Dris proposal for national licensing of the plumbing and gasfitting occupations

Endorsements

Endorsements are authorisations to perform specialist work and are available to those who hold a specified existing licence. They allow the holder to carry out this additional work if they have met the skill requirements required for the endorsement. All jurisdictions issue endorsements but the work they cover differs between jurisdictions.

Endorsements proposed in Consultation RIS

The Consultation RIS proposed three endorsements. These were:

commissioning and maintaining thermostatic mixing valves

commissioning and maintaining backflow prevention devices

testing and maintaining fire hydrants and hose reels.

Most jurisdictions licence the first two areas of work, either as part of the regulated work of a plumber or as endorsements. As a number of jurisdictions clearly find it appropriate to regulate these types of work as endorsements rather than including them in the plumber’s licence, the proposal is that this be the preferred approach. To include this training in the skills requirement for a plumber would increase regulation for those jurisdictions which do not currently licence in this way and which treat these skills as optional. Those jurisdictions which include these skills as part of a plumber licence will be able to transition existing licensees to both the plumber’s licence and the endorsement

It should be noted that, if the two tier licence model was supported, the number of endorsements would be likely to increase substantially, as skills considered necessary by industry to carry out a particular task and which are currently encompassed in the relevant Certificate IV units are not included in the Certificate III.

Hydrant and hose reel work is only licensed separately in Victoria and Queensland, under a restricted licence. The view of the steering committee was that an endorsement was more efficient, as a restricted licence would need to stand alone and require a more extensive skill set to support it. IAC members considered that only two units of competency would have been needed in order to undertake the work covered. As only two jurisdictions licence in this way, and the work is included in the scope of work and therefore the qualifications for a plumbing registration, there was an opportunity to remove this as separately licensed work.

Over 60 per cent of those providing submissions, who answered questions on the proposed endorsements either generally or specifically, supported the proposed endorsement for commissioning and maintaining thermostatic mixing valves, while close to 75 per cent of the same cohort supported the endorsement for commissioning and maintaining backflow prevention devices. No evidence was presented by submissions to suggest this is not appropriate. These endorsements are therefore included in the final proposal.

Fifty-eight per cent of those responding through the online survey did not support the proposed endorsement for testing and maintaining fire hydrants and hose reels. Respondents who commented specifically on the proposed national fire protection categories supported a restricted licence for the inspection and testing of fire equipment, which has now been included (see above). As this work is only separately licensed in two jurisdictions, and there does not appear to be industry support to maintain it, nor other evidence to support its need, it is not proposed to include the endorsement for testing and maintaining fire hydrants and hose reels in the proposed national licensing system. Little information was available on the number of licence holders affected by this removal, therefore the impact has not been costed.

Other endorsements canvassed in the Consultation RIS

The Consultation RIS also sought feedback as to whether any of the following endorsements should be required for either three tier model:

an endorsement for solar and heat pump hot water system installation

an endorsement for on-site sewerage facility maintenance

an endorsement for gas Type A appliance conversion work

an endorsement (or restricted licence) for Type A gasfitting work limited to servicing appliances

residential and domestic fire sprinklers.

12. Solar and heat pump hot water system installation

Queensland is the only jurisdiction to require an endorsement for solar and heat pump hot water system installation. This endorsement has been in place since January 2011 and seeks to address the high proportion of defective solar and heat pump installation work identified as taking place in Queensland. The Queensland representative indicated that the number of installations is increasing due to the phase-out of electric hot water systems across Australia. No other jurisdiction licenses this work as a separate category outside of standard plumbing work, and little evidence of need was indicated by industry through the submissions process.

Fourteen respondents expressed support for this endorsement, representing 12 per cent of all those answering the question on which additional endorsements might be necessary. The majority of respondents were silent on this issue. The regulated work for a plumber includes hermetically sealed heat pump hot water units that are self-contained. It is therefore not proposed to include this endorsement in those available under national licensing. There will be a small benefit in removing this endorsement.

13. On-site sewerage facility maintenance

Queensland is the only jurisdiction that currently has an endorsement on a drainer’s licence for this work. During the policy development process, the IAC convened a working group to discuss whether an endorsement was needed for on-site sewerage facility maintenance. It noted that the installation, replacement, repair, alteration and maintenance of on-site sewerage facilities is already within the proposed national licensing scope of work for sanitary plumbing work and drainage work. While Queensland continues to advocate strongly for its retention, other jurisdictions either do not licence this work or regulate it through health departments and/or local government permit arrangements. No evidence was presented that this led to a greater degree of risk.

Queensland requires a single unit of training competency for the endorsement it currently has, however the IAC did not mandate this unit for the sanitary plumber or drainer licences under national licensing. The IAC did not support either an endorsement or an exemption for this work and neither was proposed.

Less than 11 per cent of those answering the question on which additional endorsements should be included expressed support for this endorsement. The majority of respondents were silent on this issue. Given that no other jurisdiction licences this work, and the lack of support for such an endorsement both through the IAC and in public comment, it is not proposed to include this endorsement in those available under national licensing.

14. Gas Type A appliance conversion work

Victoria is the only jurisdiction to issue this endorsement and requires a gasfitting licence or registration and the undertaking of an examination relating to Type A appliance conversion. Other jurisdictions do not distinguish this type of gasfitting work in any way, and it is undertaken by gasfitters as part of their usual practice. As this work is only separately licensed in one jurisdiction, there is an opportunity to remove regulation in this area. No evidence of increased risk was provided by industry through the submissions process.

