Discussion paper: National Registration Framework for Building Practitioners

The framework is an excellent first step but doesn't address the requirements of the BCR that relate to ongoing maintenance of buildings.

FPA Australia recommends that as a minimum categories for routine service, repair and replacement and annual assessment are added to the framework. In addition, consideration should be given to the inclusion of emergency planning as part of the annual fire safety health check for all buildings.

FPA Australia has developed a comprehensive framework for the accreditation of practitioners across the full gamut of the fire protection industry from planning approval through to building occupation and ongoing safety. This is known as the Fire Protection Accreditation Scheme.

Aspects of the Scheme were recently gazetted by the NSW government as part of that jurisdictions co-regulatory model. The NSW Government have advised that further recognition of other aspects of the Scheme will be rolled out.

The Scheme has evolved over many years. It was first conceived in 2013. This has included extensive consultation with industry, government, fire agencies and building owners and their representatives. FPA Australia considers that the FPAS Scheme should be used as the model to support the NRF.

Furthermore, FPA Australia encourages the ABCB to consider engaging FPA Australia to further develop the fire protection aspects of the NRF, based on our extensive work already undertaken.

There is a desperate need for a nationally consistent framework that recognises the full suite of occupations involved in the construction and post occupation of buildings.

There is a risk that the required qualifications to support the NRF do not eventuate or fail to meet the required standards. Part of the consideration of the implementation should include the ABCB and states and territories also embracing the development of qualifications to support the NRF.

In the fire protection space, this has not occurred with significant enhancement to national training packages either being held up or not approved for development, despite numerous enquiries and reports recommending development.

There is a need for the development of training and qualifications to be taken out of the hands of the education bureaucrats and given either to industry or to the ABCB or similar body with accountability for the development and quality assurance of fire protection qualifications.

The other main risk is in relation to implementation. Having developed schemes to recognise industries where there has traditionally not been such systems, FPA Australia is acutely aware that there is a lot of work and consideration that needs to be given to a transitional implementation that embraces the relevant industry partners.

Aspects of the NRF are perhaps somewhat "aspirational", which is fully supported by the Association, however we feel that there also needs to be a clear implementaion roadmap to support the achievement of the ultimate goal.

Further education and accountability will result in improved compliance. Whilst not referenced in the NRF, the need for practitioners to be accountable and hold Professional Indemnity insurance should be considered as part of the implementation

Fire systems design work is NOT engineering work. It is based on the application of prescribed standards.

There is a requirement for a quasi performance level to be created, however this is not traditionally undertake by fire safety engineers.

It is proposed to create a level to specifically cater for practitioners who exercise judgement when designing a specific fire system that cannot meet the requirements of the prescribed standard.

This type of work can include things such as the location of systems or equipment or the hydraulic performance requirements.

This work is not generally performed by fire safety engineers, rather it is often referred to fire services for approval.

Creation of this level mirrors the requirement of the Victorian Building Regulations that permit a building surveyor to determine compliance of a performance solution only where they hold a specific qualification in addition to their building surveying qualification.

In this case the designer is required to hold the entry level fire safety engineering qualification as well as be a competent fire systems designer before being able to sign off on quasi performance solutions that are unique and specific to an individual fire safety system.

FPA Australia believes the establishment of this category will support industry and create a pragmatic pathway for the approval of performance solutions specific to an individual fire system

Change definition to:
Fire systems design work means technical design work of a specific fire safety system based on the application of a prescriptive standard. Technical design work includes design, checking, peer review and signing certificates of compliance

Please refer to attached document. Industry feedback has indicated that there needs to be separation between fire sprinklers and fire hydrants / hose reels as well as separate levels for minor design work associated with tenancy fit out and minor repairs / replacement work where such work requires building approval.

There is also a requirement for Non-DtS systems to be approved by designers.

Irrespective of the qualifications held for the various levels, it is important that an approved skill set should be included that is based on relevant units of competency from the Diploma of Fire Systems Design. Fire Safety Engineers do not generally have the skills to design fire systems

Please refer to the attached marked up review of the NRF Taxonomy document. We have used this document to identify the changes required across all disciplines and have provided our comments within that document.

Please refer to attached submission

Change the definition as follows:

Fire systems installation work means the construction, installation and commissioning testing of any part of a system or piece of equipment used for the detection, suppression or control of fire or to protect building occupants in the event of a fire .

As this discipline sits under the Construction part of the framework, all references to activities that are post construction should be removed.

Allowance is provided for an individual eligible for this discipline to achieve a registration for undertaking post construction activities (repair, replacement, routine servicing) by referencing the same qualifications under the relevant discipline in the post construction section of the framework as recommended by FPA Australia (See below)

In particular it is critically important that routine service is clearly removed from construction based activities

There is an entire separate industry that primarily undertakes routine service of fire protection systems and lumping this cohort of people into an installation category will result in significant upheaval across the fire protection industry.

Please ensure that relevant fire protection installation and where necessary design knowledge is included as part of any qualification referenced for installation categories.

It is recommended that various skill sets be created for each type of relevant fire system which would need to be completed by persons with non fire specific trade qualifications (plumbing, electrical, security, building) in order to apply for these categories.

For example a person with a plumbing qualification, should undertake further training specific to fire sprinkler systems and fire hydrant / hose reel systems to be eligible for this category. Similarly, a qualified electrician should undertake a required skill set from the Certificate III in Fire Protection Control to undertake fire specific installation work.

For further comments and suggested changes please refer to the marked up copy of the taxonomy document

Preference is for this discipline to be referred to as Fire Systems Certification.

The role is to certify, after reviewing reports, test result and having conducted an inspection that the required design has been complied with.

The certification would them be relied on by a building surveyor as part of considering whether the building is fit for occupation.

The role would also apply where major repair or replacement works where carried out that triggered the need for building approval.

Suggest change of definition as follows:

Fire systems certification work means the independent certification to verify compliance with the approved design of any part of a system or piece of equipment used for the detection, suppression or control of fire or to protect building occupants in the event of a fire. Certification work may result from any construction, installation, replacement, repair, alteration, routine servicing or maintenance activity.

Please find attached the holistic FPAS framework. This document forms part of our overall submission and not specifically to this discipline, however I couldn't find a way to upload multiple documents.

FPA Australia supports the establishment of multiple levels for building surveyors to ensure that building complexity is considered.

Please find attached a copy of the Fire Protection Accreditation Scheme Framework. This highlights the structure of the FPAS scheme and how it relates to the various stages of building approval and building occupation. We strongly encourage the NRF to reflect this model as much as possible.

Our experience in rolling out accreditation schemes has demonstrated that there is often more granularity that originally perceived. This is particularly important when implementing registration / accreditation / licensing to a cohort of individuals who have not traditionally been subject to registration and importantly where there is no accepted standard for the qualifications required to perform a specific role.

As an example, the roll out of FPAS in NSW for the category of Fire Systems Design was required to introduce restricted categories, rather than have a single category for each type of fire system. For example the initial roll out included categories that aligned with the regulatory framework and covered fire sprinkler systems, fire hydrant and hose reel systems and fire detection and alarm systems.

Pressure from industry and a realisation that pragmatically this structure was problematic resulted in sub categories (restricted registration) being created. This resulted in the original three categories becoming 10 categories. This is the type of granularity that is probably required at implementation stage as part of a transitional model. Some of these sub categories can be joined together in the future once the industry embraces the model and undertakes further training and qualifications.

FPA Australia is a strong advocate for the co-regulatory model adopted in NSW. Industry is best placed to understand the technical challenges and develop the framework to meet requirements with a strong regulatory oversight from government that demonstrates commitment and need.