Multi-tenanted buildings are common in urban Australia. Office towers with dozens of tenants sharing lifts, stairs and lobbies. Retail centres with anchor tenants and specialty stores drawing from shared assembly areas. Business parks with multiple occupants on a shared campus. Medical suites in a shared clinical building. Each of these facilities faces the same underlying challenge in emergency planning: who owns what?

AS 3745:2010 anticipates the multi-tenanted case. The standard expects a master plan owned by the building, and integrated sub-plans owned by each tenant. In practice, this is where more Australian facilities fail than in any other single aspect of emergency planning. Tenants develop their own plans in isolation from the master, or the master plan does not exist, or the master and sub-plans have never been aligned, or the coordination arrangements have broken down since a change of building manager or a change of tenant.

This guide covers the master-plan and sub-plan coordination framework for Australian multi-tenanted buildings: who is responsible for what, how the plans should align, and how to close the most common compliance gaps we see across the sector. It builds on our companion guides on emergency evacuation plans for Australian business and the AS 3745 Emergency Control Organisation.

The multi-tenanted structure under AS 3745

AS 3745:2010 recognises that facilities may have multiple occupants under different management structures, and that the emergency plan must accommodate the complete facility as a whole. The standard’s approach:

• A master emergency plan is developed for the whole building or facility, covering common areas, shared alarm and communication systems, shared evacuation routes, primary and secondary assembly areas, and building-level Emergency Control Organisation (ECO) arrangements
• Individual tenants develop tenant sub-plans that cover their specific occupied area, tenant-specific procedures, and tenant-level ECO members
• The master plan and tenant sub-plans are integrated: they use consistent terminology, common alarm signals, common assembly area designations, and coordinated procedures
• A master Emergency Planning Committee (EPC) coordinates across the master and sub-plans, typically chaired by the building owner or facility manager and including representatives of all tenants

This structure is workable and, when it is done properly, produces a coherent, effective emergency capability across the whole facility. When it is not done properly, it produces a series of disconnected tenant plans that assume the building’s common elements will function without ever verifying it.

The two governance bodies revisited

In multi-tenanted buildings, both the Emergency Planning Committee (EPC) and the ECO require multi-level structures:

The master EPC

A single overarching committee, typically chaired by the building owner or facility manager, that owns the master plan. Membership includes:

• The building owner or nominated representative
• The facility manager
• A representative from each significant tenant (with proportional representation for very small tenants)
• The master Chief Warden
• Building services representatives (fire safety engineer, security manager, mechanical services)
• Emergency service liaisons for large or high-risk facilities

The master EPC meets regularly (industry practice is at least quarterly for large multi-tenanted buildings) and owns the master plan’s currency, integration with sub-plans, and the annual full-building evacuation exercise.

Tenant sub-EPCs

Each tenant runs their own sub-committee for their tenant-specific plan. Membership is smaller and more operational. The tenant sub-EPC develops the tenant sub-plan, appoints the tenant’s ECO members, and coordinates with the master EPC through the tenant’s appointed representative on the master committee.

The master ECO and tenant ECOs

The building typically has a master Chief Warden (often the same person as the building manager or their nominee) who leads the whole-building response. Each tenant has their own tenant Chief Warden or lead Floor Warden who leads the tenant response. During a real incident, the tenant Chief Wardens report to the master Chief Warden, who coordinates the whole-of-building response and interfaces with emergency services.

What the master plan should contain

The master plan covers everything that spans across tenants:

• Facility-level risk assessment across all foreseeable emergencies for the whole building
• Building alarm and Emergency Warning and Intercommunication System (EWIS) specifications and testing regime
• Master ECO structure and membership
• Common evacuation routes (stairs, lobby, external egress)
• Primary and secondary assembly areas and their capacity for full-building evacuation
• Evacuation diagrams for common areas
• Building-wide communication procedures (public address, tenant liaison, emergency service coordination)
• Master emergency service contact list (Fire and Rescue, police, ambulance)
• Triple Zero fallback procedures for the building
• Coordination arrangements with adjacent buildings or precincts where applicable
• Annual full-building evacuation exercise schedule
• Master document control and version management

What tenant sub-plans should contain

The tenant sub-plan covers what happens inside the tenant’s occupied area, and how the tenant’s response connects to the master:

• Tenant-specific risk assessment for the tenant’s work activities and hazards
• Tenant ECO structure (typically a Chief Warden or lead Floor Warden, Deputies, Wardens)
• Tenant-specific evacuation procedures for the tenant’s occupied area
• Personal Emergency Evacuation Plans (PEEPs) for the tenant’s occupants who require assistance
• Tenant-specific alarm response (how tenant staff act when the building alarm sounds)
• Communication arrangements between the tenant Chief Warden and the master Chief Warden
• Tenant-specific training records
• Tenant-specific exercise participation
• Post-incident procedures for tenant staff (welfare, Employee Assistance Program (EAP), tenant management notification)
• Interface points with the master plan (explicit references to master procedures, master ECO contacts, master alarm signals)

The integration test

The core question for any multi-tenanted building is: does the master plan and each tenant sub-plan produce a coherent response when an incident occurs? The integration test covers:

1. Alarm signals

Does the tenant know what a fire alarm sounds like in this specific building? Does the tenant know what the lockdown signal (if separate from the fire alarm) sounds like? Are these signals documented consistently across the master and sub-plans?

