The Allocation and Funding of Commonwealth Supported Post Graduate Places
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1 The Allocation and Funding of Commonwealth Supported Post Graduate Places Submission: Funded Places for Professional Programs in Occupational Health and Safety Contents Executive summary Introduction Scope Objective Rationale National significance Accepted entry level for profession Area of skill shortage Comment on other options Signatures Letter of support: Australian Council of Trade Unions References... 13
2 Executive summary Occupational Health and Safety professionals are vital to ensuring the health and safety of Australian workers and also minimising the impact of work and non work -related injury and ill-health on the Australian community and on the economy. OHS is an emerging profession with a number of professional activities directed to its development creating a dynamic professional environment. It can be demonstrated that Occupational Health and Safety meets the requirements of a profession in that it has a defined Body of Knowledge, a code of ethics and the members of the profession are prepared to apply this knowledge and exercise their skills in the interest of others. These professional requirements are embodied in the professional certification of generalist OHS professionals currently being implemented across Australia. Education of generalist OHS professionals is mainly through full fee-paying postgraduate education. The Australian OHS Education Accreditation Board has been set up to accredit generalist OHS professional education programs. While vital to Australia, enrolments in OHS professional education are low compared with other professions causing them to be considered boutique programs and in some cases not valued within the universities. This positioning of OHS within the priorities of some universities is inconsistent with the needs of industry and threatens the supply of qualified OHS professionals to meet the increasing demand arising from the resource industry, changes in legislation and the certification of generalist OHS professionals. There appears to be a shortage of qualified OHS professionals and while the demand for OHS professional education is likely to increase the number of enrolments will not increase to the level of many other professions and so OHS is not likely to attract Commonwealth Supported Places should the allocation be determined by internal university processes. Government support by allocating post graduate places specifically to OHS programs (Option 1 or Option2 with conditions) will be important in ensuring an ongoing supply of qualified OHS professionals for Australian workplaces and the Australian community. 1 Introduction The Occupational Health and Safety (OHS) profession has four segments: generalist OHS professionals, occupational ergonomists, occupational hygienists and occupational health practitioners (nursing and medical). This submission addresses the professional education of generalist OHS professionals. As, currently, there are no specialist
3 ergonomics professional education qualifications ergonomists obtain their professional education by completing a generalist OHS professional qualification with an ergonomic stream. Occupational hygienists complete an approved post graduate program which may often be a combined generalist/hygiene qualification. In addition to their basic qualification of medicine or nursing, occupational health practitioners may complete generalist OHS professional education in addition to specialised occupational health education. A viable and effective range of generalist OHS qualifications at the post graduate level is important in ensuring OHS professionals for Australian workplaces. 2 Scope This submission addresses the provision of post-graduate funded places for education of Occupational Health and Safety (OHS) professionals. These are programs at AQF level 8 or 9 that have more than 50% of the credit points devoted to occupational health and safety. They may have OHS in the qualification post-nominal but this is not a requirement. 3 Objective The consultation paper put forward four options. Option 1: Option 2 Option 3 Option 4 Allocating additional post graduate places for specific courses or types of courses Allocating additional places to ensure universities have a guaranteed level of postgraduate places Allowing universities to negotiate their allocation of postgraduate places within an overarching funding envelope for the university Demand driven funding of all Commonwealth supported postgraduate student Options The preferred option for post graduate education of OHS professionals is Option1. Option 2 could be affective provided conditions are set on the use of any newly allocated places such that a certain number are applied to OHS professional education programs. As the approach to OHS varies across universities, and to some extent this variation is important to achieving OHS outcomes, the allocation of places to universities
