INSIGHT · LICENSING & COMPLIANCE
An inspection and test plan is a record.
Hold points stop work; witness points do not.
An inspection and test plan (ITP) identifies, for each activity, the inspection and testing to be done and the acceptance criteria, in the words of Transport for NSW's public quality specification Q6. The same document defines a hold point as a point beyond which work must not proceed without written authorisation, and a witness point as one where prior notice is given and attendance is optional. Neither is the same as the statutory inspection stages each state sets for building work, which a building surveyor or certifier inspects.
Analysed 25 October 2026 · Transport for NSW QA Specification Q6, Quality Management (Major Works), Ed 2 / Rev 0, authorised 5 February 2024 · EP&A (Development Certification and Fire Safety) Regulation 2021 (NSW) · Building Regulations 2018, Version 031, and Building Act 1993, Version 152 (Vic) · Building Regulation 2021 (Qld) · PDI (General) Regulations 2017 (SA) · Building (General) Regulation 2008 and Building Act 2004 (ACT) · all read 25 October 2026.
Key takeaways
- An ITP is defined by what it must show: Q6 cl 3.8.2 lists it: inspection and test frequency and stage, the method and acceptance criteria, the hold and witness points, when statistics apply, and who inspects, who reviews, who verifies conformity and who closes out each lot.
- Hold and witness points differ by one word: authorisation: Q6: a hold point is 'a point beyond which a work process must not proceed without the Principal's written authorisation'; a witness point is where the contractor gives prior notice and 'the option of attendance may be exercised by the Principal'.
- Statutory stages are set by state law, not by the ITP: NSW lists critical stage inspections by building class (s 61); Victoria prescribes mandatory notification stages (reg 167); Queensland prescribes inspection stages (s 44); South Australia prescribes notifications (reg 93); the ACT prescribes stages of building work (s 33).
- The record is what survives: NSW requires a certifier's record of each critical stage inspection with nine listed items, including the date, the certifier and whether it was satisfactory (s 63). Q6 requires nonconformity reports within two working days and project records kept for at least five years after completion.
- We would design the ITP as fields, not a document: A system-design recommendation: each ITP line carries activity, criterion and its reference, point type, responsible role, evidence reference, signer, date and any nonconformance link, so a later question can be answered by query.
The definitions, from a public specification
Australian Standards that define quality terms are paywalled. A state transport authority specification that defines them is public: Transport for NSW's Q6, which states it was totally rewritten in its 2024 edition to align with AS/NZS ISO 9001:2016.
Q6 states it was developed for roadworks and bridgeworks contracts let by Transport for NSW or by local councils in NSW, and is not suitable for any other purpose. It is quoted here for its definitions only. On a building project, the contract or project specification decides who the 'Principal' is and which points apply.
| Term | Definition, Q6 cl 1.3 | What it means for a record |
|---|---|---|
| Inspection and Test Plan | A document which identifies the inspection, testing (verification) and acceptance criteria for each activity | One line per activity, each with a criterion |
| Hold Point | A point beyond which a work process must not proceed without the Principal's written authorisation | A release record: who authorised, when, against what evidence |
| Witness Point | A point in a work process where the Contractor must give prior notice to the Principal and the option of attendance may be exercised by the Principal | A notice record: when notice was given, and whether anyone attended |
| Quality Records | All records used to provide evidence of conformity with the specified requirements or effective operation of the quality management system, such as records of inspection, sampling and testing (verification) | The evidence each ITP line points to |
What an ITP has to show
Q6 cl 3.8.2 places the ITPs inside the project quality plan and lists what they, or their associated forms, must show where applicable. The list reads as a set of fields.
An ITP is therefore not a quality control plan in the general sense: under Q6 it is one component of the project quality plan, alongside procedures, the records management plan and the other quality documents the specification lists.
- (a) Frequency and stage: The frequency of inspection and testing, not less than the specifications require, including the stage in the process at which it is required.
- (b) Method and acceptance criteria: The steps by which inspection or testing is carried out and recorded, in a documented procedure or by reference to a standard test method, and the acceptance criteria.
- (c) Hold and witness points: The hold points and witness points nominated in the specifications, and the time constraints for submission for their release.
- (d) Statistics: The circumstances under which statistical analysis of test results is required.
- (e) to (h) Four roles: Who performs the inspection or test; who reviews the results, assesses conformity and decides the next step if work is nonconforming; who verifies all specified inspection and testing has been done for each lot; and who closes out the lots.
