Racking, storage height and fire: how the fitout can change the building

By Brenscot Builders | Last reviewed September 2026

Racking is usually treated as a tenant's problem. It arrives after handover, it is bolted to a slab somebody else designed, and nobody tells the builder. That works until the day the racking pushes the building into a different fire category.

This is the most under-discussed interaction in industrial building. The base building can be entirely compliant, and a decision made months later about what goes on the shelves and how high can change what the building is required to have.

This article refers to NCC 2022 Volume One, which applies in Queensland until NCC 2025 commences on 1 May 2027.

The short answer

Under NCC clause E1D13, sprinklers are required in an occupancy of excessive hazard where the fire compartment exceeds 2,000 m2 of floor area or 12,000 m3 of volume. One of the ways a building becomes an occupancy of excessive hazard is by containing combustible goods with an aggregate volume exceeding 1,000 m3 stored to a height greater than 4 m. Both limbs have to be met. So a large warehouse with no sprinklers can be lawful today and become non-compliant when a tenant racks listed combustible goods above 4 m in sufficient quantity. Decide the storage strategy while the building is being designed, not after.

The clause that does the work

E1D13 has two parts, and the interaction between them is the whole point.

First, the compartment test. Sprinklers are required in fire compartments where either the floor area is more than 2,000 m2, or the volume is more than 12,000 m3.

Those numbers will look familiar, because they are the same as the Type C fire compartment limits in Table C3D3. That is a coincidence of drafting rather than a connection, and it catches people out. A Type C warehouse built right at its compartment limit is also right at the E1D13 threshold. See fire walls and fire compartments.

Second, the occupancy test. The compartment test only applies to an occupancy of excessive hazard, which the clause defines inline as a building containing either:

• Hazardous processes or storage, with the clause listing aircraft hangars, cane furnishing manufacture and storage, fire-lighter and fireworks manufacture and warehousing, foam plastic and foam plastic goods manufacture and warehousing, hydrocarbon based sheet product manufacture and warehousing such as vinyl floor coverings, and woodwool and other flammable loose fibrous material manufacture; or
• Combustible goods with an aggregate volume exceeding 1,000 m3 and stored to a height greater than 4 m. The listed goods include aerosol packs with flammable contents, carpets and clothing, electrical appliances, combustible compressed fibreboards and plywoods, combustible cartons irrespective of content, fibrous combustible material, furniture incorporating foamed rubber or plastics, paper storage in all forms, raw and finished textiles, timber storage, and vinyl, plastic, foamed plastic and rubber products.

Read that list again. Combustible cartons, irrespective of content. That is most third-party logistics operations, most e-commerce fulfilment, and a great deal of general warehousing. The goods do not have to be dangerous. They have to be combustible, over 1,000 m3 in aggregate, and stored above 4 m.

Three things people get wrong

The 1,000 m3 is the volume of goods, not the volume of racking or the building. It is an aggregate volume of the stored goods themselves. That makes it a genuine calculation, not a glance at the building.

Both limbs must be met. A small compartment full of racked cartons is not caught, because it fails the compartment test. A very large compartment storing steel bar is not caught, because it fails the occupancy test. The exposure is a big compartment plus combustible goods stored high.

4 m is not very high. A modern warehouse with 10 to 12 m clear height is built for racking well above 4 m. The clearance you are selling as a feature is also the thing that puts the building in scope.

Why this lands on the wrong person

The sequence causes the problem. The building gets designed and approved around a compartment size and a construction type. The certificate of occupancy issues. A tenant signs, fits out, and racks to the height the building was built for.

At that point the fire safety basis of the building has changed, and nobody has assessed it. Formally the position is straightforward: the building has to comply for the use it is put to. Practically, it surfaces at the worst time, usually when an insurer asks a question or a fire safety adviser reviews the site.

For an owner, this is why the storage strategy belongs in the brief. For a tenant looking at an existing building, it is why "can I rack to 9 m in here?" is a question to ask before signing, not after.

The realistic responses

There are only a few ways to deal with it, and they have very different costs depending on when you decide.

Sprinkler the building. Sprinkler systems for a Class 7b or 8 building are designed to AS 2118.1 under NCC Specification 17. This is the obvious answer and the most expensive one, and it brings tanks, pumps and an ongoing maintenance obligation. See fire services.

Compartment below the threshold. Fire walls that bring each compartment under 2,000 m2 and 12,000 m3 take the compartment limb out of play. On a multi-unit building this may be happening anyway for titling reasons. See community titles and plan sealing.

Control the storage. Keep combustible goods below 4 m, or keep the aggregate volume under the threshold. This works, but it is an operational control on a building, and operational controls decay. It needs to be documented and it needs the occupier to understand it.

Design for it from the start. If the building is going to be sprinklered, knowing at concept stage is worth a great deal. Water supply, tank location, pump room, the hydraulic design and the roof structure all change. Retrofitting a sprinkler system into a completed warehouse costs far more than building it in.