4 should be the subject of discussion with the industry and also take account of the program accreditation status. While no national labour-force studies have been conducted on the demand for generalist OHS professionals it is estimated that in the order of 500 new graduates are required to develop the OHS professional workforce and to replace those retiring. The rationale for the need for government supported places for OHS professional education and the selection of Option 1, or Option 2 with conditions, is outlined below. 4 Rationale Government supported post graduate places for OHS professional education can be justified on all criteria cited in the consultation document: OHS professional education is of national significance; the qualifications are accepted entry level for the profession; and there is a shortage of skills. 4.1 National significance Legislative requirement The right for workers to have a workplace that is, as far as is reasonably practicable, safe and without risk is legislated for in the national model Work Health and Safety Act (WHSA s 19) (p. 19) and, internationally, in the International Labour Organization (ILO) Convention 155: Occupational Safety and Health and the Working Environment (ILO, 1983). The latter is supported by Recommendation 161: Occupational Health Services, which calls for organisations to have access to sufficient and appropriate expertise as a basic right of all workers (ILO, 1985). In Australia, OHS is recognised as a management responsibility however the interpretation of the role of an officer under the national model Work Health and Safety Act [WHSA s 27 (5)] specifically includes seeking advice from suitably qualified persons as part of the due diligence of the manager (Safe Work Australia, 2011b) Impact on Australian workers Claims for workers; compensation show serious workers compensation claims in , which equates to 13.0 serious claims per 1000 employees and 7.8 serious claims per million hours worked. While there appears to have been a decrease in claims and incidence rates over the last six years 1 incidence rates increased with age with a 1 This decrease has been influenced by changes to the way number of workers and number of work hours are calculated by the ABS (Safe Work Australia, 2011a, p. 13)
5 resultant implication for Australia s aging workforce. In the same period there were 232 compensated fatalities, equivalent to an incidence rate of 2.4 fatalities per employees. (Safe Work Australia, 2011a). 2 While these figures indicate that more than 130,000 Australia workers suffer serious injury or die as a result of their work every year workers compensation figures are known to seriously underestimate workplace death, injury and ill-health. The complexity of the causation and management of work-related injury, disease and ill-health is also becoming more complex with factors such as fatigue, occupational stress and occupational diseases and ill-health with long latency periods becoming more prevalent and more recognised. Thus qualified advice is essential to identifying and minimising conditions that may contribute to work-related fatality, injury, disease and ill-health National strategy In 2002 the rate of work-related injury and ill-health in Australia was considered unacceptable by the Workplace Relations Ministers Council (WRMC) who then endorsed the National OHS Strategy (NOHSC, 2002). A new national strategy is currently being developed for This strategy identifies the importance of preventing and managing the factors contributing to work-related fatality, injury, disease and ill-health and has identified that education and training are an important factor in managing OHS issues to prevent work-related fatality, injury, disease and illhealth Impact on the Australian community While the workplace is the focus of most OHS professionals a significant number of professionals with generalist OHS education work in or advise on other areas of health and safety including transport, aviation, maritime and community safety Impact on the economy Good information on the impact of work-related injury on the Australian economy is hard to obtain however data from the then National Occupational Health and Safety Commission (NOHSC) and the Australian Bureau of Statistics (ABS) indicate that compensation claims for work-related injury and ill-health cost the Australian economy $34 billion annually (National Occupational Health and Safety Commission, 2004, p. 2) 3, 4 2 The volatility of such data is shown by the recent increase in workplace fatalities such the rate of fatalities is the highest it has been for many years. 3 This figure is based on statistics for This is approximately 5% of Australia s GDP for the same period.
