RESPONSE TO THE CONSULTATION ON REVIEW OF APPRENTICE TRAINING IN IRELAND NAME OF ORGANISATION THE SOCIETY OF THE IRISH MOTOR INDUSTRY (SIMI) 5 UPPER PEMBROKE STREET DUBLIN 2 Occupational Sectors which are covered in this submission The Motor Industry Family of Trades; Light Vehicle Mechanic, Heavy Vehicle Mechanic, Vehicle body Repair Specialist, Construction Plant fitter and Agricultural Mechanic
The Society of the Irish Motor Industry Background The Society of the Irish Motor Industry (SIMI) welcomes the opportunity to make a Submission to the Department of Education & Skills Consultation Document Review of the Apprentice Training in Ireland. The SIMI is the National trade association and representative body of 1,200 member companies, in the Motor Industry, whose businesses include the distribution, retailing, repair and maintenance of motor vehicles and their components. SIMI members are located in every county in Ireland, and the Motor Industry currently employs in the region of 35,000 people, underlining its importance to the Irish economy. Apprentice Training is a key cross sector issue for our members. Area 1 Overview of Current System The current review of Apprenticeship Training in Ireland should be clearly focused on improving and developing a system that has served Ireland well by delivering Craftspersons of exceptional skill and ability. As an Industry that relies on the availability of this skill-base and one that has supported and invested heavily in apprentice development over many decades, we see this as a vital component in our economic recovery. The Motor Industry believes that the standards-based dual system model of apprenticeship has by and large served our Industry well for over 20 years. Apprenticeship training is essential for our Industry; and Irish Apprentices in all trades, and especially those in the Motor Industry Family of Trades, have demonstrated by their regular success at the Worldskills Competitions that the quality, skills and competencies of Irish apprentices are world class. Motor Mechanics/Technicians are the life blood of the motor industry in Ireland; these highly skilled craftspeople diagnose, inspect, repair and service a variety of motor vehicle from motorcycles to heavy commercial vehicles. Some mechanics may work on all parts of the vehicle, while others will specialise in one area, for example diagnostics, or may work on just one type of vehicle. In addition to the continuous need for craftspeople to maintain their skills they also need to keep abreast with the advances in vehicle technology. An essential feature of the work of a Motor Technicians involves ensuring the safety of vehicles on our roads; important work has been carried out the RSA to encourage drivers and vehicle owners to maintain the safety of their vehicles through regular servicing and simple safety checks. In addition Vehicle Body Repairers have to ensure standards of vehicle repair to ensure that their safety to return to use on the road following accident damage.
Furthermore Body Repairers must also face challenges in relation to continuous changes and advances in materials and vehicle construction and environmental requirements. Having employed close to 50,000 in 2008, the Motor Industry now employs close to 35,000 and many of these are employed in garage workshops using a wide range of complex equipment and machinery. It is mark of the standard and quality of the training provided during the apprenticeship programmes and the importance given to health and safety training within the curriculum and in the training centres that our Industry has a very good safety at work record compared to other industries. Area 2 Governance 2.1 In consideration of compiling this submission we have consulted widely with Employers in the Industry from Vehicle Manufacturers to Franchise Dealers and Independent Garages (both car and commercial vehicles) and Body Repairers and notwithstanding the fact this places an onerous responsibility on the Employer, which they accept is a necessary part of the relationship between responsible National Agency, the apprentice and the Employer, the majority of Employers in the Motor Industry would favour the continuation of a statutory basis for Apprenticeships. Equity and Gender Balance 2.2 The Industry has been very open to intake of females in what has been a very male dominated workshop sector, but numbers have remained extremely low despite previous programmes and incentives to redress the balance. The experience in our Industry when female apprentices have completed their apprenticeship is that they tend to move into other roles within the industry. It could be possible to increase the number of female apprentices by extending apprenticeships into areas to cover roles that currently tend to attract a higher proportion of females but these will tend to be in administration and sales rather than in technical areas. Nevertheless, improvements to the current model would be welcomed by the Motor Industry and should be considered. Range of Occupations 2.3 The current range of occupations covered by the Apprenticeship system should be re-examined to ensure that they match Industry needs and the current labour market. The Motor Industry would favour an increase in the range of occupations, for example, the establishment of a Motorcycle Mechanic apprenticeship. It is likely that the EU will introduce regulations for the compulsory testing of Motorcycles, at present there is no recognised qualification for a Motorcycle Mechanic in Ireland and that is something that this review should address.
