A client contaced me this week with the following questions after they reviewed their current training requirements and found:
- Training Requirements for Confined Space & Work Safely At Height -The majority of persons last had ‘accredited’ training conducted by MSS in 2020.
- Some of their older records showed a three year expiry
- Client Cards issued by MSS states a date of completion but does not state an expiry date.
- What is the interval for training or refresher training?
- Is it possible to conduct their own internal refresher as part of our training program?
My response to the client included the following:
- Actual units of competency don’t expire until the training package changes, usually around 3-5 years – Few units of competency have specific time frames for refresher, typically CPR & Breathing Apparatus – at least every 12 months
- Confined Spaces, Height, BA, Dangerous goods etc – no expiry can be listed (I have seen some providers that put an expiry date on, this contravenes the training act)
- Other guidance on frequency comes from the WHS Regs, at appropriate intervals or as required… the requirement is: the more complex or hazardous the task, the more frequent the training. For example, Confined Spaces/ Heights – accepted industry standard is formalised training at least every two years. A court of law considers someone who hasn’t completed a task in more than 6 months to be potentially no longer competent, particularly in high risk settings and activities.
- Guidance from Insurers:
- Return to Work SA require no more than two year intervals between training. Even if you are self-insured, you will find these to be required every two years in most cases. It is worth checking with your own insurers, I think you will be surprised.
- Internal Refreshers: This is a really problematic area. A number of questions arise.
- Is the person qualified to assess? A current Cert IV in Training & Assessment plus the current individual units
- Who will issue documentation? Only a registered training organisation (RTO) can issue Statement of Attainment “Competency” documents, an assessor, even when equipped with the relevant TAE, cannot. So no formal recognised certification can be issued by a non-RTO.
- The ‘Card’ is only a facsimile of the actual Statement of Attainment for convenience.
- Course Materials – are these up to date, current with best industry practices? WHS Regulations, industry requirements.
- Are records kept of updates and revisions to training materials?
- Are training materials independently peer reviewed after each modification to ensure accuracy, conformity and compliance with current requirements.
- Who will accept the responsibility for the training provided? The responsibility rests with the person conducting training AND the company. The trainer tacitly accepts personal responsibility as there is no RTO to offset this to.
- Are you insured to do this? You have to remember that when you provide internal training, the trainer & the company assume responsibility for the outcomes. It would be tragic to find that your insurers would not pay out due to this loophole.
So, can you see the argument for outsourcing?
As an RTO we are under constant scrutiny to remain up to date, to stay current with ever changing legislation, technology and industry best practices.
We are required to ensure we have proper insurance to a minimum of $20M per incident.
Our trainers are required to continuously maintain their own professional development, under taking rertraining in each subject to at least the level they teach.
I was in training myself this week for three days updating my own certs (in subjects I actually wrote the course for… go figure!!)
If you have any questions around this, please dont hesitate to reach out. We are here to help.