Sandy McPherson, contributor to the BCA Codemark Accreditation Review and MD of external insulation finishing systems company Practica MMC, demystifies the process of ensuring facade building materials used by the Australian building industry are compliant with the Performance Requirements of the Building Code of Australia (N.C.C.).


Since the recent findings by the Melbourne Fire Bureau Safety Officers that the ‘unusual rapid’ spread of the blaze at the Docklands LaCrosse Apartment block in November last year, was, in part, the result of the use of a non-compliant and combustible (where non-combustibility was required) external aluminium composite wall cladding system, the building industry has been quick to react. 

The Victorian Building Association (VBA) carefully announced that responsibility falls on the shoulders of all parties involved in the manufacture and supply of building materials, including the design, approval and construction of a building and that all stakeholders in the building industry need to be diligent in ensuring facade building materials used are suitable for use and meet the Performance Requirements of the Building Code of Australia (BCA).

This is where things get problematic, as in recent years, residential and commercial building in Australia has embraced the use of innovative and alternative external wall cladding systems. However, this has also resulted in the saturation of non-compliant building materials and therefore cladding systems, into the building supply chain.


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To be compliant a system or material must be ‘Deemed to Satisfy’ (DtS) by the BCA, as a building solution. Systems and materials which are not DtS are referred to as ‘non DtS’ and therefore considered as an ‘Alternative Solution’.

When an Alternative Solution is presented in a design it needs to be the joint responsibility of all involved to ensure that the Alternative Solution assessment process specified by the BCA is followed, and it is demonstrated and proved through documentation that the Alternative Solution complies with the Performance Requirements of the BCA, the Building Act of 1993 and Building Regulations, 2006.  

These performance provisions include testing for damp and weatherproofing, fire performance, energy efficiency and acceptable construction – to name a few.  

All information and evidence must determine that the material, form of construction and design of the Alternative Solution, is equivalent to, or better than, the DtS provision. This allows architects, builders and building surveyors to be confident that they are choosing and recommending an innovative non-Dts (Alternative Solution) cladding system that meets the Performance Requirements of the B.C.A.

Examples of Alternative Solutions include, but are not limited to, the following generic product types:

  • Autoclaved aerated concrete (A.A.C.) 
  • Aluminium composite panels 
  • Architectural insulation panels 
  • External insulation and render finish systems including polystyrene and phenolic panel systems 

Suggested ways to ensure that the Alternative Solution complies with the Performance Requirements of the BCA may include: 

  • Code Mark Certificate of System Conformity (National) 
  • Judgement Report from an Expert (not the Building Surveyor)
  • Reports issued by a Registered Testing Authority (R.T.A.)
  • Accreditation Certificates (various state Building Commissions)   

Codemark is a building product and cladding system certification scheme that supports the use of new and innovative materials, which once assessed for compliancy with the Building Code requirements, are issued with a Certificate of conformity. It ensures that the building materials used are third-party endorsed, and is a sure-fire way to give users the confidence that the building product or cladding system in question complies with the Building Code of Australia.

A simple but effective way for Building Surveyors, Builders and Architects to instantly confirm that the Alternative Solution chosen is a CodeMark certified product or system is to cross reference it via the Australian Building Codes Board (ABCB) website, which lists all Alternative Solutions that have been given the Codemark stamp of approval. The aluminum material involved in the Docklands fire is not on that list either in terms of product (e.g. compliancy to Part 1530) or as a compliant cladding system.

A recommendation of the recent ABCB review of the CodeMark Scheme recommends that the CodeMark certificate of accreditation should look different, for example in a different colour, for Product compared to the certificate for System Accreditation.

Either accreditation and or test certificates related only to the product, and accreditation of a cladding System (including how the system is fixed and its weather tightness credentials for example) are required by the National Construction Code.

International experience over a number of years indicates special care and consideration is necessary in the use of all external wall cladding systems.  

There is an obligation by the building industry to undertake due diligence in ensuring that the material, form of construction and design chosen meets the Performance Requirements of the BCA. Alas, failure to ensure that the facade materials used are compliant (both the product and the construction system surrounding the product) may result in potentially rendering a building unhealthy or dangerous.