Building consent authority accreditation and registration update
Accreditation progress, case advisor support, common assessment issues, building control qualifications
The number of territorial authorities (TAs) accredited and registered as building consent authorities (BCAs) continues to grow.
As at 29 February 17 TAs and two private organisations contracting to TAs had been accredited. Thirty-one other TAs had completed their full on-site assessment by International Accreditation New Zealand (IANZ) and are either addressing corrective action requests (CARs) or going through IANZ's final accreditation approval processes.
All TAs and regional authorities (RAs) must be accredited and registered as BCAs by 30 June 2008, or have transferred their statutory building control functions to an accredited and registered BCA. Eight RAs and one TA currently intend transferring those functions. Others are expected to consider this option.
This update outlines:
- the support still available to TAs and RAs from the Department's case advisors
- IANZ's 'confirmation of progress' process
- the benefits of accreditation, as identified by three recently accredited BCAs
- common issues noted during the assessment process
- the development of building control qualifications
- building control accreditation schemes overseas.
Table 1: Update of assessment for accreditation
| Territorial authorities (73 in total) |
Number |
| Accredited |
17* |
| Full on-site assessment completed |
31 |
| Pre-assessment completed |
23 |
| Document review completed |
1 |
| Transferring building control functions |
1 |
| Regional authorities (12 in total) |
|
| Document review under way |
3 |
| Intending to become accredited |
1 |
| Transferring building control functions |
8 |
| Private organisations contracted to territorial authorities |
|
| Accredited |
2** |
| Full on-site assessment completed |
1 |
| Document review completed |
1 |
Accreditation assistance package
Now that most TAs are well advanced towards accreditation, and with the Government's $3 million accreditation assistance package largely exhausted, the Department has reduced its network of case advisors to five.
No further funding is available for council-specific accreditation preparation projects, the Department having decided, after considering feedback from TAs and RAs, and Local Government New Zealand that the remaining funds would be best used to continue to provide case advisor support.
Five case advisors, headed by project manager Steve Garner, are still available. He, Roger Austin, Andrew Minturn and Neil Kirk are working with TAs preparing for accreditation, while Murray Sim is supporting RAs that are either preparing for accreditation or plan to transfer their building control functions to an accredited and registered BCA.
In addition to the support case advisors continue to provide to TAs and RAs, senior management from the Department have been meeting with some of those having particular issues preparing for accreditation, to see how the Department can further assist them and to encourage them to prioritise their preparation work and maintain momentum.
The reduced case advisor network means the remaining case advisors need to prioritise their support to TAs and RAs. Also, several TAs have made limited progress towards achieving accreditation and, without increased activity, now run the risk of not meeting the June 2008 deadline. So, as well as providing support for those progressing through the accreditation process, case advisors can also work with these TAs to consider contingency plans and alternative arrangements, such as contracting out to another accredited and registered BCA or transferring their BCA functions.
Case advisor contact details
Roger Austin
Email: raustin@kol.co.nz
Phone: 021 756 823
Andrew Minturn
Email: andrew.minturn@dbh.govt.nz
Phone: 021 669 528
Steve Garner
Email: steve.garner@dbh.govt.nz
Phone: 021 525 121
Murray Sim
Email: murray.sim@axist.co.nz
Phone: 021 499 431
Neil Kirk
Email: neil.kirk@lsiconsultants.com
Phone: 021 337 234
Certificates presented to six more BCAs
Representatives from a further six territorial authorities accredited as building consent authorities were presented with their registration certificates by the Department of Building and Housing's Chief Executive, Katrina Bach, in December. The photo shows, from left, Alison Geddes (North Shore City Council), Jamie Dale (Taupo District Council), Mike Avery (Stratford District Council), Merv Balloch (Waikato District Council), Ms Bach, Bob de Leur (Auckland City Council) and Ray Applegarth (Clutha District Council).
BCAs comment on benefits of accreditation
A number of TAs registered as BCAs last year have commented to the Department on how they are benefiting from the BCA accreditation and registration scheme. Examples of this feedback are as follows.
Clutha District Council District Inspector Ray Applegarth:
'The immediate advantages have been a more productive, efficient building control unit. Staff are more confident in their decision-making as they have clear, consistent guidelines to follow.
