Australian Industry Standards (AIS) on behalf of the Electrotechnology Industry Reference Committee (IRC), has proceeded to submit its Case for Endorsement to State Training Authorities (STAs) in the penultimate process, before proceeding to the Australian Industry and Skills Committee (AISC) to seek endorsement of the revised Electrotechnology Training Package. The Case for Endorsement Submission is available on the AIS website at: “CASE FOR ENDORSEMENT”. AIS reports that the AISC deferred the Release 2.0 Case for Endorsement, and requested “further information from the IRC and directed it to lodge a single submission, incorporating all revised training products as per the table …, for consideration at the meeting of the AISC on 16 June, 2020.”
AIS states, “In order to meet this deadline the draft Case for Endorsement will shortly be circulated to all State Training Authorities for consultation and feedback for a period of 3 weeks. At the same time, all draft products will be available on the AIS website for viewing. At the end of the consultation period all STA feedback will be submitted to the IRC for review, before an IRC approved Case for Endorsement is submitted to the AISC.”
The Case for Endorsement has now been forwarded to STAs. For anyone not familiar with the history of this Electrotechnology Training Package, and mor importantly the array of detailed stakeholders feedback of concern provided to the Review process would conclude, on a cursory review of the Case for Endorsement submission, that the process of transition and Review was smooth, efficient and supported by all stakeholders. The submission details processes and stakeholders consulted, and how all aspects of the Review process required by the Standards for Training Packages 2012 and AIS Funding Agreement were met, and notes no major issues were encountered in producing the final product.
This aspirational submission belies the truth, because significant feedback and concerns were raised by major constituents in the industry during the development process about a series of major defects in the product. These issues appear nowhere in the document. Such a document should at the very least outline the processes undertaken, the key issues raised by stakeholders and the arrangements that ensued to resolve outstanding issues or those that could not be resolved or addressed but which the IRC was not able to reach consensus on. Instead the document is full of praises and platitudes, and nowhere is there any commentary on the issues raised and remain unattended.
The submission therefore, lacks credibility and warrants further work to lay bear before the public the issues that were raised and addressed or set aside/dismissed for the record so that the IRC is accountable for its actions. As evidence of the lack of credibility in the process, the request for an ‘Issues Register’, which is supposed to have been made available on the AIS website, in accordance with its contractual obligation with the government, during the whole time the Review process was underway, has remained secret and not published. Submissions made by key stakeholders, industry representatives, and SME practitioners remain unanswered. Little, is publicly known how each of these issues was addressed. This falls far short of a truly transparent and consensus building process as required by the Training Package Development and Endorsement Process Policy standard.
Moreover, the NSW UE ITAB, for instance is aware that assurances were made to the NSW electrical regulator to allay any concerns that electrical equipment category reporting of units of competency would ensue, so that the transitioned and Reviewed Electrotechnology Training Package could proceed to endorsement without any regulator objection. This advice related to what could be included to augment a Statement of Attainment in the issuance transcript of the unit of competency. The advice was patently incorrect under the AQF qualifications issuance policy. Augmentation statements are not permitted.
As specific example also, is that the NSW UE ITAB made substantive submissions since March of 2019 on a range of defects and problems related to specific units of competency and qualifications to the Electrotechnology Training Package that included the consequences of the above issue being permitted to proceed for the electrical regulator, RTOs and learners. To date these concerns have never been responded to or highlighted as a concern in any public AIS literature.
The NSW UE ITAB is a NSW government recognised advisory body with significant constitute representatives and industry/RTO networks in NSW (and a large representative constituent in an Australian context) to warrant recognition of any concerns it so raised on their behalf. Yet, these concerns have simply vanished and been expunged from the record. No mention or statement of these issues is alluded to in the submission. The NSW UE ITAB is also aware of other stakeholders in NSW too, having made submissions and not having receiving any feedback on their concerns.