What the sprinkler design itself depends on

Once you are sprinklering, the design is driven by what is stored and how. AS 2118.1 contains provisions for high hazard systems including categorised commodity design requirements, and for special commodities. Plastics, rubber, aerosols and foamed products drive a more demanding design than, say, palletised food in cartons at the same height.

Two practical consequences. First, the sprinkler design is not a fixed cost per square metre; it is a function of the commodity classification. Second, if the commodity changes, the design basis changes. A building sprinklered for one tenant's goods is not automatically adequate for the next tenant's.

Where racking is very high, ceiling sprinklers alone may not be enough and in-rack protection may be required. That is a determination for the fire services engineer against the standard, not something to assume either way.

Clearance between the top of stored goods and the sprinkler heads also matters, and it is set by the standard rather than by the racking layout. Coordinate the racking height with the sprinkler design rather than the other way around.

The racking itself

Steel storage racking is designed to AS 4084.1:2023 Steel storage racking, Part 1: Design. Since May 2023 the operation and maintenance side sits in a separate standard, AS 4084.2:2023 Steel storage racking, Part 2: Operation and maintenance, which covers safe operation, inspection and maintenance. Together they superseded the old single AS 4084-2012.

Work health and safety. WorkSafe Queensland, following an incident where a racking system failed and injured a young worker, has published that racking systems should be set up, operated and maintained according to the manufacturer's instructions and in accordance with AS 4084.1, that they should be inspected frequently for damage and overloading and at least annually to check integrity, and that the information provided at a workplace should include load ratings for racking and what loading limits apply. The primary duty of care under the Work Health and Safety Act 2011 sits behind all of it.

Damaged uprights are the common failure. A forklift strike that looks cosmetic can materially reduce capacity, which is why the annual inspection and the damage classification regime exist.

Whether racking installation needs building approval in Queensland is not settled by any published guidance we can find. The Building Act 1975 defines building work to include building or altering "a building or other structure", and whether free-standing racking is a structure for that purpose is the question. Schedule 1 of the Building Regulation 2021, which lists accepted development, does not mention racking. A rack-clad building, where the racking itself carries the roof and walls, is plainly building work. For conventional racking inside a completed shed, ask your building certifier rather than assuming.

The slab

Racking transfers its load to the floor through baseplates, as concentrated point loads at each upright. A slab designed for uniformly distributed load and forklift traffic is not automatically adequate for a particular racking layout at a particular load.

This is another reason the racking layout is worth knowing early. Changing a slab after it is poured is not a small matter. See footings and foundations.

What we would do

• Ask the storage question at briefing: what goods, what aggregate volume, what height, and is that likely to change
• Have the fire services engineer test the E1D13 position against the intended storage before the compartment strategy is fixed
• Where sprinklers are likely, design them in rather than allowing for them
• Give the racking layout and loads to the structural engineer before the slab design is finalised
• Document the storage assumptions in the handover material, so the next occupier inherits the basis rather than discovering it

Frequently asked questions

Does racking in a warehouse require sprinklers?

Not by itself. Sprinklers are required under NCC clause E1D13 where the building is an occupancy of excessive hazard and the fire compartment exceeds 2,000 m2 or 12,000 m3. Storing combustible goods with an aggregate volume over 1,000 m3 above 4 m is one of the ways a building becomes an occupancy of excessive hazard.

Can a tenant's racking make my warehouse non-compliant?

In effect, yes. The building has to comply for the use it is put to. A tenant racking listed combustible goods above 4 m in sufficient volume, in a compartment over the size thresholds, changes the fire safety basis of the building. It is worth addressing in the lease and in the building's handover documentation.

What standard applies to warehouse racking in Australia?

AS 4084.1:2023 for design and AS 4084.2:2023 for operation and maintenance, which together replaced AS 4084-2012.

How high can I rack before it becomes a fire issue?

The NCC threshold is storage above 4 m, combined with an aggregate volume of combustible goods exceeding 1,000 m3 and a compartment over 2,000 m2 or 12,000 m3. Below any one of those, E1D13 does not bite. Above all three, it does.

Does racking need building approval in Queensland?

There is no published guidance settling it, and Schedule 1 of the Building Regulation 2021 does not mention racking. A rack-clad building is clearly building work. For racking installed inside a completed building, confirm the position with your building certifier.

Sources

• National Construction Code 2022, Volume One: clause E1D13 and Specification 17; Table C3D3, ncc.abcb.gov.au and abcb.gov.au
• AS 2118.1 Automatic fire sprinkler systems, Part 1: General systems (as referenced by the NCC)
• AS 4084.1:2023 Steel storage racking, Part 1: Design; AS 4084.2:2023 Steel storage racking, Part 2: Operation and maintenance
• WorkSafe Queensland, incident alert: injury to young worker caused by racking system failure; Work Health and Safety Act 2011 (Qld)
• Building Act 1975 (Qld), section 5 (meaning of building work); Building Regulation 2021 (Qld), Schedule 1

General information only

This article is general information, current as at September 2026. It is not fire engineering or building certification advice. Whether a particular building is an occupancy of excessive hazard, and what sprinkler design applies, must be determined by a suitably qualified fire services engineer and confirmed by your building certifier.

Planning an industrial warehouse?

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