)R. GFA concessions, all such dimensions of green / amenity features and plant
rooms etc should be based on structural dimensions. In the case of the
SBD Guidelines under PNAP APP-152, the required amount of building
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 separation and building setback is primarily concerned with the available
open space between buildings or between the building and the street /
boundary lines, hence all dimensions should be measured from the finished
face of the buildings i.e. the outer face of the wall finishes and curtain walls.
This would be similar to the requirement that no part of any wall finishes
should project beyond the site boundaries. The same principle should also
be applicable to the measurements for site coverage of greenery.
Measurement of soil areas should discount the areas occupied by wall
finishes / curtain walls.

8. Access to another staircase under Clause B8.2(c) of FS

Code 2011
Clause B8.2(c) of the New Fire Safety Code has a new BD advised that in light of comments received, BD in liaison with the
requirement that only “intermediate” refuge floors can be Consultant have holistically reviewed the requirement under Clause B8.2,
used together with the roof to provide access to another the outcome has been incorporated in the final version of the FS Code
staircase for some buildings. This would effectively promulgated on 2.4.2012.
eradicate all buildings of 26 to 39 storeys without a common
lobby to provide “change of staircase”. Will BD clarify
the intention of and reconsider this?

9. Recessed Discharge Point at Ground Storey

Regarding Clause B9.1 of the new FS Code, it is stipulated BD advised that the exit route from staircase at ground storey should be
that the enclosing walls of the passage from the staircase at enclosed by fire barriers up to its ground storey discharge point leading
ground storey should be up to the ground storey discharge directly to an ultimate place of safety. The design of the ground storey
point. There are cases where such ground storey discharge discharge point which is recessed from the ultimate edge of the building
point may be recessed from the ultimate edge of the may be acceptable if the covered recessed area is a common area, open in
building (i.e. covered) but only with landscape planters on design and not encumbered with features carrying fire hazards. Such
both sides of the notional passage beyond the discharge recessed covered areas would be counted for SC and PR. However, it
point. In terms of safety in evacuation this arrangement is would be irrational to set any depth as an acceptable recess, each case has to
not inferior to the case of podium staircase transfer where be assessed based on its own design, layout and other relevant
only a 6m distance from any unprotected opening is circumstances.
required. Assuming that this arrangement is acceptable
can BD advise on the maximum extent of such a notional
passage (or the maximum depth of such recessed ground
storey discharge point) in cases where GFA is accountable

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 and not accountable for such a recessed notional passage

10. Follow-up issues from previous forums BD’s response: -

- Measuring the Height of Protective Barriers - In measuring the height of protective barrier, the height should be
generally measured from the finished floor level to the top of protective
barrier. This principle applies to the case for a solid curb (which is built
at the lowermost of the protective barrier) of not more than 150mm high
and with a maximum of 75mm width measured from the inner surface of
the protective barrier. For cases not meeting the dimensional
requirements of the solid curb as stated above, the height of the
protective barrier should be measured from the finished level of a solid
curb to the top of the protective barrier. For certainty, details of the
barriers may be provided for agreement.

- Definition of “Atrium” and “Void” in New FS Code - Please refer to item 4 (on Clause C10.3) in the Summary of Discussion
for the Forum held on 6.1.2012. The outcome has been incorporated in
the final version of the FS Code promulgated on 2.4.2012.

- Response to queries on the New Fire Safety Code - Responses to HKIA’s list of enquiry items regarding the FS Code
generally submitted on 18.11.2011 had been sent out on 10.4.2012.

Item raised by HKIE

11. For the first item, I would like to refine it to " For the BD advised that the related paragraphs in PNAP APP-2 and APP-150 will be
Wholesale Conversion of Industrial Buildings, HKIE revised such that for curtain walls projecting over public streets, the AP will
members would request BD to liaise with Lands Department be reminded of the provisions of BO s.14(2) and the need to obtain the
to resolve and clarify the discrepancies arise from the agreement of the LandsD prior to the commencement of the works.
installation of curtain wall resulting in the curtain wall
projecting beyond site boundary, as so permitted by BD
under PNAP 150, but subsequently disapproved by Lands
Department on the ground that no such provision has ever
been made correspondingly in the Practice Notes of Lands
Department.

