Building Compliance FAQs
Form 12A & Inspection Outcomes
FAQ 1 Can a Form 12A be issued if defects are identified during inspection or testing?
No. A Form 12A confirms inspection, testing, and maintenance were completed with no unresolved defects at the time of inspection.
Outstanding defects mean system performance has not been confirmed for that inspection period.
Outstanding defects mean system performance has not been confirmed for that inspection period.
FAQ 2 Can a Form 12A be issued with notes stating defects exist?
No. A Form 12A is confirmation of inspection outcomes, not a commentary or disclaimer document.
Where defects remain, a defect report should be issued instead.
Where defects remain, a defect report should be issued instead.
FAQ 3 Can defects remain open if they are fixed before BWOF expiry?
No. BWOF expiry dates do not override inspection outcomes.
If defects exist at the time of inspection, a Form 12A cannot be issued for that inspection period regardless of later remediation.
FAQ 4 Does it matter which inspection identified the defects?
Yes. Inspection records must clearly identify when and how defects were identified.
Accurate records support annual review decisions and BWOF certification integrity.
Records should identify:
inspection date
inspection type or cycle
whether defects are isolated, recurring, or system-wide
Accurate records support annual review decisions and BWOF certification integrity.
Records should identify:
inspection date
inspection type or cycle
whether defects are isolated, recurring, or system-wide
FAQ 5 What actions are required when defects are identified?
Defects must be clearly documented and communicated to the building owner or agent.
Reasoning
Inspection outcomes must be transparent so owners understand impacts on certification.
Typical actions include:
Reasoning
Inspection outcomes must be transparent so owners understand impacts on certification.
Typical actions include:
- documenting defects
- notifying owner/agent
- explaining impact on Form 12A
- escalating life-safety concerns
- retaining communication records
FAQ 6 What if a tenant removes a specified system?
Tenant's should not remove a specified system without Council permission in the form of a building consent or discretionary exemption.
If an IQP discovers that a specified system has been removed, they should:
- advise the building owner or their representative of the issue
- document the situation in their reporting, including photos where appropriate
- explain the impact of the removal and any associated risks; and
- refer the matter back to the owner to resolve with Council.
If the Form 12A is due and the specified system has been removed, the IQP cannot issue a Form 12A because the required inspection and maintenance procedures have not been completed. An SRaD should be issued instead, together with a report explaining the situation and the implications of the removed specified system.
If you consider the removal of the specified system to be appropriate, provide the building owner with a Form 11 application so they can apply to Council to amend the Compliance Schedule. If the removal is not appropriate, or Council declines the application, the specified system may need to be reinstated.
Inspection Scope & Compliance Interpretation
FAQ 1 Is identifying defects the same as declaring a system non-compliant?
No. Inspection identifies defects affecting performance; it does not reassess construction compliance.
Construction compliance relates to design, installation, and consented works, which sit outside routine inspection scope.
Construction compliance relates to design, installation, and consented works, which sit outside routine inspection scope.
FAQ 2 What if defects appear related to original design or installation?
Observations should be recorded factually and escalated outside the inspection scope.
Inspection does not reassess original construction compliance but may identify issues requiring further review.FAQ 2 description
Inspection does not reassess original construction compliance but may identify issues requiring further review.FAQ 2 description
FAQ 3 Who can sign the Form 12A for a CO₂ detection system?
CO₂ detection systems are generally classified under Specified System 2 (SS2). Although the Specified Systems Regulations and the Compliance Schedule Handbook don't specifically identify SS2.3, many councils do.
If a building's Compliance Schedule lists the system as SS2.3, the person signing the Form 12A will generally need to be an IQP approved for SS2.3. In many cases, this approval is held by an alarm company rather than an HVAC company. An HVAC company may still do the actual work but liaise with the SS2 alarm IQP for final 12A sign off.
If a building's Compliance Schedule lists the system as SS2.3, the person signing the Form 12A will generally need to be an IQP approved for SS2.3. In many cases, this approval is held by an alarm company rather than an HVAC company. An HVAC company may still do the actual work but liaise with the SS2 alarm IQP for final 12A sign off.
Annual Review & IQP Decisions
FAQ 1 What outcomes are available to an IQP at annual review?
Three outcomes generally apply:
Issue Form 12A — inspections complete with no unresolved defects
Issue SRAD — inspection or maintenance incomplete
Issue Defect Report Only — unresolved defects present.
