Discussion paper: National Registration Framework for Building Practitioners

We wish to question the appropriateness of the minimum education requirement for licensed building surveyors to be AQF 8. This requirement exceeds the existing requirement of AQF 7. We note that selected programs currently accredited by the AIBS—of which this framework has recognised its list of accredited academic courses—would no longer be sufficient for the purposes of being able to obtain a licence. This far exceeds the requirements internationally and would significantly impact the ability for any overseas trained professional to work in Australia. It would unfairly force experienced professionals to enrol onto advanced programs in Australia to become qualified. We haven’t been able to determine any reason why the education requirement has been increased, nor has any justification been advanced by this document, so would question its necessity.

Recommendation
• Reduce the minimum qualification requirement from AQF 8 to AQF to 7.

The draft NRF confuses the title of ‘Building Surveyor’ with the separate and distinct statutory role and function of a practitioner qualified and licensed to assess building work against relevant standards for the purpose of issuing approvals (certificates), otherwise known as a Building Controller or Building Certifier.

We support the definitions of building surveyor for levels 1 and 2 in the draft along with the recommended scope and limitations of work according to the licences. This support is only on the basis however that by ‘Building Surveying’ the framework means ‘Building Control’, ‘Building Certification’ or similar.

We therefore note the conflation of the title ‘Building Surveying’ with the role and function of a professional qualified in building control or building certification.

Confusion is being caused across the construction sector, and across states, by liberal use of nomenclature to describe the statutory role of practitioners undertaking the specific and limited function of building certification. These practitioners are sometimes referred to as ‘building surveyors’ in Australia. This is out of step with global use of ‘building surveyor’ which is reserved for a professional with broader competencies.

A globally recognised ‘Building Surveyor’ is competent to undertake a wide range of roles typically with a different risk profile to a building certifier, including: building surveys and measured surveys; analysing design and building defects; preparing strategies for asset management and property maintenance; preparing insurance valuations and claims; preparing strategic property advice and landlord and tenant advice; project management and development monitoring; accessibility and energy audits; specialist surveys (asbestos, damp etc.); conservation advice and sustainability advice.

Recommendation
• Review the nomenclature used to describe the role of a building certifiers in Australia and have regard for international and critical differentiation between building certification and building surveying.

The ‘Chartered Surveyor’ qualification is recognised as the equivalent to a variety of national qualifications in the EU (see directive 2005/36/EC) thus allowing Chartered Surveyors to move between national borders but remain professionally qualified.

We note there is no recognition of international degrees, diplomas and other professional qualifications on the AIBS approved degrees register for the purposes of seeking equivalency to level 1. As is stands, internationally qualified building certifiers are not given any equivalency or mutual recognition of their qualifications when applying for level.

We strongly argue that candidates with overseas credentials should have their academic and professional qualifications assessed for equivalency to the AQF. To assist governments, RICS is happy to extend its services in assessing such qualifications given its general capability and greater experience in international ‘building surveying’ programs.

Recommendation
• Embed a process that allows international qualifications to be assessed for equivalency, and that RICS be responsible for managing this process.

RICS is an Accreditation Standards Body in South Australia and Queensland. In these states:
a. Chartered Surveyors (Building Control) are considered degree equivalent for level 1 licensing requirements; and
b. Associate Surveyors (Building Control) are recognised as degree equivalent for level 2 licensing requirements.

Chartered Surveyors (Building Control) have at minimum a bachelor’s degree, and at least two years of supervised experience culminating in a rigorous written assessment and one-hour interview in front of three trained Chartered Surveyors acting as assessors. RICS assessment processes are at least the equivalent to the existing assessment processes for certifiers nationally.

Associate Surveyors (Building Control) will have at least a diploma to AQF 5 (more often 6) and at least 2 years of experience and are required to complete a written assessment that is assessed by two Chartered Surveyors (Building Control). Regrettably, these qualifications are not recognised in Australia in the building surveying profession, and we strongly argue that they should be.

Recommendation
• Recognise Chartered Surveyors (Building Control) as equivalent to level 1 licensed certifiers for national consistency.
• Recognise Associate Surveyors (Building Control) as level 2 (and 3) licensed certifiers.

As we understand it, the definition presumes experience only obtained in Australia and not overseas. It is counter-productive and largely unnecessary to expect overseas qualified professionals to have to obtain a further three years of experience before they can be licensed in Australia. Indeed, RICS already recognises up to two years of overseas experience for obtaining a licence in SA and Qld. Candidates applying for level 1 or 2 licensing need a minimum of 12 months experience in Australia as a result. The relevant state authorities have endorsed this position.

