There’s a line in South Australia’s defibrillator Act that almost nobody applies, and it’s the one that decides whether a site with several buildings on it is treated as several buildings or as one.
It matters because the number of defibrillators you need is worked out per building or facility. Get the unit of measurement wrong and the count comes out wrong too, usually in the direction that leaves you short.
This isn’t the same question as measuring floor area. We’ve covered how to calculate publicly accessible floor area separately. This is the question that comes before it: what exactly are you measuring?
The definition, in four parts
A “relevant facility” under the Automated External Defibrillators (Public Access) Act 2022 is two or more relevant buildings that are:
- owned by the same person, and
- used for related purposes, and
- where any building is within 100 metres of another.
All three have to be true. Miss one and you’ve got separate buildings, each assessed on its own.
There’s a second, quite different limb to the definition as well: an enclosed or partially enclosed structure of 600 m² or more used for sporting or recreational activities is also a relevant facility. That one catches covered courts, indoor centres and partially enclosed sporting structures that people don’t always think of as “buildings” at all. It stands on its own and has nothing to do with the 100 metres.
The part everyone gets backwards
Read part one again. It says two or more relevant buildings.
A relevant building is one with a total internal floor area of 600 m² or more. So the aggregation rule only groups buildings that are each already over the threshold on their own. It doesn’t add small buildings together to push a site into scope.
Two 400 m² buildings 20 metres apart don’t become an 800 m² relevant facility. Each one is measured on its own, each falls under 600 m², and neither is a relevant building. The 100 metre rule never gets a look-in.
That’s worth stating plainly because the instinct runs the other way. People assume the clause exists to sweep up small buildings. It doesn’t. It exists to stop a large site being carved into pieces.
So what does it actually change?
The count.
Once a site is a single relevant facility rather than three separate buildings, the publicly accessible floor area is assessed across the facility. Above 1,200 m² of publicly accessible area on land used for commercial purposes, the Regulations’ table kicks in and you’re into two, three or more devices depending on where you land.
Assessed separately, each of those buildings might sit under 1,200 m² and require one device each. Assessed as one facility, the combined area can put you into a higher band. Same buildings, same people walking through them, different answer.
Both routes give you devices. The facility reading usually gives you more of them, and more importantly it changes where they need to go, because you’re now covering a site rather than a building.
Where this bites in practice
Multi-building office parks. Three or four buildings under one owner, shared parking, tenants who move between them. Related purposes is easy to argue. Distances are usually well inside 100 metres.
Industrial estates under single ownership. This is the one worth checking carefully, because the buildings are often large enough to clear 600 m² without anyone thinking about it, and the related-purposes test is fact-dependent. A single owner leasing to unrelated tenants doing unrelated things is a different case from an owner-operator running one business across four sheds.
School and university campuses. Schools are already designated under the Act, so they need at least one device regardless of size, and primary and secondary schools are excluded from the “commercial purpose” test so the scaling table doesn’t apply to them. Universities, TAFEs and vocational colleges are designated too. The facility question still matters for how you cover the site sensibly, even where it doesn’t change the legal minimum.
Retirement villages, caravan parks and residential parks. All designated already. Again, the count and the coverage are the live questions, not whether you’re in scope.
Sporting and recreation sites. This is where the second limb does the work. A partially enclosed structure of 600 m² or more used for sport or recreation is a relevant facility on its own terms.
The two things the Act doesn’t spell out
I’d rather be straight about this than pretend the test is cleaner than it is.
“Related purposes” isn’t defined with a bright line. Common ownership plus physical proximity plus some functional connection is clearly the intent. A campus, an estate operated as one operation, a multi-building site with shared services. Where the buildings are leased to genuinely unrelated businesses with nothing connecting them but a landlord, it’s arguable, and reasonable people will read it differently.
The 100 metres isn’t given a measuring convention in the material we work from. Wall to wall is the sensible reading and it’s what we’d use, but if your site turns on the difference between 95 and 105 metres, that’s not a call to make from a site plan and a ruler.
Where either of those is genuinely borderline, the right move is to ask SA Health rather than document your own interpretation and hope. There’s also a Ministerial exemption power in the Act for genuine one-off cases, which is a conversation with the department, not a self-assessment.
Working through your own site
Five steps, in order.
- List the buildings under common ownership. The duty sits with the owner, not the tenants, so start from the title, not the leases.
- Measure each one properly. Total internal floor space inside the exterior walls, including stairs, toilets, lifts and lift shafts, plus balconies and rooftop terraces. Mark which ones clear 600 m².
- Look only at the ones that cleared it. Are any of them within 100 metres of another, and are they used for related purposes? If yes, they’re one facility.
- Then measure publicly accessible area across whatever unit you’ve landed on. That’s the area the public can reach without a key, a card, a code or an appointment.
- Apply the count. One device, unless the land is used for commercial purposes and the publicly accessible area exceeds 1,200 m², in which case use the table in the Regulations.
Write the reasoning down as you go. Authorised officers under the Act can enter and inspect, require documents, take copies and issue expiation notices. A documented assessment is a materially better position than a recollection, and it costs you an afternoon.
Covering a site, not just ticking a count
The count is the floor, not the design.
On a multi-building site, the practical question is whether someone can get to a device and back inside the window that matters. A single device sitting in building one is no use to a person who collapses in building four, whatever the table says. Walk the distances at the pace a frightened person actually moves.
Placement rules still apply to each device: mounted between 1.2 and 1.4 metres, publicly accessible, and never behind a key, a code or anything else that stops immediate access in an emergency. Signage near the device and outside near the building entrance. Registration with SA Ambulance within two weeks of installation, and again within two weeks of any change to location or access hours.
If your site is more than one building, get it assessed
Single buildings are usually straightforward. Sites are where the mistakes live, because the unit of assessment is a judgement before it’s a measurement.
If you own a campus, an estate or a cluster of buildings under one title and you’re not certain whether you’re looking at one facility or several, that’s exactly the kind of thing worth walking through with someone before you commit to a number. It’s a normal part of what we do before quoting anything.
We install and maintain defibrillators across South Australia, including SA Ambulance registration and the signage the Act requires. Start at our South Australia page, check whether any part of your site is out of scope altogether, and if you’ve got multiple tenancies in the mix, who’s actually responsible is worth reading alongside this.