Each outcome reflects inspection status at the time of review.
Each outcome reflects inspection status at the time of review.
FAQ 2 Why do disputes commonly arise at BWOF time?
Most disputes result from process issues rather than inspection outcomes.
Common causes include:
poor initial job setup
inadequate review of historical records
late identification of defects
Reasoning
Effective inspection management begins well before BWOF deadlines.
FAQ 3 SRaDs - What is an SRaD for?
An SRaD is intended to address a missed inspection. If a required inspection did not occur, an SRaD may be appropriate.
What is the confusing part?
It is often the impact of the missed inspection that causes confusion. The SRaD should address what is affected because the inspection was missed - not become a general mechanism for recording building defects.
What is the confusing part?
It is often the impact of the missed inspection that causes confusion. The SRaD should address what is affected because the inspection was missed - not become a general mechanism for recording building defects.
Can you give an example?
If required owner checks were missed and no Form 12A was issued, but the IQP inspection was completed and satisfactory, the issue is the missed owner inspection.Similarly, if two IQP inspections were required but only one was completed, the missed inspection may be addressed through an SRaD.
What should NOT be dealt with through an SRaD?
The simple test:
Was the required inspection missed?
If yes, consider whether an SRaD is appropriate.
If no, deal with the issue through the appropriate pathway - maintenance, defect remediation, construction, or Compliance Schedule correction.
If required owner checks were missed and no Form 12A was issued, but the IQP inspection was completed and satisfactory, the issue is the missed owner inspection.Similarly, if two IQP inspections were required but only one was completed, the missed inspection may be addressed through an SRaD.
What should NOT be dealt with through an SRaD?
- Maintenance issue – deal with it as maintenance.
- Defect identified during an inspection but not fixed – the inspection occurred; manage the outstanding defect/remedial work.
- Construction or installation failure – deal with the building/construction issue.
- Incorrect Compliance Schedule frequency or performance standard – correct the Compliance Schedule.
The simple test:
Was the required inspection missed?
If yes, consider whether an SRaD is appropriate.
If no, deal with the issue through the appropriate pathway - maintenance, defect remediation, construction, or Compliance Schedule correction.
Repairs, Maintenance & Consents
FAQ 1 When do repairs or replacements require a Building Consent or exemption?
Maintenance repairs are generally maintenance activities and do not typically require building consent.
Substantial repairs or full replacements may require consent or consideration of a formal exemption.
Compliance Schedule Inclusion
FAQ 1 — Do extract systems need to be included on a Compliance Schedule?
Not all extract systems require inclusion on a Compliance Schedule.
Reasoning
Systems are typically included where failure could create life-safety or health risks.
Common inclusions: mechanical fresh-air systems systems involving cooling towers smoke or fire control components hazardous contaminant extraction (e.g. spray booths, fume cupboards, commercial kitchens) Simple extract fans used for general ventilation or housekeeping purposes may not require inclusion, depending on function and risk.
Common inclusions: mechanical fresh-air systems systems involving cooling towers smoke or fire control components hazardous contaminant extraction (e.g. spray booths, fume cupboards, commercial kitchens) Simple extract fans used for general ventilation or housekeeping purposes may not require inclusion, depending on function and risk.
FAQ 2 — Does a standard split-system heat pump need to be on a Compliance Schedule?
No.
The Compliance Schedule Handbook specifically states that a split air conditioning unit that does not introduce fresh air into the building does not need to be included on a compliance schedule.
The key question is whether the system meets the definition of SS9 – Mechanical Ventilation or Air Conditioning. A typical split-system heat pump used for heating or cooling alone usually does not.
The Compliance Schedule Handbook specifically states that a split air conditioning unit that does not introduce fresh air into the building does not need to be included on a compliance schedule.
The key question is whether the system meets the definition of SS9 – Mechanical Ventilation or Air Conditioning. A typical split-system heat pump used for heating or cooling alone usually does not.
Form 12A & Compliance Schedule Scope
FAQ 1 – Can I issue a Form 12A if maintenance was not completed?
No.
A Form 12A confirms inspection, testing, and maintenance have been carried out.
If maintenance is incomplete, compliance cannot be certified for that period.
FAQ 2 - Can I fail a Form 12A because a room should have a system (in my opinion) but doesn’t?
No.
IQPs maintain existing specified systems. Installing new systems is a design issue and may require new building consent, not a Form 12A matter.
