Response 1015101516

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Personal Information

3. What is your name?

Name (Required)
Kyla Jones

5. On whose behalf are you making this submission?

Please select one item
Radio button: Unticked I am making this submission on my own behalf
Radio button: Unticked I am making this submission on behalf of a business
Radio button: Ticked I am making this submission on behalf of an industry body
Radio button: Unticked 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?
Please select one item
Radio button: Unticked Building Commercial
Radio button: Unticked Building Residential
Radio button: Unticked Building Commercial and Residential
Radio button: Unticked Building and plumbing products
Radio button: Unticked Building Certification/ Surveying
Radio button: Unticked Architecture and design
Radio button: Unticked Engineering
Radio button: Ticked Plumbing
Radio button: Unticked Compliance, testing and accreditation
Radio button: Unticked Legal and Finance
Radio button: Unticked Specialist - disability access
Radio button: Unticked Specialist - energy efficiency
Radio button: Unticked Specialist - fire safety
Radio button: Unticked Specialist - health
Radio button: Unticked Specialist - hydraulic/ plumbing
Radio button: Unticked Student/ apprentices
Radio button: Unticked Trades and other construction services
Radio button: Unticked Education
Radio button: Unticked Community and Non-Government organisations
Radio button: Unticked Government
Radio button: Unticked General Public
Radio button: Unticked Other

8. Please select your state or territory

State or Territory
Please select one item
Radio button: Unticked ACT
Radio button: Unticked NSW
Radio button: Unticked NT
Radio button: Unticked Qld
Radio button: Unticked SA
Radio button: Unticked Tas
Radio button: Unticked Vic
Radio button: Ticked 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
Please select one item
Radio button: Unticked ACT
Radio button: Unticked NSW
Radio button: Unticked NT
Radio button: Unticked Qld
Radio button: Unticked SA
Radio button: Unticked Tas
Radio button: Unticked Vic
Radio button: Unticked WA
Radio button: Ticked NA - I do not work in the building industry

Principle 1

10. Do you agree with the intent of Principle 1?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked 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.

Principle 2

11. Do you agree with the intent of Principle 2?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked 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.

Principle 3

12. Do you agree with the intent of Principle 3?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked 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.

Principle 4

13. Do you agree with the intent of Principle 4?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked 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?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked 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.

Principle 6

15. Do you agree with the intent of Principle 6?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked 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?

Please select one item
Radio button: Ticked Compliance will increase a lot
Radio button: Unticked Compliance will increase a little
Radio button: Unticked No change
Radio button: Unticked Compliance will decrease a little
Radio button: Unticked 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?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked 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.