draft policy on the regulation of the plumbing sector in trinidad and tobago ministry of public...

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Draft National Plumbing Policy of Trinidad and Tobago Discussion Paper 2/22/2012 MINISTRY OF PUBLIC UTILITIES ECONOMIC RESEARCH POLICY AND PLANNING DIVISION

2 Discussion Paper on the Draft National Plumbing Policy, ERPPD March 22, 2012

Ministry of Public Utilities

Discussion Paper for the development of a

Draft National Plumbing Policy of Trinidad and Tobago

1.0 Overview

Trinidad and Tobago is a rapidly developing country, whose construction industry has

encountered a significant increase in the number of building projects over the last two decades.

In an environment such as this, proper plumbing practices are vital for the health and well-

being of the population. Plumbing systems are aimed at collecting, transporting and distributing

water to individuals in a community, and the removal of liquid waste. Faulty plumbing systems

can result in among other things, the contamination of water sources, accidental cross-

connection of drinking-water supply and waste removal systems and chemical contamination

from corrosion of pipes and other fittings. It is important that such risks are minimised by

ensuring that systems are correctly designed, constructed and assembled using the appropriate

techniques and materials. It is also critical that plumbers are well trained in the design,

installation and maintenance of such plumbing systems and that they adhere to principles of

best practice.

A review of the plumbing sector of Trinidad and Tobago shows that it is faced with a number of

issues which include the following:

I. Inconsistent plumbing practices and poor quality workmanship- The country has been

plagued with repeated occurrences of poor plumbing installations which have become

increasingly evident at large housing developments. There have been many complaints of

poor workmanship and a lack of adherence to a set standard. This continued disregard for

the regulatory guidance laid out in the National Plumbing Code (1965) and the lack of

supervision of plumbing installations can have dire effects on the public health, living

standards and the environment in Trinidad and Tobago.

II. Inconsistent training and qualification- The training of plumbers is carried out by both the

Ministry of Education and the Ministry of Science, Technology and Tertiary Education. This

training is certified by the National Training Agency (NTA) which falls under the purview of

the Ministry of Science, Technology and Tertiary Education. While recent attempts have

been made to apply a consistent system of classification to the skill level of plumbing

practitioners, such efforts are still within the early stages of development. These attempts

have been challenged by the difficulty in making comparative assessments between

plumbers who are formally trained with varying levels of experience against those who are


experienced but lack formal training. It should be noted that in recent years, much of the

certification of plumbers has taken place at the lower levels within the sector. These levels

of qualification are on par with those of apprentices in developed countries. There have also

been complaints by some plumbing practitioners that the majority of graduates of the

current training programmes lack the necessary experience to be referred to as “plumbers”

and it is necessary to apply a clear system of categorizing plumbers, which is on par with

international practices.

III. Lack of a National Licensing Mechanism- Currently, there is no nationally recognized

system that identifies an individual who is qualified to be a “plumber”. As such, the option is

open to anyone to undertake plumbing work without the relevant training or experience.

This has left the general public susceptible to various unskilled persons putting themselves

out for hire.

IV. Unregulated Industry and Inadequate Legislation - Currently the plumbing industry is

unregulated, with the Water and Sewerage Authority (WASA) being the only body that

undertakes the licensing of a small section of plumbing works. Under WASA’s legislation

(WASA Act- Chapter 54:40), the Authority currently bears responsibility for the licensing of

Licensed Sanitary Constructors(LSCs) who are plumbers who undertake work on sewer lines

and related works. This legislation does not extend to plumbing in its entirety. Additionally,

WASA has encountered difficulties with the issuance of licences to these Sanitary

Constructors due to the inconsistencies in the experience and qualification levels of

applicants.

Also, a National Plumbing Code of Trinidad and Tobago exists, which was established in

1965. It is considered outdated by the plumbing stakeholders. This Plumbing Code is

currently under review by WASA and other plumbing stakeholders such as the Bureau of

Standards and the Plumbers Association of Trinidad and Tobago.

There is the need for specific plumbing legislation and plumbing regulations to be

developed to address all aspects of the sector and to guide the activities of the industry on a

whole.