Funding and Cost of Apprenticeship 2.4 Whatever the outcome of this Review, the current level of funding must be maintained. The supply of apprentices is already greatly reduced due to the decline in the number of Employers with the ability to take on new apprentices. The Review should not simply be a focus on saving money to the detriment of future generations of young people. Currently, the costs of the apprenticeship are shared by the State and the Employer (Employment levy, wage costs, in-company training, equipment, premises). While Employers contribute the most, in the main they believe that their investment in apprenticeship training represents reasonable value but is, more importantly an investment in the future. However they would be against any increase in the Employer s contribution towards the costs of apprenticeship training. In particular,they would stress the importance they place on the State continuing to pay the allowance for the apprentices during the off-the-job training phases. Recruitment and Intake of apprentices 2.5 Recruitment of apprentices should remain under the control of the Employers, but it is accepted that Employers who wish to take on an apprentice should be able to satisfy certain criteria in relation to facilities, equipment and suitably qualified staff to mentor the apprentice. The State should continue to acknowledge that Employers have an important role to play in the planning of future training needs of their industry/labour market. We know from past experience that failure to plan and promote the intake of apprentices in times of economic downturns can lead to serious shortages of skilled labour when the economy beings to pick up. Career Progression and entry to 3 rd level education 2.6c Some technicians will continue to work in the retail garage sector and perhaps specialise or become experts in a particular area or brand; some may advance to Workshop Management level or to Service manager level and indeed some may seek career advancement in engineering. It is important that those craftspeople who might wish to take the academic route in order to further their career opportunities should be accommodated. It is vital that apprenticeship should be recognised as credits towards entry into a relevant 3 rd level programme. Centralised National Register of applicants for apprenticeship 2.5d A centralised application system, giving Employers access to an online database of eligible apprentice applicants, whose qualifications had been screened in advance, would greatly improve efficiencies when it comes to finding a suitable apprentice in the locality. It would also aid apprentice applicants in finding a willing local Employer.
Entry Level 2.5f The current minimum entry level requirements (16 years of age with minimum of 5 Grade Ds in Junior Cert) provides the possibility for applicants who may not have the desire or ability to continue to Leaving Certificate level, to potentially have the same educational opportunities as those who opt for the more academic route into third-level and higher education. The Motor Industry does not favour any fundamental changes in the minimum entry level requirements; however some trade specific entry requirements or pre-registration aptitude tests might be considered an advantage. It may also be beneficial to provide the opportunity for specific maths and science courses to aid those early school leavers who may be weak in these areas. Probationary Period 2.5g The current position, whereby an apprentice can be released by the Employer within the first 6 months of his/her apprenticeship if the Employer considers that they have not demonstrated an aptitude for the trade should be retained. Curriculum Reviews, Updates and planning 2.6 The rapid and continuous advancements in technology within the Motor Industry mean that it is essential that Industry stakeholders are given a platform that allows them to be involved directly in the modification and review of the curriculum. Currently the reviews of curriculum are carried out on phased a basis, perhaps every 5 years. The reviews are carried out with the co-operation and assistance of subject matter experts nominated by the Social partners. Given the pace of technological change however the Industry Employers would welcome a system that would allow for quicker adjustments and updates to be incorporated into the curriculum and for them to be given a greater role in the planning and development of curriculum on an on-going basis. An example is the need for the curriculum of the Motor Industry apprentices to be updated to include modules on Hybrid vehicles, Electrical Vehicles, hydraulics etc. Those within national agency which is given responsibility for curriculum development should work closely with industry to ensure that apprentices are offered training that will provide them with the knowledge skills and competencies that meet the current requirements of industry and the labour market. Assessment 2.7 Assessment during all phases should be independently checked and evaluated. Currently Employers have the responsibility for signing off on the on-the-job phases. The current systems relies on Employers to sign off on the progress of the apprentice in achieving an acceptable standard at the end of each of the on the job phase. Whereas the needs and expectations of the Employer in relation to the apprentice s progress are crucial, the potential for inconsistencies and differing standards exist because the previously identified need to support Employer in this role through provision of specific training for end of phase assessment/evaluation.
