This article discusses how AS 1851-2012 applies to existing Class 2 residential strata buildings in NSW, clarifying that maintenance obligations do not mandate system upgrades and explaining practical compliance considerations around emergency lighting test facility requirements for strata NSW.
Question: How do the new AS 1851-2012 inspection requirements apply to Class 2 buildings that don’t have a dedicated emergency lighting test facility?
I understand that from 13 February 2026, all Class 2 buildings in NSW must have essential fire safety measures inspected and tested in accordance with AS 1851-2012 under the Environmental Planning and Assessment (Development Certification and Fire Safety) Regulation 2021.
This raises a concern about the requirement in AS/NZS 2293.1:1995 for a dedicated testing facility that allows emergency lighting discharge tests without interrupting the normal lighting supply. Many residential strata schemes built after 1995 may not have this facility. Are these schemes non-compliant?
How should AS 1851-2012 be interpreted in this context for existing Class 2 residential buildings? Do any exemptions, transitional arrangements or alternative compliance pathways apply when a dedicated testing facility was not originally installed?
Answer: AS1851-2012 is a procedure for maintenance. It does not require any upgrading of existing systems.
AS1851-2012 is a procedure for maintenance. It does not require any upgrading of existing systems.
Regarding test facilities for emergency and exit lights, they definitely don’t need upgrading to meet AS1851 even if they don’t strictly comply, but there are possible other reasons the owners may require action to upgrade:
- The accredited practitioner cannot prove performance for the AFSS without it (unlikely in my opinion).
- The isolation of the lighting or power for 90 minutes may not be operationally viable for the site (not that likely on small residential sites).
- A council fire upgrade order, CDC or DA.
Rob Broadhead
2020 Fire Protection
E: rob.broadhead@2020fire.com.au
P: 1300 340 210
This post appears in Strata News #776.
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Read next:
- NSW: Building better outcomes on defects: What NSW strata owners and managers need to know in 2025
- NSW: Fair Trading’s Common Property Repairs and Maintenance Compliance and Enforcement Policy
- NSW: Q&A Staying compliant while waiting for the AS 1851 fire safety update
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