V. Institutional Framework - A single body needs to be established to facilitate the

coordinated development of the sector and for greater collaborations between the principal

actors. Such a body would be responsible for making the necessary linkages between the

training institutions and the actual practitioners in the field. As such, it was recognised that

at present there is a dire need for not only the licensing of persons who engage in plumbing


works but also the regulation of the entire industry. Further action is required to ensure

that the training of plumbing practitioners is guided by a clear plumbing policy and aligned

with relevant plumbing regulations.

2.0 Introduction

In recognition of the need to ensure that proper plumbing practices are adhered to, for the

protection of the health and well-being of the population in Trinidad and Tobago, the

Government has found it necessary to undertake the regulation of the plumbing industry. It is

therefore imperative that a regulatory framework be established to guide the activities of the

plumbing sector. The National Plumbing Policy of Trinidad and Tobago is aimed at reducing

health and safety risks by ensuring that systems are correctly designed, constructed and

assembled using the appropriate techniques and materials. It was recognised that it is also

critical that plumbers are well trained in the design, installation and maintenance of such

plumbing systems and that they adhere to a code of best practice.

The policy framework for the regulation of the plumbing industry includes aspects such as

certification, licensing, monitoring and quality assurances for plumbing work, services and

products. In Trinidad and Tobago, this had only been partially addressed by the Water and

Sewerage Authority’s licensing of Licensed Sanitary Constructors (LSC).

The overall regulation of the plumbing industry would be aimed at ensuring that plumbing risks

are prevented or minimised through education and training and the adoption of quality

assurance systems such as codes of best practice. Many countries have enforced these codes of

best practice by establishing laws and regulations that stipulate specific standards. Trinidad and

Tobago needs to accelerate its move in this direction in its pursuit of the preservation of a

healthy and safe environment. It is evident, therefore, that the protection of public interest

justifies some degree of regulation over the plumbing sector.

The World Health Organization (WHO) made the following statement in its article “Sanitation

Challenge: Turning Commitment into Reality”

―Creating the right types of legislation/regulations in support of extending sanitation

and hygiene services and improving their quality is essential in the process of achieving

targets and maintaining achievements. Legislation/regulations should create conditions

that favour innovation (both in technology and in financing mechanisms); define

cooperation between relevant stakeholders, including the private sector; allocate

financial resources to capacity building and training, and to monitoring, implementation


and maintenance. Consistent standards for sanitation and hygiene must be set across all

other relevant sectors (for example, education, housing construction, workplace safety).

Enforcement of enacted legislation/regulations is essential. Effective

legislation/regulations will have both incentives for complying and sanctions for not

complying with the requirements. (World Health Organization 2004)

3.0 Policy Goal and Objectives

3.1 The goal of a National Plumbing Policy is to provide a cohesive approach to the sustainable

development of the Plumbing industry through the involvement of all relevant stakeholders.

3.2 The primary objective of the National Plumbing Policy therefore is to provide a regulatory

framework aimed at the following areas:

3.2.1 Protection of Public Health and Safety

a. Preservation of the health and safety of the national community

b. Protection of the environment

c. Minimization of damage to plumbing and drainage infrastructure

3.2.2 Regulation

a. Issuing of licenses

b. Consistent rules and regulations applied across the plumbing sector

c. Promoting competitive practices

d. Protection of consumers right to good service

e. Settling disputes

3.2.3 Technical

a. Devising technical standards

b. Determining approval types and certification

c. Coordinating with other industry stakeholders

3.2.4 Planning

a. Monitoring of current developments in the plumbing sector

b. Monitoring related developments in the national community which may impact the

sector

a. Anticipating and planning for future developments


3.2.5 External Relations

a. Ensuring mechanisms are implemented for providing information on the plumbing

sector to the general public

4.0 Key Stakeholders of the Plumbing Sector

The provision of a policy framework for the Plumbing sector is a multi-faceted, and involves the

active input from the following stakeholders:

The Water and Sewerage Authority (WASA)

The Plumbers Association of Trinidad and Tobago (TPATT) - The Plumbers Association of

Trinidad and Tobago has a membership of 80 plumbers and has indicated their support

for increased regulation of the plumbing sector.

