Response 818373439

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Personal information

What is your name?

Name
Craig Lovel

On whose behalf are you making this submission?

Please select one item
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

What is your organisation (if relevant)?

Organisation
Australian Modern Building Alliance

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
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

Please select one item
ACT
NSW
NT
Qld
SA
Tas
Vic
WA

Preferred Terms

1. Do you agree with the definitions for the preferred terms detailed in the discussion paper Glossary?

If not, what preferred term/s do you disagree with and why? How should they be changed?
Agree. No need to also refer to "or material". Product is sufficient

Element 1 – NCC evidence of suitability requirements

2. Do you agree with the description of the issues relating to the NCC Evidence of Suitability provisions? Are there other issues to be considered?

Please provide detail.
Generally agree. AMBA agrees with ACBC that measures implemented should apply to all building products, not just those that are “high risk ”. The Grenfell enquiry demonstrates risk understanding is not always common.

3. Do you agree with the proposal to set minimum and consistent information requirements across each evidence of suitability pathway (Proposal 1.A)?

Please provide detail.
agree

4. Do you agree with the proposed changes to increase the rigour across each evidence of suitability pathway? (Proposal 1.B)

Please provide detail.
AMBA agrees with strengthening certifications for products and better controls for accrediting bodies. Ideally based on local testing and approvals rather than carry overs from international tests that invariably are slightly different.
AMBA agrees with ABCB proposed changes to regulatory impact statement

5. If any, what are the issues with requiring a statutory declaration being provided as part of another form of documentary evidence (Proposal 1.B)?

Please provide detail.
AMBA does not agree with the use of Stat Dec's from qualified persons. As cosigning requirements unwieldy. A form such as used in California for Insulation - form CEC-CFZR-ENV-03-E would be suitable. Does require listing of the signee's registration number so presumes there are list of registered practitioners.

6. Please provide feedback on the further comprehensive changes to the evidence of suitability that are proposed (Proposal 1.C), including other changes that should be considered.

Please comment.
As noted introducing a hierarchy has significant potential for unintended consequences. This should not be implemented lightly.
There will be suppliers that will wish to game the system and take the lowest level.

Separation of design and product. Agree
Rigorous requirements for life safety items and less rigorous for other products. Disagree
Restrict certification bodies to minimum type 3 ????
New pathway for specific industry conformance scheme Agree
New pathway to allow appraisal schemes such as ATEN and BRANZ. Agree
Establish a Technical Advisory Group to review high risk components where there is no existing standard Agree

7. Are the proposed changes to the Evidence of suitability handbook appropriate? (Proposal 1.D) Are there other changes that will improve its usefulness?

Please provide detail.
Agree.
Need to include guidelines for the trained installers as well.

Element 2 – Information obligations for manufacturers and suppliers

8. Are the identified challenges with establishing product conformity accurately detailed, and are there other challenges that should be considered?

Please provide detail.
Yes

9. If any, what are the issues with respect to the availability of building product information that should be addressed?

Please list.
Should include suitable applications for the product and limitations, installation instructions, and intended use with other products or systems .

10. In relation to Proposal 2.A, please select a preference.

Please select one item
I agree with the proposal to require “all products intended to be associated with a building” be accompanied by a mandatory minimum level of information.
The requirement be broadened to “could reasonably be used in a building”.
The requirement should be limited to products intended to be used in higher risk applications, such as structural and fire related applications.
Other
If other, please provide detail.
With adequate lead time all products should be able to comply with the minimum level of information. Energy efficiency and ventilation are critical to the health and safety of the occupants.

11. Do you agree that the required information should be based on the example provided by Product Technical Statements? If no, what would be the right information? (Proposal 2.A)

Please provide detail.
Yes the Product Technical Statement is the appropriate document. Ensuring information from different sources is in the same format is essential for comparisons.

12. Have all the costs to manufacturers and suppliers from requiring Product Technical Statements been considered? (Proposal 2.A)

Please select one item
Agree with costs as described
Disagree with costs for manufacturers
Disagree with costs for suppliers
Disagree with costs for manufacturers and suppliers
Unsure
Why?
benefits should outweigh the costs

13. Is there value in facilitating the development of industry conformance schemes (Proposal 2.B)? Are there additional services these schemes could offer that would support compliance?

