Dear Mr Plumber: Application of National Building Regulations

By Vollie Brink

I find that certain people still don’t understand how to read, use, and apply the National Building Regulations — it is the cause of much misunderstanding and even conflict. Some government departments even require the architect to take on engineering work for which they are not educated, trained, or competent.

The main reason is also because the National Building Regulations do not have a clear, unambiguous definition of who is competent and for what, and there is no register of competent persons and their competencies.

There is no clear ‘boundary’ between the deem-to-satisfy rules and the need for a rational design — this is the cause of much aggravation, conflict, and unnecessary costs.

My only hope is that the new Building Regulations Act will address these problems and create an environment that is well defined for everybody to understand.

Coming back to SANS10400-P, it is a document that was misinterpreted and misused. The rational design concept was allowed to be misused by people who are not competent by any means. This has put people’s health and safety as well as the investment of developers at great risk.

Perhaps it would help to better understand the divide between deem-to-satisfy and requirement for rational design if we look at what the deem-to-satisfy does and does not allow.

“What are the ‘restrictions’ of the deem-to-satisfy rules?”

The SANS10400-P allows that the deem-to-satisfy rules be applied to housing and offices only. There are no deem-to-satisfy rules for any other buildings such as hospitals or shopping centres.

The question is, what are the ‘restrictions’ of the deem-to-satisfy rules?

  1. No bends are allowed under a floor in ground in a building.
  2. No change of direction under a floor in ground in a building.
  3. No change of gradient under a floor in ground in a building.
  4. No connections under a floor in ground in a building.
  5. No manholes and no inspection chambers in a building.
  6. Wastewater and soil water must be separate systems under a floor in ground in a building.

The above-mentioned are implicated in the deem-to-satisfy rules and are essential design criteria. It must be observed, affects a rational design, and must be carefully considered and solved by a competent experienced and registered engineer/technologist by means of appropriate engineering solutions. ‘Registered’ means in terms of the Engineering Profession Act, 2000 (Act No. 46 of 2000) and not registered by a club.

A rational design does not mean the designer may just ignore these criteria because it is called a rational design. No, the design must be relevant, fit-for-purpose, safe, and comply with the performance requirements as stated in P2.

One of the most important design requirements is to always make sure to prevent back flow into the building. From flooding the building through showers, baths and floor drains, this is a great health risk. Another great health risk is to have a manhole or inspection chamber inside a building or even inside the parking space. This can be overcome by clever rational design.

Some very good advice to you is, never undertake work for which you are not educated, trained, experienced, and registered. This is stipulated in ECSA’s Code of conduct.

I hope everyone in the building industry and all professionals will follow this code of conduct, because then we will have less problems and failures.


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