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Decision Regulation Impact Statement i
Decision Regulation Impact Statement i
Proposal for national licensing of the plumbing and gasfitting occupations i
Proposal for national licensing of the plumbing and gasfitting occupations i
Table of contents iii
Table of contents iii
About this Decision Regulation Impact Statement x
About this Decision Regulation Impact Statement x
Summary of options considered in this Decision Regulation Impact Statement xi
Summary of options considered in this Decision Regulation Impact Statement xi
Quantified impacts for the national licensing options xii
Executive summary xiii
Executive summary xiii
Purpose of the Decision Regulation Impact Statement xiii
Purpose of the Decision Regulation Impact Statement xiii
The problem xiii
The problem xiii
Government objectives for reform xiv
Government objectives for reform xiv
Options considered xv
Options considered xv
Preferred option xv
Preferred option xv
Overview of alternative options to national licensing xvi
Overview of alternative options to national licensing xvi
Automatic Mutual Recognition xvi
Status quo xvii
Factors in determining preferred national licensing option xvii
Factors in determining preferred national licensing option xvii
the licence categories that should apply xix
the regulated work that can be undertaken by the holder of a licence category xix
who can apply for a licence (e.g. individual or body corporate) xix
skilled and non-skilled eligibility requirements (e.g. qualifications, personal and financial probity) xix
other licence characteristics (e.g. exemptions or exclusions) xix
National licensing – costs and benefits xxi
National licensing – costs and benefits xxi
Impacts for licensees xxiv
Impacts for business and consumers xxiv
Safety and consumer outcomes xxv
Impacts for government xxv
Additional wider economic impacts xxvi
Consultation process and outcomes xxvi
Consultation process and outcomes xxvi
Other features of national licensing xxviii
Other features of national licensing xxviii
Fees xxviii
Licence period xxviii
Responsibilities of the national authority and jurisdictional regulators xxx
Conclusion/Recommendation xxxi
Conclusion/Recommendation xxxi
General policy context 1
General policy context 1
1.1 The Occupational Licensing National Law Act 2010 2
Options for reform 4
Options for reform 4
1.2 Options considered 4
1.3 Preferred option - requirements 5
1.4 ‘Preferred’ national licensing option – Three tier sub-option 2 5
Consultation feedback 8
1.5 Automatic mutual recognition 9
Existing Mutual Recognition Arrangements 9
Automatic mutual recognition – unharmonised approach 9
Consultation 11
Conclusion 11
National licensing – overview of preferred option 12
National licensing – overview of preferred option 12
1.6 Preferred option -Three tier, sub-option 2 - overview 12
Proposed categories of regulated work 12
The proposed national licensing categories across the jurisdictions 13
Proposed regulated work 15
Endorsements 17
Nominees 18
Exemptions 18
Limited exemptions 19
Non-skills-based eligibility requirements 19
Relevant person 19
Proposed personal probity eligibility requirements 20
Proposed financial probity requirements 22
Qualification-based eligibility requirements 24
Plumbing and services – Operations stream elective 25
Common compulsory units: 25
Plumbing and services – Operations stream core 25
OR 26
Common compulsory units: 26
Plumbing and services – Operations stream electives: 26
Common compulsory units: 26
OR 28
Experience requirements 28
Additional testing 29
Skills maintenance (continuing professional development) 29
Licence period 29
1.7 Rationale for proposed national licensing elements 29
Proposed categories of regulated work 29
Proposed regulated work 41
Endorsements 45
Nominees 49
Exemptions 51
Limited exemptions 52
Non-skills-based eligibility requirements 53
Qualification-based eligibility requirements 55
Qualification requirements for preferred option 55
Experience requirements 62
Additional testing 63
Skills maintenance (continuing professional development) 64
Licence period 65
1.8 Transitional arrangements 66
Deeming of current licence holders 66
Administrative transactions that were initiated before national licensing begins 66
Disciplinary and court processes and actions 67
Transitioning suspended licensees 67
3.3.5 Transitioning disqualified licensees and cancelled licences 67
Eligibility for those who initiated training before national licensing begins 67
Eligibility for those who completed training before national licensing begins 67
Lapsed licences 68
Current trainees for a restricted licence 68
Consultation 68
Impact analysis 69
Impact analysis 69
1.9 Transition and implementation costs of a national licensing system 69
Cost to plumbing and gasfitting licensees 69
Cost to business and consumers 70
Costs to government 70
1.10 Direct costs and benefits of national licensing 74
Labour mobility 74
Removal of multiple licences held across jurisdictions 77
Flexible licence periods 79
Licence tiers and qualification requirements 80
Reducing the costs of regulatory requirements 88
Costs imposed by new requirements 91
Business value-add 93
National Occupational Licensing Authority – ongoing operational costs 94
Potential changes in government revenue 95
Potential benefits to governments from simplified administrative arrangements 95
Other impacts that have not been quantified 98
1.11 Impact on consumer outcomes 103
Potential safety impacts 103
Consumer protection impacts 105
1.12 Comparing the impacts for licensees working in single and multiple jurisdictions 106
1.13 Wider economic impacts on the Australian economy 108
The shock to the model – the scenario modelled for this Regulatory Impact Statement 109
