Summary of Items Discussed in 5/2016 APSEC Discussion Forum on 4 November 2016
Items proposed by Convenors for Discussion Summary of Discussion and BD’s Responses
Items raised by HKIA
1. Provision of Access to A/C Platform
According to the discussion at the recent BSC/APSEC Joint Meeting held
on 23 September 2016, we understand that where a proposed A/C platform
can be readily accessible via gondola system, additional access via window
opening is NOT required for BD’s granting of GFA/SC exemption to the
same.
However, at the course of GBP submission stage, there are recent cases
where our members have been advised that access to A/C platform solely
by means of gondola system is not acceptable, and window access to such
platform has to be provided as well.
Would the BD please clarify whether access to A/C platform solely by
means of gondola system is acceptable. If not, please advise what other
means will be acceptable and the criteria.
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Based on CIC’s current guidelines, it was correct that for areas
accessible by gondola, cast-in anchors for safety belts needed not be
provided. It could be taken to mean that provisions for alternative
safe access on top of access by gondola would not be necessary.
However, it had been the relevant trade workers’ concern that gondola
had not been user friendly nor cost effective for minor repairs to
external AC units. The Labour Department (LD) had recently
supported and BD agreed to impose more maintenance and repair
(M&R) friendly design requirements for the provision of AC platform
in new buildings. Therefore, BD clarified that safe access to the AC
platform was required in new buildings to facilitate future M&R of the
external AC units, despite gondola system might have already been
proposed.
Detailed Design of AC Platforms
BD further tabled 2 draft sketches on the design of AC platforms and
advised that they were considering to accept the stacking up of
external AC units, relax the dimensions of screens for the ACs, relax
the maximum projection of AC platforms up to 900mm if justified but
to impose detailed design requirements for providing access to,
 minimum working spaces around the AC units and maximum widths
of platforms. [Post meeting notes: more detailed guidelines were
provided in a circular letter issued on 23.12.2016. Sketches tabled
for discussion were therefore not enclosed.]

Provision of Access
BD stressed that in providing safe access to external AC units, access
from (i) the domestic unit without the need to climb out to the
external, (ii) the common areas through maintenance doors and (iii)
the domestic unit requiring the worker to climb out through windows
should be pursued in such order of priority.

Cast-in Anchors
BD stated that LD was reviewing their guidelines on requiring annual
inspection. In the meantime, BD would explore with members the
possibility of using building elements such as the frame of the AC
screens (if provided) or main middle frames of window suitably
embossed or fixed with emblem for the hooking on of safety belts
instead of providing cast-in anchors. Before the finalization of
detailed designs in this regard, BD would not require the provision of
anchors but members would be encouraged to voluntarily make
suitable provisions.

It was agreed that a working group would be formed to discuss in

details the provision of anchors and the further enhancement of the AC
platform design.

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2. Protection against External Fire Spread
Clause C11.1 of COP for Fire Safety in Buildings 2011 reads: Whilst “building” includes “any part of building” as per Section 2 of the
“Subject to Subsection C5, the external wall of a building at any floor Buildings Ordinance, BD re-confirmed that the fire separation
should be separated from the external wall at the floor next below by: (a) requirement as per Clause C11.1 of the FS Code should NOT apply to
a spandrel that is a vertical element of 900mm with an FRR of not less the sprinkler protected non-domestic floors of a composite building.
than that of the intervening storey: or (b) a horizontal projection of
500mm, with an FRR of not less than that of the intervening storey. This
BD further elaborated that such fire separation was also NOT required
clause does not apply to a single family house or a sprinkler protectedat the portion of external wall between the non-sprinkler-protected
building.” domestic floor above and sprinkler-protected non-domestic floor below,
considering that fire spread should be in an upward manner. However,
Based on the above, we would like to confirm that the fire separation for the vice versa arrangement, relevant fire separation between would
requirement shall NOT apply to the sprinkler protected non-domestic still be necessary.
floors of a composite building as illustrated in the following sketch:

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3. Room Containing Soil Fitment - B(P)R 36(4)
B(P)R 36(4) reads: “No room containing a soil fitment shall open directly The BD shared the same understanding as HKIA.
into a room used or intended to be used for the manufacture, preparation or
storage of food for human consumption or…………”. Pursuant to item 2 As long as the room containing soil fitment (in this case a WC) was
properly enclosed by full height walls & a proper door, the door for
of ADF 3/2016, it is noted that “the toilet door opening should be at least
access to the WC room would be taken in considering (i) the application
1700mm from the edge of the kitchen bench”. of B(P)R 36(4) and (ii) the distance requirement as discussed in the
previous APSEC Discussion Forum (3/2016).
We understand that the toilet door opening shall be taken as the door of the
room containing soil fitment (i.e. water closet fitment, a trough water closet, However, the layout would be acceptable only where sufficient space in
or a urinal), but not the door of the room containing wash basin or similar the WC room was provided for the door swing and maneuvering of the
waste fitments only as per the below sketch. Please advise if our user inside the room. The door giving access to the wash basin as per
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 understanding is correct. the attached diagram would then not be necessary. Otherwise, the outer
door to the kitchen would be used as the toilet door in practice making
the provision of the WC room impractical and the arrangement would
NOT be acceptable.

Item raised by HKIE

4. Lamp Posts and Flag Poles
Structural design of lamp posts and flag poles is a very specialized BD responded that provisions were given in Clause 13.2 of the
subject. Can the BD issue some guideline or PNAP to facilitate the prevailing Code of Practice for the Structural Use of Steel for structural
approval of structural submission (e.g. which codes are acceptable? What design of similar types of special structures and designer might make
are the performance criteria?). reference to the general guidelines for the design. HKIE commented
that such provisions were intended for transmission towers, masts and
chimneys which design considerations should be different from the
smaller scale structures of lamp posts and flag poles. Since there was a
preceding case that BD had accepted the adoption of BS EN 40-3 for the
design of lamp posts in the recent projects, it would be worthwhile to
include the said acceptable standard in the form of PNAP for the
industry’s reference to streamline the relevant structural submission.

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5. Footbridges across Public Roads
Currently the design of a footbridge across a public road will need to fulfill
both the Highways Department SDM and the BO & its Code of Practices
(including Wind, Dead and Imposed Load, Structural Use of Steel and
Concrete). They differ in design wind pressure, direction of wind, force
coefficients, partial factors of loads and materials and many more.
RSE needs to prepare two sets of structural analysis and design submission
for the submissions. Can the BD issue some clarifications to simply the
design ?
[Note: HyD Structural Design Manual 2013 follows the Euro code and the
number of load combinations is more than 250].
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BD responded that footbridge built partly within a private lot and across
a public road should be designed to comply with the Structures Design
Manual for Highways and Railways (SDM) as well as the B(C)R,
relevant codes of practice (CoPs) and PNAPs in accordance with PNAP
APP-34 and PNAP APP-38. It was noted that the problem was
originated from the fact that the SDM 2013 adopted the Eurocode design
procedures that were different from the design procedures adopted in the
Code of Practice for Structural Use of Concrete 2013 and Code of
Practice for Structural Use of Steel 2011, which were originated from BS
8110 and BS 5950 respectively.
HKIE advised that currently two separate structural designs had to be
prepared in order to demonstrate compliance with the requirements
under the BO and the SDM 2013. Moreover, the SDM 2013 contained
specific force coefficients for footbridge configurations and canopies
that were not given in the Code of Practice on Wind Effects in Hong
Kong 2004. BD advised that it was acceptable to prepare one set of
design calculations in accordance with SDM 2013 which would
generally govern the overall design with supplementary checks to
envelop the design requirements in the B(C)R and relevant CoPs under
the BO.
To facilitate further study on the subject, HKIE representative
volunteered to conduct a comparison study of the design requirements in
SDM 2013 and B(C)R and relevant CoPs for BD’s consideration with a
 view to exploring if simplified design procedures enveloping both sets
of design requirements could be formulated.

Upon enquiry, BD advised that structural design for a footbridge located

wholly within private lot and being not an associated highway structure
would not need to comply with the SDM 2013.

Items raised by HKIS (Sr Andrew KUNG)

6. Industrial Building
(a) Paragraph 3(b) of PNAP APP-93 about planning and design of
drainage works stated that ‘where internal COMMON soil and waste
stacks are proposed in DOMESTIC buildings not intended for single
occupancy, such stacks shall be located in the common parts of the
building’. Are those private branch pipes and common soil and waste
stacks in non-domestic building not covered in this practice note?
(a) BD replied that paragraph 3(b) of PNAP APP-93 regarding
common soil and waste stacks applied to domestic buildings but
advised non-domestic buildings should also follow this practice for
enhancing better maintenance of common pipework. The PNAP
would be revised accordingly indicating the extended coverage of
this good practice.

