I am submitting these…

I am submitting these comments on behalf of the Ontario Onsite Wastewater Association (OOWA, at oowa.org), which is a provincial not-for-profit association dedicated to promoting the benefit and value of onsite and decentralized wastewater management through education, improved standards of practice, and advocacy for sound policies. We support our network of knowledgeable professionals recognized as the foremost source of sustainable onsite and decentralized wastewater management expertise.

As an industry association representing onsite wastewater professionals, we are commenting specifically on this proposal as it relates to Part 8 of the Ontario Building Code.

Action 1: OOWA supports this.
1.1: Yes, OOWA supports this action.
1.2: We would like to emphasize that candidates writing the exams should be able to access either the digital copy of the Ontario Building Code, or a print copy, to maximize the accessibility of this information for candidates. The duration of BCIN exams should be based on candidates using a hardcopy to eliminate any disadvantage there may be by taking longer to locate specific Code provisions in the hardcopy.
1.3: We don’t have any feedback to share.

Action 2: OOWA supports this action of allowing more time to write exams, while ensuring that there are enough representative questions to indicate qualification, and properly evaluate candidates’ knowledge.

Action 3: OOWA supports training and education for professionals working within the industry.
3.1 OOWA generally supports minimum mandated training prior to writing BCIN exams to try to increase the pass rate.
3.2 However, we recommend offering a simple exemption process for those who may have sufficient expertise that would exempt them from the training requirement. For example, proof of their work within the industry.

MMAH could also consider implementing a graduated system where candidates work for a period of time shadowing a qualified professional, before writing their exams, as an apprenticeship style of learning.

There is currently an internship program for building inspectors laid out in the code. OOWA suggests making this program more accessible and easier to pursue so that more candidates can use this as their path towards certification. The Ontario Building Code already specifies that individuals do not require certification for maintenance inspections only, so this can be extended as a graduated certification program. (Reference: Division C 3.1.4.4 and 3.1.4.3)

Action 4:
4.1: OOWA is not supportive of exemptions to the exam requirements.
4.2: OOWA is concerned that there could be too many ways that individuals seek exemptions to the exam requirements, without being properly evaluated for competency.

Action 5
5.1: OOWA is concerned that this might create too much content for the exams and contradict Action 1? This could result in a lower pass rate due to the variability of subject matter.
5.2: OOWA only represents individuals working on Part 8 of the Ontario Building Code, so we have no comment to add for this action. We agree that Part 8 should remain a specialist exam.

Action 6: OOWA agrees that this it is important for practitioners to remain current within the industry, and we support the requirement to have ongoing professional development, such as attending conferences and training workshops.
6.1: OOWA supports this action.
6.2: Beyond amendments to the Ontario Building Code, there should be ongoing requirements for current industry practices, notably in specialized areas (such as HVAC and onsite sewage systems).
6.3: OOWA requests that MMAH do more than just share information on new Code amendments. The MMAH could provide more information summarizing and highlighting changes. The MMAH could provide video conference learning opportunities and discussion opportunities for professionals. The MMAH can leverage industry associations to help communicate messaging to professionals.