Response 851807419

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Glossary and Proposed Terminology

Do you agree with the definitions for the preferred terms used in this discussion paper?

Building approval Yes Radio button: Checked Yes Building approval No Radio button: Not checked No Building approval Unsure Radio button: Not checked Unsure
Building approval applicant Yes Radio button: Checked Yes Building approval applicant No Radio button: Not checked No Building approval applicant Unsure Radio button: Not checked Unsure
Building surveyor Yes Radio button: Checked Yes Building surveyor No Radio button: Not checked No Building surveyor Unsure Radio button: Not checked Unsure
Declaration of Design Compliance Yes Radio button: Not checked Yes Declaration of Design Compliance No Radio button: Checked No Declaration of Design Compliance Unsure Radio button: Not checked Unsure
Occupancy approval Yes Radio button: Checked Yes Occupancy approval No Radio button: Not checked No Occupancy approval Unsure Radio button: Not checked Unsure
Project Product Register Yes Radio button: Checked Yes Project Product Register No Radio button: Not checked No Project Product Register Unsure Radio button: Not checked Unsure
Statutory building surveying assessment work Yes Radio button: Checked Yes Statutory building surveying assessment work No Radio button: Not checked No Statutory building surveying assessment work Unsure Radio button: Not checked Unsure
Statutory building surveying approval work Yes Radio button: Not checked Yes Statutory building surveying approval work No Radio button: Not checked No Statutory building surveying approval work Unsure Radio button: Not checked Unsure
Statutory functions Yes Radio button: Not checked Yes Statutory functions No Radio button: Not checked No Statutory functions Unsure Radio button: Not checked Unsure
Of the terms you did not agree with, could you expand on why, and how they should be changed?
The difficulty that I have is that it is the content of the document that determines its efficacy. If it is not robust in terms of identifying what the design is certifying then it is open to abuse.

Recommendation 13: Building Approval Documentation

Are the five proposed objectives (see Proposed measures) an appropriate benchmark for adequate documentation?

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

Is it appropriate to require Declarations of Design Compliance from each registered design practitioner responsible for an aspect of the design of a building?

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

Does the obligation for registered designers to provide a Declaration of Design Compliance differ across circumstances?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Maybe
If yes/maybe, how does the obligation differ?
With a standard template for design certification, there is no way that you should answer yes to this question. If a section of the template doesn't apply then just state N/A

Should the Declaration of Design Compliance include details of the practitioner’s relevant qualifications and/or experience specific to the design work, or is evidence of a relevant licence sufficient?

Please select one item
Radio button: Unticked Qualifications and/or experience specific to the work
Radio button: Ticked Only relevant licence needed
Radio button: Unticked Other
Please expand on your answer.
In order to sign a declaration of compliance you should be appropriately qualified. The template should ideally identify the license level required to sign. In order to be issued that license the licensee would have been required to satisfy the experience and qualifications necessary for that license to be issued.

Are the circumstances described (detailed at M13.1h and i, see below) appropriate for the building surveyor to rely on Declarations of Design Compliance?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Maybe
Please expand on your answer.
I have a problem with reference to an engineer, as design compliance by an engineer is not always relevant or appropriate. Obtaining a degree as an engineer doesn't follow that they understand the technical details of ensuring the roof system is designed correctly. That the waterproofing in a wet area is designed correctly. Also mots often these elements are designed by an architect not an engineer. This knowledge requires years of experience and knowledge of products and systems. There is no formal training for a myriad of trades such as these, that deliver in the built environment.

Is the minimum documentation list (see M13.2 in table 8) appropriate?

Please select one item
Radio button: Unticked Appropriate
Radio button: Ticked Maybe appropriate
Radio button: Unticked Inappropriate
Radio button: Unticked Unsure
What other information that should be required, or please expand on your answer?
The reference at M13.2 g. to complete construction drawings should be complete "approved for construction". This is because they are not as constructed at this stage of the project life cycle.
I am assuming that 13.2 m. is the 3rd party review.

Is an NCC Performance Requirement checklist (detailed at M13.2 f) a necessary requirement for all building types?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Maybe
Please expand on your answer.
It should be noted regardless of the building type, whether one or more or none have been included to achieve compliance. By noting that none have been used shows that the practitioner has responded to that question. It is a good prompt and if it is left blank it will prompt the question why?

Is it appropriate that the building surveyor be able to condition an approval in limited circumstances?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Maybe
What might be those circumstances?
When project time frames are particularly tight, there is a enormous amount of preliminary work that can be undertaken before work can commence on site. Having some guidance as the 90% probability of approval requirements, even 80% is often adequate to proceed with some of this preliminary work.

Is the right approach to staged building approvals being proposed (see M13.3)?

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

Is it appropriate to require a Product Register for products/systems used for the fire and structural elements (see M13.4)?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked Maybe
Should there be exceptions?
From personal experience I do not think that it should be limited to just materials covered under Section B & C. Some of the most significant failures have been around waterproofing materials. But not just these products. It should also include maintenance requirements for these products, to ensure that design life's are not compromised.