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12. Update of revised quality supervision for precast concrete BD had reviewed the requirements on quality supervision for precast
construction proposed by HKIE. concrete elements construction. BD expressed that the requirement of
monthly inspection by an RSE to the precast factory in the Mainland China
has its functional purpose for ensuring quality precast products. However,
BD realized the practical difficulty of the industry and proposed an
alternative option of conducting testing/inspection of precast concrete
elements when they are delivered to construction site. In parallel, BD also
proposed to amend the TCP of the RGBC stream from TCP (T3) to TCP
(T1) but maintained the requirement of monthly inspection by the AS.

BD also took the opportunity to clearly specify the quality supervision for
in-situ reinforced concrete works, i.e. qualification of not lower than an TCP
(T3) and TCP (T1) for the RSE and RGBC stream respectively. The
proposal details would be tabled at the coming BSC/APSEC Meeting in
May.

13. Clarification on FRP requirements for structural element on BD advised that in general, roof beams and slab are not required to have
Roof, i.e. whether roof beam & slab have any FRP FRP/FRR but should be constructed of non-combustible materials.
requirement. However, the roof of a single-staircase building in which the level of the
highest floor is more than 13m above ground level, or the roof of a building
which is designated as a refuge roof, should have FRP/ FRR – paras. 4 & 13
of the FRC Code (Section 3 in Part A and Clause C12 of the FS Code 2011)
refer. Moreover, in case the failure of the roof members will affect the
global stability of the building, or where the roof is accessible and functions
as a load-bearing floor, such roof members should also achieve the FRP/FRR
requirements.

14, The acceptance criteria of allowable load bearing capacity BD advised that Table 2.1 of the Foundation Code only provides the
of rock other than granite and volcanic rock (table 2.1 of the allowable bearing capacity for granite and volcanic rock. For other rock
CoP on Foundations refers). types, the measure of total corer recovery, point load index, etc as specified
in Table 2.1 of the Foundation Code may not be adequate. In this
connection, RSE in consultation with RGE may make reference to other
relevant design guides (e,g, GEO 1/2006) and submit the set of testing
requirements to justify the rock has the bearing capacity as prescribed in

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 Table 2.1 of the Code.

15. The possibility of adoption existing GI reports conducted BD advised that there would be no fundamental objection for allowing an
under site supervision of other AP & RGE in accordance RSE to adopt the GI works by other AP or RSE on the conditions that:
with CoP on Site Supervision i) The GI works were carried out in accordance with the Integrated Site
Supervision System implemented in 2005; and
ii) The RSE should formally write to BD that the GI information are
correct and appropriate to be adopted as the supporting documents for
the foundation submission of the project.
BD expressed that additional verification boreholes may be required to
substantiate the accuracy of the GI information.

16. Testing criteria on aging effect for stone used in cladding BD advised that internal review was being conducted. PNAP APP-16
submission. might be amended to specify the testing requirements for BSC/APSEC
members' comments.

17. Completion certification procedures for A&A works involve BD advised that the appointment of a Specialist Contractor (Demolition)
large scale demolition. for A&A works was clearly specified in relevant PNAPs. Submission of
BA14A is therefore required for demolition works involving the appointment
of Specialist Contractor (Demolition).

18. Can we ignore transient wind load induced by adjacent BD advised that wind loading from the adjacent existing building(s) had to
structures when assessing the settlement of ground in an be considered. For strength design of structural members of the E&LS
ELS proposal? works, full wind loading from adjoining existing building(s) should be
adopted in the design. However, BD would review the possibility of reducing
the wind loading for ground movements assessment if there was no safety
problem on the adjoining building, street, services, etc.

19. To avoid clashing with existing reinforcement, sometime we BD considered that these types of works are not within the scope of the
need to adjust the location of bolts for temporary steel PNAP 272 therefore an amendment submission and corresponding consent
works of precautionary measures for demolition works. As application should be made. Besides, the approval plans facilitate staff of
these temporary works will be removed upon completion of Site Monitoring Section to control the building works of an active
demolition works, will BD accept structural justification construction site. HKIE might make proposal on very minor relocation of
with record plan instead of amendment submission? base plates to BD for consideration.