6 5. When the additional cost of pain, suffering and early death of the more than 477,000 Australians injured during the same period is considered (Australian Bureau of Statistics, 2003) the total cost of work-related injury and ill-health increases to $82.8 billion dollars per annum (National Occupational Health and Safety Commission, 2004, p. 3). Due to differences in scope and methodology, it is difficult to compare these statistics with those for other countries however, for the same period, the Australian Safety and Compensation Council (2008, p. 4) placed Australia seventh in the world for workrelated injury fatalities 6 having a higher rate of work-related injury fatalities than the United Kingdom (UK), Switzerland and the Scandinavian countries. Since this data was collated the median payments for claims have increased in all occupation groups and in all industries (Safe Work Australia, 2011a). 4.2 Accepted entry level for profession The OHS profession and the delivery of OHS professional education are currently undergoing significant change. These changes include the development of the core Body of Knowledge for generalist OHS professionals, accreditation of OHS professional education, and certification of OHS practitioners and professionals. The outcome of these changes is that OHS meets the requirements of a profession as a disciplined group of individuals who: Possess special knowledge and skills in a widely recognised body of learning derived from research, education and training at a high level Adhere to ethical standards Are prepared to apply this knowledge and exercise these skills in the interest of others.(professions Australia, 1997) The requirements for professional certification together with the current tendency for entry to the OHS profession to be by mature age students result in post graduate study being the predominant route of entry to the profession Core Body of Knowledge for OHS professionals A recent national project, the OHS Body of Knowledge Project, has resulted in the development of a conceptual framework describing the core knowledge, including key concepts and core theories, with which all generalist OHS professionals aree expected to engage with and apply. This OHS Body of Knowledge forms the basis for accreditation of OHS professional education programs and also the further development of current 5 South Australia currently conservatively estimates the cost of work-related injury at $100 million dollars each year. ( 6 This comparison does not consider work-related fatalities due to disease.
7 professionals. Thus Occupational Health and Safety meets one of the core requirements of a profession as possessing special knowledge and skills in a widely recognised body of learning derived from research, education and training at a high level (Professions Australia, 1997). This project developed from the recognition that OHS lacked a defined core body of knowledge to inform education and practice of generalist OHS professionals which not only impacted the quality of advice in the workplace, but also inhibited implementation of a professional certification process. Gaps in the coverage of some important OHS topics were also identified in OHS professional education programs due largely to the lack of a defined core body of knowledge for generalist OHS professionals. This issue was considered so important that in June 2009 WorkSafe Victoria provided funding of $ for the OHS Body of Knowledge project which had two phases: Development of the Core Body of Knowledge and Implementation of the Core Body of Knowledge. The latter phase included development of course accreditation and professional certification processes Accreditation of OHS professional education As part of the progression of the OHS profession and the development of the OHS Body of Knowledge, structure and processes for accrediting OHS professional education programs have been established. The Australian OHS Education Accreditation Board accredits OHS professional education programs that meet the accreditation criteria and holders of accredited qualifications are then deemed to meet the knowledge requirement for certification as generalist OHS professionals. Accreditation provides guidance for potential students in selecting a university and an OHS program; it provides information for employers who may be requiring current OHS advisors to take on further qualifications; and it may inform recruiters and employers in their selection processes. The criteria and processes for accreditation have been developed taking account of the Commonwealth initiated changes to accreditation of universities and the standards for quality of teaching and learning Professional certification Historically, professional recognition for OHS professionals has been through internal grading processes conducted by the OHS professional bodies. A more formal, structured and rigorous certification process for generalist OHS professionals is currently being developed with implementation planned for the financial year The accreditation criteria have been structured to reflect and supplement the provider and teaching and learning standard and the process has been developed taking account of the TEQSA processes.
