Personal Information
3. What is your name?
Name
(Required)
Kyla Jones
5. On whose behalf are you making this submission?
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I am making this submission on my own behalf
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I am making this submission on behalf of a business
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I am making this submission on behalf of an industry body
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I am making this submission on behalf of a government agency
6. What is your organisation (if relevant)?
Organisation
Master Plumbers and Gasfitters Association of Western Australia
7. Which best describes your industry sector?
Which best describes your industry sector?
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Building Commercial
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Building Residential
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Building Commercial and Residential
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Building and plumbing products
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Building Certification/ Surveying
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Architecture and design
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Engineering
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Plumbing
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Compliance, testing and accreditation
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Legal and Finance
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Specialist - disability access
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Specialist - energy efficiency
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Specialist - fire safety
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Specialist - health
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Specialist - hydraulic/ plumbing
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Student/ apprentices
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Trades and other construction services
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Education
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Community and Non-Government organisations
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Government
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General Public
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Other
8. Please select your state or territory
State or Territory
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ACT
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NSW
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NT
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Qld
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SA
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Tas
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Vic
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WA
9. If you work in the building industry, in which state or territory do you undertake the most work?
In which state or territory do you undertake the most work
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ACT
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NSW
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NT
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Qld
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SA
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Tas
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Vic
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WA
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NA - I do not work in the building industry
Principle 1
10. Do you agree with the intent of Principle 1?
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Yes
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No
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Unsure
Please explain your reasoning and provide suggestions for improvement.
It should be a simple and easily accessible, interactive communication channel using clear, explanatory language.
There should also be a collaborative process and approach for all stakeholders involved in the regulatory space.
There should also be a collaborative process and approach for all stakeholders involved in the regulatory space.
Principle 2
11. Do you agree with the intent of Principle 2?
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Yes
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No
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Unsure
Please explain your reasoning and provide suggestions for improvement.
Education and training forums are essential.
Communication and collaboration with industry (and ideally key industry bodies) is paramount .
Education needs to be easily accessible and delivered in a number of forms. Suggest electronically and workshops.
Communication and collaboration with industry (and ideally key industry bodies) is paramount .
Education needs to be easily accessible and delivered in a number of forms. Suggest electronically and workshops.
Principle 3
12. Do you agree with the intent of Principle 3?
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Yes
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No
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Unsure
Please explain your reasoning and provide suggestions for improvement.
Reporting from the regulatory authority should be open and transparent.
Consistent auditing targets should be set for regulatory authority's to achieve in each jurisdiction.
Once the data has been published, deficiencies and successes should be monitored on a regular basis.
Consistent auditing targets should be set for regulatory authority's to achieve in each jurisdiction.
Once the data has been published, deficiencies and successes should be monitored on a regular basis.
Principle 4
13. Do you agree with the intent of Principle 4?
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Yes
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No
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Unsure
Please explain your reasoning and provide suggestions for improvement.
Data collection is essential. Transparency and collaboration with industry in relation to compliance is also paramount.
Principle 5
14. Do you agree with the intent of Principle 5?
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Yes
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No
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Unsure
Please explain your reasoning and provide suggestions for improvement.
Enforcement action should be published however only in relation to serious non-compliance matters.
These levels need to be discussed with industry bodies and the manner in which the message is communicated need to be agreed upon.
Those action levels should range from high, medium and low risk with a consequence in reporting and communicating to the practitioners. Medium and low risk maybe addressed with education and training where applicable. The regulations can be specific in regards to enforcement and enforcement practices surrounding non compliance.
These levels need to be discussed with industry bodies and the manner in which the message is communicated need to be agreed upon.
Those action levels should range from high, medium and low risk with a consequence in reporting and communicating to the practitioners. Medium and low risk maybe addressed with education and training where applicable. The regulations can be specific in regards to enforcement and enforcement practices surrounding non compliance.
Principle 6
15. Do you agree with the intent of Principle 6?
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Yes
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No
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Unsure
Please explain your reasoning and provide suggestions for improvement.
All regulators are responsible for enforcement of regulations surrounding parts 1, 2 and 3 of the NCC. Communication and national consistency in relation to auditing and compliance is essential particularly with the advent of automatic mutual recognition and the need identified in the BCR in relation to consistent regulation.
General Questions
16. To what extent do you believe the proposed draft framework, if implemented by building regulators alongside public auditing strategies, can contribute to improved compliance with the National Construction Code, state and territory legislation and referenced Standards?
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Compliance will increase a lot
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Compliance will increase a little
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No change
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Compliance will decrease a little
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Compliance will decrease a lot
Please explain your reasoning.
The draft regulatory framework is a proactive approach to improving auditing and compliance nationally. The draft report also reports national consistency and enforcement of the NCC. All parties should work collaboratively for these measure to promote best practice and instill building confidence throughout the building and construction industry in Australia.
17. Does the draft Framework cover all aspects of reporting on auditing that you believe would be useful?
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Yes
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No
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Unsure
Please explain your reasoning and provide suggestions for other aspects of reporting.
However, constant review should occur on an annual basis and an independent board or committee (with each jurisdiction) be established involving government, industry (experts eg in plumbing) and report to the ABCB and the BMF utilising the IGA principles. All jurisdictional Ministers should monitor the administrations under their control are adhering to the IGA principles in relation to collaboration and working together to meet agreed BMF targets.
18. Do you have any other comments about the draft Framework?
If applicable, please provide your comments about the draft Auditing and Compliance Publication Framework.
National consistency is essential however the current arrangements allow states to opt in and opt out where they see fit. This system is clearly not working and needs to be addressed as a matter of urgency.
National consistency requirements identified by the BCR and the good work undertaken by the building confidence team is all heading in the right direction.
In the past, jurisdictional regulators have demonstrated their attitude toward national direction via the ABCB does not always fit with the state regulations and therefore have an easy 'out' in failing to adopt essential regulation in some cases.
The attached documents identify the inconsistencies in relation to plumbing and its regulation throughout Australia.
National consistency requirements identified by the BCR and the good work undertaken by the building confidence team is all heading in the right direction.
In the past, jurisdictional regulators have demonstrated their attitude toward national direction via the ABCB does not always fit with the state regulations and therefore have an easy 'out' in failing to adopt essential regulation in some cases.
The attached documents identify the inconsistencies in relation to plumbing and its regulation throughout Australia.