Discussion paper: National Registration Framework for Building Practitioners

The registration of practitioners does not guarantee that additional due diligence will be undertaken. The lengthy qualification processes for individual disciplines will result in a similar approach to what is currently happening in the industry. Which typically is:
- Junior staff and intermediates undertake design works, and
- Directors (or qualified staff) sign off on the work.
This still presents a risk element as issues can still often get missed (ie, coordination element are not overtly apparent when reviewing plans)

I also note that small businesses and sole operators who do not undertake complex design works will be forced out of the industry.

Yes, maintaining that concise training can be provided specific to NCC interpretation and implementation.
I don't believe that by merely introducing registration of practitioners will necessarily correlate to NCC understanding and compliance. Many registrations (CPeng for instance) do not focus on NCC understanding currently.

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ref: NRF Registration Framework for Building Practitioners (NRFBP) page: 81

The permitted work set out in the NRFBP does not specifically list any fire hydrant or hose reel design for plumbing designers. It is noted that currently this is almost exclusively completed by plumbing and hydraulic designers in the ACT and NSW.

The scope of work able to be performed by a registered plumbing technical designer is disproportionate to the training undertaken. The hydraulic services design diploma is tailored to all aspects of hydraulic design which includes the following subjects:

Create and use spreadsheets
Produce simple word processing documents
Create and use databases 
Write complex documents
Read and interpret plans and specifications
Apply codes and standards to building trade and services contracting
Produce 2-D architectural drawings using CAD software 
Prepare simple sketches & drawings
Design complex sanitary plumbing and drainage systems
Design complex cold water systems
Design complex stormwater and roof drainage systems
Design complex (non-solar) heated water systems
Design and size sanitary drainage systems
Design and size stormwater drainage systems
Design and size domestic treatment plan disposal systems
Design residential and domestic fire sprinkler systems
Design and size consumer gas installations
Design gas bulk storage systems
Design industrial gas systems
Design gas reticulation systems
Design solar water heating systems
Conduct a water audit and identify water-saving initiatives
Design grey water re-use systems in sewered areas
Design rainwater collection, storage, distribution and re-use systems
Design trade waste pre-treatment systems
Design pump systems
Design siphonic stormwater drainage systems
Design and size sanitary pipework and fixtures
Design and size heated and cold water services and systems
Define scope and hazard level of fire systems design projects
Create detailed designs for hydrant and hose reel systems
Design fire sprinkler systems (elective)
Inspect plumbing and drainage systems (elective)
Develop workplace policies and procedures for sustainability (elective)
(course overview is attached to this commentary for reference).

Noting the above, it seems unreasonable that a person who has studied civil, mechanical, chemical or electrical engineering is able to design fire hydrant and fire hose reel systems (ref: NRFBP page 93, 94 - Water based firefighting and fire suppression designer), while a student of the hydraulic design services course is not.

Hydrant and fire hose reel systems are a fundamental part of hydraulic and plumbing design, as the principles of flow and pressure analysis are a key element of what we do. This coupled with our day to day use of the National Construction Code for elements such as damp proofing, energy usage (section J) and the Plumbing Code of Australia (NCC part 3), mean that we are well versed in interpreting and applying the NCC.

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I'd just really like to reiterate that hydraulic and plumbing design is a unique discipline with content that is not covered by any other tertiary courses. The knowledge provided in both the Diploma and Certificate 4 is concise and tailored to our trade.

I would implore you to speak with training operators running these courses such as Tafe NSW and Tafe QLD before finalising the registration requirements to fully understand the capability of their students, and the content of their courses.

Thank you for considering this commentary.