Response 429530696

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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.
I don't believe a Building Design registration adequately captures the scope of services Disability Access Consultants are involved in, they're consultant not Designers, if they were involved in the formulation of design documentation then a Design/Architectural registration would be necessary as part of the Building Approval process. This would be inline with the current requirements for each state based Act/Regs.

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
No
Ticked Unsure
If No, please provide reasons and suggestions.
With regards to Disability Access Designers, It may provide face value confidence to non-industry individuals. But as currently proposed the NRF Paper may have a detriment on Accessibility Consultants who are experts in their filed but who have no desire to become a Building Designer. The proposal may inadvertently push these people out of the industry as other industry professionals may exclude them for not holding a Design Registration. I think the Building Designer is not suitable for the current scope of services that Disability Access Consultant provide. There needs to be clear separate between Designers and Consultants, for example between a Fire Safety Engineer and Fire Safety Designer.

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.
With regards to Disability Access Designers, I believe a clearer scope needs to be defined to the extent of their role. Otherwise I foresee a large portion of the access industry not being able to continue work with their current level Registration or Accreditation. Designers should be limited to design work only i.e. design documentation. For Consultation, Performance Solutions, Inspections, these should be captured under a separate Registration - Disability Access Consultant, much like the separation between between a Fire Safety Engineer and Fire Safety Designer. Once Consults, One designs.

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

Please select one item
Yes
No
Ticked Unsure
Please explain your reasoning.
Maybe. It is the first step in having building consultants more accountable for their actions, but a registration does not mean an individual understands the NCC or how to achieve compliance. This comes from education and ensuring the education to enable registration is aligned to that registration.

NRF Discipline Specific Comments

Please provide your comments below.

Your comment relates to:
Please select one item
(Required)
Building design
Energy efficiency design
Ticked 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
Disability Access Designer
Disability Access Consultant
Descriptions/definitions
Disability Access Designers are responsible for producing plans and documentation for building work that directly relate to Disability Access.

In some cases, these practitioners work closely with Disability Access Consultants to produce compliant designs and drawings that can help obtain building permits.

Disability Access Consultants play a key role in maintaining and improving movement and usability of buildings. They provide consultancy advice and develop solutions to meet the functional needs of people with disabilities. They help protect the safety and health of people in buildings and promote cost-effective construction.
Scope of work
Disability Access Designers are responsible for producing plans and documentation for building work that directly relate to Disability Access.

Disability Access Consultants provide consultancy advice and develop solutions to meet the functional needs of people with disabilities. They help protect the safety and health of people in buildings and promote cost-effective construction.
Qualification requirements
Disability Access Designers - As per the current proposal.

Disability Access Consultants - Diploma of Access Consulting, or Cert IV where the individual has undertaken a Diploma, Advanced Diploma or higher that involves BCA/Premises Standards training i.e. Advanced Diploma of Building Surveying.
Experience requirements
Disability Access Designers - As per the current proposal.

Disability Access Consultants - 3 years minimum industry experience.
Or 1.5 years where a the individual is registered in a Practitioner class that permits involvement with Disability Access i.e. Building Designer (Limited to those that allow designing of Disability Access), Building Surveyor, Building Inspector, Commercial Builder.
Any other comments for this discipline
-

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
No
Ticked Unsure
Please provide your reasoning.
This appears to be inline with the current Vic BS system.