Showing posts with label builders. Show all posts
Showing posts with label builders. Show all posts

Saturday, March 08, 2014

In search of South Australian Building Industry Web Presence

The following is a list of various suppliers to and in the South Australian building industry. It is not a recommendation, it is just a search for suppliers I am familiar with and an investigation to what web presence they have, whether it is a web site, presence on social networks, or simply a listing in the white pages and or yellow pages telephone directories. Some of these businesses we have done design/engineering work for in the past, or otherwise specify their products, others simply have a presence in the market place which cannot be ignored.

Cold-Formed Steel Sheds:

  1. Erecta Shed
  2. Mark Lattin Steel Constructions
  3. Alpha Industries
  4. Delta Sheds {No longer trading}
  5. Galpruffe {No longer trading}
  6. Olympic Industries
  7. Magnus Australia
  8. Cockaleechie Industries
  9. Fielders Endurance Structures
  10. Ranbuild
Cold-Formed Steel
Panel and Block Construction
  1. Rapidwall
  2. Ace-Wall
  3. Hebel
General Construction Hardware
  1. Ramset
  2. Hilti
  3. Pryda {nail plates}
  4. MiTek Building Systems {Gangnail, nail plates}
  5. James Hardie
  6. Nobles {Cables and Rigging}
Retaining Walls
Soil Bore Logs
  1. Geodrill
  2. Frangos Nominees Pty Ltd
Land Surveying
  1. Jeanes & Sommerville Surveyors Pty. Ltd.
  2. Mattsson & Martyn
Building Surveyors &/or Private Certifiers
Drafting and Design Services
Work Shop Detailers
{No web presence found at moment for those I know}

Pergolas, Verandas, other Canopies and Decking
{Mostly Timber}
  1. Harkk
Concrete
Glass
General Metal Fabricators
  1. D and D Tooling
Houses and other Residential Construction
Electrical
Golf Nets and other Sports Nets
Consulting Engineers for Infra-Structure Size Projects
  1. GHD
  2. SKM
Consulting Engineers Commercial / Industrial Projects

Sunday, January 27, 2013

More on Licensing


Read recently in "The Registered Building Practitioner", volume 1 Number 4 (summer 2012), a publication of the Victorian Building Commission , that there are calls by the Australian Glass and Glazing Association (AGGA) to introduce national licensing for all glazing professionals. This being an opportune time because of moves to introduce a national licensing scheme for builders and other trades.

Whilst I agree there are problems with glazing, especially worthless certificates issued declaring glazing is installed and compliant with AS 1288. The certificates are worthless because AS 1288 is now a materials design code dependent on the Building Code of Australia (BCA) and the loading code AS1170. If the certificate does not identify the BCA classification, the structural importance level, and the AS1170 loading parameters, especially the barrier loading type, then the certificate hasn't stated anything of value. Licensing won't solve this problem. {Not the least of which I believe it is AGGA members issuing the certificates, in the first place, so they need to improve the training they provide.}

Licensing doesn't work for builders, plumbers or electricians. For that matter it also doesn't work for medical doctors, architects or engineers. Where "working" is protecting the community from unscrupulous and incompetent suppliers.

As far as I know when such licensing was introduced, there was not widespread incidence of low quality work being dumped on an unsuspecting population. Neither was the population stupid and in need of protecting by a guardian parent. All licensing schemes hidden behind the scenes are about protection and enlarging of markets by established players.

The established players typically start out supplying low quality rubbish, as they get bigger, they acquire the resources to develop and improve their product. At such point they have a scientific, technological and economic advantage over other players in the market. If they can get standards imposed and legislation passed to create performance criteria that new players cannot possibly meet, then the established players keep their lions share of the market, and prevent new players from entering, because the start up costs are too high. Secondly the smaller players already in the market will in the main be wiped out, allowing the older established players to grab markets back. For the real issue is loss of market share to new entrants to the market. The creation of standards, codes of practice and legislation is an alternative, back door approach to creating a cartel and establishing a monopoly. It is all acceptable because it is presented with an emotional base of protecting the welfare of the community.

Licensing doesn't work, it is a nonsense approach to protecting the welfare of the community. Licensing is a low quality QC (quality control) approach to product quality. QC does not prevent defects, it mostly provides traceability to who produced the defects so that the person can be found and punished. QC in a factory tends to prevent defective goods reaching the public, or at least retrieving the defective goods if the system missed them. For the building industry the public is the first to bump straight into the defective product, whilst construction is taking place.

If someone builds something without a license they will get fined, and possibly required to give assurance they will cease carrying on building works without a license. It doesn't matter whether the work is quality work or not, they are simply punished for not having the license. If a licensed builder produces low quality work, then they could loose their license, and be fined. In the age of the Internet these assurances and losses of license can be tracked at the office of business and consumer affairs website. Which is all very nice, but some poor customer experienced the low quality service. The licensing system didn't work when it was called upon to full fill its function: protect the public.




Occupational health safety and welfare (OHS&W) is another area where the QC approach is taken and it doesn't work. This time people get injured and reports about the incidents, whether it be caused by defective product or poor work practices is reported on the Internet at SafeWork SA.

Proponents of OHS&W regulation typically argue for higher penalties to provide a greater deterrent against non-compliance. Rather than focus on solving the real problem these people want to set up increasingly adversarial systems. If an employer is paying out ever increasing amounts on fines then they don't have the resources to fix the problem. Further more the regulations don't provide solutions. So an employer has to provide a safe work place but it is not stated exactly how. However since the 1980's responsibility has been split between employee and employer. Prior to that an employer may have been held 100% responsible for an employee not wearing safety glasses. Still earlier still it was just simply the employees problem. With responsibilities split the employee is required to wear the safety glasses, the employer may be required to supply, and the employer is also required to ensure the employee does wear the glasses. It is that latter part that becomes problematic. Personal protective equipment can be a hindrance to performing some tasks, or just plain inappropriate for the task environment. I remember several years back a railway engineer, asking why they needed to impose the wearing of safety helmets (hardhats), stating that sunhats would be more appropriate. Given that in the middle of no where it was highly unlikely anything would fall on anyone's head, construction work it may have been, but different than constructing buildings and bridges. Regulation gone crazy. With an adversarial system punishing for non-compliance, do not want silly impositions.

With such silly requirements imposed by adversarial system, it is not surprising that employers start to fight back. Demonstrating that what the pedantic inflexible officers enforcing the regulations want to impose is generating the hazard, not removing it. Finding the administrators and enforcers of the regulation at fault and guilty of causing accidents, then leads to creating regulations which distance the administrators and enforcers from liability. To do this the regulations become less explicit, more abstract, conceptual and generic. The result is a requirement to demonstrate through rational argument and use of scientific knowledge that a product and process are suitable for purpose and pose little hazard to life and limb.

Thus we have the BCA which is built around the concept of documentary evidence-of-suitability, rather than being built around authoritarian rule. It is governments which impose authoritarian rule by calling the BCA up in legislation, and similarly for the new national model code for OHS {welfare apparently not important nationally}.

As far as I can determine prior to the 1994 Development Act, people could just go to the local city council with a proposal of building works and council would assess and otherwise advise of changes to make before the proposal would be approved. The council is no longer permitted to do that. Both the BCA and the development act and regulations place the onus on the building proponent to demonstrate compliance by presenting adequate documentary evidence-of-suitability. Whilst expert judgement is one acceptable form of evidence, such evidence needs to be such that it can be validated by another such expert. In other words mere opinion is not acceptable it has to be rationalised and defendable judgement. If there was a coronal inquest, and the judgement would likely be tossed out off court, then it is not an acceptable judgement to defend granting approval.

It should also be noted that development approval only has a passing interest in OHS&W and the constructability of the building proposal. The assumption is that the building proponent has already determined that they can build the thing before approval is granted, or will otherwise figure out how to construct if approval can be obtained. Development approval is concerned with whether the building will pose a hazard to the community or to users once it exists in the built environment, it is not concerned with the feasibility of bringing it into existence, nor the safety of such construction process. Development approval may however cover some OHS&W issues if the work task to be carried out in the building space has a direct bearing on the design of the building. For example the design of a hazardous chemical facility requires design of the work space and a building to suit. To administer this process we now have building surveyors registered as private certifiers, but this does not ensure that the certifier has adequate competence to properly and thoroughly assess any building which crosses their desk. A whole team of people are required to get it near right, and most of the people involved have no form of license. though they may have various forms of formal higher education and certification of such.

The building works contractors act and regulations, is also misleading. It licenses building works contractors (BWC) and building works supervisors (BWS). The BWC license is mostly concerned with finances to start and finish a contract, ability to manage financial resources, and the provision of various warranties and insurances. The BWS license is concerned with planning, coordinating and supervising construction activity. A builder does not have to know what a bressemer, lintel, mullion, transom, corbel or dragon beam is. There task is to organise safe and supervise safe construction practices. Licenses however have traditionally been granted to carpenters, bricklayers, plumbers and electricians, and are still so granted. Architects are assumed licensed for purposes of BWS, but otherwise require a BWC license if set up a construction company. Engineers, technologists and engineering associates are not included. It should however be noted that the building contractors act is mostly concerned with residential construction and protecting a public assumed to be uniformed buyers of builders services. In other words wouldn't really be looking for someone with a BWS to supervise construction of a bridge. The problem with construction of a bridge is cannot rely on the civil, structural or construction engineer having adequate competence to carry out the work. Engineers want national licensing and registration to restrict practice.

Once again I say that licensing doesn't work. It is not an adversarial QC system that we need to be putting into place, such are the type of systems we should be aiming to get rid off. We should be aiming for assurance of quality or quality assurance (QA). But unfortunately QC is so ingrained that attempts to implement QA get stuffed up by continuation of QC systems.

