Submission from the Environmental Health Directorate, Department of Health.

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1 Review of plumbing regulation in WA discussion paper Submission from the Environmental Health Directorate, Department of Health. The Environmental Health Directorate (EHD) supports the concept that regulatory processes for plumbing should be managed by an entity independent from plumbing representation groups and should aim to protect the public from risks associated with how plumbing operates. Regulatory review is required where the perception is that current regulatory processes relate to plumbing connected to a metered potable or scheme water supply. This does not consider the common situations in remote Aboriginal communities or work camps where poor operation of plumbing can and does pose a significant risk to health and/or diminish sustainable water supplies. Plumbing regulation should consider that where a risk to health is evident due to poorly functioning plumbing material or connections, that the risk that should be managed as a priority. In consideration of the need that exists to attend to basic plumbing repairs where access to a licensed plumber may be limited, the EHD recommends that the regulations allow for and recognise that suitably trained persons are authorised to effect such repairs. In October 2003, the Plumbing Licensing Board wrote to Ms Tamela Vestergaard indicating a recognition of the role Environmental Health Workers trained to a Certificate 2 level in environmental health played in effecting basic repairs to faulty plumbing. They stated that they would undertake to develop a restricted plumbing permit model which recognised the workers with authorisation from the Board to do this work. To date, other than the development of two options for discussion developed by the PLB at or around 2009/10, no progress has been made on this. It is the view of EHD that there remains and currently exists a need for recognition of persons with suitable training and other than licensed plumbers to effect basic repairs to plumbing in many nonurban settings. Whilst this might be one of the considerations of the PLB as part of its overall and broad review of the need for plumbing regulation in WA, EHD considers that access to a restricted permit is a more immediate concern. It has taken 10 years to get to a point where consultation is now occurring on behalf of PLB with regard to the broader view of regulation. There is concern that this recognition and apparent need is being delayed by the PLB because of sensitivity to an industry it should regulate and not represent. WA is the largest state in Australia and there are many communities remotely located. Access to licensed plumbers is poor in many areas and tends to be expensive due to mobilization costs and a lack of competition. EHD recognises that there are many complex plumbing procedures which require the skill set and application of a recognised and licensed plumber and would never seek to replace this. What is also apparent, however, are the vast number of basic problems problems typically encountered in poorly maintained housing. Where there is a lack of servicing of housing, plumbing problems contribute to the compromised nature of health hardware in homes and this poses a direct threat to the health of people in these settings. A workforce that is locally placed or more readily mobilized on a

2 more frequent basis and is capable of effecting basic repairs to plumbing would seem to provide a solution to the issue of managing risk. Environmental health workers are trained in basic plumbing repairs. One of their current resources includes a DVD set with episodes presented by a PLB compliance officer following permission from the PLB to participate. Environmental health workers fix basic plumbing problems now around many parts of the state. In some settings, the Department of Housing provide a running tab at the local hardware store for the purchase of plumbing material by these workers to effect repairs. This is at no cost for their labor to Housing and yet with potential exposure to litigation from the regulatory authority. In summary, EHD support the concept of a regulatory approach to plumbing in WA to protect the public from health risks associated with poor operation. EHD seeks a common sense approach to acknowledging the presence of environmental health workers, their role and value in effecting timely repairs to basic plumbing and some recognition or authority to be able to continue to provide what they currently do now and into the future. Environmental health workers and plumbing The Environmental Health Directorate provides funding for non-government not-for-profit organisations to provide environmental health services to regional and remote Aboriginal communities around the state. Most of the contracted organisations are Aboriginal corporations that visit communities on a regular basis. One of the core areas of activity to address health risks from the living environment is to attend to basic plumbing repairs. Reporting from contractors of specific activities is a recent implementation and many activities appear to be under reported. Nonetheless, the information below is a summary of plumbing related activities performed under the program.

3 Pictorial evidence of situations where plumbing problems are identified and where simple repairs can be effected by environmental health practitioners Blocked drain inspection opening removed to allow drainage from the kitchen sink inside the house Blocked kitchen sink

4 Blocked laundry sink Missing disconnector trap

5 Missing tap hardware in bathroom sink Missing tap hardware in shower

6 Broken vanity bench and tap hardware in bathroom Missing laundry taps

7 Missing shower rose in ablution block Drop pit toilet blocked and at full capacity requiring pumpout

8 Leaking tap hardware Blocked drain releasing effluent

9 Blocked toilet missing seat Missing pipe at community ablution block

10 Missing shower rose and leaking outlet Blocked septic causing backwash of raw sewerage in laundry

11 Missing tap Blocked waste

12 Anecdotes depicting access and cost of using a plumber for basic repairs 1. If we take the example of a simple tap washer replace for a leaking tap the money spent is in the travel, with a small portion being the hourly rate for plumbing work ($100 p/hr +GST). The total cost for repairing a basic leaking tap repair is minimum $850 (i.e. $800 travel - $2.20 per k/m) for a Dampier Peninsula community. To make the R&M viable, the job is deferred until there are a number of plumbing jobs that are booked or an emergency. It could take two to three weeks before the visit becomes viable. While the leaking tap is waiting to be repaired, excess water is discharged to sewer (load impact on sewage lagoons), wear and tear of fittings (including pump/bore etc), use of power (electric pumps) and potential for the flow-on effect to additional maintenance i.e. damage to walls, seized taps etc. As it is, when the plumber arrives there is quite a list of jobs to be done in the area. The leaking tap is the lowest priority, and so can wait through a number of visits before it gets repaired. The local Environmental Health Worker can easily remedy this basic maintenance issue. A recent community tap leak was measured to be discharging at 4L per minute. 2. We have a referral system from the local Aboriginal medical service. If a family looks like they are getting sick from each other or their home environment they can ask us to do a check of the health hardware in the home. We have a check list and picture chart. If it s something like a blocked drain or broken taps we fix it straight away. We have an arrangement with the Housing manager where we list what repairs we did and get the material we need from the local hardware store on their account. We refer more complicated plumbing problems to the Housing manager for him to organise using a plumber. We don t get paid by Housing to do the work but do it as part of our own job. 3. For any work we need to hire a plumber for, the local rate is $130 per hour. For any work at a remote community, two plumbers are used which takes the rate to $260 per hour. Travel is charged at $3.45 per km and some of the communities we look after are up to 10 hours drive away. On top of these charges are any accommodation expenses if the plumbers chose not to camp out. We cannot book a small number of minor repairs and justify it as cost effective we send out a team to do a large number of works in one visit.

Government of Western Australia. Department of Commerce. Consultation Paper BASIC PLUMBING REPAIRS IN REMOTE ABORIGINAL COMMUNITIES

Government of Western Australia Department of Commerce Consultation Paper BASIC PLUMBING REPAIRS IN REMOTE ABORIGINAL COMMUNITIES February 2015 This publication has been compiled by the Department of Commerce.