A school needs its classrooms for Monday. A healthcare operator wants to open a completed area while work continues next door. A venue needs staff on site for training before the public opening.

Staged occupation can be possible. The first step is to define what will be occupied, how it will function safely and which approvals and completion evidence are needed before people move in. Fire brigade testing and reporting can be a critical part of that programme.

Choose the appropriate occupation pathway

In South Australia, a Certificate of Occupancy (CoO) can cover the whole building or a defined part. Temporary occupation under section 153 is a separate approval to occupy without a CoO. “Staged” describes the sequence of occupation; it does not automatically mean temporary. [1]

These are practical arrangements, rather than five separate statutory approval types. The approval must match the actual use and area proposed.

Identify what each stage needs

Start with a marked-up plan showing occupied and construction areas, shared access, exits, amenities and services. List the unfinished works and explain how later construction will affect the first occupants.

For the CoO application, the applicable documents include the Statement of Compliance, essential safety provision Form 2 certificates and evidence addressing approval conditions and partial occupation. [2] Agree who will obtain and upload each item, including supporting commissioning records and any required Council inspection outcomes.

The first stage may depend on plant rooms, pumps, alarms or escape routes outside its boundary. Include those dependencies in the handover plan and evidence package.

The regulation 103D process

What is often called “brigade sign-off” is a fire-authority reporting process. The fire authority is MFS or CFS, according to the location. [2] Council, or a building certifier authorised under section 154, makes the occupation decision. [1]

When it applies

Regulation 103D applies where the building has a fire-brigade booster assembly or an alarm transmitting to a fire station or approved monitoring service, and the approval requires fire detection, firefighting or smoke-control facilities. The issuing Council or authorised building certifier must seek a report on their installation and satisfactory operation. [2]

How to programme it

1. Confirm the scope early. Agree the proposed stage, systems and inspection arrangements with the certifier and relevant fire authority. Identify who will lodge the report request and coordinate the attendance.
2. Complete contractor commissioning. Installing contractors commission the systems to the relevant standards before MFS functionality testing. Brigade testing does not replace contractor commissioning or the installation certificates. [3]
3. Arrange brigade inspection and testing. MFS checks the operation of relevant systems for emergency response, including their interconnections. Confirm site readiness and safe access before attendance; MFS may decline testing if its site requirements are not met. [3]
4. Deal with the findings. Allow time for rectification, further evidence and any necessary retesting. Ask for the report to clearly identify the stage and systems it covers.
5. Complete the occupation assessment. The issuing authority must consider any report received before issuing the CoO. [2] The brigade report is assessed alongside the other evidence supporting occupation. An inspection booking or verbal update is not an occupation approval.

If the report is delayed

If no report arrives within 15 business days of the report request, regulation 103D allows a presumption that the fire authority does not wish to report, subject to section 152(4), including any contrary indication from the authority. This does not automatically authorise occupation or establish that the systems work. [1, 2]

Temporary occupation of multi-storey buildings

Practice Direction 10, Version 2, effective 12 June 2026, adds specific requirements. These include completed fire-authority functionality testing for the base-building systems serving occupied floors and safe zones, and provision of commissioning reports. Its Schedule 1 form expressly records a fire-authority report for the proposed occupation area. [4]

Temporary occupation therefore cannot be treated as a way to avoid those requirements. The 15-business-day provision for CoOs does not, by itself, satisfy the Practice Direction’s testing and reporting requirements. Plan the brigade involvement around the proposed stage before committing to its opening date.

Planning the handover

Resolve the remaining works

Outstanding paving, handrails or other items need to be assessed against the proposed occupation. A small amount of unfinished work can still affect an essential access route or safety measure. Identify whether the item must be completed or whether a defined exclusion or temporary arrangement can be accepted.

Define early staff access

Staff training, equipment commissioning and public opening may involve different activities and risks. Tell the certifier who will attend, which areas they need and how long they will be there. Staff-only use should not be assumed to permit unrestricted occupation.

Check the existing approval

An unchanged use does not, on its own, answer whether an occupation approval is needed. Check the building work, existing approvals and proposed handover arrangements. For temporary occupation, record its expiry and conditions and raise any proposed extension before it expires.

Bring the programme and evidence together

Agree a checklist for each handover with the builder, consultants and certifier. Include the completion documents, Council requirements, contractor commissioning, brigade attendance, reporting and time to resolve findings. Documents needed for the first occupation should be planned for that stage.

Planning a staged handover? Send TF your marked-up staging plan, proposed use and occupation date, together with the outstanding works list. We can help establish the approval pathway and evidence needed, including the regulation 103D process, so these requirements are built into your construction programme.

References

[1] PDI Act 2016, sections 152 to 154

[2] PDI General Regulations 2017, regulations 3, 103A and 103D

[3] MFS guidance on regulation 103D inspection and testing

[4] Practice Direction 10, Version 2, Part 2 and Schedule 1