The accreditation process was embraced by all staff from the outset, which enabled us to progress in a positive manner. The benefit of involving our staff throughout the process was that we developed manuals that reflect our existing work practices and procedures. As a result, operational changes were kept to a minimum, enabling manageable disruption to our ongoing workload.
The end result is an effective, quality system achieved under budget and without the need for staff increases, consent fees increases, or processing times exceeding 20 working days. Accreditation has been a positive and necessary initiative to ensuring we provide a quality service to our ratepayers and the industry.'
Taupo District Council Manager of Building and Regulatory Services, Jamie Dale:
'We enjoyed the accreditation process from the point of view that it was a challenge that all staff could sink their teeth into, and we now have formal recognition of the expertise of our building control team. Considering how new the process is and the inevitable growing pains, IANZ did a very good job and the feedback we received from them was greatly appreciated.
The consensus among staff is that we produce a much better product consistently. The process has, therefore, achieved the intended outcomes. Staff have more ownership and better understanding of the consenting process, and are better able to explain it to our customers.
We have a much more professional approach, which is proving popular with designers and builders, who are providing positive feedback.'
North Shore City Council General Manager Environmental Services, Alison Geddes:
'We have found accreditation very beneficial in that it has introduced more structure and discipline into our building control activities. The external, IANZ audit has given us, our councillors and our customers confidence that we are operating to a high standard. We now have independently proven and appropriate competency systems.
The framework for becoming accredited was developed by our own staff, who benefited hugely from working through the process. The knowledge is now held in-house.'
Accreditation process
IANZ has now well implemented a 'confirmation of progress' stage to its accreditation assessment process. This is to help confirm that sufficient evidence exists of TAs' and RAs' readiness for assessment to help justify assessment taking place, thereby reducing the number of reassessments required.
Information provided to IANZ to confirm progress is copied and distributed to technical experts. It is, therefore, important that TAs and RAs supply it as early as possible. If it is not received on time (ideally within four weeks), or lacks the required detail, the assessment may need to be postponed, delaying accreditation for the TA or RA concerned and possibly the accreditation of other TAs and RAs that were ready for assessment but were set down for later in the assessment schedule.
IANZ currently has about 40 assessments or reassessments to complete and is keen to make the best possible use of the limited time available.
TAs and RAs are also encouraged to act promptly on corrective action requests (CARs) identified by IANZ and to organise reassessments as soon as possible. All TAs and RAs have received CARs, some of which have, unnecessarily, taken weeks or months to resolve when, in the interests of progressing the accreditation process, they should be given high priority. Even when all CARs have been cleared, IANZ still has to complete its administrative process. Under this process a TA's or RA's accreditation assessment file is sent to a professional advisory committee for independent review and quality control checks before accreditation can be offered. Understandably, this takes time. TAs and RAs should be looking to get all of their Confirmation of Progress or CAR responses back to IANZ as soon as possible. This now needs to be a top priority.
Common themes to emerge from assessments
Regulation 8: Capacity of building control units
Regulation 8 requires BCAs to have a system for ensuring they have enough employees and contractors to perform their building control functions. This regulation is deliberately about capacity and is closely related to other regulations relating to the skills and competencies of BCA personnel.
Accreditation assessments have shown that many TAs are finding it a challenge to successfully meet this requirement. A number have received CARs because they do not have enough building control staff to meet the volume of work they are facing and have not instigated alternative arrangements to resolve this. Other issues relate to deficiencies in the system they use to assess whether they have the right number of personnel to do the work.
BCAs have a wide variety of building control functions and must be able to undertake them for the full range of residential, commercial and industrial building work as required by the Building Act. Many BCAs are also faced with high volumes of building consent processing and inspection work, and have had difficulty being able to recruit and retain appropriate numbers of competent and skilled building control staff, having not adequately invested in capacity building to meet their daily needs.
These challenges and the need to maintain adequate levels of staffing are not new to the sector or unique to the building control workforce. Historically, many councils have lacked enough building control capacity to meet their work volumes. The problem has become more apparent in recent years with much-increased building activity, and with many of the sector's most experienced building officials retiring or leaving the job and taking their expertise with them.
