Discussion paper: National Registration Framework for Building Practitioners

Response 712180420

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Personal Information

What is your name?

Name
Caleb Smith

What is your organisation?

Organisation
Elenberg Fraser

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
Ticked Vic
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
Yes
Ticked No
Unsure
If No, please provide reasons and suggestions.
The relegation of architects to the same level as building designers is unacceptable. Architects are required to undertake lengthy education, training and registration process. The requirement to register as a building designer in addition to architectural register is a duplication of these requirements. The recommendations should identify architects as a separate and distinct to building designers. The recommendations should also mandate the use of a registered architect for all construction over a certain dollar value rather than simply building classification.

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
If No, please provide reasons and suggestions.
For various building practitioners who are currently not government by a professional board the registration process is critical. For practitioners such as architects who are already governed by a state board this measure is unnecessary. It is important to note that registration alone is not sufficient to lift professional standards.

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.
The are currently major variations between states when it comes to professional standards. Whether it be safety in design obligations through to CPD requirements, all items should be standardised across the country. Leaving implementation to individual states and territories will continue the current ad-hoc approach and undermine the ability to deliver meaningful reform.

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

Please select one item
Yes
Ticked No
Unsure
Please explain your reasoning.
Compliance with the NCC may be improved with the recommendations however it needs to be coupled with a comprehensive overhaul of design and construction contracts and their obligations. Frequently contractors substitute materials that do not comply but when challenged there is little recourse either to make good. To frequently the consultant is chastised for holding the line in regulatory requirements while contractors accept no responsibility for pushing through substandard outcomes.

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
Architects are not building designers. Provide separate category that recognises the extensive education, experience and examinations required to become a registered architect

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
Ticked No
Unsure
Please provide your reasoning.
The two categories are acceptable in principle but level 2 should be limited to class 1 and 10 buildings only. Class 2 to 9 buildings can be significantly more complex irrespective of floor area or height particularly with regard to life and fire safety requirements.