The pattern
Building owners brace for a hardware problem. What they get is an administrative one.
An IQP is prohibited from issuing a Form 12A unless every inspection, maintenance and reporting procedure on the compliance schedule has been fully complied with for the previous 12 months. MBIE is explicit that the Building Act provides no flexibility and no exemptions. So the question at inspection time is not only "does the system work" — it is "can you show me it has been maintained the way your schedule says".
Those are very different questions, and buildings fail the second one far more often than the first.
Here are the nine reasons, roughly in order of how often we see them.
1. Missed monthly checks
The single most common cause, and it has a season. Checks slip over Christmas, when whoever does them is away and the person covering does not know the task exists. They slip again when that person leaves and nobody inherits the job.
By the annual inspection there are two or three gaps in the logbook, and a gap cannot be filled retrospectively. A check done in month five is not month three's check.
The fix: a named individual with a named backup, a recurring calendar reminder, and a quarterly review of the logbook rather than an annual one. Finding a gap in month three is a nuisance. Finding it in month twelve is a failed BWoF.
2. No logbook, or a logbook nobody can find
The work was done. A conscientious caretaker walked the building every month for three years. Nothing was written down, or it was written into a notebook that went with them.
An undocumented test did not happen, as far as your BWoF is concerned. That is harsh but it is how the regime works, and an IQP has no discretion about it.
The fix: the logbook lives on site, physically with the compliance schedule, and records results per fitting with dates and a signature. Records commonly need to be retained for the previous 24 months. Digital is fine and generally better, provided it is genuinely accessible to whoever turns up — not on the personal phone of someone on leave.
3. The fitting count no longer matches
Every fitout changes the building. Walls move, fittings come down, new ones go up, and nobody tells the council. Two years later the compliance schedule describes 47 luminaires and there are 52 on site, or 41.
This puts the IQP in an awkward position and it puts you in a worse one, because the schedule is the operative document.
The fix: reconcile the count after any fitout, and where the building has genuinely changed, apply to the council to amend the compliance schedule. Your IQP can recommend the change and the recommendation goes to council with your BWoF. Quietly testing a different number of fittings is not a solution.
4. Batteries at end of life
The hardware failure that actually occurs. Emergency lighting batteries are consumables with a finite service life, and they degrade on the shelf whether or not the fitting is ever called on.
The pattern is predictable: a building is fitted out, all the fittings are commissioned in the same month, and some years later they all reach end of life in the same month. One inspection turns up dozens of failures at once and an unbudgeted bill.
The fix: record the battery age against every fitting, and replace in planned stages rather than waiting for a failure round. This is the single most useful thing a per-fitting register gives you, and the reason we record replacements against the fitting rather than as a line on an invoice.
5. Fittings isolated during other work
An electrician working on something else isolates a circuit, and the emergency lighting on it never comes back. Or a fitting is disconnected during a ceiling job and left that way. It looks entirely normal — the fitting is not lit in normal use anyway.
The monthly check catches this immediately. Nothing else does, until the power fails.
The fix: check every fitting operates on battery, monthly, and treat any electrical work in the building as a trigger for an out-of-cycle check of the affected area.
6. Exit signs obscured
New shelving. A stacked pallet. A promotional banner. A partition put in without anyone thinking about sightlines. The sign works perfectly and nobody can see it.
This one is judged by the IQP on the day and it is entirely preventable.
The fix: the monthly check asks "is it lit" and "can it be seen from where people will be". Both. Make it a line in the logbook so it gets looked at rather than assumed.
7. Untrained people doing owner checks
Compliance schedules commonly state that the IQP is responsible for ensuring proper training is delivered, and that only people who have received that training may perform owner inspections.
Very few owners have read that sentence. So a caretaker who was shown the test switch once in 2019 has been signing a logbook ever since, and there is no record of any training.
The fix: ask your IQP to train whoever does the checks, and record that the training happened, who delivered it and when. Re-do it when the person changes.
8. A shortened discharge test
The discharge test is run for less than the building's required duration, because it takes an evening and someone was in a hurry.
It will not stand up if the IQP looks closely, and it defeats the purpose. Battery failures cluster in the last third of the discharge — precisely the part a shortened test skips.
Note also that the required duration is not automatically 90 minutes. Many New Zealand buildings are 30-minute systems under Building Code clause F6, and testing them for 90 is its own error. See how long emergency lighting must stay on.
The fix: know your duration from the compliance schedule, run the full time, and check that fittings are still producing adequate light at the end rather than merely still lit.
9. Nobody agreed who issues the Form 12A
A building with several specified systems has several IQPs. One IQP can issue a Form 12A covering procedures carried out by another — but only if that was agreed.
Buildings discover the gap in the week the BWoF is due, when it emerges that everyone assumed someone else was covering the emergency lighting.
The fix: establish who issues which Form 12A when each IQP is first engaged, write it down, and review it annually. See what an IQP is and how to engage one.
The pre-inspection walk
An hour, a month before the IQP is due, saves most of the above. Take the compliance schedule and the logbook and check:
- Twelve logbook entries for the last twelve months, or however many your schedule requires. Any gaps?
- Fitting count on site against the schedule. Match?
- Every fitting operates on battery. Any dead ones, any isolated ones?
- Every exit sign lit and visible from where people would be.
- Battery ages — anything approaching end of life you should replace before the inspection rather than after it?
- Training records for whoever does the monthly checks.
- Last discharge test — full duration, results per fitting, failures closed out with re-tests recorded.
- The Form 12A plan — who is issuing what, and are they booked?
Anything you find in that hour is a problem you can fix. Anything the IQP finds is a problem that stops your BWoF.
If a check has already been missed and you are reading this in a mild panic, there is a proper process and it is better than the alternatives — see what to do about a missed BWoF inspection.
Related: how often emergency lighting must be tested and Specified Systems under the Building Act 2004.