Part 7: Quality assurance
7.1
In this Part, we look at the main quality assurance processes that Auckland Council uses to ensure that work is of a high standard, meets internal policies, and, most importantly, complies with statutory requirements.
Why quality assurance is so important
7.2
New buildings or alterations to buildings, whether residential or commercial, represent a huge investment. For the ordinary person, it is probably the biggest single investment they will make in their lifetime. As owners of a new building, or subsequent purchasers, they want to be assured that the building meets the requirements of the Act and is fit for purpose. Likewise, designers and builders want to be assured that their work will meet requirements and avoid costly rework.
7.3
As an accredited building consent authority, Auckland Council has the responsibility for assessing building consent applications in Auckland. The assessment is carried out under specific regulations designed to ensure that all building consent applications are managed properly and that all consents granted meet the provisions of the Act and the Building Code. The consequences for the building consent authority of wrongly issuing a consent can be high and could lead to financial claims. The risk is high in absolute financial terms and in the time that the authority is exposed to the risk.
7.4
Therefore, Auckland Council has a range of quality assurance procedures to ensure that building consent applications, inspections, and code compliance certificates are dealt with properly to minimise the risk of a building not meeting the legislative requirements.
Internal quality assurance
7.5
Auckland Council has two main internal quality assurance processes: system audits and technical audits. Also, it has a set of policies and procedures, which are available on its intranet. We looked at the two main internal quality assurance processes to gain an understanding of the depth and strength of the processes.
System audits
Basis of the system audits
7.6
System audits are performed in keeping with each specific regulation of the Building (Accreditation of Building Consent Authorities) Regulations 2006 (the Regulations). The Regulations may appear straightforward but are exacting in their requirements.
7.7
Regulation 17 specifies that a consenting authority must have a system for assuring the quality of performance of its building control functions, and specifies in detail the breadth of requirements. Regulation 17(2)(h) specifies procedures for ensuring that an internal audit of every building control function takes place yearly. Regulation 18, as amended in 2013, requires those performing technical jobs to have an appropriate qualification or be working towards getting an appropriate qualification.
Systems audit work
7.8
We audited internal documents and discussed with staff the number and nature of the systems audits that were carried out.
7.9
An audit schedule control sheet records, for each of the last three years, all 18 regulations that require an audit. An audit's status is entered against each of the regulations. Audit reports are prepared for every audit.
Our observations about system audits
7.10
We observed that, in 2012 and 2013, audits were shown as completed for all relevant regulations. In 2014, at the time of our fieldwork, most scheduled audits had been completed in the planned time. Several audits were behind schedule, due to limited resources during a period of high application numbers. In January 2015, a dedicated centralised audit delivery team was formed to ensure that adequate resources are available for these audits.
Technical audits
Basis of the technical audits
7.11
The technical audits have to comply with regulation 7 of the Regulations. Regulation 7 specifies that a building consent authority must have policies and procedures for performing functions as detailed in that regulation. The purpose of the technical audits is to find out how well Auckland Council is putting approved procedures and policies into practice.
Technical audit work
7.12
Every month, each of the area offices and contractors carries out technical audits of the main building control functions (consent application lodgements, processing, inspections, and code compliance certificates). A total of 220 audits are planned each month – 55 for every function.
7.13
The audits (with the exception of inspection audits) are paperless. Each audit is made up of a series of questions that are set out in an electronic system. All of the questions are explained to ensure that the person completing the audit understands each question and its purpose. All questions must be answered because the system does not allow the audit to be recorded as complete if there are any unanswered questions.
7.14
The audits are carried out by peer staff at each office and then compiled and analysed three times a year by quality assurance staff located at the central office. A report is prepared for each four-month period for each of the main functions.
Our observations about technical audits
7.15
We reviewed several of the four-month reports and discussed the results with quality assurance staff.
7.16
The reports are prepared in a standard template and describe:
- the number of instances, for each office, where the audit has identified non-compliances at each procedural step;
- graphs of the performance of each office audited and for Auckland as a whole;
- improvements or regressions since the previous audit; and
- actions to address audit report recommendations.
7.17
The reports include a conclusion on whether the policies and procedures have been effectively put into practice throughout Auckland.
7.18
In our view, the reports are compiled well and present audit results informatively.
7.19
One aspect that we felt could be improved is the differentiation between significant and minor non-compliances. Auckland Council defines substantial compliance as generally being greater than 90%, based on the total number of procedural steps that comply. There is scope to better delineate between procedures where non-compliance could have a significant effect and those procedures where non-compliance might have little effect, such as whether a document has been stamped.