8 The criteria for certification as a generalist OHS professional will require completion of an OHS qualification at Australian Qualification Framework (AQF) Level 7 or above (excluding Graduate Certificate) (i.e. a bachelor, graduate diploma or masters). 8 Certification will also require compliance with a code of ethics and ongoing continual professional development. Thus Occupational Health and Safety meets the requirements of a profession as a disciplined group of individuals who adhere to ethical standards and prepared to apply this knowledge and exercise these skills in the interest of others (Professions Australia, 1997). The need for an OHS professional certification program was recognised by Maxwell (2004) in reviewing the Victorian OHS legislation and by the Health and Safety Professionals Alliance (HaSPA, 2008). This will bring Australia in line with other countries such as the USA, Canada, the UK and Europe where certification of generalist OHS professionals and practitioners is standard with a recent government report in the UK (Lord Young of Graffham, 2010) calling for more stringent criteria and process for certification of safety consultants. Certification is needed to recognise those competent to provide advice and support for implementation of OHS strategies and activities and to also facilitate recognition of the role of the generalist OHS professional in organisational change to develop and implement effective OHS strategies and activities. WorkSafe Victoria recognised that competent OHS advice is essential to improving safety in the workplace and incorporated Repositioning the OHS professional in the Victorian OHS strategy for (WorkSafe Victoria, 2007) Routes of entry to profession In the past, due to the lack of regulation or certification, OHS advisors may have entered the role by a range of routes. These routes may have varied from no qualifications or trade qualifications, OHS Diploma, bachelor degree in any discipline, through to OHS graduate diploma or masters programs. This will change with the implementation of professional certification which will require an OHS qualification at AQF 7 (Bachelor) or AQF 8/9 (Graduate Diploma/Masters). 9 While the certification requirements include an AQF 7 qualification the reality is that there are only three OHS bachelor degrees in Australia and demographic issues, 8 Certification will also require 3 years or equivalent OHS experience, demonstrated competence assessed through a portfolio of evidence, referees, structured continuing professional development, membership of an OHS professional body and commitment to code of ethics. 9 Transitional arrangements for current practitioners will include support to move to new certification categories but will also mean an increased demand for qualifications.
9 together with a lack of recognition by the university hierarchy of the importance of OHS programs mean that these programs are under continual threat (Toft et al., 2010) with two OHS bachelor programs being closed in the last two years. Thus the majority of OHS professionals enter the profession though a Graduate Diploma or Masters program Demand for OHS post graduate places The demand for OHS professionals with tertiary qualifications is demonstrated in the outcomes of a survey of OHS professionals employed within larger Australian companies (Safesearch, 2011) which found that the proportions of those holding a bachelor degree or higher qualification in OHS were: 59% of OHS/Health Safety Environment (HSE) advisors/coordinators 79% of OHS/HSE managers 80% of national OHS/HSE managers 82% of general managers OHS/HSE. There is also an increasing trend for higher-level professionals to hold masters degrees in OHS. The implementation of certification for generalist OHS professionals together with the skill shortage factors discussed in section 4.3 are likely to generate increased demand for post graduate OHS places. This will initially come from current practitioners wanting to upgrade their qualifications to meet the certification requirements but also from those wanting to enter a profession that now has an increased profile and clear guidelines for practice requirements. There are currently 14 universities offering OHS professional education with an estimated new enrolments in 2011 of 350 and total places 500 of which approximately 50 are Commonwealth Supported Places (CSP). This small number of CSPs is in two universities only and is at the discretion of the university. One university has indicated that their CSP places will not be available in Cost of postgraduate professional education Most post graduate entry-level OHS qualifications are full-fee paying places with the cost per program varying between $11,000 to $22,500 depending on method of delivery and other factors (statistical mode $15,402). While the majority of students will be working, many are at the stage in life when they have significant financial obligations. Thus gaining professional qualifications requires a significant financial impost.