A specific defect the ITAB has consistently raised is the unintended consequences in consolidating/amalgamating the several (electrical equipment) categories of Restricted Licensing units into one, with no range statement of the categories. The most interesting decision for amalgamating these units was, as per the Case for Endorsement submission at page 30:
“The decision to consolidate units is based on the fact that the methods taught and knowledge required to disconnect and reconnect a piece of equipment are the same for the equipment listed in the table below. Additionally many RTOs do not offer the full suite of training and assessment due to low numbers enrolling and the cost of maintaining multiple pieces of equipment.
For reference Energy Safe Victoria accepts any of the below units as proof of training and assessment in disconnecting and reconnecting electrical equipment and issues the licensing classification based on the candidates primary trade or work function.”
These two paragraphs alone, evince the decision to amalgamate the units was for training purposes and not competency purposes. Every RTO the ITAB has communicated with on the matter has affirmed that whilst the training and skills development might be the same, there is a different assessment conducted for each of the different categories of electrical equipment. If this is so, how will a candidate be able to obtain additional training and an assessment in another category if there is only one unit of competency, and they have already attained it. Either, anyone being deemed competent in the amalgamated disconnect and reconnect electrical equipment is competent across all of the categories – e.g. motors, water heaters, composite equipment, etc. (as there is no range statement listing the categories in the proposed unit) or the candidate is not competent in any category and simply trained. And thus, there is a need for additional units of competency to reflect these very categories so assessment can be made and transcripts issued.
Public providers will no longer be able to offer additional training and assessment in specific categories to candidates already awarded the amalgamated unit. The amalgamated unit introduces new barriers to an already flexible system and places a heavy burden on RTOs to establish other forms of formal reporting mechanisms for electrical regulators who want information on the category of electrical equipment the candidate was assessed in (not just training in).
The questions that arise:
- how was this permitted to happen?
- who orchestrated it?
- why has no one with quality assurance responsibilities in government or AISC identified that the drive to amalgamate the units was driven by a training provision agenda, as highlighted above, which is explicitly prohibited in the Training Package Development and Endorsement Process Policy?
The Training Package Development and Endorsement Process Policy, approved by AISC on 3 December 2019, page 3, paragraph 2 of Point 2. About Training Packages states;
“Training packages specify the knowledge and skills required by individuals to perform effectively in the workplace, known as ‘competencies’ and expressed in units of competency. Training packages also detail how units of competency can be packaged into nationally recognised qualifications that align to the Australian Qualifications Framework (AQF).
Training packages prescribe assessment requirements but they do not prescribe how an individual should be trained.”
If training as stated was the motive, the proposal should have been stalled from the start, but it wasn’t.
The ITAB is also aware that not all IRC members fully support the final product in its current amended form, and therefore, consensus has not yet been reached. Whilst a majority may be sufficient for a vote it says little about having built a consensus based national product that in the end is supposed to service all states and territories and stakeholders. The Electrotechnology Training Package impacts on many people’s future qualifications aspirations, states and territory funding models, and employers’ and regulators desire to place trust in the quality of the products and those that graduate from them. One would have to truly wonder, how good is the product if national consensus was unattainable.
- If there is no consensus amongst the IRC members, and the decision is by majority vote, why does the submission lack any of this information?
- Why does the submission lack any of the above (stakeholder concern) information?
- How can this submission be treated with credibility when it does not truly reflect the proceedings that occurred not the issues that have been raised, or the quality of the process AIS and the IRC has undertaken, when otherwise is known?
The evidence is overwhelming that there are significant structural defects with the key qualifications (e.g. electrician) in the revised Electrotechnology Training Package (e.g. content and prerequisites) to warrant deferral of its endorsement in its current form. There are a whole series of unintended consequences which will ensue, that RTOs, STAs and learners will bear the burden of, for no added value in having produced a better and more effective product for the market. In a very short time the Electrotechnology Training Package will again have to be reviewed to address these structural problems and defects at a cost to taxpayers.
The AISC may very well wish to proceed to hasten endorsement purely to get it off its longstanding agenda and support a Case for Endorsement submission that lacks credibility, but it will ultimately be held accountable and responsible for having endorsed it in the face of a host of evidence of issues presented by industry stakeholders, who have formally submitted such along with warnings of the downstream problems, and nothing was done to address them. That decision rests with the AISC.
For more information contact Tony Palladino at firstname.lastname@example.org