The Plumbing Code of Australia: A Critical Component

So what I want to do – I've said a few times today to different people it's very difficult – and like Kevin pointed out this morning, it's a bit difficult to pick the audience in plumbing because it's so diverse and so broad from great highs to the depths of trenches.

So this is – I may cover over some old ground that you're quite comfortable with but there shouldn't be too much of that but I think you need the full picture to be able to I suppose accommodate the package in your own thinking in your own mind.

So I won't go back as far as the early 20th century as Kevin did, but once upon a time in 2011 the ABCB released the NCC.

This was a dream many years ago but it didn't come to fruition until the BMF made the decision – the Building Ministers Forum made the decision to proceed.

So we've got three volumes – Building and Plumbing adopted in all eight States and Territories which is a huge feat.

It applies to all new building and plumbing work as determined by the legislation that references it.

It's performance based as you know and offering the two options of compliance – performance and prescriptive.

If you've been here longer than today, there's been a lot of conversation in the big room around the corner about performance solutions and prescriptive solutions and alternate solutions and deemed to satisfy solutions.

There's really only two options and there's only really two things to remember – performance or prescriptive.

So today's topic – PCA.

What is it? Where does it sit? Why do we have it? What's in it and why are we here now? So the Plumbing Code is a national technical policy document.

It sets performance levels for plumbing solutions and identifies acceptable solutions.

I'll go into a bit more detail.

It sits in the middle really.

We've got our regulatory structure.

State and Territory Acts call up regulations, regulations call up the code and the code calls up reference documents for its deemed to satisfy solutions.

The code gets called up in different ways.

In some States – the States vary in the way they adopt it.

They adopt either the NCC, they adopt the BCA and the PCA and some I think even still pick up just parts of the PCA but that's all coming together but it's just the way that you've got eight administrative structures, eight legislative structures and they're all going to vary a little bit but ultimately this is how it works.

So why do we have it? National consistency.

One central point for industry on technical plumbing policy matters which is the ABCB.

We're not the regulators but we're a focal point.

We're a central point for the States to come together and agree on what should be in the document and what should happen in the industry.

It provides flexibility for practitioners through the availability of performance and red tape management.

So that just means that we use the COAG Best Practice Regulation Guide and we controlled deemed to satisfy references which are predominantly Australian Standards and predominately AS/NZS 3500.

We control how they're – Well we oversee it to some extent how they're drafted, how they're produced and how often they're adopted into the Plumbing Code which gives the industry as a whole a bit more surety as to what's happening when and where.

So what's in it? Nationally agreed performance levels.

Nationally acceptable technical solutions which is what I mentioned before.

The nationally accepted technical solutions – deemed to satisfy.

Now some of these are contained within the Plumbing Code – not many – but the majority are the documents that are referenced in the Plumbing Code in the same way as Australian Standard references are the standards.

They become part of that legislation to the point that they are applicable.

The integral deemed to satisfy solutions – there's a couple in there at the moment.

It will probably grow to some extent especially with the harmonisation processes that we're going through with the Building Code of Australia but we're going through the transfer of heated water temperature controls, flow rates for fixtures, capacity for systems – system capacity for sanitary systems.

This is about putting the policy controls in a document that is managed by the States and Territories.

It's their legislation.

They don't want that to be sitting in a standard that could be changed potentially by industry or vested interests.

They want to be able to have it where they can see it and where they can manage it.

So if there's a need to increase or reduce, then it becomes their role through the PCA.

So there's core plumbing streams in the PCA.

The obvious one is cold and heated water, drinking, non-drinking, fire services to the extent that there's overlap with the Building Code of Australia.

Sanitary plumbing and drainage – they're the two core.

We have other streams – stormwater, heating, ventilation and air-conditioning, on-site waste water management.

Now these are there – I mean I've said this many times over the last couple of years – these are there because some States – When the PCA was developed, it was developed with a strong influence I suppose.

It's not a criticism of Victoria who actually regulate all of these areas as plumbing.

Not all the States do.

So they're all contained within the one document and then the States use those components as they see fit or as they see necessary.

So why are we here today? 2015/'16 the year of performance.

The Board has made decisions to advance performance where it's been sitting probably neglected to some point predominantly in the building sector but the plumbing sector is in a position now to sort of take advantage of this promotion and this development into an area that can provide a lot more flexibility for the industry.