The very idea of wanting to get ISO:9000 accreditation means the party has not got QA philosophy or the right attitude to implement QA. One major attitude adjustment for QA is getting rid of the accept or reject mentally, wanting ISO:9000 accreditation means you still have such mentality.

ISO:9000 also fosters confusion about excessive documentation and traceability. Then there are confusions concerning getting rid of inspection.

When the 1994 development act was being brought in, there were pushes to implement QA, part of that led to councils eliminating their inspections of building works. A few years later a minsters report recommended inspecting a minimum of 20% of approvals. More recently the development act and regulations have been amended imposing 60% of approvals.

The simple rule for QA is:

Quality cannot be inspected in, it has to be designed in.

That is both product and process need to designed, and they need to be designed concurrently. That is an entire system has to be designed to supply and produce a quality product. Buildings and building products are not supply by systems which have been intentionally designed to provide quality product. All this custom design nonsense actually produces low quality rubbish and a failure to supply all that are in need. Would there really be problems with health care, water supply, housing and education around the world, if systems were properly designed to supply to the demand? I believe not. We have a problem because modern business is set up to generate monetary profits not supply demand. The assumption is if didn't meet demand wouldn't make profit. But missing the point, the supply is deliberately constrained and priced high, and so falls short of meeting the full demand.

To reduce variation in the production process also need to minimise product variety. Human nature being as it is, most builders simply just push forward on the basis of business as usual without reading the specifications continuously. Thus that small architectural feature, that outcrop in the wall disappears as the builder constructs a straight wall. Such loss of feature is not entirely the builders fault, it is largely the architects fault. If the architect wanted such feature, then they should have made it clearer, and otherwise been on site at appropriate times supervising and ensuring the building is constructed to specification. Unfortunately designers design, and others build. If a designer is on site then chances are they are not fully focused on the job, because their mind is elsewhere dreaming up their next innovation. So it is often necessary that functions of builder and designer be separated. But that then imposes need for coordination and communication, and the larger the team the greater the importance.

On one hand our civilisation is a massive industrial machine, on the other it is a living, growing and evolving organism. The machine is an assembly of cogs and each of these cogs needs maintaining, and replacing if the machine is to continue to function correctly. As a growing organism, the machine has to get larger and support more and more people, it needs more cogs to expand its capabilities. But it needs a nursery, somewhere it can nurture the growth and development of the new cells, which will sustain the growth and evolution of this higher form of life. As an evolving organism, the machine doesn't need all the cogs it needed yesterday, and it needs entirely new kinds of cogs to meet its needs tomorrow.

It is this evolution which makes licensing of engineers for example a dumb idea. Has I have mentioned before, to me engineers operate at the frontiers of science and technology. I am also fairly certain that, is also the stance taken by the IEAust in the past, and also that set down in the WFEO Washington accord. So like it or not, last years engineer is this years technician. Or if we use the WFEO occupational classes, then last years engineer, is this years engineering technologist, and last years engineering technologist is this years technician. The point is this, last year as a society we did not know how to design a reinforced concrete shell as a water tank. This year we do, so whilst last year it was a risky experiment, it is now an established technology, and we do not expect it to perform poorly. So whilst last year we needed someone with a B.Eng to figure out how to design the concrete water tank, this year we want someone with a B.Tech who knows exactly how to design a concrete water tank. Next year we will push it down to an engineering design technician, and the year after that we will just get on with building and installing them.

To create legislation in a society where B.Eng is seen as having prestige, though those with are constantly whining they don't, just causes inefficiencies and places lifes at risk. Lifes are placed at risk because the graduate with the B.Eng straight from school does not have adequate knowledge of the established technology, and it is adopting and adapting the established technologies where the real need exists. It thus becomes an imposition on industry to try and train those with a B.Eng to be competent for an occupation which more rightly belongs to those with a B.Tech or even an Associate Degree or Advanced Diploma. Higher education is good if its the right education at the right time and the right place.

Put simply by pushing the B.Eng we are maintaining the established scientific body of knowledge but industry and society is loosing the established body of knowledge concerning the established technologies it has become dependent upon. Such is not acceptable. The problem arise because the collective behaviour of individuals without coordination does not provide the systems necessary to provide the lifestyles and levels of performance the people have come to expect.

It is potentially the operation of systems which is more important than the behaviour of people. Most laws are created to deliberately constrain human behaviour, which some consider inappropriate. For such behaviour penalties or punishments are imposed. Most such laws are born out off our feudal and tribal pasts, our central government is little more than the remnants of the dominant tribe which wielded the greatest power over the region. So that laws are based mostly on might is right. Can impose any constraint on human behaviour you desire as long has have the might to enforce. As population grows, that might fizzles out.

So drivers licenses for example don't work.The roads are filled with people who exceed the speed limit. Must be community groups at least once a year express the opinion that government just uses speed cameras to generate revenue. With such revenue they buy more cameras, they do not improve the roads. Once again it is QC versus QA approach.

The QC approach is to use the statistics collected by the speed cameras to identify the hot spots, then to increase monitoring of the hotspots. This produces more speeding tickets and the accusations of just using for generating revenue.

The QA approach is to use the statistics to bring the process into control. People exceed the speed limit, fining them doesn't change their behaviour. Therefore calls to make the fines higher and a greater deterrent are just counter productive. People exceed the speed limit because they don't spend all their time watching the speedometer, and they shouldn't they are likely to drive into stobie pole. {Anyone noticed how recently cars have a mind of their own. The news keeps reporting cars left the road, car collided, car drove through house wall. Apparently none of the cars have drivers, it seems the machines are rebelling against their enslavement.}

People exceed the speed limit because the safest line to take is typically to match the speed of surrounding vehicles, assuming they are travelling at correct speed, if you enter the traffic flow without seeing a speed sign. Speedometers on cars are also not precision instruments, so there is variation in the speeds of cars in the traffic stream. Therefore fining people for things not entirely in their control is not acceptable.

So there maybe a particular hotspot. that doesn't mean should go fine everyone on that road. The QA task is determine why people exceed the speed limit and also is the speed limit appropriate. Rather than have the police operate speed cameras so that people can be punished for breach of the law, it would be preferable that the department of transport properly monitor the rubbish they dump in the built environment, and properly fix the defects. For example with the default speed limit being dropped from 60km/h to 50km/h there are now an inadequate number of speed limit signs. If enter road at the right place may see the 60km/h sign, if enter elsewhere may consider the street is 50km/h. Other places there are signs which are just inappropriate, for example 70km/h speed limits on bends, get round the bend and hit traffic jamb at traffic lights. For such location the speed limit should have stayed at 50km/h, and the 70km/h sign placed on the far side of the traffic lights. It is a simple design issue, possibly a faulty installation issue which is costly to put right.

No one should consider our roads are well designed and ever will be perfect, the task however is the journey of monitoring and improving our road designs, and then physically improving the roads. This will not be improved by licensing the civil engineers involved. It can only be improved by improving the systems which provide the roads and traffic control systems. It requires observing, measuring and recording the defects in the system and having other systems in place to take corrective action. An adversarial punitive system hinders getting appropriate information to make corrections and consequently the hazards remain.

Back to the glazing. There is no doubt that inappropriate glazing is being installed, and that some people have been injured as a consequence  There is also no doubt that many existing buildings have inappropriate glazing installed. Buildings which are work spaces, need to comply with the BCA. That statement is ambiguous. The development act requires a building comply with the BCA at the time of approval. If the BCA changes during construction there is seldom the requirement for the building to be upgraded to comply with current code. Nor is there any requirement to upgrade the building at any future date as the BCA is revised. However a work space, is governed by the OHS&W act and regulations, and it requires compliance with the BCA, whilst the building space is used as a work space. That is there is an implication that a work space complies with the BCA current at the time the building space is used for work: that means given the BCA is revised each and every year employers have to keep their buildings compliant. A business potentially could be shutdown because the buildings have become far too removed from compliance with current code. Note however the OHS&W regulations are only concerned with health and safety issues in the BCA, not energy efficiency or green requirements. However if the OHS&W requirements impose an air-conditioned environment and that needs constructing then it needs to comply with current BCA energy efficiency requirements. It just depends on the situation. Everything requires thought and consideration and designing to be fit for purpose: part of the fitness however is imposed by national codes of practice. Fitness for purpose however is primarily a matter of personal opinion, of subjective judgement. When it comes to codes of practice building little empires and the exercise of power through authoritarian rule. As a community we are increasingly prepared to slap such little dictators down.

I find it unacceptable that a judge finds a government department liable, because it should have known its clients would likely get angry, and in such anger smash glazing and injure themselves. The individual is responsible for getting angry and controlling their own behaviour, if they choose to lash out violently and injure themselves that is their own fault: it does not have anything to do with whether the glazing was appropriate or not. Similarly two youths fighting on a stairwell, and falling and one becoming a paraplegic, does not have anything to do with whether the stair balustrade was at a code compliant height or not. Fighting is unacceptable behaviour in a stairwell. The experts involved in such cases seem to have been more authoritarian pedantic idiots blindly imposing code clauses without thought to intent and origin.

A slightly different situation is two youths in stairs arguing and a third person attempts to get pass, is bumped and knocked over the balustrade. Whilst a higher code compliant balustrade would have reduced the likelihood of toppling over the top rail. it doesn't change the fact that the third person took an unnecessary risk, due to likely arrogance and impatience, nor that the youths should not have been arguing in a public place.

A balustrade set at the code compliant height is not safe nor suitable for all humans. Taller than average people will topple over, shorter than average people will fall under. Putting glass balustrades on stairs is inappropriate in my opinion, I would classify as bad design. The architects and glazers would say its code compliant. I don't care, code compliant or not it is bad design to put glass balustrade on a stairway in a public place. Just as it is bad design to the code to have horizontal rails, or any other feature which permits climbing, in a balustrade.