Statutory inspection stages, by state
Separately from any contractor's ITP, each state's building law sets stages at which building work must be inspected or notified. These are carried out or received by the building surveyor, certifier or council, not by the contractor.
The stages differ in kind as well as list: NSW and Queensland name inspections; Victoria names notification stages, each followed by an inspection in person (s 34); the ACT names stages the builder must notify; and South Australia names notices to the council. A contractor's ITP can reference these stages as hold points, but completing an ITP line does not discharge the statutory step.
| State | Instrument and section | Stages, as the instrument states them (houses unless noted) | Read |
|---|---|---|---|
| NSW | EP&A (Development Certification and Fire Safety) Regulation 2021 s 61(2), (3); version for 19 June 2026 to date | Class 1 and 10: after excavation and before a footing; before pouring an in-situ reinforced concrete element; before covering framework; before covering waterproofing in a wet area; before covering stormwater drainage connections; final. Class 2 to 4 (s 61(3), a separate list): first footing; fire protection at service penetrations; fire-resisting junctions bounding a sole-occupancy unit (at least 30% of units per storey, s 61(9)); waterproofing in at least 10% of wet-area rooms; stormwater; final | 25 October 2026 |
| Victoria | Building Regulations 2018 reg 167 (Version 031, as at 1 September 2026); Building Act 1993 ss 33, 34 | Before placing a footing; before pouring an in situ reinforced concrete member the permit specifies; completion of framework; any stage the permit specifies for a reg 172 inspection; final. The builder notifies the surveyor, who must cause the work to be inspected in person | 25 October 2026 |
| Queensland | Building Regulation 2021 s 44; version from 14 August 2026 | Single detached class 1a: after excavation and before footing or slab concrete; after formwork and reinforcement before footings or slab are poured; frame bracing stages; before reinforced masonry cavities are filled; completion; plus any stage the building development approval states | 25 October 2026 |
| South Australia | PDI (General) Regulations 2017 reg 93; current version | Notice to the council: 1 business day before work starts; for stages the council specifies on approval, notice of their intended commencement (1 business day in Metropolitan Adelaide, 2 outside) and intended completion (1 business day, or 5 outside a council area); 1 business day for stages specified with a building consent under reg 57; before installing a designated building product, with a supervisor's checklist; 1 business day before completion | 25 October 2026 |
| ACT | Building (General) Regulation 2008 s 33 (Republication 52); Building Act 2004 s 43 (Republication 56) | Footing excavation, formwork and steel before concrete; class 1 and 10: structural framework before lining, and formwork and steel for reinforced concrete before pouring; completion. The licensee gives the certifier written notice at each stage | 25 October 2026 |
| WA, Tasmania, NT | Not verified (25 October 2026) | Not read from a primary source | Not verified |
A worked example: two activities
A short ITP for a class 1 house in NSW, written as fields. Each criterion either cites a public instrument or is marked project specification, meaning the contract documents, the structural drawings or the manufacturer's documented requirements the project adopts. Point types use the Q6 definitions.
The statutory rows are imposed by an instrument; the others are not. In Victoria the slab rows would cite reg 167(a) and (b), in Queensland s 44(1)(b)(i) to (iii), and in the ACT s 33(a) and (b)(ii). Every other criterion is whatever the project's own documents say; none is stated here as a requirement.
| Activity and check | Criterion and reference | Point type | Who and evidence |
|---|---|---|---|
| Wet area: substrate ready for membrane | Project specification (falls, surface preparation, membrane manufacturer's requirements) | Review by the waterproofer, recorded | Waterproofer; checklist line, photo reference |
| Wet area: membrane applied | Project specification (extent, upturns, penetrations, product and batch) | Witness point for the builder's supervisor | Waterproofer; product batch, photos, notice given and attendance |
| Wet area: before tiling | Before covering waterproofing in a wet area, EP&A (DCFS) Regulation 2021 s 61(2)(d) | Hold point: no covering until the critical stage inspection is done | Certifier's inspection record (s 63); builder records date and outcome |
| Wet area: flood test, if specified | Project specification | Witness point | Test record with duration and result |
| Slab: footing excavation | After excavation for, and before placement of, a footing, s 61(2)(a) | Hold point (statutory stage) | Certifier's record; photo of excavation |
| Slab: formwork and reinforcement | Structural drawings (project specification); before pouring an in-situ reinforced concrete element, s 61(2)(b) | Hold point | Engineer's or certifier's record as the project requires; photos of bar, cover and chairs |
| Slab: concrete delivered | Project specification (grade and any slump limit on the order) | Review | Delivery dockets matched to the pour |
| Slab: sampling and curing | Project specification | Witness point for sampling; surveillance for curing | Laboratory report reference; site diary entries |
The records that make
an ITP auditable later.