Less than 11 per cent of those answering the question on which additional endorsements should be included expressed support for this endorsement. The majority of respondents were silent on this issue.

As most jurisdictions do not currently licence in this way, and no evidence was provided to support the need for such an endorsement under national licensing, it is not proposed to include this endorsement among those proposed.

15. Type A gasfitting work limited to servicing appliances

The servicing of Type A gasfitting appliances comprises work on manufactured, certified, appliances using gas as a fuel. This work does not include installation of the appliance.

Only Victoria and Queensland licence this work separately; Victoria as an endorsement on a gasfitting licence or registration and Queensland through two restricted licences, one of which is restricted to caravans only. An opportunity was therefore presented for rationalisation of licensing in this area.

Qualification requirements between the two jurisdictions are substantially different: Victoria requires a full Certificate III plus successful completion of an examination in servicing competencies, while Queensland requires four units of competency. The Australian Capital Territory has a form of accreditation which allows those accredited to disconnect, reconnect and service Type A gas appliances. Those who apply for accreditation must hold a gasfitter’s licence or have two years’ experience with Type A appliance work and have completed an approved training course (however a search of the www.training.gov.au site indicates that the courses listed in the relevant instrument are no longer current). The Australian Capital Territory regulatory agency confirms that ‘the Certificate III for gasfitters includes sufficient units on Type A appliances to allow a licensed gasfitter to be considered suitable for gas accreditation’. South Australia has approximately 80 licences restricted to servicing and limited to particular identified manufacturers or their agents and some of these would have arisen following mutual recognition of other state licences or for historical reasons. All other jurisdictions include gas servicing as part of general gasfitting.

Queensland strongly advocates the inclusion of a restricted gas Type A servicing licence under national licensing. It states that the licence has been designed for an emerging industry which it expects to grow over the coming years to meet the demand for a sustainable and energy-efficient domestic and commercial gas product. Queensland indicates that it has 110 licensees in this field and has expressed concern that, under national licensing, qualification requirements would increase for new applicants who would be required to undertake a Certificate III qualification rather than the lower skill requirement currently in place and that therefore regulation would increase for this state. (Note that current licensees would be transitioned to an equivalent licence in the new system without requiring further training).

Queensland also has 33 Type B company authorisations, for companies such as Miele, Bosch, KFC and Sizzlers, to carry out servicing of their commercial catering equipment. There are also more than ‘30 caravan servicing and repair companies in North Brisbane alone that actively encourage annual servicing of caravans’, according to information supplied by the Queensland government.

Victoria has indicated that it has substantially more licence holders for this restricted activity than Queensland and also indicates that this is a specialist area of work for those who do not choose to install appliances. The Australian Capital Territory has relatively few workers with accreditation, but supports a restricted licence for the work. As the work is covered under general gasfitting and no other jurisdiction supported a separate licence for this work, it was not proposed in the Consultation RIS.

Removal of a separate licence for this work will reduce the regulatory burden in Victoria, as the examination currently in place would no longer be needed. It would, however, increase regulation for Queensland, as a full licence would be required rather than the four units of competency currently required.

Only approximately 9 per cent of those answering the question on which additional endorsements should be included expressed support for this endorsement. Those who supported it included the Caravan, RV and Accommodation Industry Association of Australia and two companies involved in appliance servicing, one in New South Wales and one in Victoria. The Industry Association has indicated that the sector is an expanding one and that calling out a fully licensed plumber for work on caravans is time-consuming and costly for consumers and the work required ‘quite basic’. Queensland is the only jurisdiction to offer a restricted licence for caravan servicing currently.

All other submissions supporting the restricted licence sought a disconnect/reconnect licence to allow licensees to replace like-for-like appliances such as cooktops, stoves and ovens, in their role as service agents for manufacturers and importers. One respondent suggested that a requirement to have a full licence for this work would increase risk as it would lead to unlicensed people attempting the work.

Overall, approximately 58 per cent of those responding to the question of whether a restricted licence should be available for servicing gas Type A appliances did not support a restricted licence.

Only two jurisdictions currently offer a licence with this scope of work (South Australia does not offer a separate licence category, and the ACT offers a larger scope of work), it was not supported by the IAC and minimal evidence was provided to support its inclusion. It is understood that the risks of incorrectly servicing gas appliances are no less than for other gasfitting work. It is therefore not proposed to include either an endorsement or restriction for servicing gas Type A appliances in the list of categories available under national licensing. Instead, the work will be regulated as part of the general gasfitting licence. There would be a small benefit applying to the removal of this licence in those two jurisdictions which currently offer it but this has not been quantified. This benefit would be offset for new licence applicants in Queensland, who will now need to obtain a higher qualification to do this work.

16. Residential and domestic fire sprinklers

The NFIA sought the retention of an endorsement for ‘residential and domestic fire sprinklers’, available in Victoria and issued as a separate licence in Queensland and the Australian Capital Territory. The retention of this endorsement was also supported by Victoria. New South Wales noted that this unit related to design, which is not included in the regulated work, and the work is controlled by building approval processes. The IAC did not include this endorsement, there was almost no support for such an endorsement in the other submissions received and no evidence provided to indicate a need. It is therefore not proposed to include a separate endorsement for this work.