Even without this it should be underlined that the current system has still produced a national qualification that is significantly more consistent across all of the employments and training centres/colleges in the sector than our knowledge of the apprenticeship systems in other member states. The current system requires the Employer of an apprentice to have a senior craftsperson to act as a mentor for the development of the apprentice and we agree and support the view that it is a key element to the development of the apprentice. There have been discussions over a long period in relation to the benefits of training for such mentoring crafts persons to improve this aspect of their role and to ensure even greater consistency in the system, whereas we strongly support this view some proposals that suggested training with a duration of many weeks at a cost to the Employer are not an appropriate or acceptable proposition particularly in the current climate. Awards/Credits One of the benefits of the current system is that it is a National Qualification that can be recognised for the standards achieved by apprentices who have been awarded it no matter where they have worked or what training centre they have attended. While we would clearly not want to lose the consistency and high standards achieved there is the issue of apprentices who may not complete their apprenticeship and who thereafter have no potential to have the modules and phases which they have successfully completed recognised officially in any way. There is a strong focus currently on the concept of recognition of prior learning, indeed the SIMI have been involved in a number of EU projects in relation to ECVET European Credits in Vocational Education and Training. The current situation where achievements below the full qualification are not officially credited goes against current thinking which supports recognition for learning outcomes achieved even if the full qualification has not been awarded and we believe that credits or certification of modules in line with the ECVET principles should be implemented, which aims to give people greater control over their individual learning experiences and make it more attractive to move between different countries and different learning environments. The system aims to facilitate the validation, recognition and accumulation of work-related skills and knowledge acquired during a stay in another country or in different situations. It should ensure that these experiences contribute to vocational qualifications. Delivery of Training 2.8 Block Release - Balance between On and Off the Job The majority of Motor Industry Employers consider that the Off-the-job training phases are too long, in particular Phase 2 when apprentices spend 20 weeks in a Training Centre (FAS) during the first year of their apprenticeship. While many would favour a return to Day-release we appreciate that this may not be practicable from the point of view of the best use of training centre and college resources. However there is a growing view that Employers and apprentices would benefit significantly if the apprentices were in a position to return to the workplace one day a week during off the job phases. This would help to maintain and strengthen the relationship between Employer and apprentice and keep the apprentice in touch with the reality of day-to-day activity in the workplace.
Timing of the Off- the- job training The business cycle of the Motor Industry is traditionally subject to seasonal fluctuations, with almost 60% of their business being done within the first quarter of the year when the majority of new car sales are transacted and trade-in vehicles are taken into stock. It is important that consideration is given to ensure that apprentices are not called for off-the-job training during these periods. As this is such a crucial time for the industry is really is not appropriate that motor industry apprentices should be scheduled for off-the-job training during these periods. Accessibility of off-the-job training Many Employers have reported that their apprentices are called to undertake their off-the-job phases in Training centres at great distances from their home base, even when there is a suitable training centre closer to their employment/home. The location of off-the-job training centres should as far as possible be evenly spread across the country. Duration of Apprenticeship Employers in the Motor Industry have no issue with the current minimum of 4 years for completion of an apprenticeship, however consideration should be given to individuals who successfully complete all phases and demonstrate the required competency levels in less than 4 years to be awarded to a National Craft Certificate. Distance Learning and Web based Training Motor Industry would be open to an increased supported level of web based training for apprentices and distance learning should be a feature of apprenticeship. Providers 2.9. Standards of Facilities, Equipment and Trainers in Training Centres Trainers: For many years the Motor Industry, primarily through the Distributor/Manufacturer networks, has been involved on an ad hoc basis in supporting trainers within the apprenticeship system (FÁS Trainers and Trainers in the Institutes of Technology) through for example, their sharing of their technical data and invitations to trainers to attend Manufacturers in-house training courses. The Industry would strongly support the introduction of a formal platform that would allow the Industry to collaborate more closely in the development and up-skilling of trainers who deliver training to Industry apprentices. Criticism is sometimes levelled at trainers who have not been given the opportunity to complete up-skilling training courses to keep abreast with advances in new vehicle technology and we believe the Industry can assist in solving this issue.