Are there exceptions to when the Product Register should be required?

Please select all that apply
Checkbox: Unticked All
Checkbox: Ticked None
Checkbox: Unticked Risk 0
Checkbox: Unticked Risk 1
Checkbox: Unticked Risk 2
Checkbox: Unticked Risk 3
Checkbox: Unticked Risk 4
Checkbox: Unticked Risk 5

Who is the right person to compile the Project Product Register?

Please select all that apply
Checkbox: Unticked Lead designer
Checkbox: Unticked Specialist engineer
Checkbox: Ticked Someone else
Please expand on your answer.
Project Quality Manager or Project Completions Manager. Product selection can and does change of the course of a project. There are a number of factors that can impact this, something as simple of a selected supplier folding. This is why it is an iterative process.

Recommendation 14: Documentation of Performance Solutions

Is this the right information to document Performance Solutions (see M14.1)?

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

Is the information being required sufficient to enable a holistic assessment of the design?

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

Is the detail on where Performance Solutions (M14.4) have been used, and for what purpose, sufficient information to record on the occupancy certificate?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Unsure
Please expand on your answer.
Occupancy Certificates are normally a single A4 page posted in the lobby of the applicable building. It would not be possible to include all of this information at that location. If there is a Performance Solution under section C the full details should be retained in the Fire Control Room and the location of where these are stored note don the certificate. Other details can be retained in the property managers office.

Recommendations 15 and 16: Approval During and After Construction

Is this the right process to address variations to the approved documentation (Table 12)?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Maybe
Please expand on your answer.
M15/16.1 Some times changes to the project happen that are unintended. They are the subject of a non-conformance report. This may result in the change being accepted without modification. So you cannot always pre-empt these changes. It would be better to include a minimum time frame by which the building surveyor has to be notified. Some of the standard Non-conformance templates have a requirement that the certifier also accepts the non-conformance

Should all variations be documented and included in the occupancy certificate, regardless of whether they affect the compliance of the building?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Maybe
Please expand on your answer.
Only if they have life health and safety implications as far as the relevant section of teh NCC/BCA is concerned.

Is it appropriate to require the building surveyor to inform the state regulator as soon as they become aware that building work has proceeded not in accordance with the building approval?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Maybe
Please expand on your answer.
Only if he is uncertain as to the implications of the change in terms of how the regulator may respond.

When approving variations to the building approval in constructed work (post-facto approvals) is the process sufficiently robust (M15/16.5 & 16.6)?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Maybe
Please expand on your answer.
I think part c is unnecessarily onerous. Enforcement action should not be necessary as he simply needs to say that a certificate of classification will not be issued at the end of the stage or project.
This is where a non-conformance report template including a sign off by the certifier is so helpful.

If the post-facto approval involves a Performance Solution:

Should the owner’s consent be required before a variation to the building approval can be made for constructed building work? Yes Radio button: Checked Yes Should the owner’s consent be required before a variation to the building approval can be made for constructed building work? No Radio button: Not checked No Should the owner’s consent be required before a variation to the building approval can be made for constructed building work? Maybe Radio button: Not checked Maybe
Should the regulator receive a copy of the documentation and statement of reasons? Yes Radio button: Not checked Yes Should the regulator receive a copy of the documentation and statement of reasons? No Radio button: Not checked No Should the regulator receive a copy of the documentation and statement of reasons? Maybe Radio button: Checked Maybe
Please expand on your answer.
Only if the certifier has concerns as to whether the regulator will accept the change

Do the proposed measures go far enough to address additional risks to building quality where the owner during design and construction is a developer and not the end owner.

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

Other considerations

Are different actions required to implement the proposed measures for different project types?

High level legislative principles Commercial buildings Radio button: Not checked Commercial buildings High level legislative principles Complex buildings Radio button: Checked Complex buildings High level legislative principles Buildings being delivered for certain end users? E.g. strata owners. Radio button: Not checked Buildings being delivered for certain end users? E.g. strata owners.
Detailed regulatory requirements Commercial buildings Radio button: Not checked Commercial buildings Detailed regulatory requirements Complex buildings Radio button: Not checked Complex buildings Detailed regulatory requirements Buildings being delivered for certain end users? E.g. strata owners. Radio button: Not checked Buildings being delivered for certain end users? E.g. strata owners.
Practice guide Commercial buildings Radio button: Not checked Commercial buildings Practice guide Complex buildings Radio button: Not checked Complex buildings Practice guide Buildings being delivered for certain end users? E.g. strata owners. Radio button: Not checked Buildings being delivered for certain end users? E.g. strata owners.
Please expand on your answer.
I am not quite sure that the structure of this question is such that I can respond in the manner that the response allow

Are there other actions to implement the proposed measures that should be considered?

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