(b) What is the definition of flatted factory development in PNAP (b) BD replied that “Flatted Factory” would mean factory buildings
APP-46? Any area restriction of industrial unit of flatted factory as housing many units under different occupancy, operation or even
mentioned in PNAP APP-46? ownership, contrasting to those under a single operation.

(c) Refer to PNAP APP-46 about pollution from industrial buildings and
Building (Standards of Sanitary Fitments, Plumbing, Drainage Works
and Latrines) Regulation 90, does the individual drainage outlet stated
in paragraph 6 subject to the control of Building (Planning) Regulation
36?
(c) BD replied that discharge of industrial (usually chemical) trade
effluent would not fall within the scope of waste or soil fitment and
B(P)R36 might not be applicable. However, when such effluent
became comparable to waste (e.g. laundry factory) and soil
discharge, the regulation would be applicable. BD further added
that in the context of deterring the provision of hotel-like layout of

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 workshop units, such outlets would not be acceptable unless the
workshop was specifically designed to cater for operations with
trade effluent requiring treatment.

7. BFA Requirements for the Baptistery Pool

For church development (both new or A&A submission), could the BD shared the same understanding.
baptistery pool have modification of the BFA provision? As for church
operation, for disabled and elderly, it is usual that the baptism will be only to
put water on their head instead of going down to the pool. Due to this usual
practice, the BFA requirements are not required for the baptistery pool
construction and in new development. Would BD clarify?

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8. Modification for Provision of Mechanical Ventilation / Lighting to
Residential Toilet
Modification for provision of mechanical ventilation / lighting to residential
toilet had been implemented for many years, would BD conduct a review on
it to examine the pros and cons in term of hygiene and occupier's satisfaction
in long run.
BD replied that they would review the matter under the Building
(Planning) Regulations consultancy review. BD added that toilets with
natural ventilation would not just help energy saving for the toilet itself,
the cross ventilation thus enabled to the unit would help mitigate the
difficulty of providing openable windows in noisy neighbourhood.

Item raised by AAP

9. Exit routes discharge into a lane
When a lane is not a deadend lane but a thoroughfare, there are 2 directions BD stressed that MOE must discharge to an Ultimate Place of Safety
which people can discharge. Will BD allow the total width of MOE of not less than 1.5m wide or with width of the total required width of exits
proposed building discharging into the lane be doubled the width of the discharging into the area, whichever the greater. In the case of MOE
lane when it is a thoroughfare? discharging to a lane, the width of the lane should not be less than the
total width of MOE discharging onto that lane. As it would not be
(For example, a building with 4 nos. of 1500mm MOE stair can all possible to predict the direction to which people would discharge after
discharge into a lane of 3m wide provided that the lane is a thoroughfare reaching the lane from the MOE stairs, assuming evacuees would escape
and its entire width is not less than 3m) orderly in two directions thus taking the total provided width was 2
times the width of the lane would not normally be accepted.
Nevertheless, BD would consider justifications on individual cases e.g.
phased evacuation of large developments in determining the minimum
required width of lanes.

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10. 450mm return at final point of discharge - Clause B5.7 of FS Code
450mm return wall separating exit route and MOE discharge point and i) Item 3(c) of ADF 3/2013 was relevant. BD reiterated that at the final
other accommodation and ii) another exit route has been a long practice. point of discharge, evacuees might slow down or take a pause to decide
which way to go resulting in possible congestion and clashing. The
Separation between the point of discharge to other accommodation is very required separation would help alleviate such undesirable phenomenon.
understandable because of risks of fire at point of discharge.

Separation between 2 exit routes at discharge point, on the other hand,

seems not related to fire risks. We would like to seek BD's advice on the
rationale behind this requirement.

11. Smoke seal for lift landing doors - Clause C16.5 of FS Code
It is our understanding that the FRR requirement of lift landing door are BD shared the same understanding.
fully described in C9.1, C9.2 and commentary under C17.2.
Requirements of smoke seal for doors at protected lobby under C16.5 is not
applicable for LIFT LANDING DOORS opening into a protected lobby
cum fireman lift lobby.

