Australian Refrigeration Mechanics Association

Plumbing and Drainage Bill 2018 Submission 011 12th March 2018 Committee Secretary Transport and Public Works Committee Parliament House George Street Brisbane Qld 4000 Dear Sir/Madam I am pleased to submit the Australian Refrigeration Mechanics Association’s (ARMA) response to the proposed introduction of the Plumbing and Drainage Bill 2018, to introduce new mechanical services licence classes. ARMA is an established industry representative organisation, with membership ranging from independent operators, to employees of large companies, and industry training specialists. We are focused on achieving recognition and full licensing for refrigeration and air conditioning tradespeople, as a mechanism to achieve national recognition as a technically-based trade. Accordingly, our response relates primarily towards the impact the introduction of a mechanical services license will cause the HVAC&R Industry and its tradespeople if the reforms were to proceed. Our response also provides our members’ grass-roots feedback on how vital it is to ensure recognition as a specialized trade remains alongside other peripheral trades without further fragmentation to the HVAC&R industry. ARMA will provide overview response/recommendations to all other sectors being reviewed wherein it affects the HVAC&R trade. We request this submission be included with our previous submission on the draft bill in 2017. ARMA appreciate the opportunity to take part in this important review and I would also appreciate the opportunity to attend as a witness and furthermore seek the attendance of Donald Mclean, refrigeration mechanic to attend as a witness. We also take this opportunity to thank Minister de Brenni’s staff for the opportunity to discuss our concerns. Sincerely KIM LIMBURG Chief Executive Officer Australian Refrigeration Mechanics Association Web: www.arma.org.au Plumbing and Drainage Bill 2018 Submission 011 RESPONSE TO THE DRAFT PLUMBING AND DRAINAGE BILL 2018 AND THE INTRODUCTION OF A NEW MECHANICAL SERVICES LICENCE CLASS SUMMARY Understanding Refrigeration and Air Conditioning (RAC) also referred to as Heating, Ventilation, Air Conditioning and Refrigeration (HVACR) requires a trade outcome for skills and knowledge to successfully carry out associated work within the industry. Furthermore, a great deal of confusion from government and peripheral trades, like the electrical and plumbing industries perpetuated from ignorance continues to shadow a specialized RAC industry. HVACR is a singular PRIMARY trade with a specific skillset on completion of refrigeration and air conditioning under the UEE32211 RAC or the least supported MEM30205 RAC training package streams. More importantly we express concerns based on differing training packages for the industry not only reflective of two peripheral trades, but also understandably the shortcomings of governments not ensuring the establishment of an independent HVACR Industry Reference Committee to alleviate the confusion by providing a defined training package for HVACR rightly deserving of recognition. The technical intricacies of mechanical services package (MEM 30205) serves a wide breath of industries not limited to plumbing but also covers engineering and manufacturing industries. Therefore, qualifications issued to plumbers based on the metals package MEM is contextualized to suit the plumbing codes requirements. However, the MEM 30205 (specializing in refrigeration and air-conditioning) stream, has a small percentage of core and elective competencies within this package relating to refrigeration systems. The sole purpose of this package is to gain the environmental, non-technical, licence from the Australian Refrigeration Council (ARC) to work with refrigerants, as well as an avenue to allow plumbers access to the HVACR industry. Orchestrating change in training packages for the HVACR industry is an important step forward to equalization. Therefore, we are currently seeking improved training packages in conjunction with licensing under a RAC system to future proof the HVACR industry. We are at odds as to why governments and regulators are submissive to a HVACR industry as a singular trade but in the same breadth are very supportive of electrical and plumbing industries as shown in current and proposed legislation for these industries to carry out works from a peripheral trade, HVACR. As previously mentioned, the importance of our HVACR trade cannot be underestimated. It is the only trade with elements of, electrical, plumbing, refrigeration and air conditioning, within its apprenticeship. Unlike the other trades, all knowledge and skills are achieved throughout the whole 4 years in theory and on the job experience in HVACR works. Electrical and plumbing don’t have the same apprenticeship