DoL First Aid Providers compelled to register with HWSETA. Was this well thought through?

I am writing this in response to the “Notice in direction in terms of section 27(2) of the Occupational Health and Safety Act, read with regulation 3(4)(a) of the General Safety Regulations” given by the Minister of Labour dated the 30^th September 2016.

“Regulation Gazette No 40313, 30 September 2016, Vol 615 No 10644, Page 24”

 

In this notice the following is stated by the Minister.

“Those already registered with the Department of Labour, will after the promulgation of this notice, be granted 12 months to be accredited with HWSETA.  All service providers who fail to register within the given the period will be automatically be de-registered from the Department of Labour database and will no longer be recognized as legitimate service providers.”

 

The above raises the following “ominous” concerns and I would the Skills Universe to assist me in any way that they might be able to.

 

But let me start off with a little background information:

The National First Aid and Emergency Care Training Standards Committee was formed under the then South African Medical and Dental Council, now the Health Professions Council of South Africa , in order to establish and maintain standardisation in first aid and emergency training, particularly at the lower levels.

 

They divided existing first aid and emergency care training courses into eight (8) levels, categorised as:

• Levels 1 – 3: Basic Life Support (BLS)

• Levels 4 – 6: Intermediate Life Support (ILS)

• Levels 7 – 8: Advanced Life Support (ALS)

 

Institutions could then be approved in terms of the General Safety Regulation 3(4)(d) by the Chief Inspector to issue a valid certificate of competency in first aid.

 

The following conditions were / are in place:

• Training must be done by qualified instructors.

• The validity of the certificates issued may not exceed 3 years from the date of issue.

• Certificates must indicate the level of the course.

• Any other condition as determined by the Chief Inspector.

• The certificates of approval can be withdrawn at the discretion of the Chief Inspector.

 

Now – this new “move” raises these concerns as the current DoL courses as set out above are not unit standard based and therefore “hold no” NQF credits. 

 

1. Who aligned the current levels to unit standards?

   1. The DoL system “allows” for the learners to be “re-skilled” at least every three (3) years.  This was so that learners could stay abreast new developments in the first aid field.  An excellent example would be new procedures based on automated external defibrillators. (AED)

   2. Competency on unit standard(s) does not “run out”.  Therefore, how are you going to compel a learner to “redo” a unit standard every three (3) years?

   3. And – if you are to compel a learner to redo the same unit standard over and over, what does that imply for the rest of the unit standards, NO the whole NQF ideal of facilitating access to, mobility and progression within education and training.  

2. How was the decision reached that the HWSETA must be held accountable for accreditation?

   1. The HWSETA viewpoint (2013) was that they do not accredit single unit standards, only skills programmes and full qualifications and potential providers were advised to align to the full qualifications.  Currently their website also just shows skills programmes and full qualifications... That being stated, who will be held responsible for additional costs towards programme alignment etc? And please – the system was working, why change this now, and who stands to gain the most?

3. The “powers that be” surely must be cognisant of the fact that there are several different unit standards listed on SAQA that deals with first aid, and that these unit standards are spread out across the scopes of different SETA’s, from the MQA to the merSETA? (27+ at a glance)

   1. Why then do they not allow you to “apply” to your primary accreditation SETA for accreditation?

   2. If the SETA(s) are closed down, who will be held accountable then?  Please, do not say that this will never happen.

4. First Aid training is regarded as “compulsory training” in the South African industry.  Have they considered costing implications for both the Skills Development Provider and the businesses?

 

I’ll settle for these concerns at first.