Why your SDA might be a Class 3 and not a Class 1a or 1b

Specialist Disability Accommodation Fire

Specialist Disability Accommodation (SDA) is setting new standards within the building industry, paving the way for the development of homes rather than institutions for people with a disability. However, this has created some ambiguity over when a home registered as an SDA no longer fits the model of a ‘Typical home’ under the Building Code of Australia.

The Building Code of Australia (BCA) is a technical building document adopted Australia wide which categorises how a building use shall be designed/constructed to safeguard health, safety and amenity of all occupants.

These uses are defined as ‘Building Classifications’ and include;


Class 1aa single dwelling being —

  1. A detached house; or
  2. One of a group of two or more attached dwellings, each being a building, separated by a fire-resisting wall, including a row house, terrace house, town house or villa unit.


Class 1b

  1. Boarding house, guest house, hostel or the like—
    1. with a total area of all floors not exceeding 300 m2 measured over the enclosing walls of the Class 1b; and
    2. in which not more than 12 persons would ordinarily be resident; or
  1. 4 or more single dwellings located on one allotment and used for short-term holiday accommodation,

which are not located above or below another dwelling or another Class of building other than a private garage.


Class 2: A building containing 2 or more sole-occupancy units each being a separate dwelling i.e Apartment building.


Class 3:

‘A residential building which is a common place of long term or transient living for a number of unrelated persons, including—

  1. a boarding house, guest house, hostel, lodging house or backpackers accommodation; or
  2. a residential part of a hotel or motel; or
  3. a residential part of a school; or
  4. accommodation for the aged, children or people with disabilities; or
  5. a residential part of a health-care building which accommodates members of staff; or
  6. a residential part of a detention centre.‘


While the principles of the SDA promote a focus on designing residential homes not every dwelling will fit this ideal under the BCA. For example, the classification of;


  1. A home where a couple reside with their kids and the spouse/partner is eligible for SDA funding would fall under your typical home i.e. Class 1a, whereas;


  1. A home in which multiple unrelated persons with disabilities are eligible for SDA funding with On-site Overnight Assistance would represent a Class 3. This requires a higher level of design features to protect occupant health, safety and amenity compared to a Class 1a.


Reading through what defines each Building Classification it seems that as soon as an SDA dwelling houses more than one person with a disability the only Building Classification suitable is a Class 3. This can throw some surprises to Providers who may not be familiar with the Building Code of Australia, especially in Victoria which requires the provision of sprinklers where 10% or more of persons need physical assistance in conducting their daily activities and to evacuate in an emergency.


The following table provides a brief overview of some of the differences in the BCA design requirements between a Class 1a and 3.


Requirements under the BCA


Class 1a


Class 3


Internal Fire Ratings


Not required Required
Enhanced provisions for escape during an emergency


Not required Required
Sprinkler protection (Victoria)


Not required Required
Disability access provisions (Above SDA)


Not required Required
Acoustic separation between bedroom/living spaces Not required Required


Note: This table is not representative of all applicable requirements, consultations should be sought from the relevant Sate or Territory responsible building authority such as a Building Certifier.


This is not to say that a dwelling defined as a Class 3 falls outside the potential of providing a suitable home for Participants, quite the opposite.  In most the cases with a diligent design team the additional features would not standout to the end user and more importantly aim to enhance a resident’s level of independence, participation and safety in their home.

The first step for anyone seeking to offer accommodation under SDA is to contact a Building Certifier to discuss the proposal to determine the relevant Building Classification and what design features are required. It is critical to get this right at the beginning of a development as an incorrect classification can have major implication such as: ineligibility for enrolment as SDA, orders from Local Councils to stop works/vacate the building, infringements notices, demolition and/or retrospective upgrade works, or worst-case detriment on a resident’s health.


Fire Safety

There will be fatalities! It’s not if, but when!

Read our thoughts on the fire safety requirements for Specialist Disability Accommodation on the following page There will be fatalities! It’s not if, but when!


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