Solid infill panels on balustrades on stairways are poor design because children cannot properly reach and gain benefit from handrails. A lower hand rail would pose a climbing feature. Closely spaced vertical rails however provide an alternative support system, not only for children but also for persons who slip or otherwise loose their footing on the steps. Now I doubt the glazing industry would be in favour of reducing their market by eliminating glass balustrades from stairs. Not the least of which is that architecturally if glass balustrades are eliminated from the stairs, then likely also removed from the landings so as to achieve aesthetic continuity.

The problem with the glazing industry as with most industries, is the guy installing the glass is not independent they have a vested interest in making a sale. The buyer has a vested interest in keeping their immediate costs down. A could be and maybe, about some future accident, doesn't tend to figure heavily in purchasing decisions.

At present building surveyors are more heavily involved in granting approvals for development applications than acting as consultants to building owners and buyers of buildings.

A few years back there was a balcony or more of an external decking collapse. The captain of some school team and the school principal had organised some entertainment and lunch for mothers of students. This event took place at the school captains house rather than the school, the external decking collapsed and people were seriously injured. Now I don't know who has been held liable for such injury, but it should be noted that houses are not designed as places of assembly, whilst schools do have places designed for assembly. The school principal is responsible for the use of the school property in a correct manner and providing a safe working environment for school personnel, students, and visitors  A principal however has a multitude of other issue to worry about other than proper use of the school buildings. Consequently a school principal really should not make decisions about the use of various building spaces with out consultation with a building surveyor. As I noted above a work space has to be compliant with the current version of the BCA, not merely compliant at the point in time approval was granted to go ahead and build.

It would therefore be preferable that all building owners and/or employers have access to building consultants who carry out at least an annual check that no changes have taken place to the use of the space or to the BCA which would make the buildings cease to be compliant.

Take glazing in shopping centres for example. Such glazing is largely installed as a matter of interior fitout, whether development approval is sought or required is not always clear. As to whether the glazing needs to be designed for crowd loading or not is also another matter of opinion. It is a matter that needs to be considered, and then documentary evidence-of-suitability produced to demonstrate the need or lack of need for crowd load design. Is that a job for the glazier licensed or otherwise? I very much doubt it.

The person with the authority is the building surveyor, the person who grants provisional building rules consent, which then leads to the council granting development approval. If the use of a building is not changed then development plan consent is typically not required, but building rules consent may be required for changes to the building.

Change the layout of an office, a factory, a shopping centre, a hospital, a school, or even a house, then there is potential to introduce an hazard which wasn't previously present. So whilst may not require the services of an architect or engineer, it would still be good practice to seek the services of a building surveyor, for they are the people most familiar with the regulations. It should be noted however that building surveyors are not designers, they seldom can find a design solution which meets the end-users needs and complies with the code, their skill is assessing whether a proposal has achieved compliance with the code. So if looking for a solution will typically need the services of an architect, engineer or other designer: certainly not a drafter.

One of the issues which fuelled the growth of ISO:9000 accreditation is that of double inspection. Double inspection is wasteful, it refers to suppliers inspecting and approving their product before release to the customer, and the buyer not trusting the supplier and inspecting and approving before releasing into their production process  May have noticed from the news that all the car industry seems capable of doing is tracing defective goods after release and recalling to fix the problem. The point of QA is not to release defective product in the first, not make make defective product, and not to release a defective design to production. I reiterate quality cannot be inspected in, it has to be designed in. Both product and process have to be designed, entire production and distribution systems need to be designed: not just some widget.

Our primary control systems are built around government regulations and codes of practice, and building surveyors are the primary guardians of compliance for the built environment. However our legal system is built around evidence. No one really cares if the building surveyor, architect or engineer says something is adequate. Adequacy has to be proven. The regulation for the built environment are built around conceptual proof of adequacy before permitting a potential hazard to be placed in the built environment.

The problem with the system is that it can only assess building proposals if a proposal is submitted for approval. Secondly it has been reduced to a paper shuffling exercise, thus no independent checks and balances that the approved designs have been complied with. The certificate of compliance issued by the builder which constructed the building is not independent, not even if it does require signing by the owner/buyer.

People think they can do what ever they want on their own property. In theory they can, on condition that:


  1. What they do on their property stays on their property.
  2. What they do on their property does not have an impact on neighbouring properties.
  3. The property remains their property.


As soon as changes to property involve other people, then it becomes necessary to consider the expectations of the population at large, and these expectations are largely catered for by the codes of practice and regulations.

I don't care if a glazier is licensed or not. What I care about is the quality of the product they supply, and a license does not and cannot ensure such.

Given time I could design a business enterprise which provides construction services which far exceed the capabilities of a licensed builder, the regulatory system would require I appoint a licensed building works supervisor (BWS). Since the regulations do not permit me to lock the BWS in a cupboard and keep them from being a nuisance and messing things up, I would have to design the system to cater for the presence of a useless cog (the BWS). They think they are useful, I think they are a public menace. A carpenter should not be granted a BWC or BWS, a competent and capable carpenter they may be, but that doesn't mean they have the skills to supervise others and coordinate the needs of large building projects. The BWS license is not about competency as a carpenter, bricklayer, concreter or glazier. The BWS is about the competency to plan, design and manage the construction works, and that may require coordinating the work of one or more trades. It certainly involves getting other people to do the work. A brick layer may be able to work on his own, however he seldom makes his own bricks, and consequently he has to plan the works, which may involve the delivery of bricks in appropriate sized batches at suitable times. Depending on the company a brick layer works for they may never have to work such things out because some one else organises all resources for the project. Business systems can determine the efficiency with which a product is supplied and the quality of that product.

The problem with the building industry is far too many sole practitioners, and consequently an unwarranted division of labour, along with poor coordination, and unclear lines of authority and responsibility. I was watching some engineering construction programme the other day, and one of the bosses said there was a problem with their being too many people in charge, should only have two bosses. No! Unity of command should not be violated. If there is an hierarchy then only obey your immediate boss, sure risk getting fired by the bosses superior: but the superior should only act through their appointed officers. So either the appointed officer hands control over to their superior, or the superior removes the appointed officer. The hierarchy is their for a reason. The front line personnel have different information then the staff, and the staff have a bigger picture than the front line.

The building industry lacks clear lines of authority, responsibility and command. Not the least of which is most trades people running around thinking they are not responsible for anything and council responsible for everything. They only seek certificates from engineers, on the assumption they are not responsible and the engineer becomes responsible. Big mistake. All the sales people making use of engineers certificates are taking on role of designer, and are the person responsible in charge of the project.

That shed the sales person sold last week. Well the design was perfectly correct in its own right, but it was totally unsuitable for the customers purposes, and the sales person is responsible for declaring the product was suitable for the customers needs. Ah! But the salesperson will says its not their fault the council approved it. So they did. But the salesperson didn't disclose the real purpose of the building in the development application, though the customer did clearly point out what they wanted the building for. The sales person is acting has designer, lacks suitable qualifications to do so, and doesn't carry professional indemnity insurance, though the employer may carry appropriate insurance to cover  supply of product which proves defective.

Similar situation exists for fabricated nail plated roof trusses, carports and verandah's, stairs, balustrades, retaining walls and a multitude of other building products. Most products however are subject to the requirements of fair trading laws: and not covered by any product specific regulations.

Now retaining walls was another issue raised in the Registered Building Practitioner publication. More important than the retaining wall here is the issue raised: that is certain building works say those below $5000 do not require licenses or builders warranties. Therefore quote the work below $5000 dollars or what ever limit applies, and provide without appropriate warranties.

A similar issue applies to size of building works which require development approval. Some think the constraint applies to each construction contract, rather than the development of the property. So for example, if works less than 10sq.m don't require approval: split the work into smaller portions less than 10 sq.m. Within a few years time have 100 sq.m of development. Such is not the intent of the code, and the 100sq.m of development to the property would be illegal without development approval. To be certain about approval, proposals should be documented, then a building surveyor consulted for guidance as to whether approval is needed.

Now people do these things because development approval is seen as too time consuming and too inflexible, so they build without approval, and it seems even find builders who will build without approvals.

But peoples perception of city councils come from plan drafters, builders and their own encounters with council: basically people who themselves don't know what they are doing. For example builders regularly tell their clients that council always changing the rules. Not true, council rarely changes the rules, even in BCA is revised each year. The builders don't know the rules, the builders know prescriptive building solutions which comply with the rules most of the time, but not all of the time. When they hit the situation of the building solution not complying with the actual rules, the builders think the rules have been changed, and otherwise find themselves unable to find a suitable building solution.

The principal problem lies with the buyers and the suppliers. The buyers don't want to waste time on design, they therefore do not want to waste time with architects, engineers and other design consultants. They also think builders fees are extortionate for little service. Consequently we also have a large DIY owner-builder culture: they can organise supply of trades(subbies) themselves, and check quality of work they are paying for. More importantly however they mostly just want to buy off-the-shelf product which immediately meets their needs. Consequently they either go direct to suppliers which sell complete building products (eg. sheds, carports, verandah's, retaining walls, houses etc...).

What they really need is an independent consultant to look after their needs, however architects, and engineers are clearly not those consultants. The BWS works for the contractor (BWC) or is the BWC, there is thus no independent representation of the owners needs, with council inspections cut back a safeguard for the public was removed.

