Society for Building Services Engineers

Hello everyone,

I'm reaching out to share and seek your thoughts on an experience I've encountered here in Cairns, Queensland, that has raised some significant concerns for me regarding the practice and integrity of our engineering profession, especially in the building and construction sector.

In several instances, I've observed building certifiers accepting Form 15 compliance certificates for the air-conditioning and ventilation design of sufficiently complex projects from individuals holding trade licences OR from Registered Professional Engineers of Queensland (RPEQ). This practice seems to acknowledge trade licence holders as being on par with RPEQs for the delivery of what I consider professional engineering services.

One of my main concerns revolves around the possibility that commercial interests could sway the solutions offered by trade licence holders, especially when they're responsible for providing compliance certification. This situation starkly differs from that of registered engineers, who adhere to a strict code of ethics. This code demands that the needs of the community take precedence over commercial benefits. Crucially, registered engineers do not gain commercially from the solutions they provide, ensuring their recommendations are made with impartiality and integrity. This distinction is vital, as it goes to the heart of our profession's integrity and the public's trust in us. Engineers are entrusted to always put safety, sustainability, and community welfare first, driven by a stringent ethical framework. The moment commercial interests start to dim these guiding principles, the potential threat to public safety and the quality of our engineering solutions escalates significantly.

Such practices, in my opinion, necessitate urgent scrutiny and discussion among our community. It's imperative that we address these issues to safeguard the integrity of engineering practices and ensure the prioritisation of public safety and welfare.

I am keen to hear your views on this matter. Have you encountered similar experiences in your area? How do you think we, as a community of professionals, should respond to ensure that engineering standards are not only upheld but also clearly defined and distinguished from trade qualifications?

Your insights and experiences would be invaluable in fostering a deeper understanding of this issue and in identifying possible steps we can take collectively to advocate for the necessary changes in regulation and practice.

Hmm so the suggestion is to make it a requirement for form 15 compliance certificates from trade licenses holders to be vetted by Registered Professional Engineers of Queensland (RPEQ) or only submitted by RPEQ?

From a duty of care standard point as engineers on the job, could this be intercepted in the construction stages?

Thanks for the discussion.

Hello everyone,

I'm reaching out to share and seek your thoughts on an experience I've encountered here in Cairns, Queensland, that has raised some significant concerns for me regarding the practice and integrity of our engineering profession, especially in the building and construction sector.

In several instances, I've observed building certifiers accepting Form 15 compliance certificates for the air-conditioning and ventilation design of sufficiently complex projects from individuals holding trade licences OR from Registered Professional Engineers of Queensland (RPEQ). This practice seems to acknowledge trade licence holders as being on par with RPEQs for the delivery of what I consider professional engineering services.

One of my main concerns revolves around the possibility that commercial interests could sway the solutions offered by trade licence holders, especially when they're responsible for providing compliance certification. This situation starkly differs from that of registered engineers, who adhere to a strict code of ethics. This code demands that the needs of the community take precedence over commercial benefits. Crucially, registered engineers do not gain commercially from the solutions they provide, ensuring their recommendations are made with impartiality and integrity. This distinction is vital, as it goes to the heart of our profession's integrity and the public's trust in us. Engineers are entrusted to always put safety, sustainability, and community welfare first, driven by a stringent ethical framework. The moment commercial interests start to dim these guiding principles, the potential threat to public safety and the quality of our engineering solutions escalates significantly.

Such practices, in my opinion, necessitate urgent scrutiny and discussion among our community. It's imperative that we address these issues to safeguard the integrity of engineering practices and ensure the prioritisation of public safety and welfare.

I am keen to hear your views on this matter. Have you encountered similar experiences in your area? How do you think we, as a community of professionals, should respond to ensure that engineering standards are not only upheld but also clearly defined and distinguished from trade qualifications?

Your insights and experiences would be invaluable in fostering a deeper understanding of this issue and in identifying possible steps we can take collectively to advocate for the necessary changes in regulation and practice.

Hello Troy,

I do not believe interception at the construction stage for an engineer to 'vet' the design provided by a trade license holder (or anyone else for that matter) would work for several reasons:

1. Timing and Coordination: The construction stage is beyond the design phase, where crucial coordination with architects, structural engineers, and other services should have already occurred. Changes arising from non-compliance with the mechanical services at this stage have the potential to significantly impact all aspects of the project.

