Summary of Items Discussed in 2/2015 APSEC Discussion Forum on 20 March 2015

Items proposed by Convenors for Discussion Summary of Discussion and BD’s Responses
Items raised by HKIA
1. Pipe Ducts and Essential E&M Ducts Located at Staircase
According to PNAP APP-93, pipe ducts shall be accessible from the common The BD advised that pipe ducts for building services complying with
parts of the building. An unobstructed working space of not less than 700mm in Code of Practice for Fire Safety in Building 2011 (FS Code) Clause
front of the pipes shall be provided for maintenance and repair of the pipeworks. C9.3(d) but requiring maintenance and repair should not be provided in
The doors or panels providing access to the pipe ducts shall not be less than such location that would rely on access from a flight of stairs.
600mm wide by 2000mm high.
There are precedents that pipe ducts located at the staircase can be exempted
from GFA calculations, given that they fulfill the above mentioned
requirements. However, there are recent cases rejected that the access panels or
doors should be opened at landings, and the same also apply to other essential
E&M ducts.
Please clarify if access panels for pipe ducts could be opened at staircases and
exempted from GFA calculations if the requirements of PNAP APP-93 are
complied with and also for access panels for essential E&M ducts to be opened
at staircase if maintenance works could technically be conducted via these
access panels (as per the sketch below).

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2. MOE Discharge to Lawn Area
Please confirm that MOE discharge to a ground floor open lawn area is The BD clarified that according to item (j) of the guidance on factors to
acceptable as this will certainly help in greenery calculations. For reference, the be considered for complying with the Performance Requirements B1 to
CoP for Fire Safety in Buildings only requires EVA to be hard-paved. B7 for MOE in Subsection A8 in Section 2 of FS Code (p. 12), the
MOE should be of suitable construction to prevent slipping and falling.
Hence, open lawn area should not be accepted.

By the same token, the ultimate place of safety should be of suitable

surface materials to allow safe gathering of occupants for them to
safety disperse away from the subject building.

3. Vertical Green Wall Next to MOE

A comment from BS states that it is not allowed to have a vertical green wall The BD responded that the proposal to allow a horizontal clearance
located next to the exit route because the green wall does not have specified fire between the surface of the vertical green wall to the edge of the
resistance rating. Therefore, if the MOE staircase is attached to the vertical minimum escape width was acceptable. However, the minimum
green wall, the space along the stairs with a height of 2m should be clear and clearance should be determined on a case-by-case basis as it would
without the vertical green wall system (see diagram below). As there are many depend on the types of the plants and the information provided by the

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 precedent cases of having planters next to exit routes, we suggest that a vertical AP.
green wall can be located next to an open staircase provided that there is a
reasonable clearance, say 300mm, of the vertical green wall from the required
discharge width of the staircase.

4. Prescribed Window Calculations for House and Apartment Ground Floor

Garden Unit
As the parapet wall for a garden unit on ground floor is usually higher due to the The BD advised that measurement of the prescribed window should be
security reason, we wish to reconfirm the following:- from the top of fence wall instead of above 1m above the internal floor
(a) Prescribed windows can be counted from the top of the fence wall instead level for windows abutting a street not less than 4.5m wide. In
of 1m above internal floor level. addition, the use of performance-based approach promulgated in
(b) If the window is facing a specified street of not less than 4.5m width, a PNAP APP-130 was also acceptable.
normal fence wall on the boundary of the private garden or site boundary
would not be counted as obstruction.

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5. Site Supervision
As the technical committee is reviewing the effect of construction cost inflation The BD acknowledged the issue and advised that the technical
to the site supervision frequency, we would request the BD to review the committee for the CoP for Site Supervision would review the
method of calculating the supervision frequency of superstructure works. We approaches and methodologies to calculate the frequency of
believe the requirement of using total construction floor area to assess the supervision to be required for superstructure works. The BD would
supervision frequency is unreasonable, especially for large scale development, advise the outcome of review in due course.
and this also does not take into account the works already completed. It is
commonly adopted practice that the AP/RSE has to break down the works into

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 various stages in order to make the supervision frequency reasonable. We
suggest BD to review the method of calculation and consider a more pragmatic
approach such as calculating the scale factor according to the average
construction floor area per month (similar to foundation & ELS works).