Ministry of Science, Technology and Tertiary Education (MSTTE) – the Ministry

responsible for the assessment and certification of technical/vocational training through

their agency, The National Training Agency (NTA)

The Trinidad and Tobago Bureau of Standards (TTBS)

The Ministry of Trade and Industry (MTI)

Ministry of Works and Infrastructure (MOWI)

The Ministry of Planning and the Economy

The Town and Country Planning Division (TCPD)

The University of the West Indies (UWI)

The University of Trinidad and Tobago (UTT)

Other practitioners such as the Board of Engineering (BoE) and the Association of

Professional Engineers (APETT)

The citizens of Trinidad and Tobago

5.0 Scope of the National Plumbing Policy

The National Plumbing Policy of Trinidad and Tobago will relate to those areas of plumbing concerned with water and wastewater installation. As such, the policy will govern plumbing as it pertains to the actual installation, repair, alteration, disconnection or maintenance of pipes or equipment to a water supply system or storm water systems or to receive and convey wastewater

to sanitary drains within a building or within the legal boundaries of a single premises.


6.0 Issues and Policy Implementation

A regulatory framework for plumbing covers various aspects of plumbing regulation. The

National Plumbing Policy seeks to address these key areas.

6.1 Certification of Plumbing

6.1.1 The NTA certified training programmes to be aligned to the revised Plumbing Code in

order to ensure that plumbing practitioners are equally subject to the same guidelines.

6.1.2 The level of license granted to plumbers will be determined by the certification level

granted by the NTA.

6.2 Issuing of Licences

6.2.1 The Government will establish a body to undertake the registration and granting of

licences to all plumbers who offer their services to the general public for residential,

commercial and industrial work.

6.2.2 Such licences will be granted according to the individual’s qualification level and the fees

for the licensing of plumbers will be according to services offered, that is, residential

commercial and industrial service.

6.2.3 A national registry must be maintained of all individuals to whom licences have been

granted and this information made accessible to the general public.

6.3 Consumer Protection

6.3.1 The Government will also ensure that the regulatory body established will have the

authority and capacity to investigate complaints and reports of poor service provided by

any Licensed Plumber.

6.3.2 The regulations will outline the various sanctions which can be applied to any plumber

found in breach of these regulations.

6.3.3 Efforts will be made to provide the general public with information on plumbing

practices, service standards and other relevant information as necessary.

6.3.4 The body set up to regulate the plumbing sector will act as a watchdog for the citizens’

right to good services.

6.4 Plumbing Regulations

6.4.1 The National Plumbing Code of Trinidad and Tobago must be relevant to the needs of

the current environment and should be utilized as a basis for regulating the plumbing

sector.


6.4.2 An established body will ensure increased accountability and regulation of the plumbing

sector through consistent interpretation and well coordinated implementation of

plumbing regulations and direct supervision of plumbing sector.

6.4.3 Recommendations for improvements and/or changes in plumbing operations, standards

and regulations will be made as required.

6.5 On-site inspections

6.5.1 In order to ensure compliance with plumbing regulations and the National Plumbing

Code, the government will seek to ensure that on-site inspections are conducted by the

body established to do so.

6.6 Pricing and Cost Recovery

6.6.1 A cost recovery system should be implemented to ensure that reasonable fees are

charged for the granting of licences and the inspection of plumbing installations. Such

fees should aim at covering the majority of the administrative and operational costs of

providing this service and for the gradual achievement of financial self sufficiency.

6.6.2 Fees for the licensing of plumbers offering professional services should be set according

to the level of service offered. The levels being: (a) Residential; (b) Commercial and (c)

Industrial.

7.0 Instruments for Policy Implementation

7.1 Legal Instruments

7.1.1 The Government of Trinidad and Tobago will establish the relevant legal instruments

within which the National Plumbing Policy and the regulating body established to

oversee the plumbing sector must operate. The main legal instrument will be the

National Plumbing Act along with the necessary amendments to the Water and

Sewerage Act.

Currently the WASA Act only addresses the regulation of Licensed Sanitary Constructors

that is, persons engaged in sewer works.

7.2 Institutional Framework

7.2.1 Trinidad and Tobago is currently in need of a body that is dedicated to the regulation of all

areas of the plumbing sector.


7.2.2 The Water and Sewerage Authority is the key agency with responsibility for the provision

of water and wastewater services. However, it does not routinely engage in monitoring

or regulating plumbing work beyond the point of connection with its water and

wastewater distribution network.

