Response to the Discussion Paper: Industry Engagement in Training Package Development Discussion Paper Towards a Contestable Model
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1 1 st October 2010 Response to the Discussion Paper: Industry Engagement in Training Package Development Discussion Paper Towards a Contestable Model The Electrical, Utilities and Public Administration Training Council Inc (EUPA) is recognised by the Western Australian State Training Board and funded by the Western Australian Department of Training and Workforce Development to provide strategic advice regarding skills and workforce issues for the industries that are within its scope. Western Australia s network of Training Councils perform a vital role to ensure the labour market is appropriately skilled by ensuring industry perspectives are communicated to policy makers at state and national levels. EUPA welcomes the opportunity to contribute to the discussion and supports the continual improvement of VET products and services. Industry Coverage EUPA s scope is organised in accordance with the Australian and New Zealand Standards for Industry Classification (ANZSIC) and includes the following sectors relevant to the public validation: Division D: Electricity, Gas, Water and Waste Services o Subdivision 261 Electricity Generation o Subdivisions 262, 263 & 264 Electricity Transmission, Distribution and On-Selling/ Market Operation o Subdivision 27 Gas Supply o Subdivision 28 Water Supply, Sewerage and Drainage Services Division E: Construction Services o Subdivision 32 Construction Services, Group 323 Building Installation Services Class 3232 Electrical Services Division O: Public Administration and Safety o Subdivision 75 Public Administration o Subdivision 77 Public Order, Safety and Regulatory Services The industries that EUPA represent are clearly integral to the proper functioning of communities and the economic development of our state. The sectors include public entities, national and international corporations, micro-businesses, regulated industries, statutory authorities and government-owned utilities.
2 These industries are responsible for the following broad activities: Governance and provision of human services to communities, Providing social and economic infrastructure to support sustainability, Provision of reliable and safe gas, electricity, water and wastewater services, Collection and safe treatment or disposal of municipal, commercial, industrial and construction waste, Ensuring public confidence and safety at local and state levels including the management of offenders in prison and community-based settings; and Preparing for and responding to emergency or extreme events (including environmental events). Industry Engagement in VET The industries EUPA represents are each engaged in the VET sector at differing levels and influenced by external conditions that affect the uptake of formal qualifications or competency standards as follows: Electrical services, electricity supply, gas and water sectors: These sectors operate in a complex environment that: is overseen by national and state regulatory bodies, must comply with industry endorsed guidelines and codes of practice; and/or require employers and/or workers to hold permits or specific authorisations. Many of the requirements above have been codified in VET standards. Uptake of qualifications is further assisted through the formal establishment of Australian Apprenticeships and associated support mechanisms that are inherent to the system. The sectors provide high levels of support to the VET sector through contributions to the design and review of training package qualifications. Public Administration, Public Safety and Waste Sectors: Public safety industries utilise VET standards for core operational roles as important benchmarks for performance and have national peak bodies to which they make enormous contribution to the training package process. However, the industry has been constrained when implementing VET products due to conditions that are specific to their industry that affect funding. That is, the workforce is comprised of a high number of volunteers who are not treated as traditional employees despite the value of their services to the community. This issue has not affected the industry s engagement during the design of training package products, but has led to lower uptake of qualifications in some sub-sectors. In public administration, deployment of qualifications is not regulated or supported in the manner that traditional trades enjoy, however the sectors have been widely engaged and make significant investment in the development and maintenance of Training Packages through existing arrangements. These sectors often use VET products from Training Packages across wide variety of industries, such as Local Government which is extremely diverse. The sector has reported that engagement across industry sectors would be beneficial, such as when considering civil construction qualifications.
3 The public administration sectors also struggle to access the training products that they have invested in during development due to thin market issues, funding and the reluctance of RTOs to scope for specific qualifications or where generic products are promoted by VET stakeholders. The waste industry also utilises VET products from other industry sectors but has reported a lack of engagement by its own VET industry body and issues with RTO delivery. This has resulted in poor uptake of qualifications specific to the sector despite a recognised need to cater for a diverse workforce that work across the state. Western Australian Industry Engagement As identified in the introduction, Western Australia s model for governance of VET includes the recognition of ten Industry Training Councils (ITCs) to which EUPA belongs. This Council is governed by a board of ten industry leaders and works with sub-committees of the board that involve employers, regulators, peak associations, ISCs and training providers. The in-kind investment that industry makes to drive VET in their own sectors and to provide advice covering state policy issues and industry training package development is considerable. The need for effective industry engagement cannot be understated and is integral to ensure VET products are relevant and accessible. Objective of a contestable model EUPA supports the objectives to manage training packages. That is: All of industry has avenues to contribute to the development of the qualifications Feedback from employers is taken into account Qualifications retain their national character and offer maximum benefit to pursue career objectives Qualifications meet relevant quality standards. The process represents value for money. We submit that, in our experience with the Energy Skills Australia (E Oz) and Government Skills Australia (GSA), industry engagement and training package design processes have consistently provided high quality outcomes. It has also been clear that Industry Skills Councils have provided value-adding services that support their own intelligence gathering for the purposes of training package design. These services have assisted industry in different ways but have undoubtedly assisted the ISCs to maintain a contemporary view of their respective sectors. Having said this, industry-led research is also a valuable contributor to the process of VET product design. Where industry has invested in research of its own, VET stakeholders should be encouraged to ensure this material is evaluated and included in considerations.