But there was also a socio-political action in play. Councils were reducing costs, laying people off, cutting back on inspections and not properly replacing the function removed, means the workers displaced, would justify their value and eventual return. And return they have with new regulatory requirement of inspection of works for 60% of approvals. Such return was not necessary, but HIA and MBA didn't focus on QA, and their members wouldn't go with signing off and taking responsibility for their actions. Whilst I oppose the proposal that would have made it mandatory, I don't oppose the principle. Either the BWS or the carpenter should sign off, on the carpentry works. At the very minimum they should be identified, just like movie credits. This should not generate a mass of paper work. One single piece of paper identifying all suppliers to the project, where is the hurdle in that: orders have to be sent to all. Ah! But the tax office has a problem with the building industry: undisclosed income, and questionable expenses. It seems many builders don't want to document anything, they like money under the counter, and documenting stuff could interfere with that. Well for the householder fuelling the cash economy likely to get you low quality rubbish without any warranty.

So don't want to impose a system, but provide a system. Private industry always saying it can do better than government but it seldom ever proves.  We let it take over the hospitals, it stuffed it up. Take over water supply, and the infrastructure not properly maintained: as to who is responsible for maintaining the infrastructure government or private industry, is not overly clear. A good political outcome maybe: confuse the public.

So the public cannot rely on the licensed builder nor a more specifically licensed glazier. Also the public cannot rely on the government, it may have brought council building inspections back, but it can get rid of them again. Further it needs to build staff back up to do the inspections, or it will outsource the work. Out sourcing is probably the most likely option, getting the private certifiers to do inspections.

It should be noted that people oppose increasing council rates and government taxes. Public servants tend to become complacent, arrogant and otherwise see themselves as masters, with expectations of privilege. That is they ultimately reap the rewards of their job position, but fail to do the job properly. They declare they cannot do the job properly because they are over worked and more people are required. Typically not really over worked just appalling poor managers, continuing with inefficient processes.

Independent consultants who lack the job protection of public servants are a better option, they are more likely to think of better ways of doing the job, than repeating same old behaviour. The building inspections of the past by local government inspectors were not good enough, its unlikely the new inspections are going to be good enough.

There are several problems:

1) Failure to document proposals
2) Failure to seek development approval
3) Failure to control quality of materials and components
4) Failure to control quality of work processes

There is no point in an inspector saying you got it wrong, fix it! The builder should get it right in the first place, and the threat of a building inspector visiting isn't going to make them get it right. The threat of an official inspection is really more concerned with the builder who has no intention of getting it right and doesn't care. Most defects however are a consequence of poor design and poor selection of construction processes, and otherwise unavoidable human error.

The first problem to sort out is manufacturers and suppliers having proper technical specifications for there product. For example when my client directs me to an interstate glass supplier, and I request the mechanical and physical properties of their laminated glass, I don't expect to be directed to a consulting engineer in yet another state. When we then change to a local supplier, I don't expect that supplier to then direct me to the exact same consultant in the other state. The manufacturer of the glass should be monitoring and controlling the mechanical and physical properties of its glass product and ensuring it is complying with the specification for that product. It should therefore know the properties of its product, if it doesn't then it should stop supplying to both the public and to trades.

The builder and or glazier has to be able to supply glass to a project which complies to the project specification, some rubbish about it complying with AS1288 is not acceptable. If the glass manufacturers do not have proper technical specifications for their product then the builders cannot demonstrate they have supplied suitable glass to a project.

We already have builders licensing as already indicated it is concerned with supervision of works not the competence in the execution of the works. So whilst carpenters, brick layers may get the licenses, the license is not about their competence as carpenters and brick layers. Also in South Australia most licenses are restricted (RL) and the restrictions concern a system a physical product rather than a trade. For example restrictions to carports and verandahs, to steel sheds, to residential concrete slabs and footings, to retaining walls.

So if glaziers not already operating under a restricted license, then why not? Is it because the works are typically less than $5000 dollars. I doubt that the windows for an entire house are less than $5000 dollars. But then a window is a product, comprising of timber and or aluminium frames plus glass. The glass installed in a factory. Should the factory workers be licensed glaziers? I don't believe so, they should be supervised by persons assuring compliance with a specification. On site the windows are framed, so no working directly with glass, so does general builder or carpenter install the window? What exactly is a glaziers license going to be for? How much conflict and overlap is there going to be with other trades. Windows are a specialist product and do need installing to a specific specification, but what does a glazier know about windows as a complete system. Most window manufacturers declare their window frames are not structural: that is rubbish the frame has to be structural, the window has to support the wind loads and transfer to the main frame of the building. The frames are not however designed to support surrounding structure, such as the roof over.

Licensing starts looking like trade unions creating closed shops across an entire industry, and industry associations and technical societies start looking like trade unions and cartels.

We need to push back from the builders along the industrial food chain to the retailers, the suppliers, the importers and the manufacturers.

Whilst choice magazine does some independent tests on the quality of products in the market place, it does not represent large scale testing and control of product entering the market place.

Its really the big DIY stores, and trade hardware stores that we should focus our attack on defects, and from those stores push back at their wholesalers, and from them to the manufacturers. Supply officers need to be capable of more then simply negotiating prices. The product has to be the right product and in the right condition. Supply officers may get cheaper product, but its seldom the right product.

For example cold-formed steel sheds are typically specified as fabricated from Lysaght C-sections, but builders find cheaper suppliers, apparently they can get for half the price. The problem is that Lysaght and most other Australian suppliers use steel with minimum yield strength of fy=450MPa. The cheaper imported product is either not made to any specification or made to British or American specifications. The British c-sections are typically from steel with fy=280MPa, they may have some high strength versions at fy=390MPa, either way it doesn't match the specification required for the shed. If the imported steel is cheaper, then get the shed designed for the steel used, don't arbitrarily substitute materials or components.

When it comes to windows and glass balustrades the question is whether the glass supplied meets the BCA requirements for the location installed. I content the glazier and sales person is not qualified to make that judgement and neither is the householder or other building owner. The installation maybe small enough and of such a cost it doesn't require development approval or a licensed builder. But that does not mean it does not need to comply with the BCA or any other code of practice.

So I reiterate the building owner needs to employ an independent consultant to advise, inspect and supervise building works, not rely on local government inspections or licensed builders supplying. Builders licensing doesn't have anything to do with the quality of the work, just getting it done. And local government inspectors task is to ensure compliance with code requirements, not check with the owners expectations are met. An independent consultant employed by the owner keeps an eye on things for the owner. With in the current occupational framework the most suitable person for that task would appear to be a building surveyor. Architects and/or engineers may be suitable for such task, however their primary task is design and then supervising implementation of their designs. Most things in the building industry require neither an architect or engineer to design, however design and proper documentary specification is required.

I said quality cannot be inspected in, it has to be designed in. Also that it is not the purpose of QA to eliminate inspection. Rather QA has infinite inspection, or continuous monitoring of process. With QC, inspection is carried out at too late a point in the process. So for example an engineer or representative inspects the footing reo and declares its not correct. The footing contractor then has to fix the defect and the inspector return to check the defect is fixed and other defects haven't been introduced. Proper supervision gets it right in the first place and corrects throughout the process, consequently their is no need for end of process inspection.

Similarly local government building inspectors go out inspect and its already too late: time and materials have already been wasted getting it wrong.

The double inspection situation with suppliers is wasteful, but that doesn't mean the buyer relies on some third party certification and trusts the supplier. It means the buyer has a choice to make or buy, having chosen to buy they have to go check the capability of the supplier to provide product to their specifications or check that the suppliers off-the-shelf product is suitable for their purpose.

For example, back to the glazing, I said the glass manufacturer seems unable to provide a technical specification and that is unacceptable. On the otherhand grout manufacturers have a technical specification, however they will not supply the information I need. This I find acceptable. My client is not using the grout for a purpose the grout manufacturer supports and does not want to be held liable if it fails. Its a minor market with a minor use, why have their product fall in disrepute over such usage, when perfectly fine for the purpose they wish to promote.

It is the responsibility of the end-user to assess the suitability of the product. If the use of the grout for such purpose increases then the grout manufacturer may do their own testing apply suitable conservative design factors and promote further use. The result is that new entrants to the field making use of the grout may not be able to achieve by calculation using the grout manufacturers data, the same results that established players can achieve. They may then want to protest. But end-users like my client have done their own testing for their purposes and the grout manufacturers data does not invalidate my clients designs. The problem is new entrants have to do their own testing and not rely on conservative calculations based on conservative general purpose design data. For example the grout manufacturer may always apply a design factor of 3, such may be excessively over conservative for some applications. Each product designer needs to determine suitable performance criteria for their product and not just blindly comply with national standards and codes of practice which are extremely general in nature. Its necessary to get to the specifics.

So should not rely on suppliers being ISO:9000 accredited, nor rely on suppliers quality systems, nor rely on a bit of paper. The property class 8.8 bolt is fully informed about being compliant or not. The piece of paper saying its compliant may be fraudulent. The actual bolt can be tested, and the microstructure of the steel can be examined to get some idea of its heat treatment history.

A good manufacturer will conduct such testing themselves. So a producer who needs such bolts will either test bolts received or go to the suppliers and ensure the supplier has appropriate facilities to test the bolts they make. If the supplier has appropriate facilities, then the buyer may dismiss with regular inhouse testing of bolts received.

The problem is that there is now a great deal of outsourcing and middle men suppliers between manufacturers and end-users. Those bolts you thought were sourced from a reliable manufacturer get outsourced to an unreliable manufacturer. In the blink of an eye the manufacturer becomes a third party distributor who doesn't make anything.

So first and fore most business to business supply officers and supply and distribution systems need improving to properly control quality materials and components to the building industry.

For example if say an hardware store like Bianco certifies that the bolts it supplies are PC 8.8 then it is accepting responsibility for such assertion, not passing the buck onto its suppliers. Therefore if the bolts turn out not to be PC8.8 it is Bianco that will be targeted and held responsible for supply of defective goods. To make such assertion sensibly then Bianco would require systems in place to ensure that its suppliers do supply proper product. Such however would be an extra cost, and potentially not viable if loosing sales to the large DIY hardware stores which increasingly supply the building trades.

