Managing Combustible Cladding Risk Through a Replacement Project
Managing suspected combustible cladding is a staged building-risk process, not simply a panel replacement exercise. Owners corporations, strata committees and asset managers need to establish what is installed, understand the building and regulatory context, appoint the appropriate practitioners, define an approved pathway and control delivery records.
This guide explains how those activities can be coordinated from initial review to project close-out. It supports planning and informed engagement; it does not determine whether a particular building is compliant or replace project-specific fire, façade, structural, legal or certification advice.
Key point: suspected combustible material does not, by itself, define the complete risk or the correct remedy. Building use, height, façade configuration, extent and location of material, fire-safety measures, condition, evidence and the approved compliance pathway all matter.
Start With the Building, Evidence and Immediate Risk
Begin by gathering available drawings, fire-safety records, previous reports, product information, approvals, maintenance history and correspondence with insurers, council or other authorities. Record the building classification, storeys, use, occupancy, façade construction and known locations of relevant materials.
Material and system evidence
Identify the exact products where possible and review the complete external-wall arrangement, including insulation, sarking, cavity barriers, fixings, openings and interfaces.
Building-specific risk
Consider occupancy, evacuation, façade geometry, fire spread pathways, existing fire-safety systems, deterioration and any urgent measures recommended by the appointed specialists.
Regulatory position
Confirm whether NSW registration, council directions, development consent, fire-safety requirements, the DBP framework or other project-specific obligations apply.
NSW Planning states that owners of certain buildings with specified external combustible cladding must register those buildings. Its current combustible cladding guidance identifies relevant building and cladding types and links to the assessment guide and legal instruments.
A Five-Stage Risk-Management Process
Confirm the problem and project objectives
Define what is known, what remains uncertain and whether the immediate objective is investigation, interim risk management, design, replacement, repair or a combination. Avoid fixing a budget or product before the scope and pathway are sufficiently understood.
Appoint the responsible project team
Establish who is responsible for fire, façade, structural, waterproofing and architectural inputs; regulated designs and declarations where applicable; construction; inspections; certification; and owner-side decisions. Record interfaces and deliverables in a responsibility matrix.
Investigate, design and approve the pathway
Undertake appropriate inspections, sampling and opening-up; assess the existing substrate and interfaces; compare options; prepare coordinated documents; and obtain required reviews, declarations, approvals or consents before procurement and construction.
Control procurement and construction
Use approved product schedules, samples, traceable deliveries, site safety controls, hold points, inspection and test plans, photographs, installation records and controlled variations. Work should remain aligned with the construction-issued documents.
Close out and maintain the façade
Compile inspection records, approved variations, declarations, certificates, warranties, as-built information and maintenance requirements applicable to the project. Set future inspection and maintenance actions rather than treating completion as the end of façade risk management.
Control the Interfaces, Not Only the Panels
Replacement work can expose corrosion, unsuitable framing, damaged membranes, deficient flashings, missing cavity barriers, moisture entry or undocumented changes. The contract and design process should state how unforeseen conditions will be investigated, priced, designed and approved.
Access, hoarding, public protection, temporary weatherproofing, noise, dust, waste, occupied-building staging and emergency arrangements may materially affect cost and programme. Road or footpath occupation approvals are site-specific; they are not automatic requirements for every project.
Product substitution also needs formal control. A different panel, insulation, rail, fixing, membrane or sealant can affect evidence, detailing, warranties and regulated documentation. Obtain written review and approval from the responsible parties before ordering or installing a proposed substitute.
DBP Responsibilities and Construction Records
Where the Design and Building Practitioners legislation applies, registered design practitioners and registered building practitioners have distinct obligations. The appropriate practitioner classes, regulated designs, declarations and timing depend on the building and work.
Building Commission NSW advises that construction-issued regulated designs for remedial work should include project-specific drawings, specifications, a schedule of materials or products and relevant performance requirements. Review the current remedial building work guidance and obtain advice for the specific project.
SCE Corp can assess construction scope, buildability, access, staging, safety, procurement, programme and commercial fit, and coordinate delivery with appointed project parties where the engagement permits. Specialist advice, regulated design declarations and certification remain with the appropriately appointed practitioners and authorities.
Common Project Risks to Resolve Early
Unclear scope
Assuming that visible panel area equals the full scope can omit interfaces, supporting components, latent conditions, access, temporary works and close-out obligations.
Unallocated responsibility
Gaps between consultants, contractor, certifier and owner can delay decisions or leave documentation incomplete. Name the responsible party for each deliverable.
Unsupported outcome claims
No contractor should promise approval, insurance eligibility or whole-building compliance without the project-specific evidence and decisions of the responsible parties.
Related Cladding Pathways
Start with the service owner for investigation and project pathway enquiries. Understand fire-compliance pathways
Review the broader cladding and recladding fire-compliance service. Compare cladding materials
Review material families and project-specific selection considerations. Plan the installation process
Understand sequencing, inspections and construction records. View cladding project evidence
See a relevant SCE recladding project example. Use the cladding estimator
Prepare an early planning range before a project-specific quotation.
Frequently Asked Questions
What is the first step when combustible cladding is suspected?
Gather existing drawings, fire-safety records, reports, product information and approvals, then obtain project-specific advice from appropriately qualified practitioners. Immediate actions should reflect the building, material, façade arrangement, occupancy and assessed risk rather than a generic response.
Does combustible cladding always need full replacement?
Not every building has the same risk or regulatory pathway. The required action may involve investigation, interim measures, partial or full replacement, other building work or formal assessment. The appointed specialists and relevant authorities must determine the project-specific pathway.
Who should be involved in a combustible cladding project?
The required team depends on the building and scope. It may include the owner or owners corporation, project manager, fire engineer, façade consultant, architect, structural engineer, waterproofing specialist, registered design and building practitioners, contractor, certifier, insurer and relevant authority.
What should be completed before cladding replacement starts?
Before construction, confirm the scope, investigations, coordinated construction documents, responsibilities, approvals, declarations, product evidence, access, safety controls, staging, procurement, hold points, inspection plan, occupied-building arrangements and process for unforeseen conditions and variations.
Why are opening-up inspections important?
Opening-up can reveal the existing framing, membranes, flashings, cavity construction, fixings, corrosion, moisture damage and undocumented conditions. These findings may affect design, scope, cost and programme and should be reviewed by the responsible parties before affected work proceeds.
Can a replacement cladding product be approved from a data sheet alone?
Usually not. The responsible team should consider evidence for the exact product and proposed use together with the complete wall assembly, supporting structure, fixings, membranes, cavity barriers, interfaces, installation requirements and applicable regulatory pathway.
What records should be retained after recladding?
Retain the documents applicable to the project, which may include approved and as-built designs, declarations, certificates, product and delivery records, inspection and test records, photographs, approved variations, warranties, maintenance manuals and relevant correspondence.
How can SCE Corp assist with a combustible cladding project?
SCE can review construction scope, access, buildability, staging, safety, procurement, programme and commercial fit and, where engaged, coordinate construction with the appointed designers, consultants and certifier. Regulated designs, declarations, specialist advice and certification remain with the responsible parties.
Discuss the Construction Pathway
SCE Corp can review whether the building, scope, access, approvals, programme and commercial requirements suit our building and remedial delivery capability.
Request a project review Call (02) 9051 9590