Chapter 2: Self-containment certification authorities and vehicle inspectors
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Current conditions for issuing self-containment certificates under the voluntary standard
The voluntary Standard outlines a set of conditions for the issuing of self-containment certificates. In order to be an issuing authority for self-containment certificates, organisations or people:
- shall operate a qualification scheme for testing officers they employ
- shall make documentation of this qualification scheme available on a public website or on request
- have testing officers attend a course of instruction and be tested to prove their competence.
Plumbers registered under the Plumbers, Gasfitters, and Drainlayers Act 2006 are automatically recognised as issuing authorities and testing officers for self-containment certificates.
We understand that currently the majority of vehicle inspectors used by the country’s two largest issuing authorities (the New Zealand Motor Caravan Association and New Zealand Lifestyle Camping) are retirees, and many are volunteers.
Problems with the current conditions for issuing self-containment certificates
The approval conditions in the voluntary Standard are too subjective. There are no details of what constitutes an appropriate qualification, course of instruction or competency test for testing officers.
Similarly, there is no oversight or monitoring to ensure that issuing authorities are correctly certifying vehicles and issuing self-containment certificates.
This lack of independent oversight essentially enables organisations to ‘appoint’ themselves as issuing authorities, if they consider that they have met the criteria. As such, we do not know how many issuing authorities there are nor whether all authorities are certifying vehicles to the current standards.
There is a lack of robust, independent assurance that vehicle inspectors are competent and that issuing authorities are issuing certificates appropriately in line with the voluntary Standard’s conditions.
What the Bill would change
To assure the public that the certification system is robust and fit-for-purpose, the Bill would require:
- that certifications are only carried out by certification authorities approved by the PGDB, and that vehicle inspections are only carried out by a ‘competent person’
- the creation of new regulations setting out:
- approval criteria for certification authorities
- an application process for potential new certification authorities, which would be assessed by the PGDB against the approval criteria
- requirements that people must meet to be considered a ‘competent person’ for vehicle inspection purposes.
It is anticipated that some certification authorities will both inspect and certify vehicles, whereas others may just certify vehicles and outsource inspections to a third party. The proposed approval criteria reflects both operating models.
We are consulting you about options for Certification authority approval criteria and vehicle inspector competency requirements
In this section of the discussion document, we have listed some options for how the approval criteria for certification authorities and the vehicle inspector competency requirements could be set out in regulations.
Certification authority approval criteria
Below we present the following options:
- Option 1: a robust approach to approvals with multiple pathways.
- Option 2: a more rigorous and prescriptive certification approval criteria.
- Option 3: requiring a third-party review of certification authority systems.
Options 1 and 2 are alternative approaches to the setting of technical requirements, whereas Option 3 could compliment either option.
We also present a separate option for feedback, which is to deem certifying plumbers as certification authorities and vehicle inspectors under the new regulations.
Option 1: a robust approach to approvals with multiple pathways
This option would consist of a robust criteria of requirements with multiple pathways that certification authorities can use to demonstrate how they meet the criteria.
At a high level, the proposed approval criteria cover:
- processes to ensure vehicle inspectors are competent and have sufficient understanding of the relevant self-containment requirements
- processes for inspecting vehicles to determine whether they meet the relevant self-containment requirements
- processes around recording inspection details and issuing self-containment certificates and warrant cards
- appropriate record-keeping processes
- an internal auditing system to ensure consistent, high-quality certification decisions.
The application process would be a straightforward pathway that prospective certification authorities would follow when making an application to the PGDB. Prospective authorities would need to show that their processes and systems meet the criteria to be approved.
The proposed regulatory system would be ‘light touch’ through providing multiple pathways for demonstrating how criteria are met but would still enable the PGDB to provide robust national oversight without imposing excessive costs on certification authorities. For example, a prospective certification authority would need to demonstrate to the PGDB that its auditing system and record-keeping systems meet the criteria.
Option 2: a more rigorous and prescriptive certification approval criteria
This option would have a set of robust requirements that prospective certification authorities would need to meet in order to be approved by the PGDB. This option would use the same criteria set out in Option 1.
The key difference would be that the PGDB would approve standardised vehicle-inspector training and auditing systems, which certification authorities would be required to embed in order to be approved. Such requirements would be more prescriptive and would require certification authorities to embed standardised training and auditing systems approved by the PGDB. This may mean that certification authorities have to upgrade or invest in new auditing and training systems and processes in order to meet the approval criteria.
Under this option, the PGDB would be required to undertake work to establish the standardised training and auditing systems prior to the first applications of prospective certification authorities. Further work would be required to align any new training systems for vehicle inspectors with the vocational learning system. For example, any new qualifications would need to be developed alongside the relevant Workforce Development Council and in consultation with the New Zealand Qualifications Authority and the Tertiary Education Commission.
