Response 528070929

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Personal Information

What is your name?

Name
Cathryn Grant

What is your organisation?

Organisation
Architecture & Access (Aust) Pty Ltd

Which best describes your industry sector?

Which best describes your industry sector?
Please select one item
Building Commercial
Building Residential
Building Commercial and Residential
Building and plumbing products
Building Certification/ Surveying
Architecture and design
Engineering
Plumbing
Compliance, testing and accreditation
Legal and Finance
Ticked Specialist - disability access
Specialist - energy efficiency
Specialist - fire safety
Specialist - health
Specialist - hydraulic/ plumbing
Student/ apprentices
Trades and other construction services
Education
Community and Non-Government organisations
Government
General Public
Other

Please select your State or Territory

State or Territory
Please select one item
ACT
NSW
NT
Qld
SA
Tas
Ticked Vic
WA

On whose behalf are you making this submission?

Please select one item
(Required)
I am making this submission on my own behalf
Ticked I am making this submission on behalf of a business
I am making this submission on behalf of an industry body
I am making this submission on behalf of a government agency

General Questions

Does the proposed NRF deliver an appropriate and proportionate response to BCR Recommendations 1 and 2?

Please select one item
Yes
Ticked No
Unsure
If No, please provide reasons and suggestions.
With regards to Access Consulting , NO, our competencies and experience are not reflected in the NRF. Access Consultants are placed within the Endorsed Expert Building Designers category (page 16). Access Consultants are not designers, we do not design and document buildings. We review and provide advice on the design of new and existing buildings regarding access for people with disabilities based on Australian Standards, National Construction Code and consultation with users with disability. The use of the word and category of "Design"is misleading and could lead to confusion.

Will the NRF, if implemented, enhance confidence in the building industry by ensuring that key practitioners in the building process are registered?

Please select one item
Yes
Ticked No
Unsure
If No, please provide reasons and suggestions.
The NRF may improve perceived confidence in Access Consultants through registration but it will also lead to confusion, as our role is not to design but to consult and advise architects, designers and building owners on the requirements for access for people with disability . Having to gain our three years experience working under someone with a building designer of Level 1 or 2 will not equip new Access Consultants for their role. And should this requirement come in without significant "grandfathering" then there will be a significant shortage of Access Consultants in the industry.
Currently following completion of the Access Consulting Cert 4 and Diploma course to gain Accreditation status with the Association of Consultants in Access Australia (ACAA) a new consultant must gain experience but working under the supervision of an experience access consultant. This the best way to enhance confidence in the practice of Access Consultants.

Do you foresee any risks in implementing this proposal, noting that the states and territories are responsible for implementation of the NRF?

Please select one item
Ticked Yes
No
Unsure
Please explain your reasoning.
Yes there will be significant confusion within the industry by putting Access Consultants within a design category as this is not the role we currently perform. We do not design, we consult and provide advice pertaining to access for people with disability.

Access Consultants generally do not work in building design practices and to have to have 3 years supervision by a building designer would not work as currently most Access Consultants would work with other Access Consultants or in building surveying companies. Currently the industry is not structured to achieve this direct supervision.

Do you think the proposed NRF will improve compliance with the NCC?

Please select one item
Yes
Ticked No
Unsure
Please explain your reasoning.
No. With regards to Access Consulting we see that there will be greater confusion around our role as we do not operate as designers.

NRF Discipline Specific Comments

Please provide your comments below.

Your comment relates to:
Please select one item
(Required)
Building design
Energy efficiency design
Ticked Disability access design
Geotechnical design
Structural design
Electrical design
Mechanical design
Hydraulic design
Plumbing design
Fire safety design
Fire systems design
Façade design
Building
Fire systems installation
Plumbing
Building surveying
Fire systems inspection
Project management
Descriptions/definitions
Disability access designer does not reflect the services that Access Consultants provide. We do not design but evaluate and provide advice on design documentation pertaing to access for people with disability. Disability in the title is not appropriate and is out dated. Many people in the community have a wide range of needs including those that are old and frail, they may not consider themselves "disabled" but would benefit from contrast nosing strips. "Access" is a more positive term and "Consultant" represents the work that we do , consult. We review design documents and provide advice or consult. We also consult with users of buildings, people with a disability, building surveyors, architects/designers, builders, therapists and other professionals. The term "Access Consultant" is now widely understood and recognized, a deviation from this is not recommended.
Scope of work
No comment.
Qualification requirements
We would like to see the Diploma (AQF 5) as the minimum level and preferably a post-graduate course for Access Consultants.
Experience requirements
Access Consultants do not work in building design practices and the requirement to have 3 years supervision by a building designer is not appropriate as currently most Access Consultants would work with other Access Consultants or in building surveying/certifier companies. Currently the industry is not structured to achieve this direct supervision requirement.

The requirement for experience under a building design would also not equip access consultants for their role. Currently following completion of the Access Consulting Cert 4 and Diploma course to gain Accreditation status with the Association of Consultants in Access Australia (ACAA) a new consultant must gain experience but working under the supervision of an accredited access consultant. This the best way to enhance the practice of Access Consultants.

Would you like to comment on another discipline?

Please select one item
(Required)
Yes
Ticked No

Other Comments

The ABCB is specifically interested in your comments on the registration levels for building surveyors. Do you agree with the criteria used to distinguish between with the two levels of registration for building surveyors and does it adequately accommodate the different levels of risk?

Please select one item
Yes
No
Ticked Unsure