Performance all began in 1996 for the Building Code of Australia and in 2004, 2011 for the Plumbing Code.

As Kevin mentioned earlier, the Plumbing Code of Australia was released in 2004.

It was a performance based document.

So the industry's had this for 11 years but it wasn't nationally adopted but it's been there available for States to pick up as they wanted to, and now it's there the ABCB have management of it and there's a concerted push to promote performance and its use of it.

So, yes, building had a renewed emphasis because it's been nearly 20 years since performance was introduced into the building sector and it's predominantly used for fire services and energy efficiencies, sustainability matters and there are to a lesser extent other components.

But, yes, plumbing – it is still a new concept.

So 2015 the performance push.

The grey book, sometimes known as the platinum book, sometimes known as 50 shades of grey because no one's too sure what it means.

It was released by the Board – I'm not too sure how long ago – probably it was earlier this year or late last year – and it's there as an advisory document.

It's an extract as it says and an extract of the performance criteria of all three volumes has just been dumped into one place so that you can actually refer to it as a bit of a ready reference.

It's not a legislated document.

It may become one in the future but currently it's just there as a bit of an identifier so that you can see that performance and the code itself – all three volumes – can fit in quite a small book.

You've got a copy on your tables.

We've also produced a guidance document.

There's a copy of that inside the book – the other book on your table as well if you want to have a look at it and it's also down on our stand.

This is a four-step guide that was developed based on the International Fire Engineering Guidelines which were a project that goes way back with the ABCB and its predecessors.

The International Fire Engineering Guidelines were developed to help fire engineering solutions be developed in a more efficient and suitable manner.

Well that document has been compressed from however big it is to a two pager and four-step process to just try to provide a little bit of information or a bit of advice to show that it's not that complicated a process.

It can be quite simple.

So it was a starting point.

We've also produced a solution summary which is available at our stand as well.

This one may be of use.

It's probably more for Building Code users.

It just summarises all the DTS and all the peak performance requirements into a four pager again just to show that you can actually line all these things up.

It's a bit of a ready reckoner.

We've just over the last six months or so started to release case study scenarios.

These are just examples of situations that can be turned into performance or where performance can be used just to try and – Same again, to promote its use and just to explain that it's not that complicated.

The blue one – all the blue ones you'll see with the blue band at the top are for volume one which is your commercial/multi-residential construction.

The red one is volume two – predominantly housing, and the green ones are all plumbing.

We've also got YouTube clips which are the same thing.

They just sort of animate the process and explain how it can be used.

Something that's happened as part of the public comment process and the draft for 2016 are changes to Section A.

Section A is the driver of the Plumbing Code.

It sort of tells you how to use it and how States sort of expect to be able to regulate the code and the requirements.

So there's been some sort of structural change to it and I'll go through that in a little bit in a minute.

So that's the critical driver.

AO tells you how to apply the PCA.

A1 tells you how to interpret it.

A2 tells you what will accepted for compliance and A3 tells you what documents are accepted for DTS.

So that's your list of references to the Australian Standards and other standards.

A4 was introduced last year or the year before and it introduces the classes of buildings and structures.

The classes of buildings and structures was extracted and copied from the Building Code because there are many situations in the plumbing world where a class of building is relevant to the design of a system that you use.

So we felt it was probably quite a good idea to start to overlap and harmonise this stuff and it would ultimately make the design and application of plumbing a little bit easier and a little bit more structured and consistent.

I'll focus more on AO today which is how to apply the PCA.

Is it complicated? Currently we've got a triangle or a pyramid or a tiered Nordic structure.

It depends on how far your history or your knowledge goes back of the Building Code.

It's been around since '96 when the Building Code came out and adapted by the NPRF to suit plumbing and the same system of process worked.

Performance is mandatory.

Always was.

It's the mandatory component.

The objectives and functional statements at the top of the pyramid have always been advisory and that's noted in the front of the document.

Two options of solutions.

DTS alternative solutions.

So in the future – Because I know you all would have looked at the Public Comment Draft for 2016 and submitted comments before the 31st of July, you would have noticed that they've fiddled with the structure.

The dumbbell – maybe not, maybe so.

