Submissions

Here you'll find the Master Plumbers' response to important industry issues.

Current consultations | Recent consultations

Current consultations

PGDB competence review consultation

17.5.13

The Plumbers, Gasfitters and Drainlayers Board has been consulting on its proposal to prescribe by way of Gazette notices that any tradesperson requested by the PGDB to participate in a competence review must do so as a standard term and condition of a licence. The consultation ended on Friday 17 May 2013.

Master Plumbers, Gasfitters & Drainlayers NZ Inc has made a submission on the consultation. While we acknowledge that the Board is empowered to conduct competence reviews, if other measures of competence are in place we believe there should be no need to make a licensed person's participation in such a review a standard term and condition of a licence.

As indicated in the consultation document, "competence reviews are one of the tools provided... to enable the Board to achieve the purpose of protecting... the public" and we believe that mechanisms for active engagement in quality assurance programmes and a broad brush approach to ongoing learning and development would be more conducive to the development of a robustly competent industry, thereby offering the opportunity of a competence review linked to actual evidence of potential failure.

We recognise the Board's need to carry out competence reviews for the purposes described in Section 53 of the Act. Such reviews should be carried out using a proven and transparent process that delivers the improvements or limitations that are inherent in Section 54.

At this stage we have not seen any evidence that an appropriate competence review process exists, and we recommend that the Board properly develops and consults with industry stakeholders on a suitable process that achieves the intended outcomes for both the Board and licensed persons, before attempting to implement same.

We believe it would be unwise to instigate "future competency reviews to monitor... the industry more generally" if this competency review, process and structure are not related to an identifiable and published structure of review which may be related to both technical competency as well as other elements of business competency and ethical behaviour.

It also seems reasonable to expect that the principles of quality assurance and continuous learning as well as a mutually agreed, fair and robust competence review process could be incorporated into any amendments forming part of the forthcoming review of the Act. 

Recent consultations

Building Amendment Bill No. 4

17.5.13

Last June, Master Plumbers lodged a submission with the Local Government and Environment Committee in relation to Building Amendment Bill No 4. This Bill largely focusses on the consumer's ability to seek remedy for faulty workmanship within a 12-month period of completion. In our submission, we expressed strong concerns about the implications of this Bill on subcontractors and the definition of a 'building contractor' which is used throughout Part 4A of the Bill.

Following up on our submission, we have clarified that the Bill's provisions do not apply to subcontractors. So, if a plumber, drainlayer or gasfitter is subbing to a building contractor, the responsibility for meeting the Bill's requirements sits with the building contractor. However, where a plumber, gasfitter or drainlayer is contracting directly with a building owner then the provisions will apply.

The Bill is currently working its way through Parliament, and we will keep you posted on progress.

• Read the Master Plumbers submission on Building Amendment Bill No 4 HERE.
• View Building Amendment Bill No 4 HERE.
• Read more information about Building Amendment Bill No 4 HERE.

PGDB consultation on its fees and levy review

10.10.12

Consultation on the Plumbers, Gasfitters and Drainlayers Board's review of its fees and levy closed on 9 October. 

Master Plumbers, Gasfitters and Drainlayers NZ sent a submission to the Board, which is available to view below. 

• Master Plumbers' submission on PGDB's fees and levy review consultation (PDF, 119kb)

CPD scheme approved

20.9.12

The Minister for Building and Construction has approved the Continuing Professional Development (CPD) Gazette notices, which were published in the NZ Gazette on 13 September, and take effect on 11 October 2012. 

The Plumbers, Gasfitters and Drainlayers Board (PGDB) says undertaking CPD continues to be a term and condition of licensing. Tradespeople must obtain at least:

• 12 CPD points every year for the holder of a single licence
• 20 CPD points for two trades
• 24 CPD points for three trades.

At least 75% of points must be from structured programmes accredited by the PGDB. The remaining 25% of points may be from self-directed learning, but all can be from accredited courses if so desired.

Self-directed learning could include researching and reviewing published material, attending seminars or industry conferences or on-the-job training. One hour of self-directed learning will be worth one CPD point. Tradespeople must record any self-directed learning at the time of relicensing.

All points obtained, from accredited programmes or self-directed learning, must be relevant to one or more of the PGDB-prescribed competencies.

The PGDB may prescribe specific CPD to be undertaken by groups of tradespeople from time to time. These programmes will form part of the overall CPD points' requirement.

Please note: By relicensing time, tradespeople must have completed the 2011/12 points' balance by 31 March 2013 as well as the 2012/13 points' requirement.

Review of industry training system

12.9.12

The Ministry of Education has closed its consultation on the review of the industry training system. The consultation document states: "It is intended that the changes will create an environment that will better support trainee achievement and progression through vocational education and training, by ensuring that employers and trainees are well served by ITOs with appropriate incentives."

Key proposed changes to industry training policy include:

• ITOs will focus on two key functions – arranging training and skill setting
• Greater simplicity, accountability and clarity of the ITOs' functions and roles
• Higher expectations for qualification completions for ITOs
• Industry will have responsibility for communicating skill needs directly to Government
• Amalgamating all apprenticeships into the Modern Apprenticeships scheme, regardless of age
• Raising the current 10% restriction on industry training at levels 5 and 6
• Adjust to a more sustainable funding regime that introduces a new, higher subsidy rate for apprenticeships.

