Policy update: National Registration framework for Building Practitioners

A summary of our position

• The NRF does not support the intent of the Building Confidence Report to raise the quality of building
• The assessment of building designers should be based on assessed competency in a similar way to architects
• The education and experience requirements are setting the bar too low
• The registration levels are not appropriate for the education, skill and experience required
• The scope of work is incorrectly allocated
• The NRF must better distinguish between architects, building designers and drafters
• There are risks to the future of the architecture profession
• Architects must be included in the description of project managers

Does not support the Building Confidence Report intent

• The NRF, as currently proposed (August 2020), will have unintended consequences and will result in poorer quality and a less safe outcome for the public – the end users of buildings.
• The NRF directly contradicts the purpose of the Building Confidence Report recommendations. The purpose of the report is not merely to ensure compliance with the NCC, but to raise the quality of buildings and outcomes for consumers and rebuild public confidence in the industry.
• The current proposals, particularly in terms of building designers and project managers, are insufficient to raise confidence in the building industry, because the bar has been set at a level that is too low to ensure quality outcomes.
• The stated objectives of the Building Confidence Report is to ‘enhance public trust and confidence in the building industry’. This will be best achieved through prioritising professionalism and higher levels of competence for all practitioners. 

Should be based on an assessment of competence

• The (proposed) NRF is not based on assessment of competency, which is a well-recognised high-quality benchmark for assessment that results in better building outcomes. Experience does not equal competence. Experience can relate to someone who has done something for a long time, and not necessarily well. There must be an underpinning robust assessment process of experience levels that translate to competencies. These competencies from different types of practitioners in the levels outlined in the NRF must be comparable. 

Education and experience requirements too low

• The levels of education and assessment of experience set out in the NRF are inappropriate with regard to the skills required to deliver safe buildings and buildings that comply with the NCC in all of its aspects.
• For instance, there are increasing professional registration, mandatory training and experience requirements for registered architects. It appears that the NRF is reducing the level of education, experience and skill required to design and document buildings in the building designer category of the NRF, at level 1 in particular, but also in level 2.  
• The NRF allows building designers with a diploma in building design (a 1 to 2 year course) with 3 years post qualification experience to be able to undertake a good proportion of building types that currently require a registered architect. Registration requirements for architects relate to education, experience and demonstration of competency through an examination and interview against national competency standards that are recognised internationally. There is currently no comparable assessment process for building designers. 
• The NRF does not recognise the significant differences in education and mandatory practical experience between registered architects and others providing building design services. This lack of regulatory recognition corresponds to confusion within the community as to the role and capabilities of an architect as opposed to a designer/drafter and can result in poor quality outcomes and risks to safety.
• Academic qualifications identified in the draft NRF appear out of step with the current framework for Architectural Qualifications. The Schools of Architecture in Australia deliver a two-tier degree programme with a Master’s Degree required to qualify for registration (AACA Accreditation 2019). This is equivalent to the AQF 9 not AQF 8 as set out in the NRF.
• AQF level 9 criteria provides that graduates at this level will have specialised knowledge and skills for research, and/or professional practice and/or further learning. Graduates at this level will have advanced and integrated understanding of a complex body of knowledge in one or more disciplines or areas of practice.
• Graduates at this level will have expert, specialised cognitive and technical skills in a body of knowledge or practice to independently:
• Analyse critically, reflect on and synthesise complex information, problems, concepts and theories
• Research and apply established theories to a body of knowledge or practice
• Interpret and transmit knowledge, skills and ideas to specialist and non-specialist audiences

Graduates at this level will apply knowledge and skills to demonstrate autonomy, expert judgement, adaptability and responsibility as a practitioner or learner

• The knowledge and skill outlined above is appropriate for level 1 and is particularly relevant to developing performance solutions under the NCC.
• Architects have completed an accredited program in architecture at AQF level 9, a mandatory period of two years minimum of relevant work experience and the Architectural Practice Examination prior to applying for registration as an architect. Each of the assessment programs on the pathway to registration are benchmarked against the National Standard of Competency for Architects.  All assessment programs use the context of a complex project for assessment of competency.
• For experienced design practitioners who have not utilised the conventional pathway to registration as an architect there are a number of pathways to registration available to relevantly experienced practitioners. 
• The NRF should be lifting the competency of professionals across the spectrum of building designers to an equivalent level with Architects, rather than proposing a scheme that would lower the standards across the industry and increasing risks for poor outcomes for consumers by having less qualified practitioners. This proposed NRF proposes registration of building designers before they have developed the required competencies to practice in projects of high complexity or at large scale for class 3-9 buildings.

