Is E3/AS1 really achievable?

E3/AS1 is considered the primary means to comply with E3.
E3 objective and functional requirements are to prevent moisture damage to properties that then results in health issues via mould rot and decay, and to safeguard people’s properties from damage so as not to suffer loss.
By the definition of the performance requirements, E3 clearly links sanitary fixtures and appliances with the requirement that water does not damage property and health by means of impervious surfaces.
So, how is E3/AS1 an acceptable solution to complying with E3 performance requirements? Simple answer, it’s not.
The above statement is not just on the basis of the research that TANZ has done over the last eight years, which shows that E3/AS1 is flawed, but also when considering the descriptions and trade practices that are linked to E3/AS1. To understand more, we will consider E3/AS1.
Firstly, E3/AS1 is an acceptable solution that is full of holes, not the type of pathway that inspires confidence, especially when considering water; it’s like using a sieve to bucket water.
First problem, it was formed last century, yep, 1992, so it’s around 34 years old.
Its updates have been limited, like add-ons.
What is so important with an “acceptable solution” is to have it measured by means of a verification method, oh yeah, there isn’t a verification method. So, it’s hope and pray, and she’ll be right.
The contents page is the next problem, because it’s like internal moisture has all been lumped together, regardless of how and why the moisture appeared in the home or how it is controlled or removed. It’s the same as saying, “I will contact my dentist to do some brain surgery on me because he works on the head section of people”; the fact that there is some type of connection does not mean the connection is relevant from one area to another. How does ventilation connect with showers and urinals??? It doesn’t, so it shouldn’t be under the same acceptable solution pathway.
There is no doubt that major moisture issues can result of poor and incorrect ventilation and condensation, and addressing this issue is incredibly important, so much so that the topic should have its own acceptable solution pathway, and research should be used to provide a verification method for this topic.
So, looking at E3/AS1 Containment, it mentions “Containment provided to satisfy Paragraph 2.0.1 a) may be achieved by using impervious floor coverings which: a) Are continuous and coved or joints sealed where they meet the wall”
So what does fig1 show????

Yep, can’t beat an image from 1992, tell me how many times you have seen either vinyl-covered or tiles covered, not for 20 years, so how is today’s construction, using E3/AS1 complying??
Wait, there is an option b) Extend to the doorway and all walls of the room, or to at least 1.5 m from all sanitary fixtures and sanitary appliances in open-plan rooms.
So what does that look like, for a bathroom that looks like a radius of 1.5m from the vanity, a radius of 1.5m from the shower, a radius of 1.5m from the bathtub, a radius of 1.5m from the toilet, ummm, sounds like an impervious covering is required in a wet area.
So what is an impervious surface?
- Integrally waterproof sheet material (e.g. polyvinylchloride) with sealed joints and sealed or coved at edges where watersplash may occur.
- b) Ceramic or stone tiles having 6% maximum water absorption, waterproof grouted joints, and bedded with an adhesive specified by the tile manufacturer as being suitable for the tiles, substrate material and the environment of use. Edges of the tiled area where watersplash may occur must be sealed or coved, and tiles must be laid on a continuous impervious substrate or a membrane specified by the manufacturer as being suitable for the tiles, substrate material and the environment of use.
- c) A slab-on-grade concrete floor having a steel trowel or polished finish, sealed at edges where watersplash may occur, when used in a domestic laundry within a garage, or in a building that contains only sanitary facilities.
Let’s break them down one-by-one
Polyvinylchloride shows up as either a PVC pipe or a PVC rigid sheet, not really a floor covering anyone would use, but really, it’s referring to vinyl sheeting. Here’s the kicker, in the comments.
Other floor finishes may also be capable of satisfying the performance for impervious and easily cleaned, if installed in a manner that prevents gaps or cracks within the finish and at any parts of its perimeter that are exposed to watersplash, and/or if the surface is sealed with a suitable, durable coating.
You see, vinyl is but joints and cut “to” any abutments, seldom sealed, and if so, the sealant has a 5-year warranty and probably is not going to be maintained. Often the vinyl will abut to a timber skirting with no means to seal against it, that’s reality.
What about tiles, well, for floors approx. 10% of floor tiles are ceramic, so not really relevant with approx. 90% of floor tiles are porcelain, which means the 6% moisture absorption isn’t an issue; there is no such thing as “waterproof grout”. The tile adhesives are mostly suited for porcelain tiles, so they are highly modified and suitable for use over most substrates.
The following comment is of great interest
“tiles must be laid on a continuous impervious substrate or a membrane specified by the manufacturer as being suitable for the tiles”, because this brings us to the last section C.
We see section C misapplied, misinterpreted and misunderstood. Let’s look at it closely.
A slab-on-grade concrete floor having a steel trowel or polished finish, sealed at edges where watersplash may occur
So, how is slab-on-grade concrete steel troweled considered impervious??
The surface of the concrete is troweled smooth and compact, creating a finish that prevents moisture from entering. This “impervious” finish, though, doesn’t help around construction cuts and shrinkage cracking, where water can enter and then track.
Also, this surface is unsuitable for any product that is to be directly adhered to the concrete surface and requires mechanical abrading. The mechanical abrading then leaves the concrete surface in a porous state, which then requires a membrane to be applied to form an impervious surface. So, straight to the point, steel troweled concrete must be ground (mechanically abraded) if you are going to install any floor covering over it. This is for adhesion, and since it needs to be abraded, does it need an impervious layer applied? A membrane is required. This includes tiles, vinyl, interlocking flooring, basically all flooring types used in a bathroom.
The requirement of the membrane does not stop with just the floor. As noted previously in the E3 objectives and performance requirements, a wet area needs to prevent moisture from damaging building elements, such as a wall bottom plate, this then requires a membrane upstand, E3/AS2 IWAM Code of Practice indicates 75mm (sounds reasonable) and for the membrane to terminate at the doorway (again sounds reasonable) so as to prevent building elements from becoming damaged by moisture, such as door frames, skirtings, carpet, wall board and bottom plates.
So then, on review, is E3/AS1 fit for purpose? No, it’s out of date, fails to provide an acceptable solution to meet E3 performance requirements.
When considering this, are there any other options? Yes, absolutely E3/AS2 (which is really the only option)
All of the issues with E3/AS1 have been sorted by E3/AS2. The document is up to date and supported by the IWAM Code of Practice, which gives selection, design and installation information.
E3/AS2 provides a solution for multiple types of coverings while providing clear direction on how to meet the compliance requirements of E3 performance, whereas E3/AS1 is very limited and, although relied upon, does not provide an achievable means to meet E3 performance requirements.
