SUBMISSION TO:
QUEENSLAND COMPETITION AUTHORITY
SUBJECT: National licensing of plumbing and gasfitting occupations.
This paper is the response from the Building Services Authority (BSA) to the Queensland
Competition Authority (QCA) / Marsden Jacob Associates August 2013 Issues Paper on
the above topic. A consultation meeting was attended on 13 August 2013 by Chris Boyle
and Cameron Murphy of the BSA. A number of discussion points and questions were
raised through the discussion paper. They are listed below.
Discussion Issues
1. Should option 3: AMR have been fully developed and fully costed in the DRIS?
Yes, most definitely. This option is desirable, achievable and should have been
explored in the DRIS.
2. Is the DRIS correct to note that complexities would continue to militate against
labour mobility to a significant extent in the context of AMR?
No. The licence holder will have negligible issues regarding mobility under an AMR
model of national licensing.
3. Would a harmonised or unharmonised AMR option be preferable?
The preferred AMR option would be harmonised.
4. What are the relative pros and cons of each form of AMR compared with other
options?
The AMR options still need to be fully explored. The BLA (Builders Licensing
Australasia) did carry out work from about 2005 – 2009 on rationalising and
harmonising builder and trade licensing across Australian jurisdictions. Follow-on
work from that previous work would see advancement towards harmonisation with
less effort.
The major benefit of AMR would be little (or no) cost to government, industry and
consumers under the AMR model.
5. Are the estimated gains from labour mobility in the DRIS plausible? Are the bulk of
the benefits from national licensing likely to come from greater interstate labour
mobility?
a. No.
b. No. The acquisition of an interstate licence (a second licence) is not a
barrier to contractors wishing to work in another state.
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6. How important are interstate markets for plumbers and gasfitters?
BSA considers that some large contracting businesses may have maintenance or
job specific contracts interstate. Otherwise it would be the plumber or gasfitter that
lives in close proximity to the NSW border that may require a NSW licence as well
as their BSA licence. It is estimated this applies to less than 500 contractors.
7. Do plumbers near the NSW border undertake large amounts of work in NSW?
Could they undertake more with national licensing?
As previously mentioned, the acquisition of an interstate licence (a second licence)
is not a barrier to contractors wishing to work in another state. The cost and time
involved is negligible.
8. How difficult is it to hold a licence in more than one state. What is the cost?
a. Under Commonwealth Mutual Recognition legislation, it is quite easy for a
contractor to gain a licence in another state. The contractor must apply for
the interstate licence but the requirements are less (eg. No need to prove
technical or experience competence).
b. Costs of interstate contractor licensing as at 1 July 2012 (BSA annual report)
9. Were a full range of options regarding occupational licensing for plumbing and
gasfitting occupations considered in the DRIS?
No. The AMR option was not considered.
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Supplementary Questions.
1. The DRIS estimates the cost of setting up the national licensing body at $1.64M
over the first 3 years of operation. Do you think this estimate is reasonable? More
or less? How much do you think it will cost?
a. This estimate is unreasonable.
b. The estimate is far too low given the operations of NOLA. NOLA currently
has 16 staff with 24 staff to be in place when fully operational.
c. Going by NOLA’s own estimates, the costs per year will be $8M. Therefore
$24M over 3 years as opposed to the $1.64M in the DRIS.
2. Do you think there will be cost savings from having a national licensing body?
There will be a cost impact upon BSA to implement, manage and run NOLS. This
is because BSA will be maintaining two systems. One that manages licensing and
conduct and one for licensing other than NOLS.
Conduct obligations include those relating to the provision of adequate and
personal supervision of work and liability to rectify defective work performed under
the contractor’s licence.
Policy development will become more contested for NOLS licensing and will need
to continue in its current form for Queensland licensees. BSA will need to pass the
higher cost of maintaining two licensing systems onto its licensees.
When the AMR option is fully explored, there may not be a requirement to have a
national licensing body.
3. Is it reasonable to make the following information publicly available: Number; name;
address; regulated work; any disciplinary action?
Yes. Note – address should be the business address rather than residential
address.
4. What do you think the value of labour mobility would be to individual plumbers and
gasfitters?
For the 500 contractors living in close proximity to the Border regions, it would be
worth about $400 per year in licence fees. There would be an additional small
benefit to administration costs, regulatory burden and time for those contractors.
5. What are the costs and benefits of the change in licence period from the state
system to the national system?
Currently, the BSA licence is renewed each year. Under NOLS, it is proposed to
renew licences for periods of 1 or 3 years.
The longer licence period will save the contractor some administration time and
reduce their regulatory burden by a third.
It will reduce some of the administration costs of BSA well. The estimate for this is
approximately 15% however this is overshadowed by an increase in costs to run
two licensing systems in parallel (State licences and NOLS)
6. Will the change in the number of Certificate IV courses required cost or save
operators?
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Cert IV courses will not affect a person applying for a BSA contractor licence. BSA
is not in a position to address this question.
7. Do you think plumbers and gasfitters will receive more or less service from a
national licensing body?
They will receive no service from a national licensing body. They will still require
their service from their state regulator and it will be the state regulator that will
interact with NOLA. Timeframes will be increased as state regulators may be
required to canvas a certain policy position with other state regulators before
approaching NOLA for direction. Service will be much slower to what they currently
receive. Conduct requirements will remain the domain of jurisdictional regulators.
8. Do you think the overall cost of creating and running a national licensing body is
worth the benefits?
No. The AMR model should be fully explored and costed. It may be that a national
licensing body is not required.
9. Do you think there are other things that could be done to improve regulations
affecting plumbers and gasfitters?
BSA has no comment on technical regulations for plumbers and gasfitters. This is
best left to the State occupational licensing regulators.
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