2. Contractual Commitments: At the construction stage, contracts will have been signed, and financial commitments made. Consequently, the mechanical contractor or trade license holder would naturally be very reluctant to change a design or any element of it.

3. Decline in Supervision Services: Over the past few years, the uptake of construction phase supervision services by clients has decreased. This trend means fewer opportunities for identifying non-conformances during construction. My concern, however, is not just with projects involving engineers but particularly with those where an engineer has either been specifically excluded by the building certifier or where the certifier has deemed the design and certification by an engineer or a trade license holder as equivalent.

To ensure engineering standards are upheld and clearly distinguished from trade qualifications, I believe that Form 15 compliance certificates for mechanical services (air-conditioning and ventilation) and the associated BCA/NCC energy efficiency provisions should be submitted by RPEQs for all buildings and classifications where compliance with non-prescriptive standards (such as AS1668 parts 1 and 2) is required. It is important to note that design in accordance with a non-prescriptive standard is specifically listed as an exclusive professional engineering task in the Professional Engineers Act. This approach would help maintain the integrity of our profession and the trust placed in us by the public, ensuring that safety, sustainability, and community welfare remain our top priorities.

I look forward to hearing your thoughts on this approach.

Hmm so the suggestion is to make it a requirement for form 15 compliance certificates from trade licenses holders to be vetted by Registered Professional Engineers of Queensland (RPEQ) or only submitted by RPEQ?

From a duty of care standard point as engineers on the job, could this be intercepted in the construction stages?

Thanks for the discussion.

Hello everyone,

I'm reaching out to share and seek your thoughts on an experience I've encountered here in Cairns, Queensland, that has raised some significant concerns for me regarding the practice and integrity of our engineering profession, especially in the building and construction sector.

In several instances, I've observed building certifiers accepting Form 15 compliance certificates for the air-conditioning and ventilation design of sufficiently complex projects from individuals holding trade licences OR from Registered Professional Engineers of Queensland (RPEQ). This practice seems to acknowledge trade licence holders as being on par with RPEQs for the delivery of what I consider professional engineering services.

One of my main concerns revolves around the possibility that commercial interests could sway the solutions offered by trade licence holders, especially when they're responsible for providing compliance certification. This situation starkly differs from that of registered engineers, who adhere to a strict code of ethics. This code demands that the needs of the community take precedence over commercial benefits. Crucially, registered engineers do not gain commercially from the solutions they provide, ensuring their recommendations are made with impartiality and integrity. This distinction is vital, as it goes to the heart of our profession's integrity and the public's trust in us. Engineers are entrusted to always put safety, sustainability, and community welfare first, driven by a stringent ethical framework. The moment commercial interests start to dim these guiding principles, the potential threat to public safety and the quality of our engineering solutions escalates significantly.

Such practices, in my opinion, necessitate urgent scrutiny and discussion among our community. It's imperative that we address these issues to safeguard the integrity of engineering practices and ensure the prioritisation of public safety and welfare.

I am keen to hear your views on this matter. Have you encountered similar experiences in your area? How do you think we, as a community of professionals, should respond to ensure that engineering standards are not only upheld but also clearly defined and distinguished from trade qualifications?

Your insights and experiences would be invaluable in fostering a deeper understanding of this issue and in identifying possible steps we can take collectively to advocate for the necessary changes in regulation and practice.

Hello Troy,

I do not believe interception at the construction stage for an engineer to 'vet' the design provided by a trade license holder (or anyone else for that matter) would work for several reasons:

1. Timing and Coordination: The construction stage is beyond the design phase, where crucial coordination with architects, structural engineers, and other services should have already occurred. Changes arising from non-compliance with the mechanical services at this stage have the potential to significantly impact all aspects of the project.

2. Contractual Commitments: At the construction stage, contracts will have been signed, and financial commitments made. Consequently, the mechanical contractor or trade license holder would naturally be very reluctant to change a design or any element of it.