6. Discharge of MOE on G/F in Upward Direction

A deep and long floor plate that is free of intermediate obstructions (i.e. BD explained that the proposed upward MoE discharge on G/F, as
enclosed MOE routes that cut across the manufacturing area) is often required described, might be acceptable provided that each exit route should be
to satisfy the manufacturing flows/circulations of a specialized industrial physically separated from other exit routes and other required
undertaking. To cope with the said manufacturing requirement, a series of staircases from upper floors .
protected staircases at strategic locations deep inside the manufacturing area on
G/F that lead to an elevated protected MOE routes at high level is proposed.
The proposed elevated MOE would terminate at the building edge and
discharge the occupants to the open air via a set of staircase(s) in downward
direction. Please advise if the above proposed upward discharge of MOE on
G/F is acceptable.

7. Flexibility for Solar Shading of Windows

Under existing guidelines, solar shading of windows is controlled as both The BD was receptive with the proposed sliding louvres in front of
building projection and thermal performance of glass where sunshades windows to enhance solar protection on a case-by-case basis subject to
projecting up to 1.5m are permitted under PNAP APP-19 subject to compliance submission of detailed information of such system as well as the
with APP-67 and APP-156. The limited depth of such sunshades is ineffective circumstances of individual cases. While the proposed sliding
against afternoon sunlight that penetrates windows (or even balconies) in low louvres might be considered as an amenity feature under the PNAP
angle and/or sideways, resulting in undesirable heat gain and glare problem in APP-42, considerations should be given to the possible reflection of
habitable spaces. As shown in Figures 1a & 1b, louver screens in front of sunlight from the slanted louvres to the surrounding buildings, and
windows and balconies provide complete shading regardless of sun angle, and derogation of air ventilation through the louvres. The BD strongly
they can be slid away at will from the windows and balconies for a fully open advised that pre-submission enquiry with detailed justifications

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view. These moveable sliding louver screens are common environmentally including implications arising of the two aforesaid issues, should be
friendly features seen in Europe and Australia. Figures 2a & 2b show a made prior to formal submission.
mechanical example from England and a manual system from Germany. Would
BD advise if this system is permissible under current Building Regulations and
enjoys similar benefits given by relevant PNAP and JPN for green and
innovative building features?

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8. PNAP APP-130
Para. 2, Appendix ‘A’ of PNAP APP-130 states that “Primary opening” means The BD acknowledged that HKIA’s understanding was correct, i.e. Part
any window opening which satisfies the natural lighting requirements III of Appendix A of PNAP APP-130 on guidelines on adoption of
stipulated under B(P)Rs or in paragraph 1(a) of PNAP APP-130 or any window performance-based standards for natural ventilation could be applied to
opening located in or within 1.5 from end of the external wall where the a room where the window could only meet the prescriptive natural
aforementioned window locates. lighting requirement under B(P)R 31 but not the performance
The above statement appears to imply that “Part III – Ventilation” of the said requirement using UVA method. In this connection, reference should
PNAP can apply to a room where the window can only meet the prescriptive be made to the interpretation in Section 2 of Part I of Appendix A of
natural lighting requirement under B(P)R 31 but not the performance PNAP APP-130.
requirement using UVA method. Please advise if our above understanding is
correct.

Items raised by HKIE

9. BD’s Engineering Manual (EM)
During the processing of structural submissions, RSE sometimes are requested BD advised that to ensure consistency and facilitate smooth processing
to comply with some in-house design criteria stipulated in BD’s Engineering of structural plans, the EM outlined the prevailing work practices and
Manual (EM). To facilitate a smooth approval process, it is suggested to commonly adopted engineering design principles for in-house
upload these information onto BD’s website for the industry’s reference. reference. This information can normally be found in PNAPs and
Codes of Practice issued by BD and text books in related engineering
field. Not all the internal guidelines of the EM are relevant or ready
to be publicized and uploaded onto BD’s website. If necessary, RSEs
may make use of the pre-submission enquiry facility to clarify with BD
the basic design requirements prior to preparing the detailed design.

Items raised by AAP

10. Smoke Outlet The BD confirmed that it would not be necessary to place all smoke
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In Discussion Forum dated 10 Jan 2014, BD clarified that external discharge outlets within a 30m long frontage. However, each smoke outlet
smoke outlets shall be not more than 30m apart and situated along the should not be more than 30m away from another smoke outlet along
street frontages or adjacent to external walls under clause C14.2(a). the frontage.

