Non-Climbable Zone Requirements for Pool Barriers

What This Requirement Covers

The non-climbable zone requirement for pool barriers is a safety provision intended to prevent young children from gaining access to a pool by climbing adjacent structures, fittings, or landscaping. It specifies clear distances, barrier characteristics and site conditions so that the barrier cannot be assisted by nearby objects or surfaces that a child could use as footholds or handholds. The goal is to reduce drowning risk by ensuring barriers perform as intended even when the surrounding environment contains potential climbing aids.

This requirement applies to permanent and temporary barriers that restrict access to swimming pools (including bathing or wading pools and spas where the water depth exceeds regulatory thresholds). It is relevant to designers, builders, certifiers and homeowners installing or modifying pool barriers for Class 1 and Class 10 residential situations and for Class 2-9 buildings where a pool or outdoor play space is provided, and is implemented through the National Construction Code (NCC) Deemed-to-Satisfy provisions and referenced Australian Standards.

Key Requirements

1. Non-climbable zone dimension - A non-climbable zone must be maintained so that the barrier is not within 1.8 m (measured directly from the top of the barrier) of any element in the outdoor play space that facilitates climbing, as specified in NCC Volume One ancillary provisions and applied in various parts of the NCC (see NCC Volume One, relevant clauses).
2. Horizontal/vertical elements - The barrier and the adjoining surfaces must be non-climbable and must not contain horizontal or other elements that could facilitate climbing (NCC Volume One ancillary provisions).
3. Minimum aperture restriction - Any openings or apertures in the barrier must be such that a 100 mm diameter sphere cannot pass through (NCC Volume One ancillary provisions).
4. Separation from wall elements - The non-climbable zone requires the barrier not to be within 900 mm of elements in a wall that facilitate climbing (NCC Volume One ancillary provisions).
5. Strength and rigidity - Barriers must have strength and rigidity complying with AS 1926.1 (NCC references require barrier construction to meet the Australian Standard for pool safety barriers).
6. Application to children’s facilities - For outdoor play spaces and early childhood centres, the NCC applies the non-climbable zone requirement and treats AS 1926.1 as if a swimming pool were adjacent, so the barrier restricts children from exiting without staff knowledge (NCC Volume One ancillary provisions).
7. Pool depth threshold - The NCC and state pool legislation typically regulate barriers for pools with water depth greater than 300 mm; NCC Volume Two and state schedules refer to this threshold when applying barrier requirements (NCC Volume Two, Part H7 and explanatory notes).
8. Referenced standards - In practice, the Deemed-to-Satisfy requirements for pool barriers reference:
9. AS 1926.1 - Safety barriers for swimming pools - Construction, which sets detailed barrier geometry and construction requirements.
10. AS 1926.2 and AS 1926.3 for related aspects (gates, water recirculation systems) where the NCC Deemed-to-Satisfy provisions refer to them (NCC Volume Two, H7D2).
11. NCC clauses and parts - The non-climbable zone and associated pool barrier requirements are enforced through:
12. NCC Volume One - ancillary provisions and schedule amendments (see the ancillary provisions text requiring non-climbable elements, 100 mm sphere limit, 1.8 m and 900 mm clearances, and AS 1926.1 strength requirements).
13. NCC Volume Two, Part H7 - Deemed-to-Satisfy provisions for Class 1 and Class 10 buildings (H7D2 referencing AS 1926.1 and AS 1926.2), and explanatory notes referencing the 300 mm depth threshold.
14. Other Australian Standards - While AS 1926.1 is primary for pool barrier construction, other standards may be relevant to specific materials or structures that could affect climbability, for example standards for glazing, fencing construction or structural design where applicable (cite AS 3700, AS 4100 or AS 1684 only where those standards are used for construction of masonry, steel or timber components of the barrier or adjacent structure).

Residential vs Commercial

1. Residential (Class 1 and Class 10):
2. The NCC Volume Two Deemed-to-Satisfy provisions (Part H7) require pool barriers for private residential pools over 300 mm depth to comply with AS 1926.1 and AS 1926.2 (H7D2(1)).
3. The non-climbable zone principles (1.8 m from top of barrier to climbing elements, 900 mm clearance from walls facilitating climbing, and 100 mm sphere rule) are applied in residential settings through the referenced Australian Standards and NCC Deemed-to-Satisfy clauses.
4. Commercial and institutional (Class 2-9):
5. For pools associated with Class 2, 3, 4 or other Class 2-9 buildings, NCC Volume One and Volume Two also require barriers that meet AS 1926.1 and related provisions. Additional restrictions apply for outdoor play spaces (for example early childhood centres) where the NCC explicitly applies non-climbable zone rules to prevent children leaving the play area (NCC Volume One ancillary provisions).
6. Where pools are part of public or commercial facilities, additional duty-of-care, management and access-control requirements may apply under state legislation and local regulations beyond the NCC - for example automatic-closing gates, latch positioning and staff supervision in early childhood centres (NCC Volume One ancillary provisions and state schedules).