These large retailers and smaller manufacturers are largely capable of supplying at lower price because they don't overly care about the source of supplies and don't control such supplies.

The quality of the timber, steel, concrete, brick, and glass which goes into a building is dependent on characteristics which are not visible. Cannot simply look at a piece of timber and determine its strength. Bad example, actually can, the strength grade F7 etc ... is a visual grading system, its not very consistent though and its slow, hence machine graded pine MGP grades. Still if the timber is painted its difficult to grade it.

Design and engineering is primarily about controlling inputs so that have a high level of confidence about the quality and performance of the outputs.

Licensing of people controls an input, but not an appropriate input.The very process of granting licenses is low quality, based on QC principles. Education takes place and examinations carried out at the end, resources wasted on people not able to pass the exam. The examination candidate themselves just as unaware of their inability to pass the exam as the educators and examiners are.

The problem: the education system doesn't have continuous monitoring and in-process correction. Secondly the license was granted yesterday: it doesn't mean the licensee is competent today or in any way capable of self-determination of the limitations of their own skills and ability to handle the current project placed before them. If they don't try they won't know. But that trying may cause their client a lot of hassle.

Business, industry and society are failing to sustain needed skills and retain established knowledge. That individual over there can handle complex projects, the individual over here cannot. That business over there was able to handle complex projects last week, but this week it cannot. People flow in and out off industries, and neither the businesses or the industries are appropriately designed to retain knowledge and skills. Creating licensing which restricts the supply of skills further is not helpful.

Qualification frameworks are helpful, but its not productive to talk about restrictive licensing for limited skill sets. Educate and train people for certain but never institute a system that thinks there's one and only one way to do something. It is not the performance of the glazing which is an issue its the performance of the building system which is at issue. The balustrade doesn't meet the specification for the appropriate loading. The window is made from the incorrect type of glass for its location. These are design and specification issues and cannot be complied with if no one has done any design and no one has written a specification, and no one has contracted to supply to the specification.

Most contracts are of the form that you get what is supplied. If seek out the lowest possible price then don't be surprised if it is cheap non-compliant rubbish. If someone says they supply to the code then they typically supplying low quality rubbish, and if the code wasn't there it would probably be lower quality still. Really want the supplier who says this is what the code permits, this is what we supply and here is why we don't think the codes good enough to meet your needs. Now just because they believe the code is not good enough doesn't mean the code should be revised and a higher level of performance imposed on everyone. The codes are minimum acceptable standards, not a requirement that cannot be surpassed. The concept that cannot compete if exceed the minimum is also nonsense. Manufacturers have entered markets and wiped them out with products several times more expensive then the existing offering. Quality and performance matter and if real value is there people will pay the higher price.

The problem with the building industry is the quality is not there to be seen and higher prices therefore do not appear justified. The problem is the regulations the licensing. There is an expectation of compliance with the code. But the industry participants promote themselves on the basis of they comply with the code whilst everyone else doesn't. Bad approach. In other words mere compliance is the best you can hope for, chances are however likely to get a dud.

Whilst the building industry is extremely inefficient and low quality, its not totally useless dumping complete rubbish in the built environment. It just needs better process control in place, and local government building inspectors and licensing systems are not proper controls.

So if a building owner get a building surveyor to check out the building before you buy it. If want to modify a building get a building surveyor to check over the proposals. If an employer get a building surveyor to regularly review your building. Do not wait until seek development approval to get a building surveyor, the private certifier has a different function to perform. If refer to the legal system then the private certifier is the building surveyor for the prosecution, declaring the proposal is a hazard, the building surveyor typically missing from the equation is that for the defence demonstrating the proposal is not a hazard. If haven't had a consultant building surveyor review the plans then basically wasting the approval authorities time. Do not do that.

Put simply consulting building surveyors can significantly change the building industry. Most existing buildings do not comply with the current version of the BCA, that provides significant opportunity for improvement of the building. Such improvement has a cost, such cost provides opportunity to knock the sale price of existing housing down. The buildings can become worthless and in need of demolition.

Now those glass doors and the full height window beside. How can we establish they comply with the current BCA? Does the building owner have appropriate documentary evidence, they have a certificate which states complies with AS1288: so the basic answer is no, for such certificate is worthless. Now how do we check the type of glass which has been installed, without reference to paper documents? How do we determine the loading the glass should be specified suitable for? Is it possible to safely test and inspect the glass on site, without destroying and need to replace the glass? If not then see the importance of controlling the inputs, and having reliable trustworthy documentary evidence of such control.

Sun 2013-Jan-27  01:09

Sunday, September 16, 2012

On Regulation ...


Regulation to be based on the following assertions:

1) Dynamically Adaptive: with continuous monitoring and feedback.
2) Comprehensive, continuously revised codes of practice exist.
3) All persons in the system on both sides of the equation are incompetent.
4) No approval is based on 100% compliance with the codes of practice.


Assertion one follows from the natural environment being dynamic, and the very presence and action of life in the environment changes the environment. Consequently it is necessary for life to adapt to all changes in the environment if it is to survive. A regulatory system has to regulate, maintain a position of desired equilibrium within the environment of chaos. The acceptable equilibrium position of the system can be variable, it can shift depending on available inputs and accepted outputs.

Assertion three, follows from the fact that "acceptability" is a matter of subjective opinion and judgement, and regulation is imposing the view of one or more persons on the rest of the population. So at any point in time, the population at large is not fully conversant with the imposed regulations, and those imparted with the authority to admininister also not fully conversant with the requirements. This is due to the "requirements" being continuously revised, otherwise being ambiguous, and the intent and purpose not fully disclosed. Further the majority of projects encountered by any individual only involves a subset of the complete code of practice: and each individual has experience based on differing subsets of the total.

When regulations are introduced it is because someone somewhere considers that things should be different. The purpose of the regulation is primarily to control and otherwise change human behaviour, achieve a certain level of consistency and certainty in a world of chaos.

When professions emerge, they are all about they know and others don't. So architects supposedly know better than builders. Engineers supposedly know better than architects. And project managers supoosedly know better than builders, architects and engineers. Its nonsense, because across these professions there is no common core of competency, which is increasing from one profession to the other. A project manager in particular, largely concerned with managing time and money, is likely to get people killed if really needed the competencies of a construction engineer. Where once upon a time, one person took a project from concept to reality, a multitude of people are now involved, and a vast array of professions: all so called expert in something ambiguous and without clear definition. Most professionals themselves don't know what they and only they can provide. Most of which they declare to be unique to their profession, is not unique. When pointed out not unique, they declare they do it better.

Regulatory Systems based on professions and formal education are flawed. Professions are too broad and ambigously defined to form the basis of regulation of something specfic. Formal education provides foundational knowledge, it does not involve practice to the extent to develop the necessary competence and profeciency required for regulation. Regulation needs to be based on Quality Assurance (QA) principles rather than Quality Control (QC) principles. Most existing systems are based on QC principles, that is they are based on inspection of end-product, permit defects to a significant level, and then do something about fixing the defects. A QA system is based on principle that quality has to be designed in, it cannot be inspected in, that the journey is more important than the destination. Something like the old saying: take care of the pennies and the dollars will take care of themselves. That is monitor the process, and correct small incremental steps of the journey towards the final destination. This is all better achieved if workers have knowledge of the big picture, and the importance of their contribution to the big picture. Each is both a customer and supplier in the industrial foodchain. If the individuals supplies are poor then their customers supplies are also going to be poor.

Our most fundamental law is that concerned with fair trading and the need for goods to be fit-for-function. The problem is that fitness-for-function is a matter of subjective judgement. When failure occurs, the first issue which should be resolved is: did the end-user responsibly assess the suitability of the product for their purpose, was it acceptable for them to take it on good faith that it was suitable for their purpose?

My contention is that the individual should be held accountable first before any supplier. It is getting ridiculous the number of disclaimers and warning notices manufacturers have to place on their products on account of irresponsible people. It is also getting ridiculous on the number of warning notices city councils have to install along with fencing and the likes due to irresponsible people. It is largely irresponsible people playing the system to get rich quick, that causes all the inconvenience for others. It shouldn't be necessary to put signs around stating: don't stand on the edge of the cliff, or stay away from the water. So a fundamental part of a regulatory system is constraining those who would seek to exploit the system for their own benefit at the expense of everybody else.

Speaking of the ridiculous, we are not far from having to put labels on everything: warning: Shark, stay clear off teeth, sharp, very sharp.

To a certain extent professions themselves wish to exploit, when they seek to create legislation which constrains activity to themselves. Rather than bringing benefit to the community it is mostly seen as a nuisance and hindrance. As a consequence people find ways around it, or simply blatantly ignore the legislation and go against it. Registration, protection of professional titles, and licensing all becomes a joke.

We have registration of architects, it mainly protects the title. People think architects design monumental eye-sores of no practical value, consequently they go direct to builders, or to building designers or plan drafters. People think builders charge extortionate fees for no apparent service, hence people become owner-builders. People know what they want in terms of living space, so they think all that is required is to get some plans drawn up and then submit for development approval. Builders may advise that something is impossible, or otherwise quote high prices for the unusual. The result is that owner-builders become the builders of some of the more complex houses, whilst licensed builders construct boxes.

And what is the prime purpose of the builder works contractors act and regulations? Well! It doesn't have much, if anything to do with construction of bridges, water filtration plants, or multistory office buildings. The primary purpose is to protect buyers of houses, who are not considered informed buyers and not considered capable of determining the suitability of persons providing building services, or supplying buildings. it doesn't work, people still get exploited by both licensed and unlicensed builders.

