Over the last few decades, the worldwide fire protection community has made large strides in advancing building fire safety. Advances in technology, in our understanding of fire dynamics, and the development of design and analysis tools have led to changes in the way the fire protection engineering profession approaches fire safety. With these changes, building and fire codes around the world have begun to change in an effort to reflect and make use of this new knowledge. 1

This article provides a brief overview of the fire and life safety codes and guidelines that are used in some of the countries around the globe, including Australia, Hong Kong, Japan, Sweden, England and Wales, Canada, and the United States of America (U.S.). To a varying degree, prescriptive codes play a role in all of these countries; some rely almost completely on prescriptive codes, while others have moved towards a performance-based approach to fire safety.


Australia is divided into six different states and two territories, each of which is governed by its own building control system. In the first part of the 20th century, these states and territories had adopted their own regulations as they saw appropriate. 3 During the 1960s, the various state and territory governments, the federal government, and other related organizations jointly formed the Interstate Standing Committee on Uniform Building Regulations (ISCUBR), which produced the first national model for technical building regulations. This document was titled the Australian Model Uniform Building Code (AMUBC) and formed a basis for the development of state and territory technical regulations during the early 1970s. In the 1980s, the Australian Uniform Building Regulations Coordinating Council (AUBRCC) was formed. This organization developed the prescriptive Building Code of Australia (BCA) 4 in 1990, which was adopted nationwide in 1992. 3


In 1994, the AUBRCC was dissolved, and the Australian Building Codes Board (ABCB) was formed to maintain the BCA. In 1996, the Board published the performance-based BCA, which has now been adopted nationwide.


The Australian Fire Safety Engineering Guidelines 5 was first published in 1996, with the aim of providing a framework, process, and guidance document for the application of fire engineering methods.


Additionally, Australia has dedicated standards-writing bodies, such as Standards Australia, that are private organizations similar in nature to NFPA. They are responsible for the development of specific technical standards that may be incorporated within, or adopted by, building codes such as the BCA or relevant legislation.


The performance-based BCA provides prescriptive guidance while allowing a performance-based approach to fire safety. A building will be "deemed to satisfy" the performance requirements of the BCA if it meets the prescriptive requirements of the BCA. Alternately, building designers may choose to propose an alternative solution to the authority in order to gain approval for a different method of design or construction.


The local government has generally been responsible for approving building designs in Australia, although in recent years there have been changes to legislation that enhance the role of approved private practitioners in the building design and approval process.


The first England/Wales building regulations to incorporate fire safety measures outside of metropolitan areas were developed as model bylaws in the 1950s. Many local authorities adopted these bylaws, although they were not accepted throughout the UK. In 1965, national building regulations were developed that were adopted throughout the UK, with the exception of central London, which abided by its own regulations. 6 At that time the regulations were purely prescriptive, similar to most current model building codes in the United States.


In 1985, the UK moved to a system of building regulations based on functional requirements. These are outlined in Part B of Schedule 1 of the England and Wales Building Regulations, and supported by a set of guidelines entitled Approved Documents. 7 Approved Document B provides guidance on fire safety requirements. In addition to the Approved Documents, there are British Standards that provide further guidelines for the design of various building components and systems. The British Standards are meant as recommended guidelines, as are the Approved Documents.


Authorities Having Jurisdiction in England and Wales generally recognize that full compliance with the recommendations of the Approved Documents is not always possible. Therefore, a fire engineering approach can be used to develop alternative ways of achieving compliance with the intent of the requirements. Since the 1992 edition, the Approved Documents have recognized and allowed the use of an alternative approach to fire safety design. The British Standards documents (PD 7974-0 to 7) on fire safety engineering 8 address the technical issues associated with design through use of a fire engineering approach.


The local government administers building approvals. Alternately, approval of building designs can be obtained from private-sector "Approved Inspectors" if accepted by the local authority. Approved Inspectors are evaluated by the local authority to determine if they are technically competent and must be commercially independent of the project.


Hong Kong's current system of fire related building ordinance and regulations are based on a series of four prescriptive Codes of Practice. These are:

  1. Code of Practice for the Provision of Means of Escape in Case of Fire, Buildings Department, June 1996.
  2. Code of Practice for Means of Access for Firefighting and Rescue, Buildings Department, May 1995.
  3. Code of Practice for Fire Resisting Construction, Buildings Department, January 1996.
  4. Code of Practice for Minimum Fire Service Installations and Equipment, and Inspection, Testing and Maintenance of Installations and Equipment, Fire Services Department, June 1998.

These codes were developed to a large degree around UK standards and codes during the time when Hong Kong was under British administration. In 1995-96, these Codes of Practice officially permitted the principle of adopting fire safety design alternatives. These documents were issued in the form of Practice Note for Authorised Persons and Registered Structural Engineers and Practice Note for Registered Contractors for the requirements administered by the Buildings Department and in the form of a "Circular Letter" for the requirements administered by the Fire Services Department.