The BCA scheme explicitly recognises that capacity limitations significantly impact on BCAs' performance. Like any organisation, it is important to plan and invest in the appropriate number of people needed to fulfil responsibilities. The regulations encourage BCAs to take proactive measures to help fulfil their capacity needs.
One measure used by IANZ to assess compliance with regulation 8 during assessment for accreditation is the statutory processing times for issuing building consents and code compliance certificates. Where a BCA is consistently unable to meet the required processing times, IANZ will expect to see the BCA's documented system identify and explain why this is the case, and demonstrate a plan to rectify the situation and data to indicate that the plan has been implemented and is being effective.
BCAs seeking accreditation face the immediate challenge of not only demonstrating that they are actively working towards obtaining the necessary capacity, but also establishing a system to ensure that adequate capacity can be maintained or increased for the long term. Long term, BCAs need to use that system to maintain adequate capacity to fulfil their functions.
Potential strategies
BCAs struggling to fill vacancies with traditional methods of recruitment need to consider creative ways to build their capacity. All BCAs should be developing a recruitment and retention strategic plan for the short, medium and long term. In addition, BCAs could:
- introduce a cadet training scheme. While this is a longer-term strategy it is a good way to attract new people to the role
- use field inspectors and building officials on the job to identify prospective recruits from the sector
- identify technical leaders within the BCA and use them to cross-train and upskill existing staff
- develop partnerships with neighbouring BCAs, which could include pooling and sharing technical expertise, quality control and technical leadership roles
- use the most skilled and experienced staff more strategically and not burden them with more routine jobs (eg, vetting consent applications to ensure poor quality applications are not accepted into the system in the first place)
- consider ways to prolong the transition when staff leave - eg, by allowing people contemplating retirement to work part-time, having more flexible hours, or moving to mentoring or training roles, rather than doing day-to-day work full time
- look to other BCAs for examples of systems and policies that work well and build such innovation into their own organisation
- undertake regular reviews of remuneration packages and working conditions to ensure they are in step and competitive with the market
- consider offering support for employees' further education and qualifications.
Success stories
Dunedin City Council took a business case proposal to its councillors and obtained approval to significantly increase the capacity of its building control unit with 13 additional building control staff.
Palmerston North City Council recognised that it needed to address its long-standing capacity issues in order to fulfil its functions and increased its building control staff by 50 percent to meet its daily needs prior to being accredited as a BCA.
Assessing capacity needs
Important points that BCAs should consider when assessing whether they have sufficient human resources include:
- the volume of building control work they process, inspect and approve, including projected workload peaks
- the usual type of building control work they undertake (eg, more complex building projects are likely to require more time to properly process, inspect and approve, but they may be less frequent than other applications)
- whether they can provide the full scope of activity required by the Building Act (either by using in-house employees and/or having arrangements with external contractors)
- whether their personnel have sufficient time to undertake comprehensive assessments to ensure building work complies with all the requirements it has to meet
- ensuring they can meet the legislative timeframes for processing consents and other timeframes for undertaking building control services (eg, organisational performance or customer service targets over and above those in legislation)
- the findings from any recent audit or review of their performance
- their relationships with other BCAs (eg, participation in a cluster group of BCAs)
- geographical considerations (eg, do inspectors have to travel large distances between inspections?)
- their existing mix of in-house competencies and experience, and how they assess the need for additional external resources.
Additional information
Section M-13 of the Building Consent Authority Development Guide contains additional information about human resources. Additional material about change management and resources is included in section M-10. The system for ensuring that a BCA has enough human resources may be that of the wider TA or RA (where this is applicable). If this system is used, it is important to note that the building consent accreditation body would assess the wider TA's or RA's system.
Regulation 6: Documenting decisions
Uncertainty over the requirements of this regulation, specifically 6(b), (c) and (d), is common. The regulation requires BCAs to clearly document the key decisions they make when fulfilling their responsibilities, the reasons for those decisions and their key outcomes.