Performance is mandatory.

Two options of solutions – prescriptive DTS and alternative solutions.

Exactly the same.

Different structure.

It's all about simplification of the process of making it a bit easier to understand so no difference.


They refer to the relevant PCA sections as I mentioned.

You can comply with all the relevant provisions and clauses, refer to all relevant reference standards, follow the prescriptive recipe and you've got guaranteed approval by the approval authority.

That's how it is meant to work.

Evidence of suitability subject to some – and some don't necessarily realise this, that evidence of suitability which is A2.

2 of the code applies to all DTS and performance solutions and it all comes down to what is accepted by the regulator.

So a signature from the plumber on the bottom of his application form – there's your evidence of suitability.

For a complex performance solution or something a little bit more detailed, it may require more evidence.

It will require more evidence.

So the second option – alternative solutions.

The process you'd go to.

Understand the needs of the regulatory approval authority.

You need to know what they want.

You need to know what they need because they have to cover themselves as well as you have to cover yourselves.

Consult with the relevant stakeholders.

This might be the – If you're a plumber, you consult with the designer, you consult with the regulatory approval authority, the plumbing inspector, the State Government depending on the extent and the size of the project and the process.

Consider what evidence you're going to need to be able to convince that approval authority that what you're proposing is going to work.

Capture all the relevant performance requirements.

It's not that complicated for plumbing.

Building gets a little more complex when you get into fire services and fire protection and escape mechanisms and such.

Plumbing it's usually either cold water plumbing, hot water plumbing, sanitary drainage or sanitary plumbing.

Choose the most appropriate assessment method.

There's a range of things in the front of – in AO which I think I've got on a future slide.

I haven't been checking my own notes.

They're options.

They're options again that you can nominate and in some legislation may even have to nominate what they are to identify the process that you're going to use for your alternative solution.

So expert judgment, a verification process, a verification method that's either identified within the code or one that's acceptable to the approval authority.

So much of this comes down to being accepted by the approval authority and speaking to them before it happens so that they know.

Choose the most appropriate expert.

If you've got a complex design, you need someone that's going to understand that, someone that's comfortable with assessing it, someone that's comfortable signing off on it.

If it's simple, it might just be a plumber with licensing qualifications at a certain level.

It depends on the complexity.

Consider how it can be verified.

So like evidence, how can you show that your sums, your numbers, your calculations are going to add up? Something – your distances.

What are you going to provide that's going to be able to – same thing – to go into the package that goes to the regulatory authority to show that you know what you're doing.

And document everything.

Document all the evidence for the approval authority.

Put it together as a package.

It's just like a building application.

Key consideration – recognised expert, expert judgment, recognised credentials.

Like I've said, acceptance depends on the regulatory authority.

Really it does.

Some States have this legislated as to what they'll accept.

Some don't.

Some are quite happy with their own – using their own expert judgment and their knowledge of you as an individual or your sector of the industry.

I think the NT have a requirement for a registered engineer to sign off on all alternate solutions.

That's just the process that they've got legislated.

The others haven't got that to my knowledge.

So it will depend on qualifications, experience, expertise and will depend on the degree of complexity.

So why use performance if DTS is easier? You've got a standard there.

It's all written out – black and white.

You copy the details.

Sometimes you have to.

There's several areas in plumbing and drainage that currently there's no DTS – heated water, vacuum drainage, warm water systems – Lynn, she'll talk a bit later – sulphonic drainage, macerating toilet installations, press-fit joints.

The most recent one that's hit the plumbing press.

None of these – there's no DTS – but they're used every day in Australia.

So the process is there.

It's just that it's been used in a different way or understood in a different way.

The regulators still have to accept this stuff and they currently do.

Now they're going to use – With their understanding and their development and use of the PCA, the process is going to become more structured, more rigid, so you have to able to understand how it works as well.

Sometimes it's the best way also to use performance – complex projects, heritage situations.

Stretching the DTS – it doesn't always fit.

Innovative new products and systems.

I mean you can't use performance to replace watermark but there are installations where you may have watermark products that there's no installation DTS requirements which means you're going to have to develop something.

It hasn't had to be done in the past but some of the States are actually starting to control this.