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20. Under current APP-68 (previously known as PNAP-173), BD clarified that PNAP APP-68 for cantilevered structures to adopt a
the structural design of cantilevered structure with span beam-slab construction if the span exceeding 1000mm is advisory. BD
more than 1000mm should use a beam-and-slab type of would consider RSE’s proposal case by case with due consideration of global
arrangement instead of pure slab cantilever. Recently, stability and safety, i.e. reduced working stress of rebars, detailing of rebars
most of the new residential buildings in Hong Kong have arrangement, etc. HKIE’s suggestion on limit the working stress of rebars,
balconies with a cantilever span of 1200mm to 1500mm. concrete cover etc. are already given in the PNAP.
For aesthetic reason, most architects would like to have a
thicker pure cantilever slab for the balcony, instead of
having the edge beams. Also, when the width of the
balcony is only half way across the living room, the
anchorage detail for the cantilever beam is much more
difficult to construct. We understand that the APP-68
advised to increase the slab thickness inside the flat in order
to have a straight re-bar; however, the slab would need to be
at least 300mm thick which will increase the concrete
volume a lot & reduce the clear headroom of the normal
residential unit. We would like BD to allow and consider
using pure cantilever slab construction for span up to
1500mm. The minimum cover and slab thickness can be
increased, and the design service stress at re-bar will still be
limited to certain value.

21 Query on CoP for Fire Safety in Buildings BD’s responses:-

- Diagram B3: Open Plan Layout - One of the d1 should - One of the annotations “d1” in Diagram B3 has been deleted in the final
be deleted. version of the FS Code promulgated on 2.4.2012.

- Diagram B4: Balcony Approach - One of the d2 should - One of the annotations “d2” in Diagram B4 has been deleted in the final
be deleted. version of the FS Code promulgated on 2.4.2012.

- Clause B17.5 - For staircase from basement floor with - Where the staircase is an independent staircase complying with Clause
direct discharge independently into an ultimate place of B17.4, a protected lobby is not required at that basement level and the
safety, no protected lobby is required at basement nor at ground level, provided that the staircase leads independently and directly

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 ground level? to the ultimate place of safety at G/F and the whole staircase enclosure
does not have any opening communicating with other areas of the
building.

A.O.B.
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a) PNAP ADV-3 - complaints on floor numbering system a) Arising from recent complaints against the floor numbering system of
of development projects. (Item raised by BD) two development projects, Members were reminded of the requirements
set out in the PNAP ADV-3 on Standardization of Floor Numbering, and
were requested to convey the BD's advice to members of their
organizations to revisit all building plans that have been approved prior
to the promulgation of the revised PNAP in May 2010 and to make
necessary amendments to comply with the prevailing requirements. It
was noted that Members had not experienced any problems or reluctance
in complying with the floor numbering system as set out in the PNAP.

b) Soft Copy of Record Plans for R&VD in AutoCAD or b) In response to R&VD's request for introducing a requirement in PNAP
Microstation format. (Item raised by BD) APP-13 to require the supply of soft copy of the record plans in
AutoCAD or Microstation format after project completion, Members
discussed and agreed to convey the message to members of their
organizations and to provide their response to such request to BD.

c) Excavation for Car Park to Be Considered Underground c) Members mentioned that strictly following the criteria in PNAP APP-2 to
(Item raised by HKIA) make a car park underground in sites with large difference in levels
between streets would require substantial yet unnecessary excavation if
GFA is to be exempted. Members advised that modification applied for
such cases following paragraph 15(b)(vii)(4) of the PNAP was rejected.
BD advised the concerned AP to check with the BS the reason of such
rejection and resubmit the proposal for a review if necessary.

d) Plastic WC Pan Connector for Connecting WC P-trap d) HKIA reps raised a case of rejection by BD citing the non-availability of
discharge to vertical or horizontal pipework (Item raised a British Standard for these connectors. However, a British Standard
by HKIA) for these connectors is available. BD advised that the rejection of such
connectors may be for the reason that they did not comply with other
drainage regulations. HKIA reps would provide more information to
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 BD for their review and response on this specific case.

e) Potential for UBW in Relation to GBP Approval (Item e) Members enquired if BD would follow the DB’s public statement in
raised by HKIA) LegCo that existence of potential for UBW/abuse would not be a ground
for disapproval of plans. BD clarified that in processing applications for
modifications/exemptions, potential for UBW/abuse would be one of the
relevant factors to be considered in formulating a decision.

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