12. Referral to Licensing Unit in BD

GBP Submissions to FSD will go through FSD's licensing department's BD advised that it would not be necessary for the additional circulation
comments (DG Store etc.) before FS cert for the GBP can be approved. of plans to the LU for comments because NBD would check plans with
the same requirements under BO as the LU including new buildings and
For GBP Submissions to BD, we understand that the current practice is that A&A submissions. Also, they would use the same database for
the plans will NOT be circulated to BD's licensing unit (LU) for vetting. consolidated discharge value of an existing building.

To follow FSD's practice (circulating submissions to licensing division for

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 comment) might cause additional pressure on the time for GBP approvals
and this is not preferred. However, we hope there could be a mechanism
through which comments from licensing point of views based on approved
GBP can be available for layout / FRP issues (GBP) during construction
such that any ambiguities can be sorted out and resolved during
construction / subsequent GBP amendment.

13. Kitchen in restaurant in GBP and upon OP

It is common practice that restaurant together with ancillary kitchen would
be renovated extensively after OP. Most walls enclosing kitchen will be
removed to achieve a new layout suitable for the type of restaurant and the
layout of the tenant. This will cause a lot of unnecessary construction
waste and not environmentally friendly.
BD reiterated that the enclosure of kitchens must meet the requirements
on fire resisting construction under regulation 90 of the Building
(Construction) Regulations. The alternative would be to designate the
area for shop use for the purpose of OP and then change it to restaurants
through subsequent A&A or MW submissions.

We suggest BD would allow kitchen to be demarcated by a notional line on

GBP and allow the wall to be omitted during OP inspection. The actual
layout and compliance with regulations can be ensured in licensing stage.

14. Minor works submission during construction stage

Even when a site is under construction with a RGBC or RSC with approval According to Technical Guidelines on Minor Works Control System
and consent, it is our understanding that we can still apply Minor Work (MWCS), the MWCS was devised to provide an alternative procedure
procedures for works items that falls into the Minor Works categories but for carrying out minor works mainly in existing buildings without the
not included in approved plans. need to obtain approval and consent from the BA before commencement
of works. BD advised that in general, it was not intended to apply the
Please advise if our understanding is correct. MWCS to the minor works items in a site which prior approval and
consent had been obtained for the new building works thereat. The

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 application of MWCS in such a site might lead to complication on the
responsibilities of AP/RSE/RC and procedural requirements.

Item 18 below was also relevant.

15. GFA exemption of private residential flat roof under cover

According to Para 6 of APP-19, BD noted that private flat roof was considered as 'capable of functional
"the covered areas satisfying the following criteria will not be regarded as use'. Therefore, covered private flat roof would not be entitled for
GFA and they are not required to be included in GFA calculation. GFA exemption even if paragraph 6(a) of the practice notes was
(a) The ratio of horizontal width of the covered area to the clear height satisfied.
of the projecting features above the covered area is not less than
1:8, OR
(b) ……

It is our understanding that the above (a) can apply regardless of whether
the covered area is a private residential flat roof or not.

Please advise if our understanding is correct.

16. Interpretation of para 12 of PNAP APP-2 – Pipe duct enclosing walls

Please see attached sketches. BD advised only the walls separating two exemptable areas could be
exempted from GFA calculation. Hence, only the walls separating two
pipe ducts could be exempted from GFA calculation while others
sk-1-1.pdf sk-2.pdf
should be accountable.

There is an argument that if there were no pipe ducts, then the walls
highlighted would not be required. Therefore these walls are solely

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 serving the pipe duct and do not serve any other function, and hence
qualifies for GFA exemption under the PNAP.

We hope to obtain BD's advice whether the above argument is valid or not
for the record and the rationale behind.

Item raised by BD
17. New PNAP APP-159
BD will further explain the response to comments. BD briefed members the new PNAP and highlighted additional
measures covered by the new PNAP as compared with the circular letter
issued on 17 June 2016, e.g. the limit of story heights, the reference size
of small workshops, the GFA and site coverage calculation of curtain
walls for small workshop units, and servicing arrangement for the
workshop units to be clearly shown on the general building plans. BD
also advised that the interpretation of small workshop units had been
lowered from 100m2 to 80m2 after taking into consideration the response
from the industry.

