The ABCB Discussion Paper on the draft National Registration Framework for Building Practitioners (NRF) has developed a best practice model for adoption by state and territory governments that includes a wide range of professions that are involved in design, construction, compliance and coordination roles for the design and construction of buildings. The draft NRF includes Disability Access Designers.
The Discussion Paper is the first step in the process of developing a suitable model framework for parallel adoption by state and territory governments.
The draft National Registration Framework for Building Practitioners (NRF) has been developed in response to recommendations 1 and 2 of Building Confidence Report (BCR), authored by Sheargold & Weir which was endorsed by the Building Ministers Forum (BMF) in 2017.
Initially, the BCR focussed on the standard of construction of buildings and plumbing work. However, the scope of practitioners has expanded to include Disability Access Designers and Energy Efficiency following feedback from the Subject Matter Experts group.
The NRF covers core disciplines in the fields of building production (design, checking, construction and inspection) building approval (approval to build, approval to occupy) and coordination (project management). The NRF is based on registration categories, with specific disciplines within each category. Expert roles are included by endorsement within the appropriate discipline. Including:
|Building production||Design||Building design||Disability access design|
That each jurisdiction requires the registration of the following categories of building practitioners involved in the design, construction and maintenance of buildings:
- Site or Project Manager
- Building Surveyor
- Building Inspector
- Fire Safety Practitioner
That each jurisdiction prescribes consistent requirements for the registration of building practitioners including:
- certificated training which includes compulsory training on the operation and use of the NCC as it applies to each category of registration;
- additional competency and experience requirements;
- where it is available, compulsory insurance in the form of professional indemnity and/or warranty insurance together with financial viability requirements where appropriate; and
- evidence of practitioner integrity, based on an assessment of fit-and-proper person requirements.
The Discussion Paper covers a range of topics;
- Qualifications as described within the Australian Qualification Framework
- Experience of work history beyond initial attainment of a qualification
- Accreditation of suitable courses
- Qualified registration by categories for individual discipline and level
- Endorsements for specialist training and work experience
- Grandfathering – while grandfathering is outside the scope of the NRF it is envisaged that mutual recognition principles will cover this issue including recognition of prior learning (RPL). States and territories may utilise grandfathering during transition from a void in established systems to be suitable within the NRF.
- Mutual recognition of qualifications / registration of individuals for permitted work between state and territory governments is essential for a national framework.
- Industry Accreditation Schemes A number of industry bodies operate accreditation schemes that identify people who are competent to do work in specified disciplines or special areas of expertise. Such accreditation schemes can be referenced by states and territories, either as part of a legislated registration scheme or as a regulatory tool.
“To be both nationally effective and consistent, the NRF assumes each state and territory will reference industry accreditation schemes within the context of a legislated registration scheme. Legislation is necessary to ensure that the Mutual Recognition Act 1992 (Cwlth) applies consistently and to ensure that regulators have the necessary powers to investigate offences and disciplinary matters and to prosecute offenders.”
- Good character expectations the registration is limited to individuals who have not been convicted of any offence in any jurisdiction.
- Offences covers the necessity for individuals to work within their area of qualification and registration category.
Taxonomy and Scope of Permitted Work
The Discussion Paper is unclear as to what the precise scope of work for Disability Access Designers is as one section indicates Parts D, E, F, H of NCC volume 1 for building classes 2 to 9 that contain disability access requirements while another section specifies “all NCC Building classes”, which presumably is, and more aptly, classes 1 to 10.
The Taxonomy also notes that Disability Access Designers are permitted to provide performance solutions and deemed to satisfy access designs for all relevant buildings of any size.
The taxonomy matrix raises two issues;
- NCC training and approved NCC training which does not explain what approved NCC training consists of and who approves, delivers and awards competencies.
- 3 years experience with specifying whether it is full or part-time work as a Disability Access Designer/Consultant.
While ACAA has sponsored and assisted in the development of core competencies and AQF courses at certificate IV, diploma and post graduate diploma the registered Training Organisation (RTO) becomes the initial gatekeeper for entry into the Access Consultant workspace prior to obtaining ACAA membership at Associate or Accredited category with the later requiring a formal written test.
It is hoped that state and territory governments will start with ACAA system of qualification, including allied qualifications and specialist training combined with work history and continuous professional development program as a base for due recognition of Access Consultants (Disability Access Designer) within a NRF.
For my part the title of Disability Access Designer does not fully encompass Access Consulting and suggests we are designing for 20% of the population when the real aim is 100% in a universal and inclusive manner.
The Sheargold & Weir BCR also noted:
We have consistently heard that the adequacy of design documentation is generally poor and that, on occasion, builders improvise, making decisions on matters which affect safety without independent oversight. This exacerbates disputes about the quality and compliance of building work.
We have been told that oversight by licensing bodies, state and territory regulators and local governments can be weak due either to inadequate funding or a lack of skills and resources to undertake effective enforcement. We found that, until relatively recently, there has been almost no effective regulatory oversight of the commercial building industry by regulators. Those involved in high-rise construction have been left largely to their own devices. Where there has been supervision, this has generally been by private building surveyors whom critics argue are not independent from builders and/or designers.
The building and construction industry needs to actively participate in lifting standards, competency and integrity if it is to produce safe and reliable buildings and continue to be an important driver of infrastructure development and economic growth.
The Discussion Paper needs your input to ensure a best match between ideals, reality and practicality. Please respond to the ACAA member NRF survey and don’t miss the ACAA CPD Webinar on 30th July.
ACAA will be making a submission to the ABCB and individual members are encouraged to respond to the ABCB by using the online response form.
Responses to questions on the ACBC discussion paper, outlined in the consultation form, are invited until 11:59PM AEST Sunday 23 August 2020. Only comments submitted using the online form will be considered.
A complete set of the Discussion Paper and related documents can be found at here.
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