Response 599807714

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Personal Information

What is your name?

Name
Bruce Callow

What is your organisation?

Organisation
Director/principal architect Bruce Callow & Associates Pty Ltd since 1992, practising architect since 1972; former member of Architects Board of WA (ABWA) for 14 years, Chair for 7 years, former Council member of Architects Accreditation Council of Australia ( AACA) for 7 years and a director for 4 years; examiner for ABWA; assessor for acreditation and qualifications AACA.

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
Ticked Architecture and design
Engineering
Plumbing
Compliance, testing and accreditation
Legal and Finance
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
Vic
Ticked WA

On whose behalf are you making this submission?

Please select one item
(Required)
Ticked I am making this submission on my own behalf
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
Ticked Yes
No
Unsure

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
Ticked Yes
No
Unsure

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
Yes
Ticked No
Unsure
Please explain your reasoning.
Although refinement of some qualifications and appropriate registration processes for some building design practitioners and project management would be an improvement.

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

Please select one item
Ticked Yes
No
Unsure
Please explain your reasoning.
All building design practitioners, builders and project managers need to have an understanding and competence in the NCC.
Currently, with the advent of private Building Surveyors, there has been a trend or reliance by designers and builders that they don't have to be as knowledgeable and that Building Surveyors will be responsible for identifying non-compliance with the NCC.

The NRF will raise awareness in building design and construction practitioners of their responsibility to have better knowledge, understanding and application of the NCC.

NRF Discipline Specific Comments

Please provide your comments below.

Your comment relates to:
Please select one item
(Required)
Ticked Building design
Energy efficiency design
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
Registration levels
In addition to the two levels of registration indicated in the NRF for Building Design, consideration needs to be given to an additional higher registration level for projects that are of a complexity such that the involvement of the building designer is required throughout the whole design and construction of the project in the co-ordination of consultants, contract administration and project management roles to ensure that the integrity of the design and the requirements of the NCC are maintained and not compromised.
Descriptions/definitions
In the case of adding a higher level in the Building Design category, the description/definition needs to identify the complexity of projects and the necessity to have involvement of the designers in the construction process beyond just design, documentation and specifications. This will ensure the design integrity, construction details and materials are not altered or substituted without due process demonstrating an understanding and assessment of implications that might arise post-construction during the life of the building.
Scope of work
An architect's traditional role has encompassed complete involvement with a project involving design, documentation, contract administration and project management. Building designers more generally provide only a design and documentation role. Having an additional category for complex projects, particularly in classes 2-9 and multi-storey (above 3 storeys), would assist in overcoming the problem when project delivery is otherwise in the control of building and construction practitioners who are often more focused on time and cost delivery constraints. This has been demonstrated by recent events associated with failures in some significant and complex projects where structural integrity, design detailing and use of non-compliant materials, especially in regard to cladding and fire ratings have become evident. These have often been associated with projects delivered by a process tendered and controlled by builders and construction managers who become the arbiters for the extent to which the services and involvement of the building designers and technical consultants will be limited. This has allowed construction methods, construction details and materials to be compromised and/or substituted for pragmatic or cost priorities without proper process in the context of the NCC requirements and original design integrity. Accordingly, non-compliant outcomes have arisen that create immediate and/or ongoing problems in the life of the building related to say detailing, structural, water-proofing, finishes and materials. These issues can then become owners problems post construction after the builders have left the construction site or no longer operate.
Qualification requirements
Qualifications, registration and accreditation for architects is well established in Australia through state jurisdictions with Architects Acts and associated architects registration boards, together with a coordinating role through the AACA. This has established a uniform approach for architects qualifications and registration that has national consistency and mutual recognition with a process that has been recognised as as an exemplar for other professions.
This is not the case, or at least not to the same extent, for other building design practitioners, or technical consultant disciplines, where such a consistent national approach to registration is not as rigorous , or in many cases non-existent. Accordingly qualifications, accreditation and registration need to follow a similar course to establish the integrity for registration of all building design practitioners and technical/professional consultants.

