I have read the proposed SFPE response to the current MBIE Consultation.
I don’t think that the proposed response adequately captures the importance of this topic to our profession and I don’t think that the response advocates sufficiently for our profession.
I believe that occupational registration is vital but if it only applies to current Engineers and is just a re-brand of CPEng then it will not achieve any meaningful change.
What seems to be missing from the Consultation and the SFPE response is the vitally important question of how or what will force occupational registration. If it is purely voluntary then it will serve no purpose.
The impetus must come from Legislation. The Building Act or Regulations must enforce a requirement for compulsory occupational registration.
The following is the gist of my submission to MBIE.
Please feel free to use any or all of it in your own submissions.
For Fire Engineering:
Registration / Licensing must be a requirement for any person doing fire engineering design work (including Acceptable Solutions, Verification Methods and Alternative Solutions) for all buildings that are
IL4 (all buildings),
IL3 (all buildings),
IL2 where the building:
contains any sleeping Use Group (SC, SD, SA, SR). [SH already covered by RBW/LBP regime],
contains Crowd activities which are CL, CO or CM,
has a Use Group WH or WF,
contains Use Group WL and is higher than 4 levels (with a single stair) or over 9 levels in all other cases.
The Building Act will require amendment to force this issue.
This regime will need to capture all practitioners who are not already LBP or CPEng as well as recertifying the people who are already LBP/ CPEng.
The Registration / Licensing regime should also be graduated so that there are certain niches and levels of competence being assessed for people who focus their work in different areas. For example a practitioner who only normally works with 2 level rest homes would not necessarily be interested in, nor potentially capable of, dealing with a 20 level multi-use sleeping and crowd use building.
The Registration / Licensing regime will need to set relevant training, experience and qualification requirements for the various levels.
The registration/ Licensing regime will also (as with LBP/CPEng) need to set appropriate disciplinary processes and penalties for dealing with deviations.
It is proposed that the implementation of the system should be:
6 months for IL4 (all buildings),
12 months for IL3 (all buildings),
6 months for IL2 where the building contains any sleeping Use Group (SC, SD, SA, SR).
6 months for IL2 where the building contains Crowd activities which are CL, CO or CM,
24 months for IL2 where the building contains has a Use Group WH or WF,
24 months for IL2 where the building contains Use Group WL and is higher than 4 levels (with a single stair) or over 9 levels in all other cases.