Master Plumbers and Masterlink provided feedback on the proposals by the closing date of 12 September. You can view the submission document HERE (PDF, 418kb)

Deeming of plumbers and gasfitters as LBPs

4.9.12

The Ministry of Business, Innovation & Employment (MBIE – formerly the Department of Building and Housing) has now closed its consultation on a number of areas in relation to the Licensed Building Practitioners (LBP) regime. Whilst the majority relates to construction, MIBE is also looking at changing the deeming provisions for plumbers and gasfitters.

Currently, registered plumbers and gasfitters do building work that is a necessary consequence of, and ancillary to sanitary plumbing or gasfitting work, such as flashings, penetrations and sealing. Rather than requiring registered plumbers and gasfitters to be licensed as LBPs to do this ancillary work (that they are already licensed to do under the PGD Act), or have this work supervised and signed off by an LBP, the Building (Designation of Building Work Licensing Classes) Order deems them to hold the roofing, external plastering and brick/blocklaying licences. Furthermore, the Building Act expressly forbids them from being able to apply for such licences.

As of 1 March this year, such ancillary work is 'Restricted Building Work' if it is carried out on a new build, or the penetration and associated work is greater than 300mm in diameter in relation to an existing building.

MBIE has come up with a number of options to manage this - mainly in response to concerns that the LBP Board does not have jurisdiction over plumbers if a problem arises over roofing work. Their preferred option is to remove the deeming provisions altogether and require plumbers to apply for a roofing licence if they want to undertake roofing work.

Master Plumbers believes this is a step too far and is unnecessary as the LBP Board has the ability to impose a financial penalty on a plumber in relation to faulty roofing work. In addition, plumbers are clearly competent when it comes to installing and maintaining profiled metal roofing and wall claddings – and we believe this approach by the Ministry penalises our sector unnecessarily.

A draft submission was prepared for members to complete or use as the basis for their own submission to MBIE by the closing date of Monday 3 September 2012. You can read it HERE (Word doc, 41kb)

Two PGDB consultations

17.7.12

Master Plumbers has made submissions on the following consultations by the Plumbers, Gasfitters and Drainlayers Board (PGDB), which closed on Tuesday 14 August 2012.

Overseas-trained tradespeople

The Plumbers, Gasfitters and Drainlayers Board (PGDB) was consulting on a proposal for the contents of Gazette notices with respect to new minimum standards for registration of overseas-trained tradespeople. The PGDB's proposed minimum standards will:

• enable registration in either Licensed or Certifying registration classes, provided the necessary requirements are met
• streamline the PGDB's registration process with Immigration New Zealand's processes, allowing people applying for the Licensed class to meet all the requirements while still in their country of origin
• reduce the cost and timeframe for an overseas-trained person seeking Licensed class registration
• require an overseas-trained tradesperson to demonstrate a level of competence that is neither materially higher nor lower than that required of an NZ-trained tradesperon.

More details at pgdb.co.nz.

Read the Master Plumbers' submission HERE.

Discontinuance of the common exam 9194

The Plumbers, Gasfitters and Drainlayers Board (PGDB) was also consulting on its proposal to discontinue the common exam 9194 as a minimum standard of registration as a Certifying tradesperson. The PGDB proposes to include the competencies that were previously assessed by this exam in the trade-specific Certifying exams 9195, 9196 and 9198.

More details at pgdb.co.nz.

Read the Master Plumbers' submission HERE.

Gas and electrical certification

4.10.12

Following on from the Gas and Electrical Certification and Fees Review, the current certification regimes for gas and electrical installation work are to change.

The new certification regime will:

• extend certification to all gasfitting, including removal of the 'less than 15kg' exemption
• Remove the fee for purchase of the certificate
• Allow a flexible format for providing certification information to consumers
• Require 'certification' by each person for work they have done
• Implement an online database for recording 'high-risk' installations.

Energy Safety consulted industry experts, including Master Plumbers, to verify the draft regulations, which have now received Cabinet approval. The 2012 Amendments to the Gas (Safety & Measurement) Regulations were Gazetted on 27 September 2012, and will be effective from 1 July 2013.

The draft gas regulations and the Master Plumbers' response are available to download below.

• Draft Gas (Safety and Measurement) Amendment Regulations 2012 (PDF, 70kb)
• Master Plumbers submission (PDF, 53kb)

Read more about the upcoming changes to gas certification HERE.

PGDB consultations on CPD, competencies and registration of overseas-trained tradespeople

11.4.12

The Plumbers, Gasfitters and Drainlayers Board (PGDB) has now closed its consultation on:

• its modified CPD proposals
• gazetting the competencies for the plumbing, gasfitting and drainlaying trades
• the minimum requirements for registration of overseas-trained tradespeople.

Master Plumbers made a submission on all three by the closing date of 5 April 2012. 

CPD: See update above.

Competencies: The PGDB has reached its decision on its proposal to Gazette the competencies. The majority of submitters (96%) supported the PGDB's proposal to publish the competencies in Gazette notices. These have been prepared and provided to the Minister of Building and Construction. Once the PGDB has the Minister's approval, Gazette notices will be published and the details communicated (update: the competencies came into effect on 11 October 2012).

Overseas-trained tradespeople: The PGDB has considered the submissions received on the four options it proposed in its review of the minimum requirements for the registration of overseas-trained tradespeople. The overwhelming majority of submitters supported the PGDB's preferred option. It has now prepared a proposal for the contents of a Gazette notice (see update above).