3rd May 2018 at 2:22 pm #66192
At the beginning of this year a “circular” was widely distributed regarding supposed First Aid training accreditation and DoL Approval. This “circular” intimated that First Aid training providers required either HWSETA or QCTO accreditation, and that First Aid training could only be offered in Skills Programme packages, as opposed to the current practice of offering individual unit standards for each of the three levels.
The real problem stemmed from the widespread distribution of this “circular” without any verification of the content. It originated from an HWSETA training provider and was then subsequently spread by a number of industry related associations who failed to verify the subject matter, but perhaps unwittingly, lent this “circular” credibility by further distributing it.
Essentially the “circular” indicated that First Aid training providers could only be HWSETA or QCTO accredited in order to receive DoL Approval. This was in fact a misrepresentation, as the Regulation to which they referred has been amended to accommodate accreditation with any SETA which retains quality assurance responsibilities for First Aid unit standards. The following issues raised included the requirement that First Aid had to be trained in a “skills programme” format among others.
What the author of this “circular” neglected to add, whether by intent or otherwise, was that a training provider accredited with another SETA would not be subject to the same requirements. There are a number of other SETA’s who have the First Aid unit standards within their scope, and are equally entitled to accredit training providers for these. DoL amended the 2016 Regulation, which required HWSETA accreditation, to permit all SETA accredited providers to apply to DoL for First Aid Approval.
It is interesting that the “circular” referred to QCTO accreditation, but this cannot be obtained until QCTO have a registered Occupational Qualification on their database. As there is no First Aid Qualification listed yet, this QCTO accreditation does not currently exist. It is also interesting to note that the Regulation requires a training provider to be accredited by a body delegated that function by QCTO. Nowhere does it require QCTO accreditation, and in fact direct QCTO accreditation is not acceptable under the present terminology in order to achieve DoL Approval!
On a lighter note, and in confirmation of the misleading nature of the “circular”, in the last month I have had two TETA accredited training providers who have been visited and Approved for individual First Aid unit standards by DoL. There are a number of other SETA’s who have providers accredited for First Aid unit standards who should apply now to DoL for Approval as required by the Regulation.
Lesson to be learnt here for all of us – verify information before launching a storm!
3rd May 2018 at 2:50 pm #66195
3rd May 2018 at 3:42 pm #66199
I am one of the originators of one of the articles. The other is Graham Kent Pearson, chairperson of SHASTAC.
Do not be misled into thinking that all the SETAs can provide the required accreditation for Dol Approval of GSR 3 First Aid Training Providers.
The confusion caused as a result of the Chief Inspector’s 3 NOTICES [the last one being NO. 1463 22 DECEMBER 2017 AMENDED NOTICE OF DIRECTION IN TERMS OF SECTION 27(2) OF THE OCCUPATIONAL HEALTH AND SAFETY ACT, READ WITH REGULATION 3(4) OF THE GENERAL SAFETY REGULATIONS] has culminated in Saiosh http://www.saiosh.co.za forming a sub-committee [known as SHASTAC], in order to delay the stipulated requirements until authoritative clarity is gained.
An OH&S Act Section 40 request for exemption from the NOTICES can also be lodged with the Minister of Labour.
Should you wish to read my article, please let me have your request via email. My email address is email@example.com
3rd May 2018 at 4:14 pm #66201
Why thank you Ken,
I do believe however, that the confusion has been caused by somewhat hysterical reaction as a result of misunderstanding of the content of the regulation and the structure of our training system. Your article contains many inaccuracies with regard to the requirements of accreditation, registration etc. and is generally based on conjecture.
As to being misled, I believe that recent actual Approvals given to providers with other SETA’s is sufficient evidence of my point? Perhaps you missed that one?
3rd May 2018 at 4:49 pm #66202
I was the person that wrote the “circular”. It must be understood that the “circular” was intended to be distributed to my clients and thus was written from my POV and my business relationship with them. Thus outside parties not having a business relationship with me would see the document in a completely different light and this is where people missed the bus.
SAIOSH (www.saiosh.co.za) has now formed the Saiosh Health and Safety Training Advisory Committee (SHASTAC) which will become a stakeholder in the Health and Safety Training environment and be able to represent training providers and be a professional representative. SHASTAC has already sent representation to the Chief Inspector and requested a meeting with the CI and QCTO. Once official clarity is gained updated notices from an industry point of view and not just one business will be issued. I hope this clarifies what happened and is happening!
