The minimum skill requirements for registration for both electrical and gas work are prescribed in Regulations. The EWRB and the PG&D Board have in the past examined workers on these skills. Setting and holding examinations was a key function for both boards at the time they were originally established. However, these examinations now represent duplication in assessment as ITOs have evolved to the stage where the boards can be satisfied that workers trained through the ITO competency-based system have gained the prescribed skills. Both boards have now signed Memoranda of Understanding with ITOs to remove the examination requirement.
The current requirement for electrical and gas workers to demonstrate that they are licensed to practice their occupation is sound. However, the system of training and recognising worker competency is unnecessarily inflexible and costly because specific skill requirements have been prescribed in legislation. As legislation, and the Acts in particular, are onerous and time-consuming to change, it is difficult to introduce flexibility and to ensure skill requirements are kept up to date.
The review team recommends that the level of prescriptiveness on skill requirements should be reduced. This will give training providers more flexibility to vary the technical and safety content in response to technological change or trends such as those that may become apparent in accident statistics. The review team recommends that public input into the development of competency standards relating to worker licensing should be required to ensure that public safety interests are fully addressed.
The breadth of training required to gain registration in the electrical and gas trades may be imposing unnecessary compliance costs on some employers and trainees. For example, the skills currently required of electricians by the electrical regulations are based upon the skills needed to safely rewire a house. Many electrical workers, for example some of those in the commercial sector, do not need all of these skills.
While the industry training structure allows for unit standards to be bundled together to form different qualifications, most of the current ITOs, both for gasfitting and electrical work, have not seen any particular benefit in promoting qualifications for narrower ranges of skills than those required for registration (although it is recognised that this may be due in part to the level of prescription).
It is acknowledged that electrical and gas workers may require a broad range of skills in order to be fully employed in a market as small as New Zealand. However, the PG&D Board has noted that it is difficult for trainees to gain experience in many aspects of the trade, particularly in the commercial and industrial field, because their employers tend to specialise in a narrow band of work.
The review team believes that, as long as workers can work safely, they should not be prevented from developing a narrower range of skills for specialist areas if they wish. The current breadth of training required in both the electrical and gas trades also inhibits multi-skilling. New areas of work, such as kitchen installation, increasingly require ranges of skills that cross traditional trade boundaries. There is a need for these types of skills to be defined and recognised in a way that ensures safety, but does not require workers to face unreasonable delays and hurdles or the costs of double registration.
The boards have attempted to provide some flexibility in skill recognition via special exemptions and restricted/limited licences and the cross-recognition of competencies from other trades. However, the review team believes that a simpler and more transparent system needs to be developed to enable greater specialisation and multi-skilling to develop in response to market demand.
The review team believes that this could be achieved through the ITO system. A bundle of compulsory unit standards with a heavy emphasis on safety, set at a lower level than current training requirements, could be developed as the foundation for a variety of qualifications. These qualifications could cover the traditional broad range of skills, or may focus on specialist or multi-skilled areas. The boards, in consultation with the government regulatory agencies, and with some input from the public, should be empowered to specify which qualifications they consider adequate for different classes of licensing. The boards would be required to demonstrate that safety aspects are adequately addressed by specified qualifications and can be met at reasonable cost.
Some electrical workers and union groups expressed concern that this approach would provide for a lower level of training than electrical workers receive at present and this would threaten safety. The review team's opinion is that the basic safety elements of any training should not be compromised and that the variation in training should be in the number and range of technical skills a person needs to acquire to be recognised as a skilled worker. Workers should also be made responsible for ensuring that they do not undertake work that extends beyond their level of competence.
People were also concerned that the status of the traditional trades would be eroded. However, broad trade qualifications will not be entirely replaced by narrow qualifications; workers will still be able follow traditional paths of trade training if they wish. The increased flexibility in the recognition of skills will allow narrower specialist training, which may in turn, reduce costs, both to those undergoing training and their employers.
The review team recognises the extension of the CER arrangements with Australia and the emerging alignment of the technical infrastructures of the two economies. It therefore recommends that the legislation make provision for the explicit recognition of Australian qualifications and competencies without the need for specific re-verification within New Zealand.
Both the EWRB and the review team have become aware of problems relating to these safety training requirements. These are:
- Availability of appropriate training. Those in remote areas may find it difficult and costly to comply with the requirements.
- Consistency of training offered. Although the areas to be covered are prescribed there is no control over the quality of the training. Submissions have pointed out that courses vary in length and level of difficulty and some are considered by participants to be substandard. The lack of monitoring of quality is inconsistent with the provision of other industry training via unit standards, which is monitored by the NZQA and accredited ITOs.
- Relevance of training. Anecdotal evidence suggests that some workers do not treat the safety refresher courses seriously because the courses are thought to be repetitive and not sufficiently relevant. The EWRB is of the view that it should be possible to vary the content of the safety training in response to trends, such as those identified through accident/incident reporting and auditing of electrical workers as well as training outcomes agreed to between the EWRB and Australian regulatory authorities.
The review team believes that there is a continued need for refresher safety training, particularly for workers involved in hazardous work and for refresher training in safety practices such as testing, the lack of which is a common cause of electrical accidents. The review team recommends that gas workers involved in hazardous work also be required to undertake refresher safety training. Safety training should be mandatory and this is particularly important in sectors where the requirement to employ licensed workers will be removed.
The review team recommends that, because safety training is designed to ensure the safety of the worker and the safety of the completed work, refresher safety training requirements be provided for in Regulations under the HSE Act and in other acts where appropriate. Further work will be required to develop appropriate mechanisms for monitoring compliance. One possible way in which this could be done would be to make regulations under the HSE Act similar to those that require scaffolders and commercial divers to hold certificates of competence. The regulations could require applicants for a certificate of competence to have a thorough knowledge of the hazards of the work, thorough knowledge of safe work practices, and undergo periodic training (including in first aid). The HSE Act allows for the recognition of organisations issuing certificates of competence. This could be delegated to the licensing boards or to the ITOs. The details of the training would be set out in training modules under the National Qualifications Framework and the actual delivery of safety training would be integrated with other training.
The review team considers that both the content and provision of safety training courses be reviewed. The EWRB has already called for submissions on the issue and is currently in the process of analysing the submissions received. The review team recommends that the electricity and gas ITOs, industry representatives, OSH and the other relevant government agencies work together to develop unit standards for safety training. Different unit standards may need to be developed for different sectors of industry to ensure that the content is relevant. Including the course within the National Qualifications Framework will mean that the standard of safety training will be monitored.