Equivalencies to these codes are possible through the use of a performance-based approach. Fire engineering solutions are subject to approval by the Fire Safety Committee. This committee is made up of representatives from Buildings Department, Fire Services Department, Academics, and Engineering Specialists and Practitioners. Practice Note PNAP 204 was issued in 1998 by the Buildings Department to provide guidance on the objectives, design methodology, design procedures, and proposed content of a fire safety strategy report when developing equivalencies to prescriptive code requirements. Practitioners typically make reference to overseas standards and engineering methods when carrying out evaluations. A Buildings Department official provides approval of the design after receiving comments from the Fire Services Department. The Buildings Department administers passive fire safety requirements, while the Fire Services Department typically administers active fire safety provisions, including smoke management.


Hong Kong is currently undergoing efforts to revise their system of building and fire codes. They are proceeding with an extensive effort to develop a completely new code that will become a model performance-based code. This new code is being developed by practicing engineers under the guidance of the Hong Kong Buildings Department and Fire Services Department and will incorporate a review of practices from around the world.


The Japanese system of building codes has traditionally been similar to that used by the U.S. The Building Standards Law (BSL) 9 is a prescriptive code that has been in force since 1950. This was originally based on the Uniform Building Code (UBC) developed by the international conference of building officials. There is also a Fire Service Law (FSL) 10 in place that addresses requirements for active fire protection systems. These codes apply nationwide, although various cities and regions have adopted revisions to the base codes.

In 1998, the BSL was amended to include performance-based requirements; this document was adopted in June of 2000. This new code allows three alternatives for building design. The first acceptable method is for the building design to meet the Deemed-To-Satisfy methods prescribed in the model code. The second alternative allows a performance-based design approach, based on proven alternate methods or materials of construction. The third alternative of design allows the use of an engineering analysis to prove that new alternate methods or materials will meet the performance-based provisions contained within the code.


The BSL stipulates the objectives and functional (qualitative) performance requirements. Quantitative (technical) performance criteria and Deemed-To-Satisfy provisions are provided in the document entitled Enforcement Order, the Ministry Order and Notification.

The Ministry of Construction and the Fire and Disaster Management Agency administer approval of prescriptive building and fire regulations. For designs that use performance-based analysis, approval is based upon a review by a designated Performance Evaluation Body.


Sweden developed its first prescriptive rules for fire safety over a century ago, in 1874, after several devastating fires had occurred in densely populated areas. These codes were based on the premise that loosely translates to the idea that "to accidentally burn down your house is not as bad as burning down your neighbor's house." This initial set of rules gradually evolved through several revisions of prescriptive building codes until 1994, when a partial performance-based code was issued by the National Board of Housing Building and Planning (BBR94). 11


Two handbooks provide the engineering methods, tools, and acceptable procedures for fire engineering design and calculations. The translated English titles of the two handbooks are Fire Safety Engineering Guidelines and Guidelines on Fire Safety Design of HVAC Systems.


A standard prescriptive approach is used for most types of buildings in Sweden. A set of acceptable Deemed-To-Satisfy design solutions has been provided that meet the performance requirements of BBR94. Compliance with these solutions provides an acceptable design.


Performance-based fire engineering is used on a smaller number of building design aspects but is still fairly common. This approach was basically accepted even before the introduction of BBR94. This option is generally exercised when seeking an alternate method for a particular system design rather than for a full building fire safety design.


There is no formal inspection body that regularly enforces Swedish building regulations. Generally, it is the responsibility of the building owner to verify that their building is compliant. Individual systems, such as alarms, sprinklers, and ventilation systems, are inspected regularly by certified persons and may be checked by the Fire Safety Service.


Canada has a centralized system for developing and maintaining their model code that began in 1937. The first edition of the National Building Code was published in 1941. The Canadian Commission on Building and Fire Codes (CCBFC) develops and maintains six of the model construction and fire codes. This is done through a consensus-based process where codes are updated approximately every five years. While the model codes are prepared centrally under the direction of the CCBFC, the adoption and enforcement of the codes are the responsibility of the provincial and territorial Authorities Having Jurisdiction.


The model national building, plumbing, and fire codes have equivalency provisions. These permit the use of equipment, materials, systems, methods of design, or construction procedures that are not specifically prescribed. If a designer proposes an alternate approach, then the designer must demonstrate that the alternative provides the level of performance required by the codes.


The National Building Code, National Fire Code, and National Plumbing Code are being changed into an objective based format for the 2004 editions. This will offer several advantages, including a better understanding of each requirement's intent, additional information for evaluating alternative approaches, and more flexibility to adapt to innovation.


In the U.S., the federal government does not draft or enforce building and fire regulations on a state or local level. Building and fire regulations are drafted by private organizations, such as the International Code Council (ICC) and the National Fire Protection Association (NFPA). These codes are then made available for adoption by state and local governments. These codes have traditionally been prescriptive codes for both building design and fire protection systems, as well as for other building-related areas such as zoning, mechanical systems, and electrical wiring. The 50 states have either adopted existing codes with modifications or have written their own codes. In addition, some of the major cities write or adopt their own codes rather than following the codes adopted by their state.