3. Decline in Supervision Services: Over the past few years, the uptake of construction phase supervision services by clients has decreased. This trend means fewer opportunities for identifying non-conformances during construction. My concern, however, is not just with projects involving engineers but particularly with those where an engineer has either been specifically excluded by the building certifier or where the certifier has deemed the design and certification by an engineer or a trade license holder as equivalent.

To ensure engineering standards are upheld and clearly distinguished from trade qualifications, I believe that Form 15 compliance certificates for mechanical services (air-conditioning and ventilation) and the associated BCA/NCC energy efficiency provisions should be submitted by RPEQs for all buildings and classifications where compliance with non-prescriptive standards (such as AS1668 parts 1 and 2) is required. It is important to note that design in accordance with a non-prescriptive standard is specifically listed as an exclusive professional engineering task in the Professional Engineers Act. This approach would help maintain the integrity of our profession and the trust placed in us by the public, ensuring that safety, sustainability, and community welfare remain our top priorities.

I look forward to hearing your thoughts on this approach.

Hmm so the suggestion is to make it a requirement for form 15 compliance certificates from trade licenses holders to be vetted by Registered Professional Engineers of Queensland (RPEQ) or only submitted by RPEQ?

From a duty of care standard point as engineers on the job, could this be intercepted in the construction stages?

Thanks for the discussion.

Hello everyone,

I'm reaching out to share and seek your thoughts on an experience I've encountered here in Cairns, Queensland, that has raised some significant concerns for me regarding the practice and integrity of our engineering profession, especially in the building and construction sector.

In several instances, I've observed building certifiers accepting Form 15 compliance certificates for the air-conditioning and ventilation design of sufficiently complex projects from individuals holding trade licences OR from Registered Professional Engineers of Queensland (RPEQ). This practice seems to acknowledge trade licence holders as being on par with RPEQs for the delivery of what I consider professional engineering services.

One of my main concerns revolves around the possibility that commercial interests could sway the solutions offered by trade licence holders, especially when they're responsible for providing compliance certification. This situation starkly differs from that of registered engineers, who adhere to a strict code of ethics. This code demands that the needs of the community take precedence over commercial benefits. Crucially, registered engineers do not gain commercially from the solutions they provide, ensuring their recommendations are made with impartiality and integrity. This distinction is vital, as it goes to the heart of our profession's integrity and the public's trust in us. Engineers are entrusted to always put safety, sustainability, and community welfare first, driven by a stringent ethical framework. The moment commercial interests start to dim these guiding principles, the potential threat to public safety and the quality of our engineering solutions escalates significantly.

Such practices, in my opinion, necessitate urgent scrutiny and discussion among our community. It's imperative that we address these issues to safeguard the integrity of engineering practices and ensure the prioritisation of public safety and welfare.

I am keen to hear your views on this matter. Have you encountered similar experiences in your area? How do you think we, as a community of professionals, should respond to ensure that engineering standards are not only upheld but also clearly defined and distinguished from trade qualifications?

Your insights and experiences would be invaluable in fostering a deeper understanding of this issue and in identifying possible steps we can take collectively to advocate for the necessary changes in regulation and practice.

Hi Sonia,

I think a lot of it comes down to the certifiers view on competent person and a lack of understanding from some certifiers on what professional engineering services are needed to demonstrate compliance on some projects. There is a guide put out that summarizes the Queensland Building Regulations definition and requirements of a competent person:

https://www.epw.qld.gov.au/__data/assets/pdf_file/0013/36103/guideline-for-competent-persons-17-July-2023.pdf

Interestingly, this document does use ventilation as an example for where an RPEQ is appropriate (large and complex) and where a QBCC licenced is appropriate (simple system). The problem with these definitions is there is a large spectrum of buildings between simple and complex. This is where the certifiers decision on who is a competent person and what Professional Engineering Services are being provided needs more scrutiny on some projects as you've suggested.

A lot of the elements that require sign off on a Form 12 relating to HVAC are from prescriptive standards and hence can be dealt with through QBCC licencing as wouldn't be a professional engineering service

 (https://bpeq.qld.gov.au/professional-engineering-services-and-prescriptive-standards/). If the Deemed To Satisfy solutions are followed to demonstrate compliance with the NCC these are prescriptive (refer to Part A2 in NCC2022 and the explanatory notes). AS1668.2-2012 notes in the forward that the standard is prescriptive and in Section 1.7 of AS1668.1:2015 the standard is noted as a prescriptive document.

