Is your combustible cladding rectification project considering all combustible cladding on the building?

The below links to a report on EPS concrete which was released by the Victorian Building Authority (VBA) in December 2021 which is interesting for a number of reasons which I will split over a couple of articles in order to keep the article size down.

https://www.vba.vic.gov.au/__data/assets/pdf_file/0020/146153/Attachment-2_CSIRO-Report-EPS-Concrete.pdf

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When thinking of combustible cladding in the Australian environment, I suspect most people immediately think of Aluminium Composite Panels (ACP) which get a lot of the media attention particularly after fires such as Lacrosse

(November 2014 – https://www.melbourne.vic.gov.au/sitecollectiondocuments/mbs-report-lacrosse-fire.pdf)

and Neo200 which received extensive media coverage.

(February 2019 - https://www.melbourne.vic.gov.au/news-and-media/Pages/Updated-statement-on-fire-at-200-Spencer-Street.aspx)

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An Aluminium Composite Panel is a panel made up of two thin sheets of Aluminium with a polyethylene core bonded between them.

Polyethylene is a polymer and is combustible:

(https://www.vba.vic.gov.au/__data/assets/pdf_file/0010/97579/Fact-Sheet-Aluminium-Composite-Panels.pdf)

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At a push, maybe Expanded Polystyrene (EPS) comes to people’s minds.

?EPS is a type of cladding where EPS panels are fixed to a frame and rendered and painted to look like concrete or rendered masonry.

Polystyrene is a polymer and is combustible:

(https://www.vba.vic.gov.au/__data/assets/pdf_file/0011/97580/Fact-Sheet-Expanded-Polystyrene.pdf)

Industry messaging

?The following industry websites only mention ACP or EPS and while Victoria focused as this is where I live and operate most, I suspect we could do the same for other states:

• ?Victorian Building Authority webpage related to “What is combustible cladding” only names ACP and EPS and offers links to PDF’s explaining these in more detail. https://www.vba.vic.gov.au/cladding/what-is-combustible-cladding
• The Victorian Government website only names ACP and EPS and explains that ACP and EPS will be funded for removal and mentions that:

(https://www.vic.gov.au/cladding-rectification-funding-guidelines)

• Fire and Rescue Victoria links directly back to the VBA and Victorian Government websites so the message regarding what combustible cladding is would be the same as above. https://www.frv.vic.gov.au/combustible-cladding

While ACP and EPS are arguably the two most well-known types of combustible cladding, there are other forms of combustible cladding which require consideration in the Australian environment where non-combustible construction is often required.

Other types of combustible cladding

Having been involved in cladding inspections, sampling and rectification works and acted as an expert witness for cases in Australia for the past few years I have come across many types of combustible cladding on projects.

?Other types of combustible cladding I have come across on projects in Australia are:

• Timber – self-explanatory as we know timber burns.
• Composite timber – these are often a wood and polyvinyl chloride mix formed to look like wood with the “benefits” of greater UV resistance and reduced maintenance etc.
• High Pressure Laminates (HPL) Panels – layers of phenolic resin impregnated with various fibres to build up a core with surface layers added at elevated temperatures and pressures.
• Insulated sandwich panels (ISP’s) – typically much thicker than ACP and with steel sheet facings over a core of EPS or Polyisocyanurate (PIR) or Polyurethane (PUR) or some other core.
• Fibre Reinforced Plastics (FRP) - Fibres used can vary from Glass (GRP) to carbon fibre and they are used to strengthen the plastic form. Plastics used can be thermoset (don't melt and drip upon the application of heat) or thermoplastic (do melt and drip upon the application of heat)

Without getting too technical and listing out material properties, it is true that certain types of combustible cladding are more combustible than others and therefore arguably present more of a risk than others. The above are all combustible however and under the Australian legislative environment, should not be present on external walls required to be type A and B construction without an appropriate Performance Solution (what is appropriate is completely another article so for simplicity let’s just say combustible cladding in large quantities should not be on these buildings).

Why the exclusion?

?So why would a contractor exclude these other types of combustible cladding from their scope?

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In my experience on projects, this exclusion of certain types of combustible cladding from scope is not as a result of any engineering assessment.

?I have heard it said that they don’t have enough funds or they believe the other types of combustible cladding are not dangerous enough or mistakenly believe that only ACP and EPS are the problem.

?Even if it is the case that a Statewide cladding rectification program deems a type(s) of combustible cladding to be out of scope, all this means is that the Statewide cladding rectification program has decided that their funds will not be used to pay for the rectification of this type of combustible cladding – it does not mean that the product is compliant or non-combustible and it does not mean that the contractor or the building owners are permitted to ignore it. I fear that some of the buildings where this approach has been taken by contractors and building owners will be hit with new Building Notices from the Municipal Building Surveyor and will have to go through at best an engineering assessment and at worst another rectification process again in the future.

I was approached for a fee proposal for fire engineering services on a rectification project which knowingly had EPS Concrete as well as ACP and rendered EPS. As EPS Concrete was excluded from the Statewide cladding rectification program the contractor was not interested in even assessing it. I pointed out that we would need to assess it as it is still a combustible cladding material – it simply means that any required rectification works would not be paid by the Statewide cladding rectification program. I explained we would assess the composition of the EPS Concrete used by sampling (via 50mm core drill) and working out the density at different panels on all sides of the building (total of 8 samples or so) and if they met the criteria we had set in terms of density then we should be able to justify their retention. If the density criteria was not met then we would need to remove and replace them or add mitigation measures. The contractor stated that the EPS Concrete was not part?of the funding and so did not need to be assessed, sighed, hung up and stopped returning my calls. I do wonder if he found a fire engineer who said they would proceed without assessing the EPS Concrete as its not part of the Statewide cladding rectification program – or simply shopped around until he found a fire engineer who doesn’t realise the building has EPS Concrete and simply assessed the other combustible cladding on the building. It also makes me wonder if I have ever looked at a building and not been made aware of other types of combustible cladding on the building.

Summary

?My concern is that the messaging in industry, while focusing on two of the most combustible and prevalent types of combustible cladding, has inadvertently led to the misguided belief by many that the other types of combustible cladding don’t require engineering assessment. This simply isn’t true.

?Lets not forget that its not just the cladding which should be non-combustible, but all elements of the external wall (unless exempt) so what do you do if you have a non-combustible cladding but combustible insulation underneath it. In short please contact a fire engineer and have the assessment undertaken.

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