These requirements are to ensure there is a sound audit trail. They do not mean every single, minor decision needs to be documented, because that would be administratively onerous, if not impossible. A basic rule is to ensure that adequate information is provided in the building consent file for a person with no prior knowledge of the consent to understand, from the documents, the chain of events, key decisions along the way, their outcomes and the reasons for them. Adequate documentation will also enable BCAs to justify their decision-making if a query or dispute arises, as sometimes happens.
Regulation 6 applies to all other regulations, including those relating to performing building control functions, ensuring sufficient employees and contractors, allocation of work to competent employees and contractors, competency assessments, training employees, choosing and using contractors, and ensuring technical leadership.
Further guidance on this issue is available in the October 2007 building consent authority accreditation and registration scheme update.
Processing check sheets
A number of BCAs use processing check or prompt sheets to help the processing officer record the reasons for a compliance decision.
Such sheets need to include:
- adequate space to record details of the means of compliance considered
- the building element cross-referenced against the appropriate Building Code clause
- means to record whether further information has been received and considered
- the compliance decision
- comments/notes by the processing officer.
Case advisors can provide examples of appropriate check sheets. Information is also available on the Local Government New Zealand BCA accreditation website
Regulation 10: Competency assessments
Many BCAs are still struggling to adequately record the reasons for a decision about the level of competence of an employee or contractor. IANZ expects to see evidence to support such decisions.
This evidence should include consideration of the following types of information:
- a reviewed self-assessment
- work experience and a review of work undertaken
- peer reviews or audits of work completed
- direct observation or 'buddy' reports
- organisational records
- training course results and evidence that the knowledge has been applied
- qualifications
- registration under statute (for example, Chartered Professional Engineers)
- professional and/or industry memberships and affiliations.
The person assessing competence of an employee must have an equivalent or higher level of competency than the person being assessed. The assessment must involve consideration of the above types of evidence and record how a decision about competence was reached.
Further guidance on this issue is available in the December 2007 building consent authority accreditation and registration scheme update and the Building Consent Authority Accreditation Preparation and Self-assessment Guide
Building control qualifications
One of the changes being introduced as part of the BCA scheme is aimed at ensuring that the people undertaking building control work have the right qualifications for the work they do. Long term, this requirement will help improve capability in the building control sector and raise the profile of the profession.
Regulation 18 of the Building (Accreditation of Building Consent Authorities) Regulations 2006 requires BCAs to have a system for ensuring that their employees or contractors either have an appropriate qualification or are working towards one within a reasonable time.
Progress with new building control qualifications
Currently, there is no standard regulatory building control qualification available for building officials in New Zealand. Over the past two years sector stakeholders, including the Building Officials Institute of New Zealand (BOINZ), Local Government New Zealand (LGNZ), the Society of Local Government Managers (SOLGM) and the Department, have contributed to the development of unit standards for an initial regulatory building control qualification. The proposed unit standards were lodged with the New Zealand Qualifications Authority (NZQA) in 2007 and are being assessed.
The Local Government Industry Training Organisation (LGITO) is leading the work on development of the qualifications and in late 2007 responded to a number of queries about them from NZQA. A decision from NZQA is expected early this year.
LGITO has also started work to develop a further building control qualification. These are intended to be diploma level qualifications for medium to large buildings. LGITO has obtained funding from the Tertiary Education Commission to help develop unit standards and a qualification, along with a possible sector roadshow when development work is completed. LGITO is establishing a sector advisory group to assist with this work in 2008.
Guidance on regulation 18
While the development of qualifications is progressing, a number of points can be made on regulation 18 to assist BCAs.
First, BCAs have until 2013 to comply with regulation 18. It was always intended that this requirement be medium to longer term, so a six-year transition period was fixed when the regulations took effect in 2007. The main reason for this was the absence of any standard building control qualifications for the core day-to-day role of building officials.
This transition period recognises the need to develop qualifications and give people time to attain them. The regulation was also designed to be as flexible as possible. For example, people could work towards a qualification or could seek to use an equivalent qualification gained overseas. If the building control qualification currently being developed is approved by NZQA and registered on the national qualifications framework, and also meets the Department's and IANZ's expectations for the accreditation process, this qualification will likely be a minimum requirement for many BCA personnel by November 2013.
