What the PIRB means when referring to ‘adequate supervision’ and ‘physical inspections’

This article was originally written by Erene Roux from the PIRB for Plumbing Africa. 

If you can prove that the work undertaken by another plumber was done under your adequate supervision, then as the professional and accountable plumber, you are allowed to issue a Plumbing Industry Registration Board (PIRB) Certificate of Compliance (CoC) on the work done.

The PIRB would like to draw your attention to the fact that once you have signed a PIRB CoC you are not only self-certifying that the work is done correctly and compliant, but you are personally and legally accountable for the said works.

Signing a CoC without doing the actual work and or under your adequate supervision is fraught with dangers. In this light, the PIRB highlighted two key challenges within this situation: What constitutes ‘adequate supervision’ and is ‘inspecting’ a site considered to be doing actual work for the purpose of writing a CoC?

1. According to the PIRB, adequate supervision implies that you were in control of the work done and have verified the work done to the extent that you can take full responsibility for the said works.
   Some plumbers argue that they sign off on CoC’s after ‘inspecting’ photographic evidence of the plumbing work done. These plumbers ultimately deem this to be ‘adequate supervision’.Unfortunately, photographs can rarely be used as the sole set of evidence that adequate work was correctly done, and that the said work eventually complies. Photographic evidence can therefore only be used as supplementary evidence, according to the PIRB’s recommendations.

2. According to the PIRB, the physical inspection by a plumber who signs off on a CoC is a professional responsibility and should not be taken lightly.
   When a licensed plumber self certifies that their work complies with all the current plumbing regulations and laws as defined by the National Compulsory Standards and local bylaws, the PIRB accepts that the plumber controlled and inspected the plumbing work in detail.

   “If you’re responsible, and you are doing a proper analysis, inspection and test of the system, then you’ve done your job right!” says Herman Strauss of the PIRB.
   

   This means that you can sign off on a CoC without having to worry about the work not being compliant to the applicable standards. Therefore, just ‘inspecting’ a site can be considered doing work for which a COC can be issued. The plumber signing this COC will be fully responsible for the compliance of all categories marked on the COC.

3. There will be non-conformances with most plumbing maintenance work.
   A question that a lot of plumbers have, is whether to issue a COC when there are existing non-conformances within the installation. Do you refuse a CoC? Do these non-conformances have to be fixed before a plumber can continue? It is a legal requirement to always inform the homeowner of any non-conformances and always note these non-conformances on the CoC. This legal requirement, advisable in terms of the Consumer Protection Act significantly strengthens the rights of the consumer. In fact, the consumer’s “right to fair and honest dealing”, the consumer’s right to ‘safe, good quality goods’ and ‘warning concerning fact and nature of risks’ all apply within this act. Therefore, it can be noted that this notice is ultimately twofold: firstly, so as to protect the consumer of any and or potential dangers and performance issues that are or may arise from the existing installation, and secondly, so as to protect the plumber in terms of any future liability of the homeowner of any pre-existing items of non-conformance. It is therefore critical that the licensed plumber is aware of the standards to notify accordingly.

4. The nominated value of the PIRB CoC is not limited to R1 500.
   While a CoC must be provided to the consumer for all plumbing jobs which fall into one or more of the categories listed on a COC it is not limited to work where the total value of work, including materials, labour and VAT, is more than R 1 500.00 (material costs must be included, regardless of whether the materials were supplied by another person). This means that if the plumbing work is less than R1 500.00, a plumber can sign off on a CoC, especially if there are exiting non-conformances.