by Darren


Regulating a sustainable industry is on the rise.

In 2011 the spotlight was firmly placed on the requirements for ecologically aware buildings and designs as the new energy-efficient building regulations and the supporting “Deemed-to-satisfy” standard, namely NBR-XA and SANS 10400-XA respectively, came into play. After more than two years since its enforcement, this set of regulations can now be investigated in terms of its success, how it has impacted the built sector and what developments can be expected in the coming year that will directly affect the flooring industry.


One of the biggest challenges surrounding SANS 10400-XA has been the lack of understanding as a result of confusion in terms of enforcing the standards. According to Lisa Reynolds, Sustainability Director at Saint-Gobain, the first point of departure in understanding SANS 10400-XA is to note that it is only an energy standard and does not cover all ecological issues. Lisa’s extensive knowledge on the regulations and standards was derived from her role as Chairperson of the Working Group responsible for drafting the standards for Energy Efficiency in Buildings – SANS 204-1, -2 and -3, Edition 2 of SANS 204 and the new SANS 10400-XA and as a participant in the Regulatory Advisory Group for NBR-XA.

“SANS 10400-XA is the minimum requirement,” she highlights. “In green buildings it’s a conditional requirement in the Energy Efficiency category and points can be gained for improvements on that base. The National Building Regulation is the regulatory part and SANS 10400-XA is only made mandatory by its relationship to the regulation. For this reason it impacts everyone in the building industry.”

After the enforcement of SANS 10400-XA, several people in the industry questioned Lisa on the need for SANS 204, which is a voluntary, “higher requirement” standard. She replies, “Ideally, once you put National energy-efficiency standards in place, there shouldn’t be any others, but we kept SANS 204 to tell the industry that we are going to move towards those levels over the next several years. In doing so we are warning the industry that these upgrades are coming, so that they are well prepared for it.”

This forewarning approach entails a long period, unlike Australia’s approach, who first published their figures in 2003 and by 2005 they increased these figures. (90% of South Africa’s standards are based on those of Australia.) In contrast, the UK has taken a different stance by stating that they want zero-carbon buildings by 2020.


According to Nadine Engelbrecht, an architect in Gauteng, in the past developments’ climatic design was often disregarded as design concepts were primarily based on return on investment ensuring the maximum profit for the development. “The SANS 10400-XA must be taken into consideration from the initial concept design,” she says. “Buildings cannot simply be corrected as an afterthought to meet the regulations; they have to reflect climatic study throughout the design.”

Lisa adds to these sentiments by adding that the capital cost may be slightly bigger, but it has payback value. “These intervention building and insulation materials will have paid themselves back within two years,” she continues. “The problem is that developers often build for tenants, with the tenants getting the benefit of payback and not the developer, which is why there is this concern over capital costs. The increase in costs doesn’t necessarily bother a contractor, as long as their competitor is also tendering according to the requirements of SANS 10400-XA. This levels the playing field.”

Manfred Braune, Chief Technical Officer at GBCSA (The Green Building Council of South Africa), goes on to say that the interest level in green buildings and return on investment from an energy efficiency perspective is rising and the take-up is seen in GBCSA’s increased number of certified buildings. GBCSA develops the Green Star SA rating tools to provide an objective measurement for green buildings in South Africa and to recognise and reward environmental leadership in the property industry.

“Even for projects not seeking certification with the GBCSA, green is often on the agenda because of the benefits such as operational cost savings and healthier indoor environments,” he states. “However, the problem is that the regulations are not always enforced – not that they should need to be as they aim to save on operation costs.”


“There has been confusion with this regulation – especially with the “deemed-tosatisfy” requirements. We don’t want all buildings to look the same and we want there to be an aesthetic choice without compromising energy use,” Lisa points out. “There needs to be a trade-off when designing and constructing a building – when something doesn’t completely comply to the SANS 10400-XA “deemed-to-satisfy”, then something else needs to be included to ensure the total energy use is low and conforms to regulation.”

According to Manfred, the lack of understanding of the regulation has been overcome by more professionals being trained in understanding and interpreting the regulation. He believes that the lack of understanding is more prevalent in clients who see it as just another hurdle to overcome to get a building approved.

Lisa advises industry players to get to know the regulation and, if they don’t understand it, they need to speak to experts, e.g. building material suppliers and relevant associations – many of whom are well versed in the standards – or a building control officer in their municipality can also be approached.

Alternatively, they can visit The National Regulation for Compulsory Standards’ website where all regulations are found and they can ask questions on compliance online.


When SANS 204 was originally published, (after seven and a half years) there was an optimistic belief that people would adopt it because it’s the right thing to do, but it quickly became apparent that it had to be regulated for it to be properly adopted. Drafting any regulation involves significant processes that take time and public input.

“We are in the process of rewriting SANS 204 and SANS 10400-XA,” Lisa reveals. “We are going to try and simplify 10400-XA. This is to try and change it so that the type and complexity of the building equates to the level of complexity of the interventions and the design skills required. This is not a lowering of the levels, because ultimately, the  intervention levels will be increased to meet the increasing demand on our resources.”

The process of formulating an update to a standard involves a Working Group committee. After the standard has been drafted and approved by the Steering or Technical Committee, the public is given 60 days to comment on the document. “We go through every single comment,” explains Lisa. “With SANS 10400-XA we went through 34 pages of comments. We look at the reasoning behind a comment and search for a possible solution.”

She encourages the public to get involved by placing their comments with reasons and possible solutions. Each comment needs to be listed according to the section to which it pertains – general comments cannot and will not be considered.


Nadine is of the opinion that even though SANS 10400-XA does not specify building materials and finishes, it does create an awareness in the minds of the general public that in turn impacts the flooring industry. In her experience as an architect, there has been an increase in the use of reclaimed hardwood floors and in some cases a shift to laminate or bamboo floors. Other sustainable ideas are also coming into fashion such as carpets with a greater recycled content.

Polished concrete floors contain only raw concrete and require no additional material finish thereby reducing the amount of waste and materials used. In addition, exposed concrete also has a high thermal mass that can be optimised to absorb and store radiant heat from the sun.

The industry can expect a year of change regarding SANS 10400-XA – change that will undoubtedly benefit the entire built industry. Nadine aptly explains that this regulation has forced architects and especially the public to start thinking about sustainable development. “For many years most architects and developers in South Africa have ignored the effects the building industry has on the environment and also the effects the environment has on a building,” she continues. “Ideally, locally sourced, reclaimed and recycled materials also need to be enforced, however, the awareness created by the regulations and other green building initiatives is remarkable.”

She concludes by adding that many clients now want to be more “green”, use less energy and live more sustainably. These aspirations coincide with those of the flooring industry as sustainability has become a necessity and no longer a luxury.

To download a detailed document on these regulations go to: http://bit.ly/lrvprt

Sources: www.buildaid.co.za/resources/summaryESBS; www.kcecoconsumer.com

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