Key results 109
1.14 Sensitivity testing of key assumptions 113
Alternative licence period 113
Net present value assumptions 114
Cost and benefits of the automatic mutual recognition option 116
Summary of the costs and benefits of national licensing by jurisdiction 121
Consultation 129
Consultation 129
1.15 Public information sessions 129
1.16 Feedback on Consultation RIS and draft legislation 130
1.17 National Occupational Licensing Authority (NOLA) 130
1.18 Submission Summary 131
1.19 Overview of selected stakeholder positions 132
Conclusion and recommendation 135
Conclusion and recommendation 135
1.20 Recommendation 135
1.21 Overview of the proposed national licensing approach to the plumbing and gasfitting occupations 136
Licence categories 136
Scope of regulated work 136
Endorsements 139
Nominees 139
Exemptions 139
Non-skill-based eligibility requirements 140
Qualification-based eligibility requirements 142
OR 142
Plumbing and services – Operations stream elective 143
Common compulsory units: 143
Plumbing and services – Operation stream core 143
OR 143
Common compulsory units: 143
Plumbing and services – Operations stream electives: 143
PLUS 144
Completion of the unit of competency CPCPGS4023A Install, commission and service Type B gas appliances 144
Common compulsory units: 144
OR 146
Experience requirements 146
Additional testing 146
Licence period 146
Implementation 147
Implementation 147
1.22 Implementation of national licensing 147
1.23 Key steps in implementation 148
Notification of national licence(s) 148
Issuing of new national licence documentation 148
1.24 Communication strategy for national licensing 149
1.25 Review 150
Attachment A Overview of the sector and existing licence requirements 151
Attachment A Overview of the sector and existing licence requirements 151
Overview of the plumbing and gasfitting sector 151
Overview of the plumbing and gasfitting sector 151
Regulatory framework 153
Regulatory framework 153
Overview of existing licensing requirements 154
Overview of existing licensing requirements 154
Plumbing work 154
Water (supply) plumbing work 155
Sanitary plumbing 155
Drainage work 156
Fire protection 156
Mechanical services 156
Gasfitting 156
Gasfitting Type B 157
Attachment B – List of submissions 158
Attachment B – List of submissions 158
Attachment C – National licensing policy development process 182
Attachment C – National licensing policy development process 182
Attachment D – Risks associated with plumbing and gasfitting work 187
Attachment D – Risks associated with plumbing and gasfitting work 187
Sub-option 2 – How proposed Certificate IV units address risks 191
Sub-option 2 – How proposed Certificate IV units address risks 191
Attachment E – Key changes to existing jurisdictional licensing arrangements 197
Attachment E – Key changes to existing jurisdictional licensing arrangements 197
New South Wales 197
New South Wales 197
Victoria 203
Victoria 203
Queensland 210
Queensland 210
Western Australia 218
Western Australia 218
South Australia 224
South Australia 224
Tasmania 231
Tasmania 231
Australian Capital Territory 237
Australian Capital Territory 237
Northern Territory 243
Northern Territory 243
Comparison of Certificate IV – current and three tier approach 249
Comparison of Certificate IV – current and three tier approach 249
Plumber 249
Drainer 252
Fire protection 254
General gasfitter 254
Gasfitter Type B 257
Mechanical services 257
Attachment F – Regulated work – definition of terms 260
Attachment F – Regulated work – definition of terms 260
Attachment G – Approach to impact analysis 265
Attachment G – Approach to impact analysis 265
Approach to the impact analysis – calculations and method 265
Approach to the impact analysis – calculations and method 265
Calculations used in the cost–benefit analysis 265
Calculations used in the cost–benefit analysis 265
The status quo 265
Calculating the present value of yearly impacts 266
Method underlying the computable general equilibrium modelling 277
Method underlying the computable general equilibrium modelling 277
Overview of the modelling 277
Limitations of the modelling 279
The shock to the model 280
Calculating an increase in efficiency of labour in plumbing and gasfitting services 281
Calculating an increase in capital efficiency 281
Calculating a decrease in government fees 281
Calculating changes to government expenditure 281
Inputs and assumptions underlying the analysis 282
Assumptions in the cost–benefit analysis 282
Assumptions in the cost–benefit analysis 282
Real discount rate 282
Evaluation period 282
Wage rate 283
Industry growth rates (employment) 285
Licence fees 286
Number of licensees 291
Frequency of renewal of licence 294
Time cost of applying for a licence 296
Time cost of renewing a licence 297
Transition costs for industry 298
Government communication costs 299
National licensing register costs 299
Government operating costs associated with the licensing authority 301
Mutual recognition 304
Removal of requirement to hold multiple licences across jurisdictions 306
Experience requirements 307
Business value-add (capital efficiency) 308
Improved labour mobility 308
Changes to Certificate IV units 309
Duplicate testing in Victoria 313
Cost of introducing financial probity requirements 314
Removal of personal probity requirements for non-contractor licences 315
Removal of the requirement for apprentices to apply for a licence 319
Introducing worker licences in Queensland 319
Introducing contractor licences under national licensing 319
Providing evidence of skills maintenance 320
Attachment H – References 321
Attachment H – References 321
Reports and presentations 321
Reports and presentations 321
Legislation 323
Legislation 323