Please provide detail.
Agree with the development of industry schemes, guidelines and training.

14. In relation to the proposal for minimum product conformance assessment for certain manufactured building products (Proposal 2.C), please select a response.

Please select one item
I agree with the proposal for minimum product conformance assessment for certain manufactured building products
There are additional triggers that should be considered
There are additional assessment paths to determine conformance
Other
Please provide comment to support your selected response
National approach preferred.

Element 3- Product labelling and traceability

15. Do you agree that there is a need for improved product labelling and/or traceability?

Why?
Yes. Fiberglass Insulation has labelling requirements in the standard. PIR and phenolic IB are all preprinted. Spray polyurethane foam or beads blown into walls more difficult to label. This is where a detailed check sheet such as used in California is needed. Or an upload into a building "passport" of the product technical.

16. What are the gaps/shortcomings in the existing labelling requirements? If any, what are the particular products or, classes of products that need priority attention?

Please provide detail.
Insulation labelling not properly addressed. Stapling to a roof joist possible. Better to have spec sheet included in building passport along with the signed off check sheet.
Note the problems of packaged materials verses products to which a label can be applied and products where application is machine mixing and sprayed on into place

17. Do you support mandating labelling requirements in accordance with Standards Australia Technical Specification 5344:2019 across building product standards (Proposal 3.A)?

Why?
Agree.

18. What opportunities are available with digital technologies to enhance building product traceability (Proposal 3.B)?

Please list.
Note the work of CSIRO and the CRC (Building 4.0) on digital labelling

19. What else can be done to improve product labelling and traceability? Are there examples where it is being done well?

Please provide detail.
not sure

20. The options under consideration in this part would require regulatory impact assessment, and that cost would be offset against current costs to rectify problems with some products. With that in mind, do you have information that might help point to the costs or benefits involved?

Please provide detail.
n/a

Element 4- Research, surveillance and information sharing

21. If anything, what is needed to improve research, surveillance and information sharing across the product assurance system?

Please provide detail.
Agree. There should be a coordinated national system in regard to non-conforming product.

22. Will the tasks listed in Proposal 4.A help achieve improved oversight and coordination of the product assurance system? What additional tasks should be considered?

Please provide detail.
Agree with proposals A - J.

23. Is there value in having a central information portal and, if so, what information should it contain (Proposal 4.B)?

Please provide detail.
Yes agree

24. What additional guidance and training would assist with ensuring that products are appropriately supplied and specified (Proposal 4.C)?

Please list.
As per Insulation Installation road map comprehensive guidelines and training urgently needed. Ideally from installers industry body rather than an individual supplier.

Element 5- Compliance and enforcement

25. Do you agree with the description of the current compliance and enforcement regime?

Please provide detail.
Agree .
this is also a recommendation from the Insulation Installation roadmap. Random audits.

26. Do you support additional enforcement on the supply of building products (Proposals 5.A & 5.B)? Do you see any barriers to their implementation?

Please provide detail.
Supported.
Need conformity across all jurisdictions
Construction is a national industry and for suppliers of goods and services to the building industry to have different legislated requirements in different states is not practical.
We would not support Building surveyors making random inspections of factories and warehouses which is proposed.
Building regulators can have this power but not surveyors. If a surveyor suspects a problem, he should arrange for a building regulator to accompany them to factory or warehouse.
If there is a problem with a product or certificate the surveyor under mandatory reporting should notify the regulator and appropriate action should be taken by the regulator not the building surveyor.
The Building Surveyor is welcome to go to site and sample the product not to factory and warehouse.

27. Are there any other measures that would improve enforcement and compliance of building products?

Please list.
Process for reporting of concerns from the general public or other building suppliers to the Building regulator for investigation.

28. Are there any final comments that you have on the scope and implementation of a National Building Product Assurance Framework?

Please comment.
Regarding insulation harmonizing with the Insulation installation roadmap as presented to Vic & NSW governments for implementation according to the timelines set there.