An ITP filled in at the time can be checked years later only if each line points to something that still exists. Two public instruments list what their records hold.
The NSW Regulation requires a certifier's record of each critical stage inspection, made as soon as practicable, including the development application and certificate numbers, the site address, the type of inspection, its date, the certifier's name and registration number, and whether it was satisfactory (s 63(3), (4)). Victoria's Building Act requires the surveyor to ensure a record of each inspection is made (s 35A).
Q6 sets the contractor side for its contracts: a nonconformity report with the particulars, root cause, proposed disposition and corrective action, submitted within two working days of detection (cl 3.12.2); a hold point on the rectification itself (cl 3.12.4); and project records retained for at least five years after the date of completion (cl 4.3.4).
What we would put in a system
For each ITP line, we would test for five fields.
Where agents help here is narrow. A compliance agent can draft ITP lines from a specification and the state's inspection stages, read a certifier's record or test report and attach it to the right line, and flag a covered-up hold point with no release record, and a person confirms each. No agent signs an inspection, releases a hold point, or decides whether work conforms, and no software makes work compliant.
| Field | Why it is load-bearing |
|---|---|
| Criterion with its reference | A criterion without the instrument, drawing or specification clause it comes from cannot be checked against a later revision. |
| Point type and release record | A hold point needs who authorised release and when; a witness point needs when notice was given and whether anyone attended. |
| Signer, role and date | Q6 separates the person who inspects from the one who reviews, the one who verifies and the one who closes out. |
| Evidence reference | The photo, test report, docket or certifier's record the line relies on, stored where it can be retrieved. |
| Nonconformance link | Where a check fails, the line points to the nonconformity report and its disposition, not just a cross in a box. |
- Compliance: Holds ITP lines, releases, evidence and nonconformances as one record per job.
- Compliance agent: Drafts ITP lines and attaches evidence; a person confirms.
- Manufacturers: For factory and offsite producers whose ITPs travel with the product.
- Defect records and warranty periods: How long each state's statutory warranties run, and what a defect record holds.
Questions worth asking
of your own inspection records
For a builder in NSW: can you show, for each wet area, the date waterproofing was inspected before it was covered?
Section 61(2)(d) of the EP&A (Development Certification and Fire Safety) Regulation 2021 lists that inspection for class 1 and 10 buildings, and s 63 requires the certifier's record. A builder's ITP line that holds the record reference answers it directly. General information as read on 25 October 2026, not legal or compliance advice.
For a subcontractor: does your ITP say which points are hold points and who releases them?
Under Q6's definition, a hold point needs written authorisation to proceed and a witness point only prior notice. An ITP that does not name the releasing role leaves the difference unrecorded. General information as read on 25 October 2026, not legal or compliance advice.
For a manufacturer of building modules or components: are factory ITP records linked to the site stage they precede?
Statutory stages such as framework or waterproofing inspection happen on site in some states; a factory record that names the stage and the unit it covers can be matched to it later. In NSW, s 61(10) states the critical stage inspection section does not apply to an inspection required when a building or dwelling is built off the site in sections and transported to the site for assembly. General information as read on 25 October 2026, not legal or compliance advice.
Questions people ask
about inspection and test plans
What is an inspection and test plan in construction?
Transport for NSW's QA Specification Q6 (Ed 2 / Rev 0, 2024) defines it as a document which identifies the inspection, testing (verification) and acceptance criteria for each activity. Its cl 3.8.2 requires ITPs to show frequency, method and acceptance criteria, hold and witness points, and the roles who inspect, review, verify and close out each lot. General information as read on 25 October 2026, not legal or compliance advice.
What is the difference between a hold point and a witness point?
In Q6, a hold point is a point beyond which work must not proceed without the Principal's written authorisation. A witness point requires prior notice to the Principal, who may choose to attend; work is not stopped for authorisation. General information as read on 25 October 2026, not legal or compliance advice.
Is an inspection and test plan the same as a quality plan?
No. Under Q6, the ITPs and their forms are included in the project quality plan, which also holds procedures and the records management plan. The ITP is the activity-by-activity verification part. General information as read on 25 October 2026, not legal or compliance advice.