Members encountered project recently where the above is interpreted as all

smoke outlets for basement fire compartments have to be located within a
frontage of 30m. This seems to be not a correct interpretation of the BD
Forum minutes record as it is impractical especially for large development with
many fire compartments.
The BD advised that the arrangement as shown in the diagram was
Furthermore, for large basement with more than 1 compartment, some of the acceptable under FS Code Clause 14.2(a).
smoke outlet will be in the form of horizontal 'ducts' running at the high level of
the basement and for discharging smoke from the external wall at ground level.
In such case, the 'internal smoke outlet' might be arranged as attached. We
would like to have clarification whether the distance of different 'internal
smoke outlets' within the same compartment can be more than 30m apart. (see
Sketch)

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11. Sustainable Building Design Guidelines (SBD Guidelines)
Half of the width of street can be accounted for the intervening space in the The BD advised that the matter would be discussed in the Working
calculation of Permeability. Open space under OZP designated as promenade Sessions formed under the BSC/APSEC on the draft revised PNAP
or non-building area may be considered in the calculation of Permeability also. APP-152.

Following the above, it seems that a certain extent of the sea, river or green belt The BD responded that as there had been cases where the greenbelt
abutting the site boundary could be allowed to be included in the permeability was rezoned for development, inclusion of greenbelt in the
calculation. All these areas are under the control of various statutory entities, permeability calculation would create a lot of problems and it would
similar to street. And future developments will have to set back from common contradict the principle of a self-sustained design.
site boundaries if the SBD Guideline still apply.

AOB Items
12. Temporary Refuge Spaces (TRS) and Wider Corridor / Lobby
(Item raised by AAP)
Further to item 14 discussed in 5/2014 APSEC Discussion Forum, AAP The BD advised that they would check the minutes of the Working
enquired that whether Scenario 1 should be adopted instead of Scenario 3 i.e. Group meetings and follow up in the next Discussion Forum.
the location of TRS can be provided in the exempted area of wider corridor/
lobby.

13. Sampling of Mechanical Couplers for testing

(Item raised by the BD) The revised sampling rate enables continuous sampling of the
The rate of sampling for testing of mechanical splices for strength tests by mechanical splices for strength test throughout the construction works
accredited laboratories would be revised in that the number of specimens on site. The relevant revised standard appendices for approval would
would be sampled at a rate commensurate with the number of couplers to be be applied to all new submissions approved on or after 1.4.2015.
used for splicing steel rebars instead of the aggregate amount delivered to the
site.

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14. Protective Barriers for Planter walls
(Item raised by HKIA)
Whether the 1.1m inner walls of planters located at the perimeter of the The BD advised that such inner walls of planters would be considered as
podium gardens shall comply with the requirements of the protective barrier protective barrier under B(C)R 8.
under B(C)R 8, as there would have no level difference between the podium
floor and the planter?

15. Review of Occupancy Factor for Flats

(Item raised by HKIA)
HKIA requests to review whether the occupancy factor of 9 can be uniformly The BD advised that there was no strong reason for review of such
applied to all type of flats in Table B1 of FS Code. occupancy factor. However, as the representative from REDA pointed
out that more and more small units would be built to respond to the
market demand, the BD would not object to HKIA representative to
raise the issue again at the Technical Committee on FS Code.

16. Request for Amendment of Plans

(Item raised by AAP)
Whether BD can allow AP to amend plans for rectification of contraventions The BD noted that the amendments might be possible if the required
even though the plans are to be disapproved as proof of ownership / realistic changes to the plans would not be too extensive and sufficient time
prospect of control of the land forming the site cannot be accepted? would be allowed for the case officers to prepare and issue the refusal
letters.
17. Posting-meeting Note :

Item 21 of the Summary of Items discussed on 8 August 2014

FS Code Subsection E13 – Internal Wall and Ceiling Linings and Decorative Finishes (Item raised by HKIA)

HKIA would like to enquire about the progress in revising the requirement of non-combustibility for decorative finishes and linings within protected

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exits in Subsection E13 of Part E of the FS Code.

In its 4th meeting held on 31.7.2014, the Technical Committee on FS Code agreed with the recommendation that FS Code Clauses E13.1(a) and
E14.1(a) would be amended from Class A1 under European Classification to C (i.e. Class 1 under BS 476 Part 7) for the purposes of maintaining
consistent standards between BD and FSD. Corresponding amendments to FS Code would be promulgated.

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