Where I think there is some discussions in competent person requirements is that there is often engineering judgement (a professional engineering service) to translate prescriptive standards into an HVAC design that gets glossed over and generally needs more discussion with some certifiers.

Hello Troy,

I do not believe interception at the construction stage for an engineer to 'vet' the design provided by a trade license holder (or anyone else for that matter) would work for several reasons:

1. Timing and Coordination: The construction stage is beyond the design phase, where crucial coordination with architects, structural engineers, and other services should have already occurred. Changes arising from non-compliance with the mechanical services at this stage have the potential to significantly impact all aspects of the project.

2. Contractual Commitments: At the construction stage, contracts will have been signed, and financial commitments made. Consequently, the mechanical contractor or trade license holder would naturally be very reluctant to change a design or any element of it.

3. Decline in Supervision Services: Over the past few years, the uptake of construction phase supervision services by clients has decreased. This trend means fewer opportunities for identifying non-conformances during construction. My concern, however, is not just with projects involving engineers but particularly with those where an engineer has either been specifically excluded by the building certifier or where the certifier has deemed the design and certification by an engineer or a trade license holder as equivalent.

To ensure engineering standards are upheld and clearly distinguished from trade qualifications, I believe that Form 15 compliance certificates for mechanical services (air-conditioning and ventilation) and the associated BCA/NCC energy efficiency provisions should be submitted by RPEQs for all buildings and classifications where compliance with non-prescriptive standards (such as AS1668 parts 1 and 2) is required. It is important to note that design in accordance with a non-prescriptive standard is specifically listed as an exclusive professional engineering task in the Professional Engineers Act. This approach would help maintain the integrity of our profession and the trust placed in us by the public, ensuring that safety, sustainability, and community welfare remain our top priorities.

I look forward to hearing your thoughts on this approach.

Hmm so the suggestion is to make it a requirement for form 15 compliance certificates from trade licenses holders to be vetted by Registered Professional Engineers of Queensland (RPEQ) or only submitted by RPEQ?

From a duty of care standard point as engineers on the job, could this be intercepted in the construction stages?

Thanks for the discussion.

Hello everyone,

I'm reaching out to share and seek your thoughts on an experience I've encountered here in Cairns, Queensland, that has raised some significant concerns for me regarding the practice and integrity of our engineering profession, especially in the building and construction sector.

In several instances, I've observed building certifiers accepting Form 15 compliance certificates for the air-conditioning and ventilation design of sufficiently complex projects from individuals holding trade licences OR from Registered Professional Engineers of Queensland (RPEQ). This practice seems to acknowledge trade licence holders as being on par with RPEQs for the delivery of what I consider professional engineering services.

One of my main concerns revolves around the possibility that commercial interests could sway the solutions offered by trade licence holders, especially when they're responsible for providing compliance certification. This situation starkly differs from that of registered engineers, who adhere to a strict code of ethics. This code demands that the needs of the community take precedence over commercial benefits. Crucially, registered engineers do not gain commercially from the solutions they provide, ensuring their recommendations are made with impartiality and integrity. This distinction is vital, as it goes to the heart of our profession's integrity and the public's trust in us. Engineers are entrusted to always put safety, sustainability, and community welfare first, driven by a stringent ethical framework. The moment commercial interests start to dim these guiding principles, the potential threat to public safety and the quality of our engineering solutions escalates significantly.

Such practices, in my opinion, necessitate urgent scrutiny and discussion among our community. It's imperative that we address these issues to safeguard the integrity of engineering practices and ensure the prioritisation of public safety and welfare.

I am keen to hear your views on this matter. Have you encountered similar experiences in your area? How do you think we, as a community of professionals, should respond to ensure that engineering standards are not only upheld but also clearly defined and distinguished from trade qualifications?

Your insights and experiences would be invaluable in fostering a deeper understanding of this issue and in identifying possible steps we can take collectively to advocate for the necessary changes in regulation and practice.

Hello everyone,

I'm reaching out to share and seek your thoughts on an experience I've encountered here in Cairns, Queensland, that has raised some significant concerns for me regarding the practice and integrity of our engineering profession, especially in the building and construction sector.