7.20
Another aspect that Auckland Council is trying to improve is the feedback that peer auditors give to the officer who carries out a particular role. A quality assurance system is effective only when omissions and errors are discussed, acknowledged as lessons learned, and acted on in subsequent work. During the second half of 2013, Auckland Council made it compulsory for auditors to give feedback, but it appears that this feedback is not always received.
7.21
Lastly, the paperless audits for most building control functions appear to work efficiently but they do not yet extend to building inspection audits.
External quality assurance
7.22
IANZ routinely assesses building consent authorities to check whether they are complying with the Regulations. IANZ prepares reports for each authority, with a copy supplied to MBIE's Building and Housing Division. One of the important features of IANZ reports is the inclusion, where necessary, of "Corrective Action Requests". These are formal matters to be addressed by an authority. If they are sufficiently serious and not addressed in a reasonable time, they might threaten accreditation. Also, IANZ makes recommendations that are intended to help maintain an effective quality management system, but are not conditions for accreditation.
7.23
IANZ audited Auckland Council in September 2012 and in September 2014. These were routine scheduled audits.
7.24
In the 2012 audit report, IANZ made five Corrective Action Requests and 18 recommendations. IANZ stated that Auckland Council:
- had made significant progress in merging seven building consent authorities into one coherent organisation; and
- continued to maintain a positive approach to its work and accreditation in general.
7.25
Other specific findings from the 2012 audit were that:
- policies and procedures were, for the most part, recorded appropriately;
- procedural variations in different locations had reduced considerably;
- application receipt processes and completeness checking were appropriate;
- on several occasions, the statutory clock was applied wrongly;
- in general, inspection planning, management, and performance had been satisfactory; and
- for the most part, code compliance certificates were issued appropriately.
7.26
All five Corrective Action Requests were acted on and cleared.
7.27
The 2014 audit report stated that:
[Auckland Council] is to be congratulated. At this assessment there were no Corrective Action Requests determined. It is noted that [Auckland Council] had much improved processes, systems and record keeping. A number of strong recommendations and recommendations were made and these will hopefully reinforce the excellent progress in the refinement of procedures and their implementation.
7.28
The 2014 report contained 31 recommendations for improvement, including eight "strong recommendations". Strong recommendations relate to matters that, if not addressed, could be raised as Corrective Action Requests during a later audit.
Annual strategic audit of quality assurance
7.29
Each year, Auckland Council summarises the findings from its quality assurance system in a formal report to its Chief Operating Officer. The report outlines:
- quality policy objectives, their current status, and whether the objectives have been met;
- results of external body audits;
- results of systems audits and technical audits;
- risk register outputs;
- financial performance; and
- recommendations for the year ahead.
7.30
The latest report covers the year to 30 September 2014. The report noted that:
- Six of the seven objectives on quality had been met, with one partially met. The partially met objective was the website not being user friendly.
- There were no corrective action requests raised arising from the 2014 IANZ audit, which was seen as positive and unusual for such a large consenting authority.
- The graduate recruitment programme was continuing.
- Auckland Council had representation on working parties associated with the introduction of the Building Amendment Bill (No. 4), which proposes four new types of building consent and aimed at reducing processing time for low-risk applications.
- The transition to the new organisation structure went smoothly, with significant staff and union engagement.
- Higher risks in Building Control include the potential significant increase in consent activity and the resources required to meet demand as a result of the Special Housing Areas and to ensure that the NewCore initiative was put into effect.
7.31
The report identified the improvements to be made during 2015. They include:
- resolving problems with poor IT performance, which has slipped recently;
- introducing digital devices for inspectors to improve service delivery and reduce the cost of inspection activities;
- introducing a tactical online consent application and processing solution to deliver better customer experience and process efficiencies;
- working to provide a more integrated consenting experience for customers through the Customer Centric Regulatory Audit Programme; and
- improving the guidance material and advice available to customers to help guide them through the consenting process.
Our observations about quality assurance
7.32
Auckland Council has rigorously approached and carried out its responsibilities for assuring the quality of building control functions.
7.33
In our view, the strengths of the current approach include:
- ensuring that all aspects of the building control functions are covered;
- comprehensive recording of quality assurance work;
- using peer staff as technical auditors;
- striking a good balance between operational staff carrying out audits and dedicated quality assurance staff in the central office;
- analysing non-conformance and raising non-conformance matters with the appropriate staff; and
- promptly attending to matters raised in the 2012 IANZ report.
7.34
The congratulatory remarks in IANZ's 2014 report suggest that Auckland Council's systems and processes are sound.
Aspects to improvement
7.35
We saw the need for Auckland Council to address several technical audit matters, including:
- having a more nuanced categorisation of what might be deemed significant non-conformance compared to less significant non-conformance; and
- ensuring that there is feedback from the peer auditor to those being audited in every instance of an identified non-conformance.
7.36
Moving to a paperless system for the audits of inspections would improve efficiency.