Equipment and Facilities One of the most frequent complaints in the Industry and particularly Vehicle Manufacturers, who are constantly involved in the delivery of new technology training in all the vehicle ranges, is the apparent inability of the National training system to keep pace with the speed of change of vehicle technology. This can be the case in relation to the knowledge of trainer and in relation to the equipment and vehicles used for training in colleges and training centres. In some members states the Vehicle Manufacturers are more closely engaged with the apprenticeship training system and therefore are more utilised as a resource in relation to both vehicle technology and the development of the knowledge and expertise of the trainers. The challenge in relation to the pace of changes in our sector is recognised by national training agencies across Europe and there needs to be a specific strategy in place to ensure that our apprentices are trained on the most up to date current technology rather than on vehicles that reflect an earlier time. Economy 2.10 Individuals who successfully complete an apprenticeship in the Motor Industry are likely to have a career for life and have the skills to progress to higher levels. While there are costs initially to the State, these are outweighed by the added benefit to the economy in the long run as those who hold a National Craft Certificate are usually guaranteed employment and will contribute to the economy through PRSI etc. Even in a time of a downturn in the economy when there are shortages of work the transferable skills of the Motor Mechanic can be utilised in other sectors in Ireland, for example IT sector and aircraft industry. Similarly in the event that emigration is the only option they have a transferable and recognised skill which will allow them to support themselves in another country if they so choose. In the context of the economic value to the state of the investment in the training of craft workers it is estimated that the service and repair business in professional and legitimate garages in Ireland is somewhere between ¾ and one Billion Euros per annum. The cost-benefit of properly maintained vehicles in the context of reduced road deaths and the reduction in serious injuries following road traffic accidents injuries should not be underestimated. In Ireland, rectification, service or repair work on vehicles is not subject to any legislative control in relation to the qualifications of the person undertaking the work, despite the significant potential risks in relation to death or serious injury if such work is improperly completed. This contrasts with the situation in relation to connecting both electricity and gas to homes, business premises etc. The only requirement to have a National Craft Certificate qualification, as a Motor mechanic, is in fact to be appointed as a Commercial Vehicle Tester under the RSA. And yet even in this situation the vast majority of people undertaking vehicle servicing, at least in legitimate businesses, are qualified motor mechanics. Both the qualification and the skills/productivity of those who have come through the current system are recognised and valued in the Sector. Although there is no current legislative requirement in relation to who may interfere with or work on a vehicle, even commercially, if such a requirement were ever considered necessary it could be readily implemented because the current system has delivered crafts persons to a consistent and recognised standard over the years. In Europe there are currently on-going discussions in relation implementation of further changes to the Periodic Technical Inspection regimes (vehicle testing). It
would be a very short-sighted policy if Ireland reduced or removed the developed apprenticeship infrastructure, with the singular aim of economising in the current economic downturn. We believe it would be a hugely retrograde step and one that would devalue what has been achieved and would be a matter of regret in the future. In conclusion, SIMI would thank the Department of Education and Skills for invitation to make this submission to the Apprenticeship Review Panel and we remain available to expand on any of the issues raised here.