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We have requested the Victorian Government and the VBA to clarify their absurd change to the regulation.


Dear Sir/Madam,

I thank you for the Victorian Government Gazette No s 22 Wednesday 13th January 2021.
I seek clarification about the definition of “external insulation and finish (rendered) wall system.”


1..Is this a structure built from timber or steel frames? Are the frames then clad with EPS-FR? Is the cladding fixed to the timber or steel, mechanically, and then rendered?

What happens if you don’t render the EPS-FR then clad it with, any of the cement sheet products, which are then mechanically fixed to the timber or steel? Is this application allowed as a finished wall?

From my perspective, the wall is the timber and steel and the rest a cladding. Am I correct with my assumption? Therefore can be used for Type A and B?

2. The next example is a solid concrete wall with no voids no voids in the concrete. The concrete wall has a minimum 90/90/90 FRL, no holes. The concrete is the engineered wall.

The formwork is EPS-FR which is on either side of the wall, the interior panel is insulation, and the exterior can be insulation or formwork.

If we render the EPS-FR formwork exterior, it is not compliant even though the structure will not burn down nor spread the fire.

3. Option two, what happens if we choose not clad the formwork with cement sheet or say many legal laminate products? Is this then considered a compliant wall for Type A and B?

I have provided a couple of photos for you to review. Note the images show what happened when the inside of this structure caught fire. You will note that the flames did not cause the external walls to catch fire. The wall is intact, and no of the external EPS-FR was deformed or melted.  The building next to it was no more than 2 meters away, and the flames reached well over 5 meters in the air. There is no render or cladding of any sort on the EPS-FR. The product performed to its specification. Note the EPS did not ignite or flame.

Antonio Dal Bon (MAICD)






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