RICS agrees it is vital that any building surveyor seeking a licence in Australia must have the appropriate experience in the country but asking anyone who comes to Australia to do an additional 3 years supervised work is needlessly onerous, particularly if you already a Chartered Surveyor.

As the largest built environment professional body in the world, with a significant operation in Australia, we again would be more than happy to offer our services in determining experience and qualification equivalency on behalf of the relevant state authorities.

Recommendation
• Recognise overseas experience to count for a maximum of two of the minimum three years of experience required to become a licensed level 1 certifier in Australia.
• Recognise overseas experience to count for a maximum of one of the minimum two years of experience required to become a licensed level 2 certifier in Australia.
• Authorise RICS to be the professional body to determine and approve international experience as relevant to level 1 and 2 requirements in Australia.

A number of States and Territories currently define the experience requirements for the accreditation of building certifiers based on the National Accreditation Framework (NAF). The NAF is in need of a major review as it is both outdated and written originally as a guide for universities to prepare their course curricula, not as a document defining the post qualification competencies required of practising professionals. RICS believes the experience required of building certifiers should be updated and defined as competences, as in the ability to perform a task at a specific level. RICS would be happy to be involved in this review.

Recommendation
• Review the National Accreditation Framework so that it is up to date and competency based.

We agree with the registration levels proposed but will note in the qualifications subheading an inconsistency that has emerged that needs a review.

We agree with the definitions provided for registered project managers at level 1 and 2, along with the scope and limitations of work for each level.

We note a potential inconsistency with the minimum education requirement that conflicts with the requirements in the registration levels subheading. The latter requires a credential to at least AQF 7, while the qualifications sub-heading listed an “advanced diploma” as sufficient. An advanced diploma is AQF 6. This needs to be reviewed. For the record, RICS would support AQF 7 level qualifications as the minimum education requirement.

Recommendation
• Conduct a review to ensure consistency in the minimum education requirements for level 1 licensed project managers.

There is no discussion about professional qualifications obtained either in Australia or internationally being given any opportunity for equivalency for professionals that may not have degrees. We would also strongly encourage offering automatic recognition to any Chartered Surveyors (Project Management) being automatically recognised as a Registered project manager to level 1, and our Associate RICS Project Managers to level 2.

RICS accredits project management programs at institutions in Australia and across the world and as such we have a deep understanding of the profession beyond Australian shores and the equivalency of qualifications to Australian qualifications.

Recommendation
• Recognise relevant overseas qualifications to be recognised as equivalent to qualifications needed to become a level 1 or 2 registered project manager in Australia.
• Authorise RICS to be the professional body to determine and approve qualifications as relevant to level 1 and 2 requirements in Australia.

The concept of a project management qualification at tertiary institutions in Australia is relatively new (in fact RICS accredits undergraduate project management degrees at UTS and RMIT), and as such project managers working in the built environment tend to have construction management, quantity surveying or building surveying qualifications. We would recommend that any determination of “relevant qualification” would include those qualifications as relevant to becoming a registered project manager.

Recommendation
• Approve qualifications in construction management, quantity surveying and building surveying at AQF 7 (or higher) as relevant qualifications for the purposes of becoming a registered project manager.

We support what is being proposed for both level 1 and 2 but would again note that there is no indication that overseas educated and practiced professionals have the recourse to seek any equivalency or mutual recognition of experience.

Recommendation
• Recognise relevant overseas experience to be recognised as equivalent to experience needed to become a level 1 or 2 project manager in Australia.
• Authorise RICS to assess and determine international experience extensive experience and knowledge in the requirements of the project management professions given its capability and experience in assessing international qualifications.

The definition of 'building surveying' applied in the draft NRF is misleading and requires considered review together with the National Accreditation Framework. For the category of work referred to loosely by the draft NRF as 'building surveying', the intention of the draft NRF is to develop a framework for 'building certifiers' or 'building controllers.' These individuals have particular competencies and statutory function that are not the same as the internationally recognised definition of building surveying.

This unnecessary confusion must be resolved.

A Chartered Surveyor qualified in the true specialism of Building Surveying — typically a building pathology expert undertaking technical due diligence of buildings post occupancy — has attained specific competencies that are quite distinct from Building Control.

A holistic approach to risk is required to maximise consumer protections. This means, at least, a competency based approach to assessing the skill and experience of any individual and a rigorous assessment process before awarding any qualification or registration.

So as a start, recognising the distinction between Building Control (or building certification) and Building Surveying as established by the competencies of an international professional qualification would be a big step forward.