FAQ 3 - Am I responsible for upgrading systems to meet current Code?
No.
IQPs verify ongoing performance of existing specified systems. Retrospective upgrades are a building owner and consent matter.
FAQ 4 - If I take on a new site and notice a room that appears to need equipment that isn’t installed, does this affect my Form 12A?
No.
A Form 12A applies only to specified systems that are installed and listed on the Compliance Schedule. If no system exists in that room and none is listed for that space, there is nothing to inspect, test, or certify for that area.
FAQ 5 - Can I note and recommend that the absence of equipment be reviewed?
Yes.
While it is not a Form 12A matter, an IQP may professionally note observations and recommend the owner seek advice if a space appears to require assessment.
This does not alter the scope of the 12A and does not create a defect.
FAQ 6 - What if the Compliance Schedule is unclear about the equipment to service or the areas to inspect?
Do not assume. Clarify and document.
The Compliance Schedule defines the scope of inspection. If equipment descriptions, locations, or system coverage are unclear, you must seek clarification from the building owner and/or council.
Where scope is ambiguous, record the limitation and detail the uncertainty in
your Form 11. Do not guess. Do not extend scope beyond what is confirmed.
FAQ 7 - What if the Compliance Schedule lists equipment that does not exist in the building?
Record the discrepancy. Do not certify what is not there.
If a listed specified system is not present, this is a Compliance Schedule accuracy issue.
Detail the discrepancy in your Form 11 and advise the owner that the Compliance Schedule may require amendment. Do not issue a clean 12A without addressing the inconsistency.
FAQ 8 - What if there is equipment in the building that is not listed on the Compliance Schedule?
Declare it. Proceed cautiously.
Unlisted specified systems must be declared in Form 11 detailing.
Council will likely question how the system was installed and whether it required building consent. This may trigger further investigation and a Certificate of Acceptance (COA) process.
The IQP’s role is to identify and document — not to regularise the consent history.
FAQ 9 – Does an IQP inspect the means of escape?
Not in its entirety.
An IQP is responsible for the specified system they are engaged to inspect. For SS15/2 final exits, this means checking that the doors, hardware, panic furniture, self-closing devices, locking mechanisms and associated components operate as intended.
The broader means of escape—including how the building is managed during normal occupancy—is the responsibility of the building owner or occupier. Temporary obstructions, such as trolley barriers or chained aisles, are operational issues rather than defects with the specified system itself.
If an IQP observes an obstruction during an inspection, it should be reported to the building owner or person in charge so it can be rectified.
Technical
FAQ 1 What duration is required for emergency lighting?
Check out our Tip here
FAQ 2 SS9 Inspection Frequencies
SS9: Don't automatically default to quarterly inspections any more
The traditional approach for SS9 has often been quarterly IQP inspections. But councils are increasingly looking at what the nominated standard actually requires.
AS/NZS 3666.2:2011 is an operation and maintenance standard with component-specific frequencies — including monthly, three-monthly and annual requirements.
For example, Dunedin City Council identifies:
The key point: The Standard may allow routine tasks, such as cleaning filters or exhausts, to be undertaken by the owner/tenant and recorded for the IQP to review. The service team can then continue with its usual quarterly inspection, checking that the required monthly activities are being carried out and recorded.
SS9 IQPs should have access to the applicable Standard, check the version relevant to the age and type of equipment, and advise the owner/tenant what is required, what is acceptable, and who is responsible for each task
The traditional approach for SS9 has often been quarterly IQP inspections. But councils are increasingly looking at what the nominated standard actually requires.
AS/NZS 3666.2:2011 is an operation and maintenance standard with component-specific frequencies — including monthly, three-monthly and annual requirements.
For example, Dunedin City Council identifies:
- AS/NZS 3666.2:2011: monthly – filters; 3-monthly; annually
- AS 1851:2012 Section 13: monthly – kitchen exhausts and outdoor air intakes; 3-monthly; annually
The key point: The Standard may allow routine tasks, such as cleaning filters or exhausts, to be undertaken by the owner/tenant and recorded for the IQP to review. The service team can then continue with its usual quarterly inspection, checking that the required monthly activities are being carried out and recorded.
SS9 IQPs should have access to the applicable Standard, check the version relevant to the age and type of equipment, and advise the owner/tenant what is required, what is acceptable, and who is responsible for each task