Discussion paper: National Registration Framework for Building Practitioners

Not even sure regarding these two recommendations, as their already is a licensing scheme in place for plumbing practitioners in most if not all states. It almost appears that the recommendations were specifically made for unlicensed building categories of which plumbing is not therefore should be excluded from the paper.

Key practitioners are already registered in Victoria for a number of classes of pluming and some building categories. Has this enhanced confidence in the building industry? The very fact this question is asked / considered answered that question. This may work for certain building trades that are not currently licensed / registered however will make no difference in my opinion for trades that are already licensed / registered and therefore regulated.

The current Plumbing Regulations 2018 in Victoria adequately detail and prescribe all plumbing classes within the state of Victoria. The proposed plumbing classes listed within the NRF are in my opinion not comprehensive enough to capture the full scope of plumbing work as listed within the National Construction Code Volume Three Plumbing Code of Australia.

This will lead to the risk of consumers being left further confused in an already complex subject, when it comes to other classes of plumbing work not listed within the NFR and other plumbing categories listed within the Plumbing Regulations. Furthermore, it appears implementation will still be left with the state and territory regulator which in this instance is the VBA. The VBA would need to implement 2 differing streams of licensing concurrently, one being the categories listed within the NRF and the second being all other plumbing classes such as gasfitting, roofing, HVAC and Fire Protection.

The paper fails to address the fact that in Victoria by way of example Plumbing and a plumbing apprenticeship captures a greater scope of works than just water, sanitary and drainage. How will this look moving forward in way of apprentice training?

The same individuals carrying out work to the NCC will still be carrying out the same type of work in the same manner, the only thing that the proposed NRF will do is introduce further confusion within licensing and registration of plumbing practitioners. The improvement of compliance with the NCC lies the responsibility of the relevant State and Territory regulator as they implement the entire scheme. To improve compliance is not to add regulatory burden but rather to simplify the current requirements.

Unfortunately compliance will always be left second to profits and unless the regulator implements tough compliance checks (inspections and audits) with substantial ramification for failure to comply. Industry has and will continue to put profits before compliance unless checked.

Registration is already present in most if not all State and Territories.

Definitions of plumbing is captured within the Plumbing Regulations 2018 in Victoria.

Scope of plumbing work is adequately captured within the Plumbing Regulations 2018 in Victoria.

Qualification requirements of plumbing is captured within the Plumbing Regulations 2018 in Victoria.

Experience requirements for plumbing is captured within the Plumbing Regulations 2018 in Victoria.

Whilst the system may not necessarily be perfect the current regulatory regime appears to be completing its regulatory function in Victoria.