Option 3: requiring a third-party review of certification authority systems
Under this option, a third-party assurance body (such as Telarc or International Accreditation New Zealand) would be required to review the proposed systems of prospective certification authority. The reviewer would provide their findings to the PGDB and advise if the systems satisfy the prescribed criteria. Such third-party overview can be a common step in regulatory approval. We understand that an ISO 9001 audit of a small business might take 1.5 days and cost over $2,000.
This third-party review would be run in addition to either of Options 1 or 2.
Assessment of options
We are assessing the options against the status quo, which in this case is the conditions under the voluntary Standard.
| Option | Costs – the costs on participants in the regulatory system | Practicality - how easy each option is to implement | Effectiveness – the potential to drive freedom camping reform and regulatory outcomes | Overall score |
|---|---|---|---|---|
| Option 1: a robust approach to approvals with multiple pathways | There will be small new costs for those issuing authorities (IAs) who transition to the new regulatory regime associated with demonstrating how they meet criteria. No direct costs for owners of self-contained vehicles. -1 |
Straightforward to implement as it is based on similar processes the PGDB performs for approving employer licences. 2 |
Is ‘light touch’, which is likely to encourage existing IAs and vehicle inspectors (VIs) to be recognised under the new regulatory regime. Still enables PGDB to provide national oversight of regulated parties. 1 |
2 |
| Option 2: a more rigorous and prescriptive certification approval criteria | Would add a higher compliance burden on some current IAs. Would add additional costs on to the regulator associated with establishing standardised auditing and training systems. Ultimately, may increase levies and certification costs paid by owners of self-contained vehicles. -1 |
Would require the regulator to undertake further work to establish of standardised training and auditing systems. -2 |
Would provide a very high level of certainty that CAs had required processes in place. 1 |
-2 |
| Option 3: requiring a third-party review of certification authority systems | Would increase costs on certification authorities on top of the approval criteria. May result in higher certification costs paid by owners of self-contained vehicle. -2 |
Would require coordination between prospective CA’s, the PGDB, and the third-party reviewer. -1 |
Would provide a very high level of certainty that CAs had required processes in place. 1 |
-2 |
Our preferred option
We discuss our preferred option for the approval criteria at the end of this chapter.
Vehicle inspector competency requirements
Below, we present the following options for vehicle inspector competency requirements:
- Option 1: requiring vehicle inspectors to be knowledgeable.
- Option 2: requiring vehicle inspectors to have a relevant trade qualification.
- Option 3: requiring vehicle inspectors to be assessed as “fit and proper”.
Options 1 to 3 are based on a common set of requirements set out in Appendix Two. Options 2 and 3 would be additional requirements that could be placed on top of Option 1.
Option 1: requiring vehicle inspectors to be knowledgeable
Under this option, regulations would include a set of competency requirements based around vehicle inspectors needing to:
- know about and understand the technical requirements
- be able to inspect a vehicle’s performance against the regulatory requirements by using PGDB-issued guidance and inspection manuals
- know how to enter the results of the inspection into the national register of self-contained vehicles (if applicable)
- know where to seek help if they are unsure about the technical requirements or how to interpret them.
Under this option, a certification authority would recognise a person as a vehicle inspector where that person was able to demonstrate their competency in the requirements listed above.
Option 2: requiring vehicle inspectors to have a relevant trade qualification
Under this option, regulations would include a set of competency requirements set out in Option 1 above.
In addition, prospective vehicle inspectors would be required to demonstrate they have a relevant trade qualification. The types of qualifications could be in mechanical engineering, plumbing, building or related trades. The prospective vehicle inspector would need to provide proof of their qualification(s) to the certification authority that employed them prior to them starting inspection work.
Option 3: requiring vehicle inspectors to be assessed as “fit and proper”
Under this option regulations would include a set of competency requirements set out in Option 1 above.
Under this option a certification authority would also need to check that a prospective vehicle inspector was a “fit and proper person”. This is a common regulatory check and is used to provide assurance that people applying for a position are reputable.
The certification authority would need to undertake a background check of prospective vehicle inspectors, which would look at their previous behaviour including their criminal history and previous relevant work disciplinary records. The certification authority would then assess whether the person was “fit and proper” to be a vehicle inspector.
