Additional guidance for regulation 17, 2010 quality assurance requirements
Regulation 17 of the Building (Accreditation of Building Consent Authorities) Regulations 2006 sets out the quality assurance requirements which must be implemented by building consent authorities by 30 November 2010.
The following information has been taken from the Building Consent Authority Accreditation Preparation and Self-assessment Guide 2007.
The purposes of regulation 17 are to ensure:
- a building consent authority continually strives for high-quality outcomes in all aspects of its building control operations and has the necessary tools, processes and systems to achieve this
- the quality assurance system is managed, fully understood and consistently applied by all employees and contractors undertaking building control functions
- a building consent authority's senior management team reviews its quality assurance system at planned intervals to ensure the system's continuing suitability, adequacy and effectiveness.
A quality assurance system is a documented system that describes the building consent authority's structure, responsibilities, procedures, processes and resources for implementing quality assurance management principles to:
- achieve its performance objectives and building control outcomes
- ensure it meets its responsibilities and obligations
- enable it to continually improve its performance and service delivery.
Sound quality assurance systems will ensure building consent authorities strengthen their decision-making at the critical building consent, inspection and approval stages of their work. This will lead to better quality and greater consistency in the performance of building control functions and improve the level of compliance achieved for all building control work undertaken by building consent authorities, in turn leading to greater consumer confidence.
Content of a quality assurance system
Sound quality assurance systems should be living documents that are updated as building consent authorities' operations change or areas for improvement are identified. A quality assurance system should include all of the activities that contribute either directly or indirectly to quality. There is a small amount of duplication between regulations 5-16 and regulation 17. This is intentional. Documented policy and procedure systems require basic quality management principles to be effective. It is not possible to implement some policies without giving consideration to quality assurance management principles.
Quality management leadership and the role of employees and contractors
Quality assurance systems need to be comprehensively implemented to be effective. While it is important to assign responsibility for managing the quality assurance system, ensuring quality should be part of the responsibility of everyone in the building consent authority. All employees and contractors must have ready access to the building consent authority's quality management system and have received training in its content and operations, and how it applies to their work for at least the relevant sections that cover the tasks they perform. Some aspects of the quality assurance system will have greater relevance to some employees and contractors than others. It is important that building consent authority employees and contractors have the opportunity to participate in the development and ongoing improvement of the quality assurance system where this is appropriate. The building consent authority should also have mechanisms to ensure its employees and contractors are consistently applying its quality assurance system.
Review of the quality assurance system
To be effective, quality assurance systems need to be reviewed and updated when there are changes to the regulatory environment and operating practices. Regular strategic-level reviews are one means of ensuring the building consent authority assesses the need for change and acts on it. Such reviews should include consideration of the need for changes to the quality assurance system, including the quality policy and quality objectives. Outcomes of any review should be recorded and progress to implement any decision tracked to ensure changes are implemented. This review is required by regulation 17(5).
Regulation 17(2) also requires that a building consent authority undertakes three different types of review.
- The procedure for management to review the authority's performance (17(2)(d))
- The procedure for ensuring that an internal audit of every building control function is undertaken within 12 months of the previous audit (17(2)(h))
- The procedure for management to review the effectiveness of the authority's quality assurance system (17(2)(n))
Further assistance with developing quality assurance systems
To further assist building consent authorities to prepare and implement quality assurance systems, the Department is planning to collate and share good examples of quality assurance systems, develop further guidance including templates and resources and hold a series of regional workshops in the later part of 2008 to introduce the material to the sector.
Two-yearly assessments and 2010 requirements
Accreditation assessments are required to occur at least every two years. The next rounds of assessments are likely to begin in late 2008 for those already prepared. For others, they will generally be timed around the anniversary of a building consent authority's first assessment.1 Building consent authorities are not required to meet the 2010 requirements until 30 November 2010. However, depending on the timing of their next assessment a building consent authority should have their quality assurance system effectively implemented and available for assessment. Evidence of effective implementation of quality assurance systems will be required such as completed management reviews and internal audits. If the BCA's quality assurance system is not assessed at this next scheduled assessment, the BCA will require a special assessment2 before 30 November 2010 to assess the effective implementation of the 2010 requirements.
To avoid the need for two separate assessments before November 2010, the Department encourages building consent authorities to develop and implement a quality assurance system, as soon as possible and before their next assessment. This will allow plenty of time to fine-tune the system and develop the required evidence of effective implementation before their next assessment. It will also allow more time to address corrective actions which will inevitably arise and to clear these well before the 30 November 2010 deadline.
Streamlining and refining documented systems
Looking for ways to streamline and refine documented policy and procedure manuals should be a focus of continuous improvement in the coming months. BCAs have taken a variety of approaches to document their systems. One thing for BCAs to consider is the need to implement and maintain their system. Simple systems, which simply meet the requirements of the regulations, may be more effectively implemented and maintained rather than large, complex and overly comprehensive systems. These sorts of systems, with multiple manuals and which exceed the requirements of the regulations, risk grinding the organisation down in unnecessary bureaucracy.
There has been confusion about the meaning of the term 'policy' as used in the regulations. The regulations use the term in the context of operational rules or statements of intent rather than higher level statements which might require political approval. This has led to a lack of guidance in the form of a policy statement for each core BCA process. This policy statement should document the scope or boundaries of the process and include who the policy covers, where the policy applies (and any exceptions) and note who has approved the policy.
- IANZ will work to spread the workload over 18 months and so may negotiate an earlier or later assessment date with the BCA.
- This attracts an additional fee - refer Building (Consent Authority Accredition Fees) Regulations 2007.
Some authorities also mistakenly thought that documented procedures could simply consist of statements of intent. However, the expectation is that procedures must also include descriptions or specifications of how things are done. Procedures show a team which member does what, and when and how something is carried out. Procedures should identify trigger points for action and give guidance on any limitations or special considerations that may apply.
For example, if an application is incomplete, the applicant is notified, and the application is not lodged in consent system. Although it is difficult to give guidance about how comprehensive procedures need to be, when ambiguities are noted by the IANZ assessment teams and/or the need for further guidance is raised by staff in the course of their work, procedures need more clarity.
Another underlying requirement of the system is to identify the records that provide evidence that the procedure is being followed and that the required systems have been implemented effectively. Examples of records may include completed consent and inspection check sheets, providing they record the outcome and reason for key decisions.
This is important because Regulation 6 requires BCAs to record details of decisions along with the rationale for making a decision, whether positive or negative. The policy statement or procedure should define which decisions are key decisions and identify the scope of decisions for which this information is recorded.
On the other hand, some policies and procedures contain too much extra information or unnecessarily repeat the same information in a number of policies and procedures. Some also do not clearly separate policies and procedures and cover issues which are not required by the Building (Accreditation of Building Consent Authorities) Regulations 2006.
All accredited BCAs should now aim to review their documentation to ensure it is 'pitched' appropriately and records the right amount of detail. Unnecessary information should be removed. Streamline and refine your systems now during 2008.
The Department will develop further guidance material to assist the sector over the coming months.