2. Assembly areas

Does the tenant sub-plan send occupants to the correct primary assembly area? Does it acknowledge the secondary assembly area? Does the master plan’s capacity assessment account for the tenant’s occupant numbers?

3. Communication chain

When the tenant Chief Warden needs to communicate with the master Chief Warden, who do they contact, on what channel, and what is the fallback if that channel fails? Is this documented in both the master and tenant plans?

4. Common evacuation routes

Do the tenant’s primary and secondary routes align with the building’s primary and secondary routes? Are there tenant-specific route obstructions (locked internal doors, stock storage, construction) that might affect the shared route?

5. PEEP arrangements

Does the master plan know which tenants have PEEP occupants? Does the master ECO know how to support tenant PEEP execution during a full-building evacuation? Are the shared lifts, refuge areas, or assistance points documented in both plans?

6. Exercise participation

Does the tenant participate in the master’s annual full-building evacuation exercise? Does the tenant’s sub-plan exercise schedule align with the master schedule?

7. Emergency service handover

When emergency services arrive, does the tenant Chief Warden brief the master Chief Warden, who then briefs the emergency service? Or does the tenant brief directly? See our guide on the handover to emergency services. Both approaches have merits; what matters is that the answer is documented and consistent between the master and sub-plans.

Common gaps we see in multi-tenanted planning

From working across Australian multi-tenanted buildings for more than 40 years, these are the recurring gaps we encounter:

• The master plan does not exist. The building has evacuation diagrams and an alarm system, but no documented master plan. Each tenant has their own plan (of varying quality). Nothing coordinates them.
• The master plan exists but is not integrated with tenant sub-plans. The two are developed in isolation. The tenant sub-plans reference “the building alarm” without knowing what signal it produces or where the assembly areas are.
• Tenant sub-plans use different alarm signal terminology than the master. “The evacuation signal” in the tenant plan is unclear because the building’s signal is not defined in the tenant plan.
• Tenants send occupants to different assembly areas. Some tenants use the primary; others default to a “our usual spot” that is not documented in the master plan.
• The master ECO has never met the tenant ECOs. On the day of a real incident, the master Chief Warden does not know the tenant Chief Wardens.
• PEEP occupants are known to the tenant but not to the master. The master Chief Warden does not know that occupants remain in the building until the tenant Chief Warden tells them mid-incident.
• The tenant does not participate in the master’s annual evacuation exercise. The tenant runs their own separate exercise, which does not test the whole-building response.
• A change of tenant or building manager has broken the coordination. The new tenant has not been onboarded to the master plan. The new building manager has not been briefed on the tenant sub-plans.
• The Triple Zero fallback procedure is documented in the master plan but not shared with tenant Chief Wardens. In an outage, the tenant defaults to re-dialling Triple Zero without knowing the building has an alternative path.

Building the coordination properly

For a multi-tenanted building that is starting from a position of poor coordination, the sequence to fix it is:

Step 1: Constitute or reconstitute the master EPC. Confirm chair, membership, terms of reference, meeting cadence.

Step 2: Audit the current state. What master plan exists? What tenant sub-plans exist? Where are the gaps and misalignments?

Step 3: Update or develop the master plan. Address the elements listed above (facility risk assessment, alarm and EWIS, master ECO, common routes, assembly areas, communication chain, Triple Zero fallback).

Step 4: Engage each tenant. Provide the master plan and require tenant sub-plans to integrate with it. Establish a template for the tenant sub-plan interface with the master.

Step 5: Establish a master ECO with meetings that include tenant Chief Wardens. This is the operational integration point.

Step 6: Schedule and run a full-building evacuation exercise that involves every tenant. This is where integration gets tested in practice.

Step 7: Debrief the exercise and revise both master and tenant plans based on lessons learned.

Step 8: Lock in ongoing arrangements: quarterly EPC meetings, six-monthly ECO skills retention across all tenants, annual full-building exercise, and defined onboarding processes for new tenants and new building managers.

Tenant onboarding: an underrated element

Multi-tenanted buildings routinely see tenants come and go. Each change is a coordination risk. A robust master plan includes a tenant onboarding procedure that covers:

• The new tenant receives the master plan and the master alarm signal briefing during move-in
• The new tenant is required to develop or update their sub-plan within a defined interval (typically 60 to 90 days)
• The new tenant appoints a tenant Chief Warden or lead Floor Warden who joins the master ECO
• The new tenant participates in the next scheduled full-building evacuation exercise
• The new tenant is invited to the next master EPC meeting
• The building manager confirms the new tenant’s PEEP occupants (if any) and integrates them into the master response

Without an onboarding procedure, new tenants default to whatever they did in their previous premises, which is unlikely to be aligned with this building.