Assessment of options
We are assessing the options against the status quo, which in this case is the conditions under the voluntary Standard.
| Option | Costs – the costs on participants in the regulatory system | Practicality - how easy each option is to implement | Effectiveness – the potential to drive freedom camping reform and regulatory outcomes | Overall score |
|---|---|---|---|---|
| Option 1: requiring vehicle inspectors to be knowledgeable | Largely reflects the different processes of current issuing authorities (IAs) and is unlikely to add substantially to the regulatory burden for IAs and Vehicle Inspectors (VIs). Minimal costs on regulator. 0 |
Largely reflects the different processes of current IAs. 0 |
Is ‘light touch’, which is likely to encourage existing IAs and VIs to be recognised under new regulatory regime. Still enables PGDB to provide national oversight of regulated parties. 2 |
2 |
| Option 2: requiring vehicle inspectors to have a relevant trade qualification | Would increase costs for existing VIs, who would need a trade qualification to practice. Heightens the risk of the current network of volunteers falling over if existing VIs do not transition to new regime. -1 |
Would be reasonably straightforward for certification authorities to implement. 0 |
Would provide a higher level of certainty that a VI has knowledge and expertise. 1 |
0 |
| Option 3: requiring vehicle inspectors to be assessed as “fit and proper” | Would increase costs on VIs and certification authorities (CAs). Heightens the risk of the current network of volunteers falling over if existing VIs do not transition to new regime. -1 |
Would create another layer of processes that prospective VIs and CAs would need to complete. -1 |
Would provide a level of certainty that a VI has knowledge and expertise and is a fit and proper person. 1 |
-1 |
Option for regulations to deem certifying plumbers as certification authorities and vehicle inspectors
Plumbers registered under the Plumbers, Gasfitters, and Drainlayers Act 2006 are automatically recognised as issuing authorities and testing officers for self-containment certificates.
Under this option, certifying plumbers would continue to be deemed as certification authorities and vehicle inspectors where applicable and this would be specified in regulations.
The Certifying class is the top-level registration and licence. Certifiers have demonstrated they possess the advanced competencies required to design, manage the installation of, test and certify their own work, as well as be responsible for the work of those they supervise. They are the only plumbers that can verify work for official purposes (e.g., sign off compliance documents for local councils). Certifying plumbers, like all plumbers operating in Aotearoa New Zealand, are required to be registered by the PGDB.
This option would continue the status quo under the voluntary Standard. However, the PGDB would consider how to ensure that certifying plumbers upskill themselves on the new self-containment regulatory requirements as part of implementing the new regulatory system.
In the absence of deeming certifying plumbers in regulations, this group of plumbers would be required to apply to be certification authorities under the application criteria and/or meet the competency requirements expected of other vehicle inspectors.
Assessment of option
| Option | Costs – the costs on participants in the regulatory system | Practicality - how easy each option is to implement | Effectiveness – the potential to drive freedom camping reform and regulatory outcomes | Overall score |
|---|---|---|---|---|
| Deem certifying plumbers as certification authorities and vehicle inspectors | Would not increase costs on plumbers who choose to work in this field. 0 |
Reasonably straight forward to implement. PGDB would consider how to support existing plumbers working in this field to transition to the new regulatory regime, this is likely to be through education and communication campaigns. -1 |
Continues the status quo that plumbers are assumed to have a high level of competency to undertake work in this field. 2 |
1 |
Our preferred option for Certification Approval Criteria and competency requirements for vehicle inspectors
We are acutely aware of the fragility of the current vehicle inspector network and risks associated with not having enough existing vehicle inspectors and issuing authorities transitioning to the new regime.
At this stage, our preferred option is for regulations to set out a reasonably robust criteria of requirements with multiple pathways which certification authorities can use to demonstrate how they meet the criteria, and competency requirements for vehicle inspectors based around vehicle inspectors being able to demonstrate they are knowledgeable. We also think that regulations should deem plumbers as certification authorities and vehicle inspectors.
The preferred option will be ‘light-touch’ but will still enable the PGDB to provide robust national oversight without imposing excessive costs on certification authorities and vehicle inspectors.
More details of our proposed option are available in Appendix Two.
Questions
Certification authority approval criteria
Question 3. To what extent do you agree with Option 1: a robust approach to approvals with multiple pathways?
Please explain your reasons.
Question 4. To what extent do you agree with Option 2: a more rigorous and prescriptive certification approval criteria?
Please explain your reasons.
Question 5. To what extent do you agree with Option 3: requiring a third-party review of certification authority systems?
Please explain your reasons.
Competency requirements for vehicle inspectors
Question 6. To what extent do you agree with Option 1: requiring vehicle inspectors to be knowledgeable?
Please explain your reasons.
Question 7. To what extend do you agree with Option 2: requiring vehicle inspectors to have a relevant trade qualification?
Please explain your reasons.
Question 8. To what extent do you agree with Option 3: requiring vehicle inspectors to be assessed as “fit and proper”?
Please explain your reasons.
Deeming plumbers as certification authorities and vehicle inspectors
Question 9. To what extent do you agree that certifying plumbers should be deemed as certification authorities and vehicle inspectors under regulations?
Please explain your reasons.