4 Features of industry-defined qualifications EUPA agrees that industry-defined qualifications must be national, consider external forces on industry, ensure public benefit, provide cross-industry skills and be efficient. A focus on future development is also highly important and one that may need more exploration when considering the review of training packages and accredited courses (subject to the second discussion paper). The impact of external influences on training packages cannot be understated for the sectors that EUPA represents. This applies to industry defined codes and formal guidelines, enterprise safety measures such as permits and authorisations, government oversight through regulatory arrangements and public/community scrutiny of the services provided. Attributes for Training Package Development EUPA supports a strong, independent, national body that has the credibility, technical and VET expertise to provide quality training package products. EUPA stresses the necessity to ensure that the needs of all industry stakeholders are considered and addressed during training package design. That is, the organisation must act with the highest of integrity and ethics while listening to the views of stakeholders that may be large or small, or that may be considered powerful or have limited influence at a political level. Regardless of the exact process, the outcome must result from transparent practices. Co-contribution arrangements The paper understandably raises co-contribution by industry to support training package development. It recognises that investment by industry is often a strong signal of industry commitment to its skills development needs. It is not clear that the existing contribution made by industry in the current process has been recognised. EUPA experiences significant investment by industry stakeholders at state and national levels to design, review and implement VET products, services and policies. This Council strongly asserts that the processes in place today would not have been successful without the investment of time and resources by individual enterprises, regulators and peak bodies. For this reason, continued support by industry is essential to the production of valid quality products. However, imposing additional financial contribution requirements on industry is likely to see VET products for some industry sectors suffer. Each sector is unique in structure. Funds may be sourced from treasury, government grants, rate payers or customers. The expectation of customers will also be different. For example, a utility service is under significant pressure to justify infrastructure costs to the consumer and local governments must convince rate payers that their funds are directly benefiting their local community.
5 EUPA proposes that the sectors it represents will have very limited capacity to offer further financial contributions to the VET system. A framework driven by industry The discussion paper draws our attention to the possibility of streamlining endorsement processes and reducing red tape. EUPA supports efforts to remove barriers to implementation that create unnecessary cost and time burden. A risk based approach to endorsement that defines the extent of the process makes good sense and should assist industry to adapt to the increasingly rapid rate of change through progressive skills programs. Models for consideration Approach 1: This approach is considered to be inappropriate by the Council. The model provides for Industry Training Coordinators housed within the Department of Industry who react to a business case for change by forming Training Development Panels. The model requires government intervention early in the process by placing decision-making and prioritisation in the hands of the Industry Skills Committee. Government intervention at this early stage introduces risks that are external to the industry sector. For example, decisions to progress with a business case may be influenced by factors relating to government process or the capacity of the coordinators which could be overcome by implementing a different model. Further, by reacting to individual cases, there is a risk that a piece-meal approach to training package review may eventuate which could lead to issues regarding career/skills progression both within and across industry sectors. Finally, government support through funding of the Training Development Team (supported by in-kind contributions from industry) is preferred. Approach 2: This approach sees the implementation of Industry Sector Committees independent of government. EUPA supports the stated selection process of that committee by industry, recognising that the criteria for selection that ensures industry is supportive; and that there is a greater public good is appropriate. Importantly, the approach should provide for continuity in dealing with issues over time and stability in respect to the ongoing management of training packages. However, there is a risk that the Industry Skills Committee may be required to interact with a much larger number of bodies for the purpose of overseeing the VET sector. The concept also flags the need for industry to invest in the Committee after four-five years as government funding is considered to be seed-funding only. EUPA draws attention to the significant investment made by industry at the panel level through the provision of technical expertise and questions the ability of industry to support the committee through further financial contribution.
6 The concept provides for Training Development Panels to be formed as necessary, which seems to align with current processes which draw on technical advisory groups or similarly named assemblies. Approach 3: This approach shows closest alignment to the current arrangement. EUPA s experience with the current training package development owners (ISCs) is that the model generally works well across the board. However, the proposed reduction in numbers of organisations will require the new designated body to represent an enormous scope of industries. It is proposed that this would be unmanageable without significant funding and support to ensure all sectors receive an appropriate level of service. The approach does potentially provide for the continuity and stability that industry requires of VET stakeholders. Preferred Approach EUPA supports Approach 2 Industry assigns responsibilities to preferred organisations. This approach appears to give maximum assurance to government that the owner of training package development will rest with a credible, industry supported organisation. However, EUPA does not support the notion that government funding is limited to four-five years as seed funding. Industry already makes significant contribution to the process and would continue to do so as members of a panel in the proposed approach. At a time where all stakeholders are faced with increasing pressures, passing on additional cost may well result in industry sectors disappearing from the VET landscape if participation is unaffordable. This is not a scenario that EUPA can entertain. The Board of EUPA Training Council looks forward to engaging further with the Department of Industry. For direct enquiries or questions, please contact Mr Kevin Peachey, Acting Executive Director on (08) or kevin@eupa.com.au Yours sincerely Joe Fiala Chairperson EUPA Training Council Inc.
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