Second, the intent of the regulation is to specifically capture the technical jobs that form part of BCAs' building control functions, as opposed to, say, administrative or management components. The regulation is specifically aimed at the people who are involved in processing building consent applications, inspecting building work for compliance or issuing legal documents such as building consents, notices to fix or code compliance certificates. In most cases this will include technical employees such as building officials, trainee building officials, technical clerks and possibly some administrative staff who contribute to technical building control tasks. It will also include contracted people doing similar technical tasks and more specialist contractors used, such as engineers or plumbing and drainage specialists.
Third, given the range of different technical skills and expertise used by building control units in their work, there is unlikely to ever be a single 'one size fits all' building control qualification that will cover all of the skill sets BCAs need for all building projects they process. What is an 'appropriate' qualification for a specific person will differ, depending on the work the person is required to undertake and their background.
This means that people undertaking the core building control tasks that council building officials do now, such as processing building consent applications and carrying out building inspections, will likely be required to have a specific regulatory building control qualification, or be working towards one.
For people in more specialised technical positions, a core building control qualification may still be relevant, but they will most likely require a specialist qualification. In most cases such qualifications will already exist as part of their profession's own entry standards. For example, a structural engineer reviewing building consent applications for their specific structural design components will likely need to have a degree in engineering.
In such cases the BCA's system mentioned in regulation 18 will merely need to contain some fairly basic procedural steps so that the BCA is satisfied such technical personnel or specialist contractors have the requisite qualifications for the work. This will also link in with the competency requirements of some other regulations (eg, regulations 9, 10 and 12).
To an extent, what is 'appropriate' will also be decided by each BCA, depending on how their building control unit is structured and the roles different positions actually undertake. For example, any administrative staff who help with the initial vetting of building consent applications may be regarded by the BCA as performing a technical role (at least for that part of their job) and, hence, be required to have, or be working towards, a qualification appropriate for that part of their role.
Future updates
As the regulatory building control qualifications being developed by the sector are finalised and then registered on the national qualifications framework, the Department will provide further guidance about regulation 18 and its relationship with the qualifications.
Building control accreditation schemes overseas
The Department has been following developments overseas in accreditation schemes for local building control authorities (such as councils).
New Zealand's BCA scheme was designed after consulting with the local sector to develop standards that are right for this country and recognise the challenges facing the sector. The scheme sets standards that are realistic, and are also consistent with the developments in countries New Zealand often uses for comparison, such as Australia, the United States and Canada. In recent years, all of these countries have made changes to how they regulate building work.
United States
In the US, International Accreditation Service Inc (IAS) offers an independent and voluntary building department accreditation scheme. IAS assesses the operational systems and processes, qualifications, experience and competence of building control departments in city and county councils throughout the country. IAS and the organisations it accredits are broadly comparable to New Zealand's accreditation body (IANZ) and council building consent authorities.
The IAS scheme provides national recognition that council building departments are professionally qualified and competent. Accreditation is promoted as extremely important because building control departments are responsible for public safety, health and welfare, and may be sued if they don't perform as required.
Applicant organisations must meet 74 criteria, based on standards set by the International Organisation for Standardisation (ISO) (in this case, ISO/IEC 17020: 1998 General Requirement for the Operation of Various Types of Bodies Performing Inspection).
Accredited city councils include Plano (Texas), Las Vegas City and Henderson City (Nevada). More than 20 council building control departments are currently being assessed.
Australia
A new New South Wales (NSW) state government organisation, the Building Professionals Board, replaced a number of the former accreditation bodies on 1 March 2007.
The Board was originally set up under the Building Professionals Act 2005. One of its key roles is to accredit local government and private certifiers in NSW to issue construction, occupation, subdivision, strata, compliance and complying development certificates. These are similar to New Zealand's building consents, certificates for public use and code compliance certificates. The Board also investigates complaints against accredited building certifiers and audits certifiers and councils.
The accreditation scheme establishes the core skills, knowledge, qualifications and experience requirements for any person seeking to be accredited. The Building Professionals Regulations 2007 define the 21 categories of accreditation that can be approved by the Board, including building surveying, fire safety, engineering and stormwater compliance.