4th May 2018 at 8:47 am #66209
Thank you Graham, that was the impression I held and why I found it strange that related associations subsequently re-distributed it without confirming the details and clarifying the circumstances under which it was written. The general impression created by this re-distribution among accredited providers for First Aid unit standards with other SETA’s was particularly negative.
As an indication of the number of training providers accredited for First Aid unit standards with other SETA’s, TETA alone lists 107 providers for 119567, with 394 registered assessors and 178 moderators. The SAQA website for this unit standard lists 231 accredited providers, which unfortunately is not altogether accurate as many of the SETA’s do not keep the data up to date. There are 8 other SETA ETQA’s who have this unit standard within their scope, so a global figure of 400 accredited providers for this unit standard may well be conservative.
If this will be of any help, at a meeting on 26 April last year, with DoL, the SETA’s and others from SAQA, DHET and QCTO, some of the resolutions reached, among others are:
· The DoL will sign MOUs with all the relevant ETQAs;
· The DoL will regulate the compliance issues of First Aiders;
· The ETQAs will be responsible for the accreditation, monitoring, managing refresher and registrations/re-registrations of First Aiders;
· The relevant ETQAs will accept applications and not turn applicants away, but will wait for the amended memo from the DoL before they approve these applications;
With the reports that I have received from providers who have recently been Approved by DoL for First Aid training, it would appear that these DoL MoU’s with the relevant SETA’s have been concluded.
I applaud your efforts in establishing SHASTAC and agree that such bodies are important in maintaining standards within individual sectors.
3rd May 2018 at 5:57 pm #66203
Hi Nigel. Thanks for taking the time to respond.
I respectfully ask whether you read my article?
The OHS and FA training industry are admittedly relatively new to the Accreditation landscape, but not new to interpretation of legal requirements.
We have sought and been advised on some of the issues and are exercising our right to debate, disagree or demand change where necessary. This is one of those areas.
Amongst others debateable issues, the latest CI’s NOTICE says:
“accompanied by a valid accreditation document issued by the Quality Assurance Body that has been delegated the quality assurance responsibilities for First aid unit standards by the Quality Council for Trades & Occupations (QCTO), established in terms of section 261 (1) of the Skills Development Amendment Act, 2008, AND HAS BEEN AUTHORISED BY THE CHIEF INSPECTOR TO CARRY OUT SUCH ACCREDITATION”.
We await “THE CHIEF INSPECTOR’S WRITTEN AUTHORISATION OF THE QAB/S TO CARRY OUT SUCH ACCREDITATION.
Well, either which way, we are now represented by Saiosh and will see the direction our discussions take.
4th May 2018 at 9:49 am #66212
Naturally I read your article. However, if you refer to my reply to Graham, you will find that I have background knowledge of this issue that extends well before the beginning of this year. And while you may have some experience in legal interpretations, in this instance, knowledge of the area in which such interpretations are made is required. You admit the FA and OHS training industry is “relatively new to the Accreditation landscape”.
My question is why is this relatively new? SAQA processes have been in place for almost 20 years now and there are literally hundreds of providers already accredited for various FA and OHS training, including DoL Approval. These providers have gone to the trouble and cost of achieving accreditation but are seriously disadvantaged by non-accredited providers costing that obviously does not carry the costs of quality assurance.
Your article unnecessarily spreads doom and gloom over a process which thousands of training providers have already proven to be attainable. The message I read is “less control”. In a country where we presently suffer as a result of a lack of controls, you are advocating less control? You may have been out of the mainstream, but I can assure you that in the last ten years the training environment in general has suffered an ever growing number of fraudsters as a result of no control.
In an ideal world, ideals are fanciful and wondrous. While I may concur with some of your principles, in our present environment we are far removed from ideal. Above all else, there are thousands of training providers who are prepared to exhibit their credibility via quality through accreditation and financial viability through DHET Registration. By what standard then do you encourage the unaccredited to apply for exemption from DoL requirements?
It would indeed be interesting to see if SAIOSH, who are considered a pillar of compliance, via SHASTAC, will approve an uncontrolled environment.
4th May 2018 at 10:42 am #66213
Thank you for you opinions and input Nigel.
As a committee member of SHASTAC and entrepreneur of some 30 years in the OHS training arena, my opinions will not be swayed without adequate argument.
It appears as if some misanthropes have taken a stand against providers who are disadvantaged, for whatever reason. I gladly speak for those who have approached me to do so.
There appears to be an undemocratic motion by the depreciators to exclude the one-man operations, who do not have the time, resources or knowledge to navigate these hurdles.