Registration levels

• What is proposed – A building designer registered at the relevant level is permitted to design and document building design work using Performance or Deemed-to-Satisfy Solutions. The three levels of registered building designer are:

1. 1. 1. Registered building designer level 1 All buildings
      2. Registered building designer level 2 Medium rise buildings
      3. Registered building designer level 3 Low rise buildings

• An individual registered as an architect under architect’s legislation will meet the requirements to be registered as a building designer level 1.
• We strongly recommend that they be described as follows:

1. 1. 1. Registered Architect – All Buildings
      2. Registered building designer level 2 Medium rise buildings (with medium rise being defined as two storeys rather than three – and with qualifications on it depending on the number of consultants that are required to deliver the building).
      3. Registered building designer level 3 Low rise buildings

• This would then prevent the necessity of requiring registered architects (noting they are already registered to practice) to also be registered as building designers. It would also differentiate between skill level of an architect and building designer and provide greater confidence and understanding for the public.
• The issue we have relates to the scope of work in each level and the qualifications and experience requirements in each level. Design of buildings of type A should be restricted to registered architects and the management and coordination of design follows that same logic through various classes of building designer. Class A buildings are the source of the most drastic failures and risks.
• Architects are the profession who would, traditionally, provide expert and impartial input in relation to design, regulatory compliance and construction quality. 
• Architects are required by (legislated state) Registration Acts to be professional providers of design and documentation services as well as independent arbitrators between the client and contractor during construction. The knowledge and capability of designers who have not completed the prescribed tertiary education and post graduate architectural registration requirements are significantly less than those of a registered architect. In addition, designers are also not required to be insured (increasing community risk) or to abide by a code of ethics, which are both requirements of architectural registration.

 Scope of work

• The NRF views architects as largely equal to building designers and other lesser qualified practitioners offering building design services. This does not provide clarity regarding the relative capabilities of an architect as opposed to a building designer or drafter and will not result in improved public confidence, which is the core objective of the Building Confidence Report.
• The NRF and Taxonomy provide a register of individuals in core disciplines. This will only be effective providing each core discipline is appropriately framed. 
• The Taxonomy lists people qualified to undertake Design Level 1 as having an ‘Approved degree in architecture, architectural science or architectural design’. This demonstrates a fundamental misunderstanding of the difference between the education pathway required by a registered architect and that required for other designers within the building sector. 
• Building science and building design degrees do not provide an equivalent scope or standard of education to that attained by a graduate of an accredited architectural program. It is therefore not reasonable to expect the same standard of service to be provided by a building or other designer as can be expected from a registered architect. 

The distinction between architects and building designers

• Architectural science and architectural are not terms supported by various Architectural Registration Acts in Australia. The restriction of the term architect is stipulated so that the public and consumers of architectural services have confidence in the standard of professionalism and expertise that they can reasonably expect an architect. This benefit is diminished when a system such as the NRF implies that people with lesser qualifications are capable of providing equivalent expertise to a registered architect.
• Using the term ‘architect’ in relation to people who are not registered is misleading and diminishes the very real distinction between the capability of an architect as opposed to a designer. This will not achieve the objective of the NRF, which is to clearly articulate the different roles that specific groups of people can undertake within the construction sector to a suitable standard. Incorrect use of the term architect also contradicts the Restrictions and Protections section of the NRF.
• Therefore, it is recommended that this distinction is expressed:
• Through the removal of the use of the term ‘architect’ from the NRF, except where it refers to a person who is a registered architect.
• In the Taxonomy, with registered architects being listed as the only practitioners suitably qualified to undertake Design Level 1. 
• In the education requirements, with Building Design Level 1 requiring an AQF Level 9 qualification, which is the level of education required to satisfy the architectural registration requirements.
• The NRF recognises the suitability of the existing architectural registration system in Australia, on the basis that it already meets the objectives of the NRF in relation to education, accreditation and mutual recognition. The benefits inherent in architectural registration should not be diminished by the failure of the NRF to clearly distinguish between architects and others involved in the design of buildings.

Risks to the future of the architecture profession

• In its present form, Table 01 NRF Taxonomy Level 1, has the potential to reduce the accreditation requirements of a registered architect by allowing a comparison of a person with a degree in architecture plus NCC training to a registered architect.
• This document and the support of the ABCB may become an influential document in allowing the establishment of “building designers” to a lesser level than a registered architect but by association suggesting a person with a degree in architecture plus NCC training is equal to a registered architect.
• Given that the funding of University courses in architecture are tied to the requirements of practice, if the equivalent NRF registration requirements are lowered to undergraduate degree plus honours, the federal funding and HECS for masters of architecture may be removed.

Project Management

Architects must be included as project managers.

Project Managers are responsible for project managing the project. This includes managing the program, the scope, the inclusions of all the consultants, as well as managing the cost of the project and keeping the client well informed throughout the project.

Without a deep understanding and knowledge of all of the consultants on the project, the future complexity of construction in Australia, and the importance of the building to the public/urban design and other social implications, the project manager can be driven purely by time and cost.

We recommend the Project Manager should be AQF9 qualified and minimum 2 years post graduate experience, have a code of conduct and be required to hold PI insurance and do ongoing CPD annually.