10 Most OHS professionals are not remunerated at a level which makes paying fees for postgraduate study attractive as a career development option, thus funding of post graduate places should be supported for equity as well as supply reasons. While students may have an expectation of increased salary post qualification and there is an increasing trend, salaries for OHS professionals vary widely. A national salary survey estimated total actual remuneration estimated at: $96,851 for OHS/HSE advisors/coordinators $136,004 for OHS/HSE managers $173,474 for national OHS/HSE managers (Safesearch, 2011) 10. The majority of OHS professionals would operate at the advisor/coordinator/ manager levels and these salary ranges are only achieved post qualification and after considerable experience. 4.3 Area of skill shortage There is a shortage of qualified OHS professionals to provide high-level advice to Australian work-places. 11 The current numbers of OHS professionals and the current and future demand are difficult to estimate and no studies have been conducted. However a comment by a specialist OHS recruitment agency is enlightening. Over the past five years SafeSearch have placed more than 500 Health, Safety & Environment (HSE) professionals into over 100 organisations operating in Australia, including 20 of the ASX50 and many of the world s largest multinationals. The majority of these assignments have included a search component as there is an ongoing shortage of post-graduate qualified and suitably experienced professionals to meet the continuing demand from our clients. On some occasions, due to the lack of candidate pool in Australia we have been forced to extend our search to overseas locations such as the UK where safety is a highly recognised profession. Julie Honore, Managing Director, SafeSearch At least three factors are impacting on this shortage. The resource industry employs a high number of OHS professionals compared with other industries and OHS tends to be an aging profession (Borys, Else, Pryor, & Sawyer, 2006). Implementation of harmonized OHS legislation through the national model OHS legislation is also creating demand for qualified OHS professionals. 10 These estimates may be considered to be skewed towards the upper end as they are drawn from 50 volunteer organisations that are larger and in some cases multi-national. 11 Pryor, P (2010) unpublished research as part of PhD.
11 5 Comment on other options While 14 Australian universities currently offer OHS qualifications enrolments in OHS professional education programs are small compared with many other professional programs and are often considered boutique. This combined with the fact that OHS teaching units are small in staff number and OHS academics are not able to attract large research funds mean that OHS is not highly valued as a discipline within universities (Toft et al., 2010). This is evidenced by the recent closure of a suite of OHS programs that by all measures was viable and attracting student numbers. This lack of value of OHS as a discipline within the university hierarchy mean that Option 3 is not a viable option for OHS professional education. Similarly unless conditions are set on any newly allocated places requiring that a certain number of places are allocated to OHS the Option 2 is not viable for OHS. Signatures Pam Pryor, Registrar, Australian OHS Education Accreditation Board Keith Brown, CEO, Safety Institute of Australia Letter of support: Australian Council of Trade Unions.
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13 References Australian Bureau of Statistics. (2003) Year Book Australia. Retrieved , from Australian Safety and Compensation Council. (2008). Comparative performance monitoring report (9th ed.). Canberra: Workplace Relations Ministers' Council Borys, D., Else, D., Pryor, P., & Sawyer, N. (2006). Profile of an OHS professional in Australia in J Occup Health and Safety Australia NZ, 22(2), ILO (International Labour Organization). (1983). Convention 155: Occupational safety and health and the working environment.. Geneva. ILO (International Labour Organization). (1985). Convention 161: Occupational Health Services Geneva. Lord Young of Graffham. (2010). Common Sense Common Safety. London: HM Government Maxwell, C. (2004). Occupational Health and Safety Act Review Melbourne State of Victoria. National Occupational Health and Safety Commission. (2004). The cost of work-related injury and illness for Australian workers, employers and the community. Canberra: National Occupational Health and Safety Commission NOHSC (National Occupational Health and Safety Commission). (2002). National OHS strategy Canberra: Commonwealth of Australia. Professions Australia. (1997, July 10, 2009). Definition of profession from Safe Work Australia. (2011a). Compendium of workers' compensation statistics Australia Canberra Safe Work Australia. Safe Work Australia. (2011b). Interpretive guideline - Model Work Health and Safety Act: The Health and Safety Duty of and Officer Under Section 27. Canberra: Safe Work Australia. Safe Work Australia. (2011c). Model Work Health and Safety Bill: Revised draft 23/6/11. Canberra Safe Work Australia Safesearch. (2011). Health safety and environment remuneration survey Melbourne Toft, Y., Capra, M., Kift, R., Moodie-Bain, D., Pryor, P., Eddington, I., et al. (2010). Safeguarding Australians: Mapping the strengths and challenges toward sustainable improvement in OHS education and practice. Final Report, Part 1. Sydney: Australian Learning and Teaching Council. WorkSafe Victoria. (2007). Talking with professionals Unpublished slide presentation.
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