but, due to the introduction of the ARC environmental licensing scheme working with refrigerant has severely changed the scopes of works allowing electrical and plumbing trades to work illegally at times. While governments continue to support plumbing with the proposed mechanical services licensing this will not elevate illegal scopes of works or benefit the HVACR industry or consumers. Plumbing and Drainage Bill 2018 Submission 011 RECOMMENDATION 1: Accordingly, ARMA expresses - A more progressive option to the proposed reforms that is to introduce under QBCC legislation an occupational skills based trade licence, inclusive of all refrigerated systems for the HVAC&R Industry and regardless of value of works– As a balanced and progressive option, which does provide a reform to benefit industry, the environment and consumers, within a practical fiscal structure. Of the proposed reforms presented, ARMA believes -The scope of work associated within the refrigeration and air conditioning occupational licence should only be undertaken by a full qualified HVAC&R tradesperson who has undertaken a full 4-year apprenticeship. In respect to sheet metal workers who are highly skilled to carry out duct work however, we ask why RAC qualified tradespeople have been excluded from the ductwork in the proposed draft bill. Although, we note ductwork continues to be included within the scope of works for RAC contracting licenses. Therefore, clarifying reasoning to the inclusion of ductwork is because HVACR works has the primary skillset which should be acknowledged in line with trade qualifications, understanding relationship between ductwork, air flow and high pressured refrigerated systems. Therefore, we request ductwork to be inclusive of the scope of refrigeration and air conditioning occupational licensing. This inclusion will remove unnecessary costing on domestic dwellings, applies best practice and benefits to consumers who otherwise would require another trade to complete the installation of air-conditioning. Exclusion would also deliver a licence which is not matched/consistent with skills outcomes of the RAC trade. Attachment “A” provides examples of poor design and installation by peripheral trades carrying out duct work installations associated with HVACR systems when unsupervised by RAC tradespeople. It is commonplace to find limited access to systems and on many occasions no access at all to the systems as a direct result of duct installers not skilled in the entirety of the HVACR systems. RECOMMENDATION 2: Accordingly, ARMA seek introduction of a refrigeration and air conditioning occupational licence under the current structure of the QBCC inclusive of associated HVACR ductwork and under the sheet metal trade’s scope of work to be correctly worded as associated HVACR works. Sheet metal work associated to HVACR systems must continue to require supervision by RAC tradespeople ensuring the “Total System” is correctly installed. Mechanical Services – Plumbers who also carry out associated HVACR works, do not have the appropriate skillsets to work with high pressure refrigerated systems, inclusive of Co2, ammonia and hydrocarbon refrigerants. Therefore, governments must provide clear, concise scope of works ensuring work by mechanical services plumbers is contained to the skills they have acquired and do not allow for mechanical services – plumbers to work on refrigerated systems. In 2009 a plumber in Nambour died as a result of cutting through high pressure refrigeration pipe, works that should never have been carried out by anyone other than a RAC tradesperson. As with sheet metal workers, the mechanical services – plumbers do not have the skillset to understand the combined ductwork, air flow and refrigeration systems to work without supervision by RAC tradespeople. Plumbing and Drainage Bill 2018 Submission 011 RECOMMENDATION 3: Accordingly, ARMA support a mechanical services – plumber occupational licence only, with HVACR associated scope of work to be correctly worded as associated HVACR works. Mechanical services - plumbers work associated to HVACR systems must continue to require supervision by RAC tradespeople ensuring the “Total System” is correctly installed. ARMA support the Mechanical services – medical gas occupational licence. Likewise, confusion over defining skillsets and competencies achieved in specialized electrical work carried out by refrigeration and air conditioning tradespeople are vastly different to wiring a house. The main contention is from state regulatory bodies with the backing of a very strong electrical industry bodies as to what RAC tradespeople are legally allowed to wire within their scopes of work, unlike the electrical fraternity known to work illegally in the HVACR scopes of works

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