7.2.3 The responsibility for the implementation of the National Plumbing Policy and the overall

regulation of the plumbing sector would best be served by an independent body.

7.3 Inter-Ministerial Coordination and Collaboration

7.3.1 Effective regulation of the plumbing sector requires a co-ordinated and collaborative

approach by the relevant plumbing stakeholders. Various measures and strategies must

be undertaken to ensure that this collaboration and co-ordination is carried out in an

effective manner.

7.3.2 Attempts will be made, through collaborative planning and information sharing, to

ensure that the National Plumbing Policy is in alignment with policy guidelines being

implemented for other related areas as they are developed such as the Building Codes

and Renewable Energy initiatives.

7.4 Contribution to National Sustainability

7.4.1 Given the critical importance of plumbing to the preservation of a safe water supply and

the prevention of cross-contamination of water and wastewater infrastructure, it is

critical that Trinidad and Tobago engage in safe plumbing practices in order to protect

the health and well-being of the population.

7.5 Public Education

7.5.1 The Government will launch a broad programme for educating the general public and

key stakeholders about the basic standards and key concepts pertinent to ensuring

appropriate plumbing installations.

8.0 Monitoring and Review of Policy Implementation

8.1.1 This policy must be monitored on an ongoing basis to ensure that it meets the objectives

for which it was created and has the desired results. As such, the Government will

ensure that such monitoring will include:

Identification of key performance indicators


Setting of performance targets over specified periods

Establishing an implementation plan for undertaking such monitoring.

8.1.2 It is critical that the Policy remains current and applicable to the changing environment.

It must also be in concurrence with other policies on which it impacts or is impacted. To

ensure that this is achieved, it is intended that the policy be reviewed and updated

every five (5) years through the:

Publication of notices announcing the Government’s intention to undertake policy

revision and requesting comments from interested parties on the intended revisions

Providing information on how to access the current policy and carrying out consultations

where possible to facilitate public participation

Updating the policy based on comments received and submitting this draft revised

policy for public comment

Finalising revised policy for use by general public.

9.0 Required Actions for Successful Policy Implementation

9.1 In order to ensure that the National Plumbing policy is fully implemented and adhered

to by all stakeholders, the government will undertake the following:

Establish a body dedicated to the overall regulation of the plumbing sector

Prioritize the development of the necessary plumbing legislation required for governing

the plumbing sector.

Identify the parameters and areas of responsibility of the various bodies related to the

plumbing industry.

Ensure that all required regulations are in place and that the Plumbing Code of 1965 is

updated and widely circulated to all stakeholders.

Develop appropriate regulations and operational policies inclusive of penalties prior to

the establishment of this body with mandatory time periods included for the review of

the existing policies.

Implement a cost recovery system to allow for fees and annual subscriptions to be set at

a rate that will cover the majority of the administrative and operational costs of the

regulatory body.

Convene regular stakeholder consultations to discuss the status of the plumbing sector,

provide recommendations for its improvement and to monitor the implementation of

the National Plumbing Policy and other related regulatory guidelines.


Bibliography

1. Cayman Water Authority;2011

2. International Code Council; The International Plumbing Code: A Guide for Use and

Adoption; 2011

3. Judd, Blane and Prospal, Richard; World Plumbing Council; Environmental Aspects of

Plumbing; 2010

4. MidCoast County Council; MidCoast Water Response to: Discussion Paper: Reforming

Arrangements for Regulating Plumbing and drainage in the NSW; December 2008

5. National Plumbing Regulators Forum; ‘Barriers to National Consistency’ Industry

Forum, Australia; March 2008

6. New South Wales Government; Reforming Arrangements for Regulating Plumbing and

Drainage in New South Wales; May 2009

7. http://www.pic.vic.gov.au/www/html204-what-is-plumbing-work.asp

8. The Water And Sewerage Authority (WASA) of Trinidad and Tobago; the National

Plumbing Code;

9. The Laws of Trinidad and Tobago

10. World Health Organization (WHO) in collaboration with World Plumbing Council; Health

Aspects of Plumbing; 2006

11. World Health Organization (WHO); Sanitation Challenge: Turning Commitment into

Reality; 2004

http://www.pic.vic.gov.au/www/html204-what-is-plumbing-work.asp

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