Exceptions and Exemptions

1. Pools with water depth of 300 mm or less are generally outside the primary pool barrier requirements referenced in the NCC Deemed-to-Satisfy provisions; however, local state legislation can differ and may still regulate certain small wading pools.
2. Out-of-ground or above-ground pool walls may not be considered effective barriers unless specifically constructed to meet barrier criteria - NCC schedules note that some above-ground walls are not deemed effective barriers (NCC Volume Two and state schedules).
3. There are cases where a Performance Solution is accepted instead of the Deemed-to-Satisfy solution; in such cases, the relevant Performance Requirements must be demonstrated in accordance with the NCC performance provisions (refer to A2G2/A2G4 process in the NCC).
4. Early childhood centres and similar institutional contexts: the NCC excludes certain walls and doors from the non-climbable ancillary requirement except where those walls fall within a defined non-climbable zone for a barrier (NCC Volume One ancillary provisions).

State and Territory Variations

1. The NCC is a nationally adopted code but each state and territory may include a schedule or local amendment that modifies pool barrier implementation. Notable variations include:
2. New South Wales - NSW-specific provisions in NCC Volume One and Volume Two (for example NSW H7P1, NSW H7D2 and NSW G1P2/G1D2) reference the Swimming Pools Act 1992 and Swimming Pool Regulation 2018 and require barriers for pools deeper than 300 mm; NSW also clarifies out-of-ground pool walls are not effective barriers and refers to AS 1926.1 and AS 1926.2 for compliance.
3. Queensland, Tasmania, Northern Territory, South Australia and others - the NCC H7D2 text includes state-specific notes and references; states maintain their own pool safety legislation and may impose additional requirements (for example registration/inspection schemes, specific gate latch locations and signage).
4. Always check the relevant state schedule in NCC Volume One (Schedules 4-12) and the local pool safety legislation for exact amendments and enforcement practice.

Practical Compliance Tips

1. Place major climbing aids well outside the 1.8 m zone - locate pot plants, decking steps, play equipment and fixed furniture at least 1.8 m horizontally from the top of the pool barrier, or ensure they cannot be used as stepping aids.
2. Keep walls and adjacent surfaces smooth and free of footholds within 900 mm - ensure walls within 900 mm of the barrier do not have projections, horizontal lines or textures that can be used to climb.
3. Check apertures and gaps - verify that any opening or gap in the barrier cannot pass a 100 mm sphere; measure gaps at their largest points (including between rails and around posts).
4. Follow AS 1926.1 construction details - use the Australian Standard for dimensions, gate hardware and material strength requirements; this will satisfy the NCC Deemed-to-Satisfy route for most installations (NCC Volume Two, H7D2).
5. Design gates to self-close and self-latch, out of reach of young children - position latches at heights recommended in AS 1926.1 and where state law requires; ensure latches are not readily operated by young children.
6. Account for landscaping growth and renovations - when planting or adding structures near the barrier, allow growth and future modifications to be considered so you do not unintentionally create a climbable surface within 1.8 m.
7. Confirm state rules and inspections - check the relevant state pool safety legislation, council or certifier requirements (including registration and inspection regimes) before construction or modification; state schedules in the NCC may modify Deemed-to-Satisfy provisions.

References

1. NCC 2022 Volume One - Building Code of Australia: ancillary provisions requiring non-climbable elements, 100 mm sphere limit, 1.8 m and 900 mm clearances, and requirement to comply with AS 1926.1.
2. NCC 2022 Volume Two - Building Code of Australia, Part H7 Deemed-to-Satisfy provisions (H7D2) and explanatory notes referencing the 300 mm depth threshold and AS 1926.1/AS 1926.2.
3. AS 1926.1 - Safety barriers for swimming pools - Construction (refer to this Standard for detailed barrier geometry, gate hardware, and construction requirements).

Note: State schedules and local pool safety legislation can add or modify requirements in the NCC. Where documentation is unclear for a specific site, consult the relevant state schedule in NCC Volume One and seek advice from a registered building certifier or local authority.