Special assessments and the need to notify IANZ of any 'critical change' that may affect accreditation
Recently IANZ highlighted the need for BCAs to notify it of any 'critical change' to the BCA that may affect accreditation. This requirement comes from the provisions of the Gazette notice requiring IANZ to undertake special assessment audits and related provisions of the Building (Consent Authority Accreditation Fees) Regulations 2007. The requirement is also covered in IANZ's standard offer of accreditation as a pre-requisite to accepting accreditation.
The Regulations define a 'special assessment' and a 'critical change' as follows.
- special assessment audit means any audit that is undertaken because of a critical change that does not, in the opinion of the building consent accreditation body, warrant a full technical reassessment audit
- critical change, in relation to a building consent authority, means a change that:
- (a) has occurred since the authority's accreditation or most recent full technical reassessment audit, as the case may be; and
- (b) is, or may be, in the opinion of the building consent accreditation body, a crucial indicator as to whether the authority is able to perform its building control functions so as to continue to comply with the prescribed criteria and standards for accreditation; and
- (c) includes any matter about which the Ministry [meaning the Department] or the building consent accreditation body receives a complaint that is not dismissed following initial inquiries into it by the Ministry or the building consent accreditation body (as the case may be) and, if substantiated, would indicate a critical change
A key phrase to note in the definition of 'critical change' is the reference to 'a crucial indicator as to whether the authority is able to perform its building control functions so as to continue to comply with the prescribed criteria and standards for accreditation'. While there will always be a need to exercise a degree of judgement, to help BCAs understand what changes need to be notified, the Department will work with IANZ to develop and publish guidance material, including examples, of what may constitute a critical change.
In the meantime, we suggest that changes that ought to be notified would include things like:
- any significant loss of building control capability or capacity that contingency arrangements cannot adequately address (eg, loss of senior technical staff and an inability to replace them quickly)
- new or amended building control management or staffing structures, contracting arrangements, or building control systems that differ substantially from what existed at the time of the previous accreditation assessment.
In most cases, good forward-planning and timely liaison with IANZ should substantially reduce the need for special assessments, for example, by:
- maintaining contingency arrangements to cover the loss of critical building control capability or capacity between routine assessments (eg, to reduce the impact of the loss of key technical staff members, particularly in a small BCA where limited internal capacity makes it more difficult to provide the necessary cover for a vacancy)
- informing IANZ promptly of any unexpected changes and how the impacts of change will be addressed
- timing any major operational changes so the changes can be considered as part of a routine reassessment.