Response 819506178

Back to Response listing

Personal Information

What is your name?

Name
Stuart Smith

What is your organisation?

Organisation
WebFM Pty Ltd

Which best describes your industry sector?

Which best describes your industry sector?
Please select one item
Building Commercial
Building Residential
Ticked 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
Other

Please select your State or Territory

State or Territory
Please select one item
ACT
Ticked NSW
NT
Qld
SA
Tas
Vic
WA

On whose behalf are you making this submission?

Please select one item
(Required)
I am making this submission on my own behalf
Ticked 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.
The current NRF has omitted the major category of Maintenance which is required under the BCR. The BCR recommended registration of those involved in design, build and maintain. Owners need confidence that the suppliers are suitable and competent to maintain the complex systems on a new building.

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.
The NRF has omitted a large number of disciplines that have critical responsibilities for the design, build and maintain functions. Also the NRF as proposed in complex and therefore difficult to implement. If the Registration Framework is to be successful it needs to be simplified.

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.
The NRF by defining only a limited number of disciplines creates a risk that other critical disciplines are omitted.

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

Please select one item
Ticked Yes
No
Unsure
Please explain your reasoning.
The NRF is a sound concept and in particular the requirement for training in NCC requirements. This will improve the overall industry knowledge and delivery of services. However by excluding a large number of disciplines the outcome will be partial and not a holistic solution.

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
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
Ticked Project management
Registration levels
These comments are not related to a specific discipline as it would be two cumbersome and repetitive. The attached report provides an overview of our comments and recommendations covering all of the NRF and the 17 disciplines.

In summary
- The category of Maintainer is missing from the NRF

- The category of Project Co-ordination is unnecessary as this is a duplication of the Builder role. The risk is that the client may need to hold registration for a role that is not responsible for NCC compliance yet has an accountability that is unclear. The only roles applicable to compliance within the NCC are Designer, Constructor, Maintainer and Certifier.

- The limitation of only defining nominated disciplines reduces the effectiveness of ensuring owner confidence in the whole building. Eg Lift Engineers, Interior Designers, Safe Access Systems all have critical roles in fire and life safety of a new building.
Descriptions/definitions
See attached report
Scope of work
See attached report
Qualification requirements
In general qualification requirements should be left to the current standards set out by other educational authorities based on their particular role and competency.
Experience requirements
Please refer to the attached report
Any other comments for this discipline
Please refer to the attached report

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 NRF would benefit from a simplified and consistent registration level across all disciplines. The 3 levels shown for Builder, 1 Open/Commercial, 2 Restricted/Commercial, 3 Residential offer a simple approach based on type, complexity and risk of works. This should be applied to all disciplines including Designers, Constructors, Maintainers and Certifiers.

Are there any other matters you wish to comment on?

Comments
Please refer to our report (attached)