Response 988309909

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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
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
Ticked No
Unsure
If No, please provide reasons and suggestions.
I think confidence in the industry should be done by making it clearer to the public the difference between licensed and registered building practitioners (RBP) and the processes involved for a RBP to 'attain' registration and maintaining that registration.

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
Yes
Ticked No
Unsure
Please explain your reasoning.
"The purpose of the NRF is to achieve national consistency in the registration of building practitioners across the jurisdictions to achieve significant economic benefits, improve the efficiency of the registration process through options such as mutual recognition and enhance public confidence in the building industry."

However,
Alignment across the states and territory schemes make this a potential problem.
We need to recognise that building is not only a skill but is facilitated through knowledge of local conditions and of the familiariy of different trades working together. Direct mutual recognition may not be the answer but through a conversion test or inteview may be a qualifier in order to ensure the practitioner is completely aware of the local "ground knowledge". This will also prevent some looking for an "easier" local condition to qualify for the title of Registered Builder but using that qualification in another state which has a more stringent condition or robust testing mechanism for qualifying.

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 always read, studied or examined from a state perspective with many sections of the NCC having state based conditions. It falls back again to what the RBP has been trained and practiced regularly.

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
Ticked Building
Fire systems installation
Plumbing
Building surveying
Fire systems inspection
Project management
Registration levels
For a Registered Builder (unlimited), the minimum qualification for this title at any Level should be made to a Diploma at minimum. This would be more appropriate for the required working knowledge of a practicing builder. So for
the Level 3 - Limited/Residential does have a low bar which is not in line with one of the purposes of a NRF which is to instill public confidence.

The levels do obfuscate the qualification. It would be better not to use numbers but actual titles like Domestic or Commercial builder as is the case in VIC.

Further, the levels should have a defined pathway for builders in one level to obtain the relevant qualification for other levels.
If we recognise that commercial and domestic work are very different in scope, the opportunity for experienced builders in say Level 1 and Level 3 to move between levels or be registered in a number of said levels.

Of importance to clarify the Licensed and Registered builder definitions to the public. Much of the confidence in Building Practitioners really boils down to the education of the end consumer and making them aware of the qualifying of building practitioners. The industry is currently rich in manpower and people with desires of being registered builders. There is clearly no need to "lower the bar".
Descriptions/definitions
Rather than Builder (Individual), use Builder (Discipline).
Scope of work
Further to the point made in Registration Levels:
e.g. There is little difference nor additional requirements for a DB-U in VIC to be able to do CB-L (Non-structural Fitout) work but under the current qualifying system, there is no direct way to gain the required experience except through working for a CB-L or CB-U and attaining this 3 year experience.
Qualification requirements
For a Registered Builder (indivdual), the minimum qualification for this title at any Level should be made to a Diploma at minimum. This would be more appropriate. There is currently also problem with the system in VIC where the Diploma has NO pre-requisite so a person who has no working experience in the industry and NO Cert IV (seen as the logical pre-requisite) can sign up at a RTO/TAFE to undertake it. This renders the Cert IV redundant in a way and it places a large strain on teaching to bring a class of differing building experience to the same level. So with a rising number of interested parties looking to be licensed, real estate agents, mortgage brokers and conveyancing lawyers are all registering in VIC to do FREE TAFE and undertake a Diploma as their first qualification in Building & Construction. Often with little or no site experience. Making class based teaching difficult as they are mixed in with full time tradespeople who are following the normal route of Cert III, IV and Diploma. This needs to addressed with the training package developer: Artibus Innovation and Australian Skills Quality Authority (ASQA).
Experience requirements
For initial qualifiers, the three year experience should have clear demonstrated on site experience rather than a third party sign off being taken as proof. A logbook system may be a more comprehensive measure.

For those attempting to move between levels, a new three year experience is not practical for a practicing builder in either level. How does a practicing builder in one level (say a VIC DB-U) spend 3 years working for a CB-L (Non-structural Fit Out) so as to qualify for a Commercial License? I believe an alternative needs to be proposed for registered builders moving between levels.
Any other comments for this discipline
None.

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.
If we are to split the builders into 3 levels, by recognising that the work and skills needed are very different, surely it shoudl follow for Building Surveyors that the day to day checks they carry out should follow these three levels. Though, L1 & L2 titles for the Building surveyors seem to follow the VBA standards of BS-U and BS-L

Are there any other matters you wish to comment on?

Comments
I disagree with this:
"Builder work is primarily a coordination function. Trades doing construction or installation work are not required to be registered as a builder (individual)"

This is a very simplistic view of a builder.
Many trades go on to be very acomplished builders because of their experiences as working tradespeople ad the ability to much of the work themselves.
The Builder (Discipline) needs to be established which will enable these trades to transition through to the equivalent of a DB-U level.