Fire Protection Code
UPDATE
Fire Protection Code
Service Apartment Purpose Group under UBBL 1984 : 2021 Amendments
By Ir . Au Chong Hun Managing Director Primetech Engineers Sdn Bhd
UPDATE
This article discusses the rationale behind the introduction of Service Apartment Purpose Group and the Provision of Residential Sprinklers in the UBBL 1984 : 2021 Amendments .
Under Malaysian building regulations and practice , the term ‘ Service Apartment ’ can be subject to different definitions . For instance , it can refer to serviced-multi-room-suites which are operated like hotels , or it can refer to residential apartments built on land with commercial titles .
From a legislative perspective , the original UBBL 1984 under Purpose Group III only had subgroups hotel , hostel or flat . Each sub-group would have different passive and active fire protection requirements . In the late 90s and early 2000s , most BOMBA officers would understand and categorise “ service apartment ” as “ hotel ”. This confusion was understandable mainly due to the word “ service ”. Much effort was expended to convince BOMBA that the “ service apartment ” is first and foremost “ not serviced ”.
However , from the fire engineering perspective , the determination of fire provisions should rightly be based on the design of the building and not the type of land title . If the building is designed and will be operated as a hotel , then the protection systems required should be that of a hotel . But if a building is designed and operated as an apartment , then building the same building on commercial land or otherwise should not increase or decrease its fire risk .
As such , it would be overkill to interpret and apply the UBBL requirements of a hotel to an apartment . Do we really require sprinkler protection for a five-storey apartment block because the total number of “ rooms ” exceeds 50 ( assuming one apartment has three bedrooms )? Do we calculate the travel distance from the furthest room door of the apartment unit or from the main door of the unit ? Should we be installing public address ( PA ) speakers in every room of the apartment ?
That was the gist of the prevailing issues which led to the historic first BOMBA circular on this subject on November 11 , 2005 following the BOMBA-Professional dialogue of October 18 , 2005 . Basically , this first circular acknowledged that although the land title is commercial , some service apartments were intended to be built purely as residential apartments . It was agreed that the fire protection system would be determined based on the design and usage of the building . To appeal against the imposition of hotel requirements , evidence of building design and usage , including evidence of Sales and Purchase agreements ( of at least 50 % of the total units ), would need to be submitted as substantiation .
Since then , the service apartment genre has flourished and matured . Less and less service apartments were designed as “ purely residential ” as one would on a residential title . Many developments started to incorporate commercial
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