The building works contractors act and regulations provides for two licenses:

1) Building works contractors license (BWC)
2) Building works supervisors license. (BWS)

For the purposes of the act, registered architects are taken as equivalent to building works supervisors. This highlights another potential problem with regulations: excluding appropriate people from the work, or otherwise adding extra costs to their being able to perform the work. There is no mention of engineers, construction engineers, construction managers, or project managers. So these professions will have to get their building works supervisors license if involved in works which may require the license or be found to require the license. Doing so may be difficult, because whilst the legislation defines some qualification framework, and that framework is primarily about supervision of works, in practice licenses are granted to persons with trades certificates. There appears to be no longer any specific requirement to have knowledge about the "construction" of a building and its component parts, nor any extensive knowledge of construction processes. Further there are restricted licenses and general licenses, most only have restricted licenses. So a carpenter has potential to get a license for single storey residential construction without necessarily knowing anything about buildings, other than the timber framing. Their primary task as a building works supervisor is simply to coordinate all the other trades, and largely they rely on the other trades to know what they are meant to do. That basically means the building works supervisor is not an informed buyer. Ah! But should be a building works contractor, shouldn't it?

A building works contractor (BWC) license can be held by either a corporation or a person. A building works supervisor (BWS) license can only be held by a natural person. The BWC has to appoint a BWS. Sole practioners require both a BWC and BWS license. The BWC license is primarily about having financial resources, and the ability to manage cash-flows to start, carry out and complete the works. The BWS license, is about being onsite coordinating and supervising the works. For many of the large builders the BWS, spends most of their time on the road travelling between sites, and consequently not supervising anything. Their role becomes one of QC with lots of rectification work, and consequential delays for new house buyers. And it is often the supposedly un-informed buyers pointing out the defects and demanding rectification: because the BWS was never there to supervise. Which leads to view of extortionate fees for both BWC and BWS, and hence large owner-builder culture. If want it doing right, then do it yourself. So the owner-builder manages their own finances, and otherwise coordinates the services of the sub-contractors, and otherwise relies on them to know their own particular role. Owner-builders not being licensed builders are required to live in their house for a minimum amount of time and are otherwise restricted from building another for a specified length of time.

A few years back, the role of developers was considered, and whether they should be required to have a builders license. I believe the basic argument was it wasn't necessary. Developers generally managing their own finances, or otherwise upto the lending authority to determine if developer able to manage finances. Secondly most otherwise employ the services of BWS, or otherwise coordinate the services of sub-contractors each of which has either a BWS and/or BWC license. For it seems it is possible to operate a business with only a BWS license, on condition not contracting to supply the building works, only to supervise, and the owner otherwise manages the finances, and otherwise all sub-contractors work direct for the owner and have both BWC/BWS licenses. I think its treading a fineline, and a risky approach, but otherwise possible. The issue is that the BWC normally completes a stage of work and gets paid for what they have supplied thus far, if they can manage the stages and cash-flows effectively then they can carry out works far in excess of their financial resources. When working through a BWS only, then the owner has to control the cash-flows and is otherwise responsible for insurance on the building. For the ultimate issue is not whether the owner is happy with the building, but whether the building is suitable for selling to others, and whether or not it poses a hazard or nuisance to the community at large.

Whether constructed by a licensed builder or an owner-builder, a building requires a certificate-of-occupancy before anyone can move in. The certificate-of-occupancy, is issued by a building surveyor (BS) either working for city council or as a private certifier. Building surveyors were once architects or engineers who specialised in the regulations, building surveying is now a profession in its owner right, with its own qualification framework. They now know more about the regulations but less about architecture and engineering: but possibly greater consistency in compliance checking against the regulations.

Any case the certificate-of-occupancy is dependent on certain inspections either by the BS issuing or BWS, or possibly others suitably qualified to ascertain that construction was in accordance with approved documents. When the 1993 Development Act and regulations were being brought in, there were attempts to get each sub-contractor to sign-off on their part of the work, it didn't get very far. On the other hand the principal BWS working for the principal contractor is responsible for accepting or rejecting the work of subcontractors (subbie). So the BWS can sign-off on the subbies work. That is the BWS can implement what ever systems they wish, to safeguard themselves. So principals can exercise more aggressive or assertive practices directed towards the quality of the subbies work. There is a standard form: Statement-of-compliance in the development regulations. This form is to be signed by both the BWS and the building-owner, and completion of such is part requirement before the certificate-of-occupancy can be issued. There are certain stages of work which need to be checked, most especially checking of that work which will be hidden on completion of the building.

Irrespective of what is mandated by regulations or how appallingly it may be administered, especially since 1993 when much of the city council inspections ceased, there is an intent and objective behind the code, and the primary requirement is to demonstrate that a finished building is suitable for purpose. Subject to the occupational, health safety and welfare act (OHS&W) there is also a requirement that the construction processes used are safe and that all industrial plant used is also safe.

The SA OHS&W Act and Regulations may now be obsolete. Not sure whether we have or have not adopted the national system this year, and what changes it makes. Quite frankly I don't really care. OHS&W clearly highlights the stupidity of regulations and regulators: make laws, institute penalties, and keep increasing penalties hoping the problem will go away. The entire solution and focus by OHS&W consultants is to create laws and make penalties greater as a deterant to unsafe practices. Laws and higher penalties doesn't solve anything.

Just take speeding on the roads. The government is annually accused of using speed camera's and handheld radar guns for collecting revenue. The government says not. The equipment is expensive and from overseas, they collect enough from speeding fines to buy more of the equipment.  The government advertising is that "speed kills". If this was true then the police would have a shortage of body bags, not an accumulation of funds to buy more speed camera's. They are accused of using statistics to determine the hotspots where they will generate most revenue. Its a QC approach, break the law, impose the penalty. The penalty just becomes a cost of doing business, or away of life. In the main people don't go out of their way to speed, they just don't pay constant attention to their speedometers. If the real concern was public safety then would take a QA approach and use the statistics to implement solutions which would slow the traffic in the hotspots, and both speeds and revenues would drop.

When it comes to OHS&W, the employers cannot implement safer systems if they just made a massive payout as a penalty. Nor can they implement safer systems if there is no guidance as to what constitutes a safer system. Further if decisions are purely financial, then a monetary penalty just becomes the cost of doing business. If the risk of a penalty is low, because risk of accident is low, and otherwise safer systems are high cost, then unsafe practices will remain. Employees are also partly to blame, which existing OHS&W regulations recognise. For example, employers provide safety glasses, but employees refuse to wear, and employer responsible for making sure they do wear. So if employee gets injured both parties are at fault. But there is another issue, and that is the one sided view of employees, that owners are getting rich whilst they get injured. Not always so, and it ignores the housing, cars and vacations that employees themselves expect to afford. The current workers maybe lucky and able to work safely, but a newcomer may not have such proficiency and luck, and the current workers luck may run-out.

The basic requirement behind all the regulation is that products and processes are suitable for purpose, and that actions taken pose minimum hazard to the community at large. The regulations are in place due to failure of individuals and corporations to exercise due-diligence, exercise a duty-of-care and select suitable products and processes and otherwise minimise risk of hazard. Regulations exist due to a culture of self-interest and not caring about others in the community. Everyone wants the regulations imposed on everyone else, but for themselves to be exempt.

Have a dispute with a neighbour, and one thing they will do is raise an issue with the city council about any building works that have taken place on neighbouring property. A city inspector may come round an inspect or may just get a notice of illegal construction and request to remove or apply for development application. If such happens then need to be able to demonstrate that the existing building complies with the building code. That poses a problem, because many of the required performance criteria are concerned with physical properties of: materials and or component parts of a building. These properties cannot be determined by a visual inspection. Further many things which require a visual inspection are no longer visible in the completed building.

Whether a building or other product, there is much in the finished product relevant to its performance which cannot be assessed by a visual inspection. Engineers coming out, kicking dirt and looking at stuff is largely a total waste of time. There is a need for evidence, real documentary evidence of what has been built. Not some paper shuffling exercise of what should have been built, but what has actually been built.

In the main we in Australia expect to live in a relatively democratic society with reasonably free market. Once again regulation is seen as failing. The competition watchdog, is protecting the wrong thing: it protects competition rather than diversity of suppliers. By protecting competition we allow the big retailers and supermarkets to wipe out local stores, it supposedly brings efficiency and lower prices. Once they attain monopoly, they may then experience penalty. What exactly is the difference between a large national retail corporation and a cartel? The big supermarkets are accused of pressuring farmers and pushing to buy for less than costs to produce.

But what does it cost to produce? One problem with manufacturing has been that protection of local industry dependent on certain productivity gains, but many of the gains claimed were pseudo improvements. There may well be potential in the farming industry to produce for less, but if no pressure to do so, then in the main they won't implement any productivity changes. That suggests that may be competition is required to bring about gains. Personally I don't believe the focus should be on competition, the focus should be on sustaining a diversity of suppliers. Each supplier having a clear differentiation from others. That suppliers focus on added-value and quality, rather than lower prices. The population is not altogether focused on a lower priced basket of goods. The populations focus is being able to afford the goods they need and having some cash to spare for luxuries. The spare cash has been decreasing. If they can get what they need at a lower price and at an acceptable level of quality, they will buy the lower priced goods.

Quality does not equal high performance, it equates to required and accepted performance at the right time. The more expensive product may last longer, but the lower cost product can be bought when needed: less need to save, less need to use a credit card. The added value is not so much in the lower price, but the associated payment schedule and otherwise lack of interest payments. In the long term the higher priced product may be an over all lower cost, but in the short term it is not an attainable goal.

That is where regulation becomes hindering rather than beneficial. Regulation sets performance criteria which whilst low are typically not low enough, and consequently hinder persons in buying goods best suited to their needs. Additionally once in place the performance criteria tend to increase from year to year, making it increasingly difficult for more and more people to obtain that which is suited to their needs. Legislation is primarily to protect buyers from unscrupulous suppliers, but there should still be a responsibility on the part of the buyer to become appropriately informed about the goods and services they propose to use.

