The NSW Productivity and Equality Commission has made recommendations to lower the Occupational Entry Regulations (OER) for air conditioning and refrigeration trades.
In a review entitled Better occupational entry regulations: Policy implications of new research which was released this month, the commission said OER in Australia is more stringent for select occupations compared to the average OECD country.
Pointing to refrigeration and air conditioning the commission said more stringent OER is associated with reduced business dynamism and lower productivity which leads to higher prices and less choice for consumers.
“New South Wales offers fewer pathways to obtain the necessary qualifications required for becoming an air conditioning and refrigeration mechanic compared to other states,” the report said.
“Victoria and Queensland are more flexible; both allow people to qualify either through a Certificate III or by completing an apprenticeship.
“Victoria is particularly accessible, offering Certificate IV, Diploma, and Advanced Diploma qualification options. This can help to attract a wider set of professionals with diverse backgrounds and encourages greater variety and innovation in services. “
Industry groups rejected the report pointing out that the current requirement of a Certificate III level apprenticeship is both appropriate and necessary to safeguard public safety, ensure environmental compliance, and maintain the technical standards of industry.
The Australian Refrigeration Council (ARC) and the Air Conditioning Mechanical Contractors Association (AMCA) have prepared submissions to the commission pointing out that RAC is a highly technical profession which requires a Certificate III apprenticeship as the minimum standard.
“Given the specialist nature of the trade, technical complexity and environmental risks associated with RAC work, we believe stringent occupational entry requirements are essential. Specifically, ARC recommends a minimum Certificate III qualification as the standard for obtaining an unrestricted RAC licence across all jurisdictions,” ARC stated in its submission.
AMCA executive general manager, Ben Hawkins, said anything less than Cert III will compromise safety, environmental responsibility, and system performance.
“The Commission’s recommendation to lower entry requirements highlights a broader issue: the skills, knowledge, and responsibilities carried by practitioners are not always fully understood, and the value of our trade is too often underestimated,” Hawkins said.
“AMCA Australia supports efforts to reduce unnecessary business costs and improve productivity. However, these goals must not come at the expense of weakening the air-conditioning and refrigeration trade.
“Our technicians work with electricity, refrigerants, and complex plant — often in hazardous environments such as confined spaces or at heights. These are not low-risk tasks, and they demand comprehensive training to protect workers, building occupants, and the environment.”
Hawkins said this risk profile is only increasing as traditional refrigerants are phased out for environmental reasons and replaced with natural and synthetic alternatives, many of which carry higher flammability ratings (such as A2L and A3).
“Handling these substances safely requires an even higher level of technical skill, regulatory awareness, and rigorous training,” he said.
“If anything, the industry will require greater training, not less, to manage these new risks. “Lowering qualification standards at this critical juncture would expose workers, buildings, and the public to unacceptable safety hazards.”
Air-conditioning and refrigeration systems are critical to building safety and comfort, energy efficiency, and fire protection.
“Lowering qualification standards would risk undermining the very systems that safeguard people and ensure buildings operate reliably and efficiently,” Hawkins said.
“As an industry, we need to make sure the critical role air-conditioning and refrigeration technicians play in maintaining buildings — which are essential to air quality, comfort, and quality of life — is better understood and valued.”