Personal Information
What is your name?
Name
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Jarrad Bailey
On whose behalf are you making this submission?
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
What is your organisation (if relevant)?
Organisation
McCormack Propert Services
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
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
If you work in the building industry, in which state or territory do you undertake the most work?
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
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: Checked Yes | Declaration of Design Compliance No Radio button: Not 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: 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: Checked Yes | Statutory functions No Radio button: Not checked No | Statutory functions Unsure Radio button: Not checked Unsure |
Recommendation 13: Building Approval Documentation
Are the five proposed objectives (see Proposed measures) an appropriate benchmark for adequate documentation?
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Yes
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No
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Maybe
Please expand on your answer.
Building practitioner should always take responsibility of what they have completed
Is it appropriate to require Declarations of Design Compliance from each registered design practitioner responsible for an aspect of the design of a building?
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Yes
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No
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Maybe
Does the obligation for registered designers to provide a Declaration of Design Compliance differ across circumstances?
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Yes
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No
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Maybe
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?
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Qualifications and/or experience specific to the work
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Only relevant licence needed
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Other
Are the circumstances described (detailed at M13.1h and i, see below) appropriate for the building surveyor to rely on Declarations of Design Compliance?
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Yes
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No
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Maybe
Please expand on your answer.
All applicable information should be provided to ensure an accurate assessment
Is the minimum documentation list (see M13.2 in table 8) appropriate?
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Appropriate
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Maybe appropriate
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Inappropriate
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Unsure
What other information that should be required, or please expand on your answer?
Will increase the cost of building works but required for appropriate assessment none the less.
Is an NCC Performance Requirement checklist (detailed at M13.2 f) a necessary requirement for all building types?
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Yes
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No
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Maybe
Please expand on your answer.
All work should meet expectations. Completing these will also ensure the works are well assessed and accurate prior to work starting.
Is it appropriate that the building surveyor be able to condition an approval in limited circumstances?
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Yes
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No
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Maybe
What might be those circumstances?
Limitation on what can be done due to existing structures. All works need to be completed although existing / surrounding issues still need to be taken into account. It is improbable that the entrie building can be rebuilt to suit changes in building regulations
Is the right approach to staged building approvals being proposed (see M13.3)?
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Yes
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No
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Maybe
Please expand on your answer.
Ideally design should be completed to it's full extent but this is not always practicable
Is it appropriate to require a Product Register for products/systems used for the fire and structural elements (see M13.4)?
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Yes
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No
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Maybe
Should there be exceptions?
No, it should be expected that it is well know what is in location to make an appropriate assessment. This will increase design costs but shortcuts only cause problems
Are there exceptions to when the Product Register should be required?
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All
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None
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Risk 0
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Risk 1
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Risk 2
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Risk 3
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Risk 4
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Risk 5
Please expand on your answer.
Everything should be correct before building works take place. Slowing design up is not a bad thing as will allow builders the ability to construct the project effectively with minimal defects and cost implications
Who is the right person to compile the Project Product Register?
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Lead designer
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Specialist engineer
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Someone else
Please expand on your answer.
All applicable parties should be involved where necessary
Recommendation 14: Documentation of Performance Solutions
Is this the right information to document Performance Solutions (see M14.1)?
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Yes
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No
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Maybe
Please expand on your answer.
This will increase costs but performance solution reports are only generally required when a design will not meet current legislation. It needs to achieve appropriate levels of consideration and it is then up to the building surveyor if what is proposed is acceptable and whether exemptions is necessary are acceptable
Is the information being required sufficient to enable a holistic assessment of the design?
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Yes
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No
Please expand on your answer.
There will always be necessity to make exemptions but the first approach is to always focus on legislation
Is the detail on where Performance Solutions (M14.4) have been used, and for what purpose, sufficient information to record on the occupancy certificate?
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Yes
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No
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Unsure
Please expand on your answer.
Performance solutions are only required when legislation is not achieved. Changes may need to be made and these solutions need to be justifiable
Recommendations 15 and 16: Approval During and After Construction
Is this the right process to address variations to the approved documentation (Table 12)?
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Yes
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No
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Maybe
Please expand on your answer.
Variations may be necessary after approval as some times discoveries are made on site which effect the original plan. Original submission need to take into account as much as possible even is site attendance is necessary.
Should all variations be documented and included in the occupancy certificate, regardless of whether they affect the compliance of the building?
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Yes
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No
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Maybe
Please expand on your answer.
Nobody keeps this information so any changes documented will never be seen. The VBA has no record on building permits other than the building permit number. This information is rarely available and when it can be located is often not applicable
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?
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Yes
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No
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Maybe
Please expand on your answer.
Unless a Building surveyor has approved the work, no building approval should be made. Notification should be made to prevent building surveyors signing of on work that does not meet code.
When approving variations to the building approval in constructed work (post-facto approvals) is the process sufficiently robust (M15/16.5 & 16.6)?
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Yes
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No
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Maybe
Please expand on your answer.
No system is perfect but something is always better than nothing. This should be released by a governing body yearly to find the correct balance.
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: 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: Not checked Maybe |
Please expand on your answer.
The regulator has no idea what is going on at the best of times and fails to understand what they are looking at. Having a report and reason for a list of non compliance is paramount.
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.
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Yes
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No
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Maybe
Other considerations
Are different actions required to implement the proposed measures for different project types?
| High level legislative principles Commercial buildings Radio button: Checked Commercial buildings | High level legislative principles Complex buildings Radio button: Not 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: 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: 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.
Commercial building are utilised by a significantly larger array of people meaning more diversity is applicable and therefore requiring additional consideration
Are there other actions to implement the proposed measures that should be considered?
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Yes
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No
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Maybe
Please expand on your answer.
Small steps help changes be addressed, too much too fast will lead to failures across the board
Do you have any other comments about the discussion paper?
Further comments
No