The basic decision to buy rather than to make is because do not have time and other resources to do one self, knowledge is typically only a minor reason for choosing to buy. For example cannot perform surgery on yourself, but the doctor should not be so arrogant as to assume only they can understand anything about the operation. Its the patients body that the doctor (sawbones) is going to hack into, the patient has a right to know about the procedure and the objective and intent of the operation. The doctor may spend a long time studying to become a doctor, but they don't spend all that time on a single operation, and the science behind medicine is increasingly becoming common knowledge. Also when it comes to medicine people can grow the ingredients for herbal medicines, they can buy medications from supermarkets, or from pharmacists, or get a prescription from a doctor. They can also try the services of practitioners of alternative medicine.

In the main people have freedom of choice. The issues are:

1) Is the buyer appropriately informed and acting responsibly.
2) Is the supplier acting irresponsible and deliberately misleading.

Now all the law can do is punish after injury, and otherwise seek compensation. What we really want regulation to do is prevent the injury, and avoid the need for compensation. For example the people would rather that the global financial crisis (GFC) did not happen. On the other hand they would also rather that those responsible were punished rather than being given massive payouts. Punishment however doesn't solve the current problem, nor prevent future re-occurrence.

I spend a lot of time dealing with problems caused by a failure to carry out appropriate planning, design and management towards desired objective. Clients bumping into the regulations at the wrong time. Their behaviour is exactly why the regulations emerged in the first place. But the regulations based on QC principles permit far too much progress in the wrong direction before they kick into play.

Whilst I may often consider that my life would be easier if there was more regulation and could spend more time on design and avoiding problems in the first place, I ultimately conclude regulation wouldn't work. We have regulations, they fail, and they fail because we don't have the resources to properly police and enforce. More regulation would require more effort at enforcement.

What we need is less regulation, simpler regulation, more generic. As my dad is always citing, in England they apparently only had one simple driving law: driving without due care and consideration.

In Australia we have road rules which seem to be classified as law: so comes down to arguing technicalities. So lots of articles on current affairs shows about tolerances and accuracy of speedometers and speed cameras. So skip that person wasn't driving without due consideration to other road users: they weren't exactly over the speed limit, not known for certain anyway, therefore can get off paying speeding fine. With simpler law don't care about proving for certain above speed limit, only that they weren't at or below the limit.

Those that argue 10% error in speedometer, only consider one direction, and otherwise tend to be tailgaters. If there is such error, then when speedometer at 60km/hr, then have +/- 6km/hr variation. So vehicle's actual speed could be somewhere between 54km/hr and 66km/hr, a total of 12km/hr difference in speeds. If ask me that's too great an error to be permitted. The person being tailgated at the lower limit, the tailgater attempting to travel at the upper limit, the tailgater using the accelerator rather than the break, trying to pressure the slower vehicle out off the way: basically driving without consideration: driving by instruments rather than with care. Given the actual velocity can be 66km/hr, and the limit is 60km/hr, they have potentially exceeded the speed limit.

There has to be tolerance in regulations to allow for variation. In terms of the speed limit, it is an upper limit, variation is only permitted below never above. But there is an issue on ability to measure. If all instruments have a bilateral error, then at 60km/hr all measurements will indicate a real value which is slightly above the speed limit. Therefore would always have to be driving at less than the speed limit, so that the upper limit on the error is below the mandated speed limit. Such is impractical. It is therefore necessary to specify the method of measurement in particular its accuracy and precision. Is 60.1 km/hr above the limit, or is 60.05km/hr above the limit? What variation will we tolerate?

Most of our codes of practice are distinctly lacking in tolerances, most especially the building code of Australia (BCA). Though there are some general statements about: "to the degree necessary". It then being left as a matter of judgement. The BCA is currently revised each and every year, mostly removing ambiguities, and otherwise explicitly excluding from the scope of the code or otherwise explicitly bringing into the scope of the code. So the majority of buildings do not comply with the current code. All houses built prior to 2012, will not fully comply with BCA:2012, next year houses built this year will not comply with BCA:2013. More than that no house built this year will fully comply with BCA:2012. It will only comply to extent of the assessment made, in the time available. Another person looking at documentation may identify additional issues to be addressed and require design changes to achieve compliance. Another person looking at the actual construction may require additional changes before issuing a statement-of-compliance, compared to the person who issued such statement. 100% inspection seldom ever picks up 100% of defects. So there will always be defects in the design, defects in the documentation of the design, defects in the assessment of the documented design, and defects in the construction, defects in the supply of materials, defects in the inspection of the building at any stage. The ultimate objective is not to get rid of these defects, but to make them so small and insignificant to the extent that the product is robust enough to perform satisfactorily despite the presence of defects.

For me regulation is just a carry over from a culture with a QC mentality. As a culture we haven't really grasped quality assurance, and ISO:9000 series of codes is a relatively poor substitute for real quality, but probably better than nothing. The problem with ISO:9000 is that people have the wrong approach in the first instance: wanting accreditation: is having an accept or reject mentality: and that is something which has to be rejected to implement real quality systems. The implementations end up as bureaucratic paper shuffling, tracking defects produced and laying of blame. In short simply have it nicely documented that the business is defect ridden. Don't buy from ISO:9000 company because likely paying an extortionate amount of money for defects, whether the defects make it to you or not. Further their systems are slow, so a few years down the track, may get a recall, because now discovered supply of defected work. There is no real quality there. Now when start being more rigorous with audits, then get fewer accredited suppliers, but then it starts to become questionable as to whether it really matters. Are you imposing demands so high that shooting self in the foot? Well the answer there is you're not doing it, some third party is, who isn't interested in your needs. With the origin of QA the buyer did the audit of the supplier, the buyer was informed, and for the buyer it was better to improve the quality of suppliers, than to set up and make the component themselves. The buyer invests in the supplier and expects some return on such investment, such as lower supply price. If not then they will achieve the desired economy by making the component themselves. The buyers are therefore informed or capable of becoming informed.

If don't have informed buyers, and not able to properly police the regulations, then no real point to regulations. If must have, then simple and generic is preferable.

A Proposal for building Industry (possibly other areas).

Simply have a register of practitioners. No classification as with the Victorian system. I don't care about job titles of professions. From an industrial engineering viewpoint, I can divide and combine job functions and design a whole new array of occupations and professions, which have potential to do the job more productively and with higher quality than the current array. Such is not a technical problem however, but socio-political. Like engineers don't like being referred to as cogs within the machinery of industrial society. Apparently these employees are something more than a cog. Sorry! but no they are not, all persons operating within the machinery of industrial society are cogs without exception. Breaking free of the machine is extremely difficult if not impossible. Most don't want to break free of the machine, but redesign the machine and build it differently. For example a desire to impose regulation on others, and create exclusive little empires.

So as may have become apparent from other posts, I oppose legislation which restricts supply of services, and therefore I will oppose anything specific about engineers. I don't oppose in terms of approving authority, only in terms of supply of services. So the SA Development Act and Regulations has some activities restricted to persons on the national professional engineers register (NPER). The only issue I have with that, is that currently the assessment process for being on the register is based on largely irrelevant nonsense, and misses the real technical issues why we make reference to NPER. Put simply the legislation can bring us more trouble than benefit.

So my proposal is a simple register, without any prior assessment, there is no implication that those on the register are competent, there is no major restriction of services to those on the register. All persons working for regulating authorities and granting approvals, and all private certifiers, are required to be on the register.

The regulating authorities having jurisdiction, will only accept documents which have been endorsed by a person on the register of practitioners. It doesn't matter what they are, its not on the register. If scribble on the back of an order form by a salesperson, is suitable documentation for a garden shed, then a sales person can be on the register. The issue is when the salesperson submits similar scribble for a large industrial facility. Buyers who choose such approach largely deserve all the hassle they get from the authorities. However it causes a great deal of inconvenience to everyone else in the industry, and other buyers.

It causes inconvenience to other buyers because businesses which supply design services, have to spend their time fixing up other peoples mess. Whilst design consultants are fighting all these regulatory "bushfires", people who are trying to do the right thing are hindered in accessing design services. This results in people considering that seeking approval takes too long, and therefore they go ahead and build without development approval, which then becomes a future regulatory bushfire to put out. So system becomes a self perpetuating lock into fighting fires.

The proposal is hopefully a simple means of breaking out off the current system of endless emergencies all requiring immediate attention.

Its relatively simple in operation. The regulatory authority receives documentation unsuited to the scope of the project. The person who submitted is removed from the project, and a black mark put against their name on the register. Too many black marks they get struck from the register. This does not stop them from supplying, it simply prevents them from endorsing documentation for submission to the regulating authorities. They now require someone else to review their documentation, and endorse before submitting to the regulating authority. The other person has to be a registered practitioner (RP), since they risk being struck from the register for someone else's work, they will need to carry out a thorough review of the work, or insist they do the work themselves.

The consequence of this, is that many cold-formed steel shed suppliers for example will quickly have their salespeople struck from the register as quickly as they were first registered. The sales people will then have to seek the services of other salespeople who have remained on the register, or otherwise seek the services of drafters or engineers. None of which need to be registered, its just faster for all concerned if able to endorse and submit own work, rather than get it reviewed and endorsed by someone else. Owner-builders cannot be registered, but all practitioners in the industry can be registered. Note it is: can be registered, not a requirement.

The only requirement is that documentation submitted for approval is endorsed by a registered practitioner, and that the regulatory approval is granted by someone on the register. Getting on the register being easy, staying on the register difficult.

