Personal Information
3. What is your name?
Name
(Required)
Peter Douglass
5. On whose behalf are you making this submission?
On whose behalf are you making this submission?
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I am making this submission on my own behalf
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I am making this submission on behalf of a business
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I am making this submission on behalf of an industry body
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I am making this submission on behalf of a government agency
6. What is your organisation (if relevant)?
Organisation
Private consulting structural engineer
7. Which best describes your industry sector?
Which best describes your industry sector?
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Building Commercial
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Building Residential
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Building Commercial and Residential
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Building and plumbing products
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Building Certification/Surveying
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Architecture and design
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Engineering
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Plumbing
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Compliance, testing and accreditation
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Legal and Finance
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Specialist - disability access
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Specialist - energy efficiency
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Specialist - fire safety
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Specialist - health
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Specialist - hydraulic/plumbing
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Student/apprentices
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Trades and other construction services
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Education
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Community and Non-Government organisations
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Government
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General Public
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Other
8. Please select your state or territory
State or Territory
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ACT
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NSW
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NT
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Qld
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SA
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Tas
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Vic
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WA
9. If you work in the building industry, in which state or territory do you undertake the most work?
which state or territory do you undertake the most work?
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ACT
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NSW
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NT
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Qld
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SA
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Tas
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Vic
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WA
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NA - I do not work in the building industry
Mandatory inspections
10. What are your views on the definition proposed for mandatory inspections?
What are your views on the definition proposed for mandatory inspections?
My views on the above are as follows:
1. Mandatory inspection for assessment of compliance of building work should be undertaken at stages of construction as nominated by the designer on the design and/or construction drawings.
2. Mandatory inspection for assessment of compliance of building work should be undertaken, in person, by the responsible senior member of the structural/mechanical/electrical/civil engineering components of the building works being undertaken.
3. Mandatory inspection for assessment of compliance of building work should be undertaken at the appropriate sequence time of construction before the subjects of inspection are covered over by the following stages of construction are undertaken.
1. Mandatory inspection for assessment of compliance of building work should be undertaken at stages of construction as nominated by the designer on the design and/or construction drawings.
2. Mandatory inspection for assessment of compliance of building work should be undertaken, in person, by the responsible senior member of the structural/mechanical/electrical/civil engineering components of the building works being undertaken.
3. Mandatory inspection for assessment of compliance of building work should be undertaken at the appropriate sequence time of construction before the subjects of inspection are covered over by the following stages of construction are undertaken.
11. What are your views on the definition proposed for Certificate of Compliance?
Views on Certificate of Compliance?
My views on the above are as follows:
1. The phrase "prescribed person" should be replaced with "responsible senior member of the structural/mechanical/electrical/civil engineering components of the building works being undertaken".
1. The phrase "prescribed person" should be replaced with "responsible senior member of the structural/mechanical/electrical/civil engineering components of the building works being undertaken".
12. Do you agree the risk based model is the correct approach to identify the types of mandatory inspections for a building?
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Yes
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No
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Maybe
If no/maybe, what is an alternative approach to determine the types of mandatory inspections for a building? (Note: each complexity level prescribes minimum mandatory inspections to be carried out.)
An alternative approach would be to require the engineering component design team to nominate the particular components to be inspected during the progress of construction and prior to "building in" of the respective components.
Determining minimum mandatory inspections
13. Should there be minimum mandatory inspections for commercial buildings or should it be determined at the discretion of the statutory building surveyor?
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Minimum mandatory inspections
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Discretion of the statutory building surveyor
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Other
Please expand on your answer.
With all due respect to building surveyors, such personnel should not, and can not, be expected to know which particular components of a building are critical to ensure compliance with the design/construction drawings and the designers' engineering philosophy for the manner in which the building is to react to given load actions.
Knowledge of the role played by any particular engineering component of a building is specifically designed by the respective design team.
A building surveyor has no fore-knowledge of the designers' philosophy applied to the design of a particular building.
Knowledge of the role played by any particular engineering component of a building is specifically designed by the respective design team.