18. Minor Works Items in Demolition of Buildings

The industry’s feedback on the current protocol and the possibility of BD noted that in the course of demolition of buildings, some
adopting similar practice following the principle of the post OP components such as windows, AC racks, and UBWs could be
rectification work as promulgated in the circular letter of 9.1.2014. demolished under minor works control systems (MWCS) before the
demolition of the parent buildings. However, MW records for works in
this regard seemed redundant as the building would be demolished.
The proposed direction aimed at streamlining the administration
procedures. Members generally welcome the direction. Details of the

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 proposed measures would be discussed in the Working Group to be
formed soon.

19. Extension of opening hours of AP Working Rooms in CP3

The Rooms are closed at 5:30 pm. BD does not intend to extend the BD advised that working hours of the BD staff manning the AP Rooms
opening hours of these rooms beyond the office hours. were from 9:00am to 5:45pm (from Monday to Thursday) and 9:00am to
6:00pm (Friday). Taking into account the time required for BD staff to
record the usage of photocopiers therein, it would be difficult to extend
the current opening hours. However, BD would still explore the
feasibility to extend the opening hours from 5:30 to 5:45pm.

20. Omission of the provision of Flue Aperture Openings

BD had liaised with EMSD and in principle agreed that provided a building After discussion, it was agreed that a set of conditions indicating the
is not supplied with gas and there would be a DMC controlling the supply relevant control under the DMC rather than the actual DMC clause
of such in the long run, he could favourably consider the BD’s referral of would be provided. [Post-meeting note: memo with the conditions
applications for exemptions on the non-provision of flue aperture. HKIA were sent to EMSD on 2.12.2016.]
would provide sample DMC clauses for EMSD’s consideration.

21. Acoustic Window PNAP APP-130

BD had implemented the PNAP for two years and would like to hear from
the industry feedback on the following:
(a) The possibility of providing cross ventilation to studio flats by having
toilets with window access to open airs to improve performance in
CFD analysis and the possibility of providing secondary windows for
cross ventilation to meet the requirement of para 5 of Appendix A of
APP-130.
(b) In conducting CFD analysis, are dead cases frequently encountered
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Members expressed difficulties in adopting the acoustic window design
as stipulated in PNAP APP-130 and opined that the provision of cross
ventilation could help but the site constraints would usually make light
wells or building re-entrants difficult to design for particularly when
balancing against the efficiency of layout. Notwithstanding such
difficulties, BD appeal for the provision of re-entrant and light well and
advised that BD would be adopting a facilitating role in this regard.
 even for a slight deficiency in openable window area? [Post-meeting note: PNAP APP-130 was revised on 23.12.2016 giving
(c) Any improvement since the introduction of the top-hung windows with flexibility in the computation of openable window areas should help the
acoustic fins? industry on the wider use of acoustic windows.]

AOB items
22. Wind Code for Balconies and A/C Platforms
(Item raised by HKIE) BD responded that the prevailing Hong Kong Wind Code gave general
Code of Practice on Wind Effects in Hong Kong 2004 may not be fully methods to calculate the wind loads on buildings for the structural
applicable to certain building features/ components such as balconies and design but it did not cover those buildings or building features of
A/C platforms. In such cases, can some recognized international unusual shape of which the relevant wind design might be based on
standards be adopted instead? experimental wind tunnel data as mentioned in the code. Alternatively,
BD might accept assessment of wind effect on the special structures not
covered by the local wind code making reference to some recognized
international design standards under the current practice.

23. PNAP ADM-8 - Revision of submission of Part II structural

calculations in CD/DVD format
(Item raised by BD)
BD explained that the introduction of the initiative aimed to save the
PNAP ADM-8 has been recently revised for the introduction of submission
papers, efforts and time of both the industry and BD. In fact, it had
of Part II structural calculations in CD/DVD format as an alternative
been revealed in three sample projects that there were significant saving
measure to the conventional paper format. RSEs are welcome to adopt
of paper printing as many as 30,000 pages by adopting the initiative to
the new measure.
promote green environment for the community. RSEs were
encouraged to make good use of it.
24. Vertical Lifting Platforms
(Item raised by HKIA)

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Further to item 32 of 2/2016 APSEC Discussion Forum on 18 March 2016, The BD advised that the subject had been discussed at the Technical
can BD enlighten on the development in formulating the general criteria Committee (TC) on Design Manual: BFA, and BD would update the
for accepting the use of the vertical lifting platform in new or existing Design Manual accordingly. In short, the use of VLP in new buildings
buildings in lieu of accessible passenger lift or ramp? would be limited to those with insurmountable difficulties in providing
accessible ramps or lifts.

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