More information about New Zealand's building control accreditation scheme can be found on the Department's website http://www.dbh.govt.nz/bofficials-bca
Wide range of resources available
Over the past 18 months the Department has developed various resources to assist BCAs to develop the systems, processes and procedures necessary to achieve accreditation. As BCAs work towards resolving corrective action requests (CARs) from their assessment by IANZ, it is timely to remind of the availability of these resources for possible use in expediting the CAR process and helping achieve better consistency and standardisation across the sector.
The Building Consent Authority Development Guide, published in February 2006, includes:
- Building consent application checklist
- Means of compliance checklist
- Producer statements checklist
- Consent assessment and task allocation checklist
- Technical skills matrix plan processing
- Technical skills matrix inspections
- Compliance schedule checklist
- Certificate of acceptance checklist
- Quality records example table
- Continuous improvement form.
Weblink: http://www.dbh.govt.nz/pub-bca-accreditation#consent-authority
The Building Consent Authority Accreditation Preparation and Self-assessment Guide, published in February 2007, includes:
- Quality assurance activities requiring policies and procedures checklist
- Calibration register form
- Equipment register for vehicles form
- Documentation register for vehicles form
- Manufacturers' technical literature register form
- Technical manuals register form
- Standards register form
- Library register form
- Legislation register form
- Building control activities requiring policies, processes and procedures checklist.
Weblink: http://www.dbh.govt.nz/pub-bca-accreditation#bca
The Guide to applying for a building consent (simple residential buildings), published in January 2007, includes:
- Consent design summary checklist.
- Application for building consent form
- Building consent form
- Application for project information memorandum form
- Certificate attached for project information memorandum form
- Agreement between residential property developer and purchaser form
- Development contribution notice form
- Application for code compliance certificate form
- Code compliance certificate form
- Application for certificate of acceptance form
- Certificate of acceptance form
- Compliance schedule statement form
- Application for amendment to compliance schedule form
- Warrant of fitness form
- Certificate of compliance form
- Application for determination form
- Notice to fix form
- Application for certificate for public use form
- Certificate for public use form
- Certificate of compliance with inspection, maintenance and reporting procedures form.
Weblink:http://www.dbh.govt.nz/building-regulations
Further information
Further information about the Building Consent Authority Accreditation and Registration Scheme is also available on the Department's website - www.dbh.govt.nz/bofficials-bca
Further information about IANZ is available at www.ianz.govt.nz
Information about BCA accreditation, including an accreditation resource kit, is also available at www.lgnz.co.nz/projects/building-consent/
For general enquiries about the Building Consent Authority Accreditation and Registration Scheme or case advisor support, please contact one of the following people at the Department of Building and Housing.
Building Consent Authority Accreditation and Registration Project
Consent Authority Capability and Performance Group
Department of Building and Housing
PO Box 10-729, Wellington
Telephone: 0800 242 243
Malcolm MacMillan
Manager Consent Authority Capability and Performance
malcolm.macmillan@dbh.govt.nz
Aimee Chalmers
Manager Performance Monitoring and Review
aimee.chalmers@dbh.govt.nz
Andrew Minturn
Senior Advisor and Case Advisor BCA Accreditation and Registration
andrew.minturn@dbh.govt.nz
Steve Garner
Project Manager and Case Advisor BCA Assistance Package
steve.garner@dbh.govt.nz
Peter Sparrow
Senior Advisor Performance Monitoring and Review
peter.sparrow@dbh.govt.nz
For specific enquiries about applying for accreditation, accreditation assessments, the accreditation assessment process and scheduling, accreditation fees, corrective actions and how to interpret them, or the standards and criteria for accreditation, please contact:
International Accreditation New Zealand (IANZ)
Private Bag 28-908,
Remuera, Auckland
Telephone: (09) 525 6655
Elizabeth Stevens
Accreditation Coordinator
estevens@ianz.govt.nz
Geoff Hallam
Programme Manager Inspection Body Accreditation
ghallam@ianz.govt.nz
David Sidwell
Accreditation Officer
dsidwell@ianz.govt.nz
Chris Astbury
Accreditation Officer
castbury@ianz.govt.nz
Allan Glover
Accreditation Officer
aglover@ianz.govt.nz