So you'll find that if you have a watermark product but there's no sort of ready reckoner on how to install it, that the plumbing inspector, depending on where you are, may actually tap you on the shoulder and say "Well where's your alternate solution application?" or "Where's your DTS?" And to save money and time.

There are benefits in some situations.

It's not a one size fits all.

Performance can be hugely advantageous especially on large jobs – because you can, because it's there.

The PCA provides that structure.

So the guidance document is a bit of a means to an end.

Like I said, it's a four-step process.

It's available from the website.

It's based on the process described in the IFEG document and it's suitable for any NCC solution.

It wasn't developed for plumbing.

It wasn't developed for building.

It's the same performance structure.

The four steps – prepare a performance based design brief.

Now this is a sort of techie IFEG speak but really it's just about planning what you're going to do.

Draft up a bit of a plan.

It can be of your own processes.

Analysis modelling testing – collate the evaluated results.

Prepare a final report.

Four steps.

A simple form of solutions require simple applications to process.

So I'll briefly go through them.

These are sorts of questions that you can ask yourself if you're going through this process.

What are the design objectives? Who should be consulted? What is the basis of the solution? What evidence is proposed? Which DTS provisions are applicable? This caused a little bit of controversy in the office recently because there's a component in AO which is potentially going to be removed and it's a reference to DTS as part of the performance solution.

This is the way the whole system was developed way back.

You can use DTS as a measuring stick if you need to.

You can still use it as part of calculating whether your performance is going to fit.

It can be used in different ways.

And which performance requirements are applicable? Second step – analysis modelling testing.

I'm probably running over time here.

Sorry Murray.

Which assessment methods in AO9 are most suitable? These are the ones I mentioned earlier.

Evidence in accordance with A2.

2 which is your evidence clause, verification methods, comparison with DTS and expert judgment and, back to that earlier point, expert judgment.

Who's an expert and who's judgment is that? It comes down to the regulatory approval authority and the regulators are working on that now trying to get a little bit of consistency in how they can apply it but it's eight countries within one so it's always going to be a challenge.

Every job is different.

Step three – collate and evaluate results.

How's verification achieved, collation of documentation, analysis of design calculations, certification of plans and calculations by a third party recognised expert.

Vacuum toilets – you know there's international expertise in that area that may be sufficient to sort of help you through that process.

Physical inspections if they're necessary.

Certification under test conditions.

Any or all of those, they're all options.

And your final report, what should you put in it? Hydraulic design, calculations, verification sheets, third party certification if it's necessary.

The qualifications of the expert – Depending on the level of the complexity, it might be a plumber with certain – a contractor plumber that's got certain licensing categories against his name.

That might be sufficient.

It depends on what it is.

Statements of acceptance – acknowledgement by the owner, the developer, the builder, the network utility operator.

This sort of stuff will help future owners or future work change within that project or that building.

Any or all of the above.

So what will they accept? It depends on complexity and it depends on the authority.

Simple, simple.

So guidance material – there's a little bit out there.

There's not a huge amount.

We're sort of trying to do our bit with what we've started with the Guidance document and the examples.

We have here – Fair Trading have done a fair bit of work in New South Wales since the PCA came out.

They have a very sort of black and white prescriptive sort of process and that's how it works for them and they prefer that but they've introduced a guide on how it works for them.

They've got their tick sheet – their pro forma for that.

Brisbane City Council which you're probably familiar with that if you've worked in this area.

Western Australia have just released this year a guidance note on how they manage it within Western Australia.

All these ones in the centre and on the right hand side are building related ones.

The VBA has processes.

The building ones gets a little bit more complex because you're talking about a lot more about large life safety risk where it gets into fire areas so they have a lot more information available.

But even industry – WoodSolutions, Department of Defence are up here somewhere, Fire Engineering, organisations are providing their own advice so this is to sort of help clients – help people understand.

So it's getting there.

It's getting better.

So a final wrap-up.

PCA formalises the process.

The system is there now.

We're just trying to – it just puts it into one place and a little bit more consistent in how it's applied.

It provides structure for the designer, the contractor, the regulatory authority.

It provides surety to the regulatory authority and it provides surety to the property owner.

PCA and alternative solutions – it's not that complicated.

That's my new catchcry.

That's me.

(Audience Applause).

Source: Youtube