Discussion paper: National Registration Framework for Building Practitioners

Response 541203915

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Personal Information

What is your name?

Name
Moshe Gilovitz

What is your organisation?

Organisation
Moshe Gilovitz Architect

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
Vic
Ticked 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
Ticked Yes
No
Unsure

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

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.
There are many barriers to the implementation of such a framework. These include political and ideological issues, market supply and demand issues, grand-fathering and transition issues. The idea has merit but may not be deliverable.

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

Please select one item
Yes
No
Ticked Unsure
Please explain your reasoning.
Most of the parties to be regulated in the framework are already regulated in some jurisdictions. NSW is an exception. Do we have evidence that present frameworks are influencing NCC compliance across jurisdictions? We have potential for a controlled study before we expend regulation. The main benefit of the framework is that it will help regulators find a responsible person and hold them accountable when something goes wrong.

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
This sounds OK but it is actually just an intuitive extension of the framework for building surveyors/certifiers. If we ar to have registration levels, then i would like to know why, and what is the evidentiary basis for those particular levels. in the absence of that I prefer just a single level.
Descriptions/definitions
-
Scope of work
Once again, just an extension of the way we currently think about building surveyors. No real analysis of the work is given.
Qualification requirements
-
Experience requirements
I do not support the idea that a graduate must work for an employer for x years and then that person is good.
Experience should only be required where there is a demonstrated need for the specific competencies that are to be gained by experience and not classroom learning. If there is to be an experience requirement, even six months, that should be supported by a statement of what is to be gained from experience and a method for recording and confirming that gain. There needs to be clarity about the value of undergraduate and post-graduate experience, and about the value of experience in self-employment.

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 is essentially the current framework. This framework has some meritorious connection to the fire safety requirements of the NCC. It has the merit that a person can enter the industry and work at Level 2, while studying to obtain Level 1 qualification.

However, there may be other arrangements of levels that are better suited to the future industry. We need to do some analysis of risk and the industry of the future. We could also look at market factors, supply and demand od practitioners and the implications of this framework for the supply of training.