In the case of establishing an additional category of Building Design Practitioners for complex projects the qualifications should require an accredited 5 year degree in architecture, or an accepted equivalent, and registration as as an architect. It should be noted that the requirement of a 5 year accredited architectural degree does not exclude other less qualified building designers with relevant experience, or with unaccredited overseas qualifications. This addressed by alternative pathways to registration facilitated by AACA through examination and assessment that are accepted by the Registration Boards in state jurisdictions.
Experience requirements
Meeting the the requirements of an accredited 5 year degree (or equivalent) and registration as an architect, automatically requires a minimum of 2 years post graduate experience across all categories of design, documentation, contract administration and management before registration.
Any other comments for this discipline
Whilst most of the above comments relate to whether a further category of Building Design Practitioner is justified, many of the points made are relevant to what is important about having the registration of all levels of building designers. This also supports Recommendations 1 & 2 of the NRF overall.
It should be noted that even for single residential and projects up to three storeys, it is equally important that qualified and registered building design practitioners are involved as much as they are for the suggested complex, multi-storey and high value class 2-9 projects. These larger projects are generally initiated by larger businesses, corporations, developers and government. As such they are experienced 'proprietors' who are more likely to take civil action against poor design practitioners and consultants if problems or defects are encountered. That said, some of the recent problems encountered are on projects where the 'proprieter' is also the developer and sometimes the builder. These present conflicts of interest in their own right that neither the BCR or the NRF address.
On the other hand, single houses in particular are for private individuals who are making the most significant, often once in a lifetime, investments using their their own money in one off projects. These are also the projects most often involving building designers who have minimal qualifications and no registration requirements. When things go wrong for these small time proprietors it is more devastating financially, more difficult to rectify defects and to call builders into account than it is for larger corporations and government who engage qualified consultants and may be involved in multiple projects for many millions of dollars.
Architect's Acts in the state jurisdictions are as much about consumer affairs as they are about qualifications, accreditation and registration. the difficulties encountered with smaller projects are the ones that most commonly the disciplinary matters come before Architects Registration Boards where the relationship between proprietors, designers and builders have broken down and civil action is not an affordable solution. Accordingly, the qualifications and registration requirements of building design practitioners in the class 1 and 10, and Class 2-9 up to 3 storeys is not to be underestimated or devalued. Proprietors at least have the registration boards to turn to with an architect's project, while clients of other buildng designers have no such option because there is no registration body, only consumer affairs or building tribunals if relevant to the problem. The BCR refers to not burdening these smaller proprietors with possible additional expense, but the cost burden should not be that significant and minimal compared to the problems that can be encountered through inexperienced or unqualified practitioners of both design and building construction. Recent inquiries into banks, financial institutions and financial planners have clearly identified how these small investors are more vulnerable and often the victims who are exploited and the least able to overcome the difficulties they have encountered with large companies or institutions. Having appropriately qualified and registered design and building practitioners involved to guide and manage these small projects, as well more the complex, can easily be justified as part of the NRF.

Would you like to comment on another discipline?

Please select one item
(Required)
Ticked Yes
No

NRF Discipline Specific Comments

Please provide your comments below.

Your comment relates to:
Please select one item
(Required)
Building design
Energy efficiency design
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
Ticked Project management
Registration levels
Project Management - Level 1 & 2.
Descriptions/definitions
Description/definition is satisfactory and encompasses traditional role of architects in tendering, contract administration and project management/co-ordination of consultants etc. Accordingly, registered architects should be included as qualified for the project management discipline.
Scope of work
The scope of work encompassing for project managers class 2-9 buildings in the NRF is satisfactory. However, project management can also have a role, and is generally part of the role undertaken by architects in class 1 buildings and this should also be recognised in the NRF. The consumer protection aspects of state Architects Acts provides protections for proprietors in class 1 projects by the traditional contract administration and project management roles of architects during construction. These services are not generally provided by other building designers, especially if their services are just limited to design and documentation.
Qualification requirements
Accredited architectural degrees and registration of architects requires competence in contract administration and project management. As such, qualified architects should be included in the Level 1 & 2 Project Management category/disciplines.
Experience requirements
Project managers need experience and qualifications in co-ordinating technical consultants (Building Design Engineers etc) and integration of their technical discipline within the design and construction process; they need detailed construction knowledge and experience, along with knowledge of project procurement, contract administration and project management. Many Project Management consultants have come through various pathways and aren't necessarily experienced in design, documentation, contract and construction matters. This inhibits their ability to properly identify problems during the design and construction process. Accordingly, project managers need appropriate qualifications, training, experience and registration to ensure that they play a relevant and useful role.
Any other comments for this discipline
Project Management is a traditional role of architects and it is embedded in their accredited architectural courses, qualifications and registration requirements. As such, registered architects and their qualifications should be automatically recognised as appropriate for both levels of project management in the NRF

Add another comment?

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
Ticked Yes
No
Unsure
Please provide your reasoning.
As a result of recent building failures on multi-storey and more complex projects, it appears that the Building Surveyors profession has has experienced crippling professional indemnity insurance premiums.
It is hoped that by having two levels of for building surveyors, those that want to limit their services to 'restricted buildings', will be able to be offered more reasonable insurance premiums that will make their services more affordable for smaller investors especially those in the class 1 category.

Are there any other matters you wish to comment on?

Comments
Architects registration through Architects Acts of the state jurisdictions have in practical terms simply protected the title 'architect' whilst at the same time prescribing quite stringent and specific requirements for qualifications, accreditation and registration. Despite the specific requirements of registration, there has been little of no specific or statutory role for registered architects recognised in former BCA or the NCC or in state building statutes or approval process related to design and construction.
Architects Boards and the AACA have established exemplary processes to achieve recognised standards of qualification, accreditation, registration and competency in the profession.
The BCR identifies, and the NRF provides, an opportunity to finally establish and define a statutory role for architects as the competent and qualified professional that they are and how they can contribute a specific role in the quality and control of the built environment in Australia.