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Regulate The HVAC&R Trade In QLD As A Specialised Trade, Require Min Cert III RAC Quals

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To Hon, Mick de Brenni, Minister for Public Works and Housing, Hon. Grace Grace, Minister for Employment and Industrial Relations, Hon. Dr Anthony Lynham, Minister for Natural Resources and Mines and Premier for Queensland, Hon. Annastacia Palaszczuk, we submit the following to acknowledge and make necessary changes to licensing reforms for the HVAC&R Industry

 The HVAC&R Industry demand changes in recognition of a national skills based license, and implore the QLD government to adopt and implement policies with legislative reforms, to ensure the HVAC&R Industry is recognised as a specialised licensed trade alongside other peripheral trades. The HVAC&R industry do not want further fragmentation of its industry any more: 

WHY?

There is no current documented evidence showing any prosecution from works carried out by current national Arctick environmental license holders with a Certificate II in Split/Systems qualification who consistently exceed their scope or break the law from work done throughout Australia however, evidence shows:

·         A RAC trade person who attends 9 jobs, 9 installations with leaks, all installed by plumbers in Victoria

·         QLD Rac tradesperson arrives onsite to find Cert II installer has released all R32 refrigerant, along with many other notable flawed works.

·         Rochester, Victoria, 2 diesel fitters die in a fatal explosion working with refrigerants they didn't understand.

·         2009 Nambour, Qld, plumber dies as a result of cutting pipes and not understanding the pressures relating to refrigerants.

·         QLD, plumber simply chops the pipe and releases all refrigerant to remove a/c system and repair water leak.

·         QLD electrical industry refer to several incidents blaming the RAC tradesperson, regardless of two fatalities occurred by an electrician.

FACT

·         An estimated 75% of split system installations in QLD are carried out by non-trade qualified RAC persons, and do not meet the designed parameters for energy efficiency.

·         The Bligh government implementation of policy was to allow and promote electricians as installers of a/c's and not HVAC&R trade qualified tradespeople. In addition, these changes made all whitegoods stores display signage beside all systems stating "Must be installed by a licenced electrician: false and misleading.

·         Peripheral trades are not technically competent to carry out any HVAC&R works, unless a full 4-year apprenticeship in HVAC&R has been achieved.

·         No fully qualified HVAC&R tradesperson can legally work in electrical or plumbing industry without the recognised qualification by those industries.

·         Increased skill shortage nationally due to the introduction of a lesser qualification to accommodate the environmental ARC licence.

·         Less viability for survival of small business in the HVAC&R industry due to peripheral trades undercutting of air-conditioning installations putting immense pressure on family businesses. 

·         Higher OH&S risks to HVAC&R tradespeople from exposure to faulty work carried out by environmental license holders. 

RESPONSE TO QLD HVAC&R LICENSING REFORMS

The functions of the Service Trades to only include plumbing, unless agreement and recognition ensures HVAC&R sector is operated by HVAC&R industry. Firefighters place their lives in danger entering premises with refrigerants and engulfed in flames as evident in the Tamawhere incident in New Zealand, we request the united firefighter’s union be included in the Services Trade Council.
No increase in the monetary threshold not for the refrigeration and air conditioning trade. The former QBSA were made aware of HVAC&R works exceeding monetary value by peripheral trades and in support of peripheral trades (Electrical) increased the monetary value, failing consumers, industry and environment. The monetary value must be reduced to zero to prevent further deaths/injuries. 
No increase to the monetary threshold for Qld Home Warranty Scheme.
Type A gas work licensing function should be transferred to the QBCC however, should include hydrocarbons under refrigeration and air-conditioning and limitation on RAC tradespeople who only have current knowledge on the handling of hydrocarbons
NO mechanical services license should be introduced because of the OH&S risks, from not being fully qualified in doing a 4-year term of an apprenticeship in the HVAC&R industry. (mechanical services does not cover all requirements under a Certificate III in refrigeration and air-conditioning). The mechanical services license will encourage Certificate II ARC license holders to work outside of their scope of qualification due to lack of prosecution by the regulator.
The HVAC&R industry want reform and better regulation in all areas of the industry however; it must remain as a specialised trade with its own trade recognised license.
Licensing assessors must be HVAC&R qualified with the correct tools to carry out effectiveness of efficiency on RAC systems.
Licensing of plumbing and drainage apprentices should not include any RAC work including the condensate drain. Only HVAC&R tradespeople are technically competent in this area as proven in Victorian with the lack of technical competence plumbers have in relation to HVAC&R work.
The provisional plumbing license should be removed.
The QBCC should consolidate its functions and powers only if it includes RAC Certificate III requirements to carry out all HVAC&R works with zero monetary value for the licence. The monetary value is easily exploited by the Certificate II ARC license holder when producing more than 1 invoice on work carried out by keeping large jobs under the QBCC licensing requirements, and allowing these Certificate II ARC license holders to work outside their scope.
The HVAC&R trade is a specialised trade therefore, must stand alone and should not be streamlined into existing licensing and technical requirements.
Mobility of trade services through Automatic Mutual Recognition will exclude the HVAC&R industry as it is not a license trade the same as all other industries. The meaning of Mutual Recognition as it stands today is a licensed person moving from one jurisdiction to another and must be authorised by the licensing authority in each state to work within their equivalent scope of work. HVAC&R tradespeople only hold an environmental license.  
Designs for the introduction of a continuing professional development scheme." -can only exist if all HVAC&R trade qualified persons are up skilled in the use of all refrigerants. 
CONCLUSION

The exclusion of a trade license for the HVAC&R industry does not instil any confidence for its tradespeople or consumers.  The introduction of a national license trade for the HVAC&R industry will:

·         Improve business efficiency and the competitiveness of the national economy

·         Reduce red tape

·         Improve labour mobility

·         Enhance productivity; and

·         Boost consumer confidence and protection without the unnecessary costs or lessening competition.

ARMA will also make a formal submission.



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