I categorically seek inclusion, rather than exclusion, for reasons such as equality, fairness and accessibility to the market-place. The barrier to entry and right to continue under these conditions is too high and an alternative “approval” mechanism needs to be found for the lawful short-course legal compliance training providers. If not, commerce and industry loses their skills, and they lose their legitimate livelihoods.
Please re-read Pres Ramaphosa’s call for deregulation in my article. Am I to assume those commentators who side with the NOTICE, disagree with the President’s sentiments?
All of this debate while the occupational disease and injury rate patently spirals out of control.
I await the outcome of the Saiosh delegation and representation.
Nigel, you are free to engage with me personally via skype on ken_annandale
4th May 2018 at 1:26 pm #66216
Thank you Ken. This was brought into the public domain and there it shall remain. There is no misanthropy, nor is there lack of democracy. Democracy intimates majority decision making. Among the thousands of accredited training providers, I can guarantee you that a very significant percentage are one man operations. Of my own 250-300 training providers I have supported through accreditation over the last 18 years, the percentage of one man operations is around 30%. You claim to speak for “disadvantaged” providers – just how many are you speaking for? I am sure the vast majority of accredited training providers view unaccredited training providers as advantaged, most certainly in terms of unfair training pricing. Democratic?
The providers I refer to above are in the main, Lifting Machine Operator (LMO) training providers who are subject to a regulation, Driven Machinery Regulation 18(11), which has been in effect since 1993, with an additional National Code of Practice to which providers must adhere. If you read this regulation it has an alarming similarity to that of the First Aid regulation, and has been in effect for the last 25 years, with amendments. TETA lists 747 accredited training providers for unit standard 242974 Operate a counterbalance lift truck. How is it then that you claim that these one man operations are being disadvantaged when there is anything up to 240 of these one man operation LMO training providers who have achieved accreditation subject to similar yet more onerous conditions than those of First Aid training providers?
The “barriers” you are presenting are therefore far from insurmountable. There are more than sufficient accredited training providers to cater for industry and commerce training requirements. I note you make no reference to numbers in support of any of your statements, yet you make unsupported claims of the occupational disease and injury rate patently spiraling out of control.
What is apparent is that, since September 2016, there has been ample opportunity for First Aid training providers to address accreditation. Instead of addressing the issue appropriately, time has been squandered with misinterpretation, pretentious aspirations, rabble rousing and misdirection. If the rather large LMO training sector has achieved compliance with similar regulations, what makes the unaccredited First Aid training providers any different?
- This reply was modified 1 year, 2 months ago by Nigel Shipston.
4th May 2018 at 1:52 pm #66218
This discourse has been thoroughly enjoyable.
Nigel what it does do, is underpin the disconnect when it comes to training literate, semi-literate and illiterate employees in OHS and related life-support skills [as my article intimated].
I am very keen to view the demographic of those already accredited and suggest there may be certain conclusions that can be drawn.
The fact is countless aspirant [previously and currently disadvantaged] SMMEs will be barred from entering, or forced to stop serving the market because of this soon to be over-regulated sector.
Let’s see where we go after the interaction between Saiosh, DoL, QCTO, et al.
I will buy you a beer is there isn’t a positive change in sentiment towards the OHS and FA training market after the representation.
Kind regards and thanks for the interaction.
4th May 2018 at 2:26 pm #66219
Appreciated Ken, likewise! If you need any assistance with those SMME’s, please let me know. There are many ways to get them on board and you know, where there’s a will there’s a way! I didn’t spend all my time last year getting the Minister to recognise SMME’s with DHET Registration for nothing. Nor did I get grey hair working with all these authorities for nothing. My consolation is that I generally get to protect my providers.
Long distance beer offer accepted.
Have a great weekend.
9th May 2018 at 2:26 pm #66255
Thanks for comments above!
Can you please confirm (if you perhaps know that is) whether or not TETA is still accrediting providers on single unit standards? I do know you and Lynel have dealings with providers seeking accreditation. I have battled to get anyone to respond from TETA to applications since November and so far there is no response.
My understanding of QCTO newsletters to the SETA’s was that this was to end as of end March 2018.
Can you comment?
Thanks for assistance!
9th May 2018 at 3:18 pm #66256
They are still taking applications up to end June when the unit standards expire. However, you still have time to train until the last enrollment date of the unit standard, and quite possibly, if there is no QCTO replacement this will be extended. The 31 March date was the previous cut off date for SETA operations, but that has since been extended to 2020. If you need assistance you can drop me a mail at firstname.lastname@example.org.
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