# The AS 1851 Trap: Is Your 'Competent Person' a Liability?
NSW Facility Managers: If you think Section 14—Emergency Planning—is just a box-ticking exercise for your Annual Fire Safety Statement (AFSS), you are gambling with your PCBU liability. Under AS 1851-2012, Section 14 is a statutory requirement, and the definition of who can "service" it is tighter than most providers want you to know.
The 'Competent Person' Mandate (Clause 1.4.9)
Compliance starts with the individual. Under **AS 1851-2012, Clause 1.4.9**, a Competent Person is defined as someone with the specific training, qualification, and experience to correctly perform the task.
In the context of **Section 14 and Appendix J**, this is where the industry "generalists" fall over. To reach the AS 1851 benchmark for signing off on emergency procedures, the person *must* hold the following Public Safety (PUA) Units of Competency:
The Experience Gap: Documented & Validated
A certificate is just paper. The Standard requires **documented and more importantly, validated industry experience.** True competency in Section 14 requires a proven track record of applying these units in complex, real-world facility environments.
The PCBU Liability Risk
If you accept a Section 14 sign-off from an unqualified individual, the **PCBU (Person Conducting a Business or Undertaking)** isn't just failing an audit—they are assuming 100% of the legal liability in the event of an incident.
In a courtroom, an AFSS built on an unqualified Section 14 report is a "legal minefield." You aren't paying for a service; you are paying to transfer risk. If your provider lacks the **002/003 units** and the **validated veteran experience** to back them up, the risk never leaves your desk.
The Section 14 Tactical Checklist
Per Table 14.4.1 and AS 3745 benchmarks:
Stop guessing. Start complying.
Hit us up for your Free Emergency Plan roadmap: https://www.complianceready.com.au/checklist