Building manager change: the other coordination risk

A change of building manager is a similar risk in the opposite direction. The new building manager takes on the master plan without necessarily having any relationship with the tenant Chief Wardens or knowledge of the tenant sub-plans. A robust master plan includes a building manager transition procedure that covers:

• Formal handover of the master plan and all tenant sub-plan interface documents
• Introduction to each tenant Chief Warden
• Review of the current EPC and ECO membership
• Review of the exercise schedule and recent debrief actions
• Review of any outstanding compliance issues
• Confirmation of the master ECO succession (does the new manager take the Chief Warden role, or delegate?)

Precincts, business parks and campuses

The master and sub-plan structure extends to multi-building precincts, business parks and campuses. In these environments, additional coordination is needed:

• A precinct-level plan that covers cross-building coordination (shared roads, shared external assembly areas, adjacent-building notification)
• Multi-building alarm and communication arrangements
• Coordinated exercise schedules
• Precinct-level emergency service liaison for major incidents
• Cross-tenant Triple Zero fallback (see our companion guide)

For very large campuses (universities, hospitals, industrial complexes), the coordination effort is significant but not optional. AS 3745’s expectations apply across the campus, not just within individual buildings.

When to engage professional support

Multi-tenanted emergency planning is one of the areas where professional external support delivers the highest value. Building managers rarely have the time or expertise to coordinate multiple tenants into an integrated plan. Tenants rarely have visibility across the building. Coordinating multiple tenancies into one coherent plan is demanding work, and it is work First 5 Minutes has done for Australian buildings, precincts and campuses across more than 40 years, supported by the largest Emergency Control Organisation training team in the country. Explore our facility emergency evacuation plan service, our AS 3745 compliance essentials, our audits and inspections service, and our Chief Warden training program, or contact our team on 1300 321 120 to discuss multi-tenanted planning for your facility.

Frequently asked questions

Who is legally responsible for the emergency plan in a multi-tenanted building?

The building owner has the primary WHS duty as a Person Conducting a Business or Undertaking (PCBU) with management or control of the workplace. Each tenant also has a PCBU duty for their occupied area. AS 3745:2010 anticipates a master plan owned by the building and tenant sub-plans owned by each tenant. Where multiple PCBUs share a workplace, they must consult, cooperate and coordinate their WHS duties.

Do tenants need their own plan if the building has a master plan?

Yes. The master plan covers building-wide elements. The tenant sub-plan covers the tenant’s occupied area, tenant-specific procedures, tenant ECO members, and PEEPs for tenant occupants. A tenant that relies solely on the master plan does not have a compliant plan for their occupied area.

What if the building owner has not established a master plan?

The tenant should raise this with the building owner and facility manager. The absence of a master plan is a building-level compliance gap. In the interim, the tenant sub-plan should cover what would normally be in the master (building alarm response, assembly area, common routes) as best the tenant can. But the correct fix is to constitute the master plan properly.

How often should the master EPC meet?

Industry practice is at least quarterly for large or complex buildings, more frequently for very large or high-risk facilities. Small buildings may meet less often but at least twice a year.

Who leads a whole-building evacuation exercise?

The master Chief Warden, coordinating with the tenant Chief Wardens for each tenant’s participation. All tenants should participate in the annual full-building exercise required by AS 3745. Tenant-only exercises are useful supplementary activities but do not replace the full-building exercise.

What happens when a new tenant moves in?

The building manager provides the master plan and briefs the new tenant on building-specific arrangements (alarm signal, assembly area, master ECO). The new tenant develops or updates their sub-plan within 60 to 90 days, appoints a tenant Chief Warden who joins the master ECO, and participates in the next scheduled exercise.

What if a tenant refuses to coordinate?

Rare, but occurs. The building owner’s options depend on lease arrangements and jurisdiction, but usually include contractual obligations relating to WHS and emergency compliance. In practice, most tenants coordinate willingly when the master plan is well-run and reasonable. The building manager’s tone and approach matters.

Do tenants share their PEEPs with the building?

Yes, in summary form. The master Chief Warden needs to know which tenants have PEEP occupants and their approximate locations. Full PEEP details remain with the tenant. This is a common compliance gap: tenant PEEPs are unknown to the master, and PEEP occupants are missed in a whole-building response.

What about visitors and contractors?

Visitor and contractor management is a shared responsibility. The building manages visitor sign-in for common areas; tenants manage visitors in their occupied areas. Both should be accounted for in a full-building evacuation, and the master plan should include a visitor and contractor accounting procedure.

How is a bomb threat handled in a multi-tenanted building?

The master Chief Warden decides on the whole-building response (evacuate, partial evacuate, shelter, lockdown, search) in consultation with police. Individual tenant Chief Wardens follow the master direction. See our bomb threat procedures comprehensive guide for the underlying procedure.

What if two tenants have contradictory sub-plans?

That is the master plan’s job to resolve. The master plan sets the building-wide standards (alarm response, assembly area, communication chain) and tenant sub-plans must comply. Contradictions typically arise when tenant plans were developed in isolation. The fix is to re-integrate under the master plan through the master EPC.