In several instances, I've observed building certifiers accepting Form 15 compliance certificates for the air-conditioning and ventilation design of sufficiently complex projects from individuals holding trade licences OR from Registered Professional Engineers of Queensland (RPEQ). This practice seems to acknowledge trade licence holders as being on par with RPEQs for the delivery of what I consider professional engineering services.

One of my main concerns revolves around the possibility that commercial interests could sway the solutions offered by trade licence holders, especially when they're responsible for providing compliance certification. This situation starkly differs from that of registered engineers, who adhere to a strict code of ethics. This code demands that the needs of the community take precedence over commercial benefits. Crucially, registered engineers do not gain commercially from the solutions they provide, ensuring their recommendations are made with impartiality and integrity. This distinction is vital, as it goes to the heart of our profession's integrity and the public's trust in us. Engineers are entrusted to always put safety, sustainability, and community welfare first, driven by a stringent ethical framework. The moment commercial interests start to dim these guiding principles, the potential threat to public safety and the quality of our engineering solutions escalates significantly.

Such practices, in my opinion, necessitate urgent scrutiny and discussion among our community. It's imperative that we address these issues to safeguard the integrity of engineering practices and ensure the prioritisation of public safety and welfare.

I am keen to hear your views on this matter. Have you encountered similar experiences in your area? How do you think we, as a community of professionals, should respond to ensure that engineering standards are not only upheld but also clearly defined and distinguished from trade qualifications?

Your insights and experiences would be invaluable in fostering a deeper understanding of this issue and in identifying possible steps we can take collectively to advocate for the necessary changes in regulation and practice.

Hi Sonia,

QBCC trade certifiers license allows them to do a Form12. Yes, we met with QBCC last year about this, and the fact Engineers having to compete with trades. We do this as well and very frustrated, that systems in A/C are not "DtS" - but require engineering to achieve acceptable operational performance. So EA. said that its engineering work.

Also - PI we carry by law - they don't. We carry 10 million, they carry $250,000 as SC1 in assets under Finacial reporting rules. The Certifier is not getting the details that a SC1 can only certify $250,000 valued works annually and we told QBCC many trade contractors on a Certify license exceed this, breaching the law. They are not acting on it - but we are making advocacy attempts to get them to change the declarations on a FORM 12. Certifiers need to step up as they are responsible to assess competency in the Form12 author. 

Hello everyone,

I'm reaching out to share and seek your thoughts on an experience I've encountered here in Cairns, Queensland, that has raised some significant concerns for me regarding the practice and integrity of our engineering profession, especially in the building and construction sector.

In several instances, I've observed building certifiers accepting Form 15 compliance certificates for the air-conditioning and ventilation design of sufficiently complex projects from individuals holding trade licences OR from Registered Professional Engineers of Queensland (RPEQ). This practice seems to acknowledge trade licence holders as being on par with RPEQs for the delivery of what I consider professional engineering services.

One of my main concerns revolves around the possibility that commercial interests could sway the solutions offered by trade licence holders, especially when they're responsible for providing compliance certification. This situation starkly differs from that of registered engineers, who adhere to a strict code of ethics. This code demands that the needs of the community take precedence over commercial benefits. Crucially, registered engineers do not gain commercially from the solutions they provide, ensuring their recommendations are made with impartiality and integrity. This distinction is vital, as it goes to the heart of our profession's integrity and the public's trust in us. Engineers are entrusted to always put safety, sustainability, and community welfare first, driven by a stringent ethical framework. The moment commercial interests start to dim these guiding principles, the potential threat to public safety and the quality of our engineering solutions escalates significantly.

Such practices, in my opinion, necessitate urgent scrutiny and discussion among our community. It's imperative that we address these issues to safeguard the integrity of engineering practices and ensure the prioritisation of public safety and welfare.

I am keen to hear your views on this matter. Have you encountered similar experiences in your area? How do you think we, as a community of professionals, should respond to ensure that engineering standards are not only upheld but also clearly defined and distinguished from trade qualifications?

Your insights and experiences would be invaluable in fostering a deeper understanding of this issue and in identifying possible steps we can take collectively to advocate for the necessary changes in regulation and practice.