A building surveyor has no fore-knowledge of the designers' philosophy applied to the design of a particular building.
14. Do you agree on the list of mandatory inspections for each building complexity (BC) level? Are there any other inspections that need to be included as part of this list of minimum mandatory inspections?
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Yes - agree with the list
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No - changes needed
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Maybe
If no/maybe, how should the list be changed?
In my opinion, it is not realistic or practical to expect the construction industry to interpret a published list of minimum mandatory inspections and apply the listed items appropriately to a particular building design.
Such a list is too vague and open to misinterpretation by persons having little training and knowledge of the consequences of incorrect selection.
Hence, the concept of such a "list of minimum mandatory inspections" should be discarded.
My above responses to items 10. 11, 12 and 13 would favour the designers' notification on the design drawings/documents of the particular building components to be inspected, leaving no opportunity for misinterpretation.
Such a list is too vague and open to misinterpretation by persons having little training and knowledge of the consequences of incorrect selection.
Hence, the concept of such a "list of minimum mandatory inspections" should be discarded.
My above responses to items 10. 11, 12 and 13 would favour the designers' notification on the design drawings/documents of the particular building components to be inspected, leaving no opportunity for misinterpretation.
15. Do you think all the parts of the fire safety systems have been identified for minimum mandatory inspections?
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Yes
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No
If no, please provide the additional fire safety inspections you would include.
The fire safety inspections should be as nominated on the fire safety design/construction drawings/documentation by the responsible senior fire safety officer of the particular design team for the building to be constructed.
Are there other critical fire safety inspections or tests that you would include in the list?
Please refer to my response to above item 15.
Who conducts the inspections
16. Who do you believe is competent to conduct the inspections?
Appointed statutory building surveyor Very Low Checkbox: Checked Very Low | Appointed statutory building surveyor Low Checkbox: Not checked Low | Appointed statutory building surveyor Medium Checkbox: Not checked Medium | Appointed statutory building surveyor High Checkbox: Not checked High | Appointed statutory building surveyor Very High Checkbox: Not checked Very High |
Independent building surveyor Very Low Checkbox: Checked Very Low | Independent building surveyor Low Checkbox: Not checked Low | Independent building surveyor Medium Checkbox: Not checked Medium | Independent building surveyor High Checkbox: Not checked High | Independent building surveyor Very High Checkbox: Not checked Very High |
Independent designer and/or consultant Very Low Checkbox: Not checked Very Low | Independent designer and/or consultant Low Checkbox: Checked Low | Independent designer and/or consultant Medium Checkbox: Not checked Medium | Independent designer and/or consultant High Checkbox: Not checked High | Independent designer and/or consultant Very High Checkbox: Not checked Very High |
Designer who participated in the building design Very Low Checkbox: Not checked Very Low | Designer who participated in the building design Low Checkbox: Not checked Low | Designer who participated in the building design Medium Checkbox: Not checked Medium | Designer who participated in the building design High Checkbox: Not checked High | Designer who participated in the building design Very High Checkbox: Checked Very High |
Fire systems installers Very Low Checkbox: Checked Very Low | Fire systems installers Low Checkbox: Not checked Low | Fire systems installers Medium Checkbox: Not checked Medium | Fire systems installers High Checkbox: Not checked High | Fire systems installers Very High Checkbox: Not checked Very High |