It also partly assists with respect to those complaining about fees. The plan drafter wins a job, but gets removed by the regulating authority, the job then has to go to someone else, and be reviewed and endorsed by a registered practitioner better suited to the project. If the plan drafter wants to take on more challenging projects and remain registered to pursue simpler projects without hassle of paying someone else to review their work, then they should seek review at the appropriate time. The need for such review becomes an extra expense, and the party providing such review may well be competing for the same work. More likely however, that the party reviewing the work, would never have otherwise been considered, and the work would never have existed. Some projects just need drawing up, and then otherwise should be reviewed and rejected without involving the regulating authorities.

What happens with salespeople, plan drafters and others in the industry, is that by the time a proposal has been bounced back and fourth between the regulating and authorities, and engineering eventually supplied, the proposal is far too expensive for the owner to pay for. Yet they have otherwise wasted money attempting to get regulatory approval. If they do get regulatory approval they also have a limited time in which to complete the approved building works. If it turns out more expensive than anticipated, then may use up all the available time getting approval for additional funding, and thus have to seek regulatory (development) approval again. Alternatively if too expensive, may then expend more time and resources simplifying the design and getting approval again. All of this is really supposed to have occurred before seek approval.

Plan drafters draw up floor plans of what the buyer wants, but it doesn't mean its possible to put walls around the space or roof over it, using conventional building materials and technology as desired and documented. Plan drafters don't design, and they don't assess fitness-for-function of designs against scientific principles, at best they may use prescriptive codes: though in general they have never read any of the codes, don't have the codes, and rely solely on regulating authorities to tell them what to change. It causes unnecessary delay for the buyer, and city councils are blamed for the delay (always changing the rules), making people think that councils are a hindrance. When in reality the plan drafters, builders and many others are the problem, because they don't know the rules: just one solution which sometimes complies with the rules, but not in all situations.

Under the proposal we will still have all the service providers we still have, and the delays experienced will remain. But the delays will now have a cost, for no longer can buyers use the city council building officials as design coordinators, nor as checkers of designs and documentation. However, approval itself should be faster, because the building officials will only be checking suitably documented proposals. That is the documentation received by council will be fit-for-function.

The quality of documentation will improve, hopefully due to more attention to design, and constructing the building on paper rather than: simply putting lines on paper as a token gesture towards representing the proposed intent.

Once the register is in operation some may suggest that registration be limited to those with suitable qualifications, such as building surveyor, architect or engineer, I propose not necessary. The purpose of most  regulation is to achieve minimum compliance for performance of end-products, the quality of service is little considered, that is how the end-product gets the required performance is irrelevant, only that it gets it. Compliance with some wishy washy definition of a profession, or its whimsical capability is of no consequence. Getting on the register is easy, staying on the register is difficult, getting back on the register is impossible or extremely difficult.

Staying on the register requires working within scope of capabilities and sustaining a portfolio of work that gets approval first time every time, with zero to minimalist requests for further information. Getting struck from the register means failed to work within scope of capabilities and work generating an annoying amount of requests for further information on a regular basis. What the annoying amount should be is a matter for determination, but I suggest 3 to 5 black marks against the name on the register, results in being struck off.

Getting back on the register requires working in scope of capabilities, and building a portfolio of work endorsed by a registered practitioner (RP) with little request for further information and little need for revision of the work. That is demonstrating the capability to stay on the register once granted approval to be placed back on the register.

Getting work reviewed and endorsed by an RP costs money each and every time: no regulated fixed fee as there is with development approval. Each and every review and request for further information generates additional cost. Further just as the plan drafters etc.. currently blame the city councils for delays, they will start to blame the RP's for delays. It is therefore not good for the RP's business to do review work for persons who think it is all a game. The RP's could increase costs of review work, to cover the hassle of being taken away from their design work: or simply ask the plan drafter (other) to go away, as not interested in their work as its more trouble than its worth. Increasing fees would simply put the cost of review beyond the capacity of the plan drafter to pay from the fees they earn from their work.

Defining qualifications not necessary, simply have to work within scope of capabilities and otherwise increase capabilities to match scope of work which they attract. As for the regulators, well they have codes of practice to ensure compliance with: they can do it blindly and pedantically, thoughtfully or whimsically. Qualified or not we have no real control over how well they do their job: but they are equally well in a position to be struck from the register.

Once there are two complaints against an RP, then an independent audit of that RP's portfolio of work can be carried out. If found unsatisfactory then the RP can be struck from the register, if that happens and they are on the approval side of the regulations, then they are also in a position where they can loose their job. At the very minimum, demoted and placed under supervision of another RP. New persons for the approval side of the regulations will only be taken from the register, and only after they have had a minimum of 10 years continuous registration. The skills on the approval side should therefore start to improve: no raw graduates with bachelor degrees in building surveying.

It should also be noted that an unofficial independent audit can be carried out at anytime by anyone at a cost. For all that is required is for one RP to get their work reviewed by another RP. For significant and complex projects, this is a desirable approach. Thus whilst one consultant may not win a given project, they may however pick up experience as an independent reviewer. In the market place an independent reviewer can be as harsh as they wish compared to government regulators. Government regulators are seen as obstructive when make harsh assessments. When a business makes a harsh assessment that's what they get paid for, don't like their approach then find someone else. This is not the same situation as private certifier where by cannot remove them from project once appointed. This is an optional and desirable review, and opportunity to see how others in the market work.

Returning to the shed salesperson's scribble again. Their starting point for an RP may be a plan drafter, but the plan drafter refuses to endorse the scribble: it is below the quality of work they normally produce. But the scribble on the back of an order form is all that is required, the problem is the saleperson lost RP status, and now requires an RP to endorse, but cannot find one at the right price and who can produce appropriate documentation in the right time. The shed supplier has a problem to solve. They can adopt computer software to resolve the issue of providing appropriate documentation in a short period of time, but still have an issue of getting an RP to endorse each and every project.

Shed suppliers have a habit of submitting any documentation in convenient reach, and not necessarily relevant to the current project. Further they fail to realise that they are making design decisions and the engineer responsible for the standard calculations is not responsible for the current project. The engineer is not the one who said the design was suitable for the current project, but the salesperson. The salesperson is the one making an assessment of the wind loading at the site and any other conditions. If the building fails, the issue isn't whether the building was suitable for intended purpose but whether it was suitable for the current purpose.

Now the RP endorsing the design for submission to the approving authority is not responsible for the design or its suitability for an intended purpose, they are however responsible for getting it designed to be suitable for intended purpose. Suitability assessed by approving authority is simply compliance with codes of practice. The RP is therefore responsible for employing the appropriate people to achieve a compliant design.

If the shed supplier makes use of software, they still need an RP to endorse that the input/output of the software is relevant to the current project. They therefore really need someone on staff, not an external consultant. They therefore either need a salesmanager who endorses all the proposals before submission to council. Or allocate the task to estimator, material take-off people, or employ appropriately skilled technical person on staff.: such as associate technologist(structures).

The approach is QC, since defects are permitted and penalties imposed. The penalty being: that get struck from register and commercial life is complicated as a consequence. At no stage is anyone identified as more competent and capable. The approving authority simply has a job to do, make an assessment against the approved codes of practice. The applicant for approval has a job to do, produce documentation which argues their case for being granted regulatory (development) approval.

In setting up the register, there is no concern about shortages, there is no concern about numbers to make the register work, there is no concern about the cost of assessing qualifications for there aren't any. Everyone who practices in the building industry (or OHS&W or other area as appropriate) is permitted to register. Most already know what type of projects generate requests for further information from council, and they know who fixes this for them. So it is their own fault if register as RP, and get struck off almost immediately. Setting a minimum period of say 5 years before can get back on the register, will provide some incentive to seek the services of appropriate RP in the first place.

By not setting required qualifications, the register assists industry to determine appropriate education, training and qualifications to suit its particular needs. Thus they train people to suit the scope of work. As the scope of work gets more challenging, the supplier starts interacting with consultants and other specialists. Individual RP's may improve their qualifications and obtain work with the consultants the shed supplier does work with. The shed supplier will then need a new RP. The shed supplier provides experience on simple and relatively repetitive projects from structural design perspective, but this becomes good foundation for designers moving onto more complicated projects. But the opportunity to tackle more complex projects can only be offered elsewhere. In similar manner, many consultancies have little repetitive work on which to develop basic skills to high proficiency, they need people with a higher level of proficiency at entry level positions.

Business can base its job roles on any suitable qualifications it chooses. So when the plan drafter turns up at an RP's office for a review, they can be advised to go elsewhere because they do not meet that businesses requirements for employment as a drafter, and as a consequence it will be a harsh and expensive exercise for them to get endorsement. The result of such behaviour, will be the formation of business networks suitable for particular types of project and providing for at an appropriate level of quality and productivity.

Clearly one shed supplier is not going to get their submissions endorsed by another shed supplier, but neither are they going to go to the big city consulting engineers to get endorsement. There is simply an imposition to rely less on the approving authority to find out what is required, and a need to pay someone to get the documentation right. Getting the documentation right requires technical design skills, not simply drawing skill.

My interest is getting design skills of an appropriate level into industry where they are used, rather than higher skills locked away in large consultancies where the skills are too expensive to buy, for those with the need, because the consultants over estimate their actual contribution, importance and worth to smaller projects.

It is easier to design, than solve problems due to lack of design. It is easier to design and achieve compliance in the first place, than it is to modify existing illegal construction and bring it into compliance.

If regulation is not appropriately policed and people see it as hindrance they will avoid. Regulatory approval needs to be fast, and needs to provide benefit. Approval cannot be fast if people still carrying out design whilst attempting to get approval. Need to get design done before approval is sought. Description of proposal is not design.

With the right regulation will build the skills of the workforce, increase competence, and improve quality and productivity. If implement inappropriate regulations then entry to the workforce, to an occupation becomes too difficult and expensive, and so does starting an alternative business.

Entry easy. Staying difficult. Getting back in, impossible or extremely difficult.

Sun 2012-Sep-16  00:09AM