Until recently, the major building and fire codes used in the U.S. were variations of the Uniform Building Code, 13 the Standard Building Code, 14 or the National Building Code. 15 In 1994, the three organizations that developed these codes merged their existing codes under the newly created entity called the International Code Council (ICC). In 2003, the organizations formally consolidated into the ICC. Several states have already adopted the ICC codes. Another recent development in the U.S. code community is the publication of NFPA 5000 16 by the National Fire Protection Association (NFPA). Both the ICC and NFPA have pursued the development of performance codes but in fairly different approaches. ICC has published a stand-alone performance code titled the ICC Performance Code for Buildings and Facilities, 17 and NFPA has incorporated a performance option within NFPA 5000. Both approaches will continue to support the use of prescriptive documents as the primary available solutions.


Both the ICC set of codes and NFPA 5000 provide prescriptive requirements that must be met by the design team and be approved by the local Authority Having Jurisdiction before a certificate of occupancy will be issued and the building can be legally opened. However, for designs that do not use the companion performance-based code or the performance option within the code, both of these sets of codes allow alternative methods and materials to be used upon approval of the local authorities.


The countries discussed above have all developed a set of Deemed-To-Satisfy prescriptive requirements that provide a minimum acceptable level of safety from fire. These documents typically provide guidelines from which engineers can design most buildings.


However, many countries have found that traditional, purely prescriptive codes do not always offer the flexibility that is needed to accommodate specific design or functional needs of the stakeholders, or for more modern methods of design and construction. A trend towards acceptance of the performance-based approach has begun to emerge in many countries around the globe. Some have used this approach for many years, while others are in the initial stages of developing and accepting this process. 2 It should be noted that although many code systems have moved towards a performance framework, the traditional methods (Deemed-To-Satisfy) are still widely used. The difference between prescriptive codes and performance-based codes is that the performance-based regulations are focused upon acceptable outcomes and not on a limited set of solutions.


In addition to the worldwide codes and standards mentioned in this article, several documents that have recently been published in the United States help to provide guidelines for engineers who wish to go outside the prescriptive or Deemed-To-Satisfy approach to building design, whether to obtain an equivalency or to suggest a completely new method of design for a building. At the same time, these documents provide building officials and other authorities with a framework on which to base their examination of the proposed building designs. Among these publications are NFPA 101, the Life Safety Code, 18 which provides a performance option, and the SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings. 19 The Society of Fire Protection Engineers is also developing several other guides to assist in undertaking performance-based designs, including the ICC/SFPE Enforcer's Guide to Performance-Based Design Review. 20



  1. Meacham, B., The Evolution of Performance-Based Codes and Fire Safety Design Methods, National Institute of Standards and Technology, NIST-GCR-98-761, November 1998.
  2. Custer, R.L.P., Meacham, B., Introduction to Performance-Based Fire Safety, National Fire Protection Association, Quincy, MA, 1997.
  3. History of the Building Code Australia.
  4. Building Code of Australia. Australian Building Codes Board, Canberra, Australia, 1996.
  5. Fire Engineering Guidelines. 2nd edition, Fire Code Reform Centre Ltd, Sydney, Australia, 2001.
  6. London Building Acts (Amendment), 1939.
  7. The Building Regulations 1991 Approved Document B Fire Safety 2000 Edition. Department of the Environment Transport and the Regions, London, 2000.
  8. BS 7974, Application of Fire Safety Engineering Principles to the Design of Buildings Code of Practice, 2001.
  9. The Buildings Standard Law, Building Centre of Japan.
  10. The Fire Services Law Enforcement Order, International Fire Service Information Centre, Japan.
  11. Brandskydd, Boverkets Byggregler, Teori & Praktik. (Swedish) 11 Brandskyddslaget and LTH Brandteknik, Stockholm, Sweden, 1994.
  12. Canada's Code Development Process, National Research Council of Canada.
  13. Uniform Building Code, International Conference of Building Officials, Whittier, CA, 1997.
  14. Standard Building Code, Southern Building Code Congress International, Birmingham, AL, 1999.
  15. National Building Code, Building Officials and Code Administrators International, Country Club Hills, IL, 1999.
  16. NFPA 5000, Building Construction and Safety Code, National Fire Protection Association, Quincy, MA, 2003.
  17. ICC Performance Code for Buildings and Facilities, International Code Council, Falls Church, VA, 2003.
  18. NFPA 101, Life Safety Code, National Fire Protection Association, Quincy, MA, 2003.
  19. The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings. National Fire Protection Association, Quincy, MA, 2000.
  20. SFPE Enforcer's Guide to Performance-Based Design Review Review Draft. Society of Fire Protection Engineers, Bethesda, MD, 2003.