17. Who do you think is best placed to determine notification stages (timing of inspections)?
Appointed statutory building surveyor Very Low Checkbox: Checked Very Low | Appointed statutory building surveyor Low Checkbox: Not checked Low | Appointed statutory building surveyor Medium Checkbox: Not checked Medium | Appointed statutory building surveyor High Checkbox: Not checked High | Appointed statutory building surveyor Very High Checkbox: Not checked Very High |
Independent building surveyor Very Low Checkbox: Checked Very Low | Independent building surveyor Low Checkbox: Not checked Low | Independent building surveyor Medium Checkbox: Not checked Medium | Independent building surveyor High Checkbox: Not checked High | Independent building surveyor Very High Checkbox: Not checked Very High |
Independent designer and/or consultant Very Low Checkbox: Not checked Very Low | Independent designer and/or consultant Low Checkbox: Checked Low | Independent designer and/or consultant Medium Checkbox: Not checked Medium | Independent designer and/or consultant High Checkbox: Not checked High | Independent designer and/or consultant Very High Checkbox: Not checked Very High |
Designer who participated in the building design Very Low Checkbox: Not checked Very Low | Designer who participated in the building design Low Checkbox: Not checked Low | Designer who participated in the building design Medium Checkbox: Not checked Medium | Designer who participated in the building design High Checkbox: Not checked High | Designer who participated in the building design Very High Checkbox: Checked Very High |
Fire systems installers Very Low Checkbox: Checked Very Low | Fire systems installers Low Checkbox: Not checked Low | Fire systems installers Medium Checkbox: Not checked Medium | Fire systems installers High Checkbox: Not checked High | Fire systems installers Very High Checkbox: Not checked Very High |
What percentage of the construction is inspected
18. What percentage of the building construction should be inspected for different BC levels?
0-50% of the building construction Very Low Checkbox: Checked Very Low | 0-50% of the building construction Low Checkbox: Not checked Low | 0-50% of the building construction Medium Checkbox: Not checked Medium | 0-50% of the building construction High Checkbox: Not checked High | 0-50% of the building construction Very High Checkbox: Not checked Very High |
100% of the building construction Very Low Checkbox: Checked Very Low | 100% of the building construction Low Checkbox: Not checked Low | 100% of the building construction Medium Checkbox: Not checked Medium | 100% of the building construction High Checkbox: Not checked High | 100% of the building construction Very High Checkbox: Not checked Very High |
Statutory building surveyor can exercise judgement on how much of the building construction must be inspected Very Low Checkbox: Checked Very Low | Statutory building surveyor can exercise judgement on how much of the building construction must be inspected Low Checkbox: Not checked Low | Statutory building surveyor can exercise judgement on how much of the building construction must be inspected Medium Checkbox: Not checked Medium | Statutory building surveyor can exercise judgement on how much of the building construction must be inspected High Checkbox: Not checked High | Statutory building surveyor can exercise judgement on how much of the building construction must be inspected Very High Checkbox: Not checked Very High |
Designer prescribes the percentage of inspection as a guideline for the statutory building surveyor Very Low Checkbox: Not checked Very Low | Designer prescribes the percentage of inspection as a guideline for the statutory building surveyor Low Checkbox: Not checked Low | Designer prescribes the percentage of inspection as a guideline for the statutory building surveyor Medium Checkbox: Not checked Medium | Designer prescribes the percentage of inspection as a guideline for the statutory building surveyor High Checkbox: Not checked High | Designer prescribes the percentage of inspection as a guideline for the statutory building surveyor Very High Checkbox: Checked Very High |
19. Should there be guidance on determining the percentage that must be followed?
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Yes
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No
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Unsure
If yes, please specify and for which BC level.
Any concept involving a "sliding scale of percentage" for inspection building components is totally inappropriate and should be abandoned.
20. Do you think there are elements where there needs to be multiple inspections for the same element?
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Yes
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No
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Unsure
What happens in the event of non-compliance
21. Does the proposed approach address all the issues related to mandatory inspections?
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Yes
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No
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Maybe
If No/maybe, what items are missing to ensure mandatory inspections are compliant and meets the requirements of BCR Recommendation 18?
Please refer my responses to items 10, 11, 12 and 13.
Other considerations
22. Do you have any further comments?
Additional comments
If the committee does not require the notification and site inspection of nominated building components during construction by the senior responsible design engineer for the respective field of endeavour, then the root cause of the issue has not ben understood.
It would also be required that such compliance inspections should be undertaken personally by the senior responsible designer whether the original design office may be located intrastate or interstate within Australia or from elsewhere overseas.
The use of a proxy representative should not be allowed.
It would also be required that such compliance inspections should be undertaken personally by the senior responsible designer whether the original design office may be located intrastate or interstate within Australia or from elsewhere overseas.
The use of a proxy representative should not be allowed.