Response 353778886

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Personal Information

What is your name?

Name
Conrad Harrison

What is your organisation?

Organisation
MiScion 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
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
Ticked Other

Please select your State or Territory

State or Territory
Please select one item
ACT
NSW
NT
Qld
Ticked SA
Tas
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.
Engineers Australia signed 3 international accords: the Washington Accord, the Sydney Accord and the Dublin Accord. A degree compliant with the Washington Accord is part of the problem not the solution. A degree compliant with the Washington Accord is meant to produce a graduate who can tackle problems for which there is no prior art and no established body of technical science. A graduate with a with a degree compliant with the Sydney accord is meant to be conversant with the prior art and technical science of established technologies, and to be able to adapt them to suit specific purposes. Buildings have a few thousand years of prior art and the science of mechanics is at least 100 years old. Engineers Originate, Technologist Adapt and Technicians Apply.

It is not acceptable to rely on industry to impart the necessary knowledge of the established technologies. Grenfell towers, Lacrosse Tower, Opal Towers, Mascot towers are all indicative of a failure throughout the entire supply chain for people NOT to be fully conversant with established technologies and required quality characteristics to produce quality robust design.

Limiting structural design to civil engineers is also not acceptable. Mechanics comes from mechanical engineering. Ditch digging mud waddling civil engineers shouldn't be permitted any where near structures. And there are no degrees in structural engineering.

A 4 year degree in architectural engineering provides a clue. One year technical science. 1 year of structural systems. 1 year of mechanical systems. 1 year of electrical systems. In short a bundle of 3 AQF-6 qualifications with a common AQF-5 in technical science and mathematics.

Properly educate people in the established technologies. There is no engineering involved, so stop referring to engineering calculations and engineers reports.

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.
Engineers Australia's members are already seen by many people in the industry as less than competent. not the least of which they design things which cannot be built or place people at risk of injury during fabrication and construction. They have poor design skills.

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, with practice limited to MIEAust CP.Eng, There will be a spike in defects, in consequential injuries and deaths. Engineers Australia doesn't care. If CP.Eng is the best we have and they are technically incompetent, then we need to make the assessment criteria more rigorous. Probably increasing education from 4 years of abstract, esoteric irrelevance to 5 years. Numbers decrease, supply becomes short supply, fees increase, Engineers Australia achieves its objective. But defective design will remain, until focus on the established technologies and the body of technical science which real engineers have spent the past 100 years or more developing. There are no real technical problems, as a society we know the solutions, they are just not being implemented properrly.

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

Please select one item
Yes
Ticked No
Unsure
Please explain your reasoning.
The NCC is deficient. It mostly relies on performance criteria for spaces to determine the performance criteria of the buildings frame and fabric. It has very little reference to the component parts and systems of a building. Further there are many things in the built environment, especially structures which are not habitable buildings, and not bridges and otherwise not suitable for classification as class 10 buildings.

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
Ticked 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
Should acknowledge the full range of the Australia Qualification framework (AQF), and all three of the WFEO international accords: Washington accord, Sydney accord, and Dublin accord.

Building are an established technology. They should be designed by persons fully conversant with technology, and that person is meant to be a graduate with a degree compliant with the Sydney accord, not the Washington accord. The Washington accord is to create graduates who can solve problems not yet solved, create technologies not yet invented.

Further more the AQF requires increase in depth of knowledge as move from one level to the next, not an increase in breadth of knowledge. Most professional degrees are little more than bundles of AQF-6 qualifications and no where near acceptable as AQF-7 or AQF-8 qualifications: this is just elitist inflation.

Some projects may have unique features which require engineering, but most involve adaption of established technology to suit specific purpose making use of established principles. No need to build prototypes, verify or calibrate theory. We expect to design and prove concept by calculation.
Descriptions/definitions
Engineer: That for which there is no prior art or established technical science. 5 year M.Eng. Only required for unique and unusual features.

Technologist: Adapt established technologies based on established body of technical science to suit specific purpose. Bring the work of engineers into the main stream. 3 year bachelor degree.

Associate Technologist: Main stream designer. Adapting established technologies based on established body of technical science to suit specific purpose. 2 year associate degree.
Scope of work
Associate Technologists do the bulk of design work. Technologists review and approve, and design that which is less frequently employed. Engineers only called in if there are unusual features for which there is no established body of technical science.
Qualification requirements
Associate Technologists: 2 year Associate Degree.
Technologists: 3 year Bachelor Degree
Engineers: Bolgna Process: 3 year Bachelor, followed by 2 year Masters. (masters covering national standards and general practice is not an acceptable masters programme)
Experience requirements
For all a minimum of 5 years experience under the supervision of suitably qualified persons with at least 20 years experience.

Alternatively a dynamically adaptive system, of Approved Persons (AP). Only AP's are permitted to submit documentation for regulatory approval. All existing practitioners automatically registered as AP's. Work which generates too many requests for further information attracts demerits. Too many demerits and loose AP status. Can still produce work, and supply services, but work has to be reviewed by an AP before can be submitted to regulatory authority.
Any other comments for this discipline
There is no existing degree in structural engineering or structural technologies. Graduates either have degrees in civil engineering or mechanical engineering, as design of structures is dependent on mechanics. Whilst a building has a structure, a structure doesn't have to be a building. There are also machine structures and non-machine structures. A building structure is a locked mechanism. Whilst a machine is a structure which moves. There are all kinds of structures in the built environment, and many of those dumped into the category of class 10, are better designed by graduates of mechanical engineering than civil engineering. But in any case the real requirements are about becoming conversant with the technology being designed and adapted. Whist a rafter and floor beam, crane jib and drive shaft are all beams. It is necessary to be conversant with the characteristics of the specific technology if the beam is to be designed to be fit-for-function. As far as I know civil engineers are not taught design, and rely on architects for design: whilst mechanical practitioners are designers.

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 levels are adequate with respect to the NCC/BCA classifications, but development approval encompasses all items in the built environment, and often anything not seen as a building is lumped into class 10. Building surveying technicians are not adequately qualified to properly assess anything and everything classified as class 10 building, and neither are building surveyors. So a level above Level 1, is needed.

Are there any other matters you wish to comment on?

Comments
The qualification framework for building surveyors is part of the problem. Previously building surveyors had qualifications in either architecture or engineering: they had some experience with design and the fundamental science used to verify design. Building surveyors now appear to be some form or low level lawyer, with little technical competence and blindly adhering to silly rules which may cause more hazard than good when applied without proper understanding of the technical origin.

Too many councils only employ building surveying technicians and outsource to private certifiers. This can cause conflict with respect to distribution of development approval fees. For example sending people off to pay for Regulation 88 certificates, when development approval fees are meant to pay for such assessment in first place. By doing this the council keeps a greater portion of the approval fee as don't have to send out to private certifiers as the building surveying technician can approve based on the Reg 88 certificate.