Are critical stage inspections the same as an ITP?
No. In NSW, critical stage inspections are set by s 61 of the EP&A (Development Certification and Fire Safety) Regulation 2021 and carried out by the principal certifier or another certifier. An ITP is the contractor's own plan; it can reference those stages as hold points. General information as read on 25 October 2026, not legal or compliance advice.
What are the mandatory inspection stages for a house in Victoria?
Building Regulations 2018 reg 167 prescribes: before placing a footing; before pouring an in situ reinforced concrete member the permit specifies; completion of framework; any stage the permit specifies for a reg 172 inspection; and final, on completion of all building work (Version 031, as at 1 September 2026). General information as read on 25 October 2026, not legal or compliance advice.
What this analysis
does and does not show.
Evidence note
- What it shows
- Public definitions of an inspection and test plan, a hold point and a witness point, the content an ITP must show under one state transport authority specification, the statutory inspection or notification stages for building work in NSW, Victoria, Queensland, South Australia and the ACT, and the inspection and nonconformity records those instruments require, as read on 25 October 2026.
- Key facts quoted
- Q6 cl 1.3 definitions and cl 3.8.2 (a) to (h); nonconformity report within two working days (cl 3.12.2); records kept at least five years after completion (cl 4.3.4); NSW s 61(2), (3) and s 63(4); Victoria reg 167 and Act ss 33, 34, 35A; Queensland s 44; South Australia reg 93; ACT s 33 and Act s 43.
- Q6 is written for Transport for NSW and NSW council road and bridge contracts. Its definitions are quoted as a public reference, not as requirements for building work.
- We tried to read the Victorian roads Section 160 specification and a Main Roads WA quality specification; the Victorian host did not resolve on 25 October 2026 and the WA document was not found, so neither is used.
- WA, Tasmanian and NT inspection stages were not read from a primary source and are marked not verified.
- No Australian Standard is quoted. Where a project specification calls up a standard, its text is not reproduced here.
- The worked example is illustrative. Its project-specification rows are placeholders for a project's own documents, not requirements.
- Nothing here is legal or compliance advice, and nothing here determines whether any work conforms or any inspection was sufficient.
Bring us one ITP and the records behind it.
Send us an inspection and test plan from a recent job and the records it points to. We will show you which lines reference a statutory stage, which hold points have a release record, and which evidence could not be found again.
General information about published specifications and legislation, as read on 25 October 2026 at the versions listed. Not legal or compliance advice, and it does not determine whether any work complies. Statutory stages cover NSW, Victoria, Queensland, South Australia and the ACT only.
Sources
Suggested citation: Transport for NSW QA Specification Q6 (Ed 2 / Rev 0, 2024); EP&A (Development Certification and Fire Safety) Regulation 2021 (NSW) ss 61, 63; Building Regulations 2018 (Vic) reg 167 and Building Act 1993 (Vic) ss 33 to 35A; Building Regulation 2021 (Qld) s 44; PDI (General) Regulations 2017 (SA) reg 93; Building (General) Regulation 2008 (ACT) s 33 and Building Act 2004 (ACT) s 43; as read 25 October 2026. Derived figures: none.
- Transport for NSW - QA Specification Q6, Quality Management (Major Works): Ed 2 / Rev 0, authorised 5 February 2024 · read 25 October 2026 · State transport authority specification
- NSW legislation - EP&A (Development Certification and Fire Safety) Regulation 2021: Current version for 19 June 2026 to date · read 25 October 2026 in a visible browser window because the site blocks automated access · Legislation register
- Victorian Legislation - Building Regulations 2018: Authorised Version No. 031, incorporating amendments as at 1 September 2026 · read 25 October 2026 · Legislation register
- Victorian Legislation - Building Act 1993: Authorised Version No. 152, incorporating amendments as at 16 September 2026 · read 25 October 2026 · Legislation register
- Queensland Legislation - Building Regulation 2021: Current version from 14 August 2026 · read 25 October 2026 · Legislation register
- South Australian Legislation - Planning, Development and Infrastructure (General) Regulations 2017: Current authorised version, previous version to 16 September 2026 · read 25 October 2026 through a rendering proxy because the site blocks automated access · Legislation register
- ACT Legislation Register - Building (General) Regulation 2008: Republication No 52, effective 1 October 2026 · read 25 October 2026 · Legislation register
- ACT Legislation Register - Building Act 2004: Republication No 56, effective 1 October 2026 · read 25 October 2026 · Legislation register