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AUTOMOTIVE TRAINING VICTORIA (ATV)

A submission in response to the recommendations contained in the Final Report of the Expert Panel –

A Shared Responsibility – Apprenticeships for the 21st Century

The submission is made by the:Victorian Automotive Industry Training Board Inc.Level 3/464 St Kilda Road, Melbourne Vic 3004Telephone: (03)9866 1294Email: [email protected] Officer: Kevin Redfern, Executive Officer

mailto:[email protected]

ATV is the peak advisory body on all matters of training with statutory recognition under the Education & Training Reform Act 2006 to:

To prepare quality training plans detailing industry requirements, the quality and types of training needed by industry and training arrangements (within national and State strategic frameworks)

To promote training within the industry

To liaise with or participate on national industry training advisory bodies

To participate in accreditation and recognition processes

Automotive Training Victoria’s Coverage

Manufacturing

Passenger Motor Vehicle

Bus Assembly

Truck Assembly

Retail

Passenger Motor vehicle, Sports Utility Vehicle & Commercial

Road Transport

Earthmoving & Construction Equipment

Tractor & Farm Machinery

Aftermarket (Parts & Accessories)

Recreational Boating

Outdoor Power Equipment

Bicycles

SUBMISSION

The following responses encapsulate ATV’s assessment of the recommendations contained in ‘A shared responsibility-Apprenticeships for the 21st Century’ put forward by the Expert Panel.

Recommendation 1

1. Establish a National Custodian to oversee reform that will ensure Australia has a high qualityAustralian Apprenticeships system that: responds to the needs of the economy supports nationally consistent standards for employment and training of apprentices and

trainees supports high quality skill development to ensure all apprentices and trainees have well

rounded and highly respected skills required by the economy.As a first step an independent taskforce should be established to work with the eight jurisdictions to align their systems and develop a framework and process for the establishment of the National Custodian. The taskforce would be led by an independent chair and have a representative from each state and territory government, a union and an employer group.

ATV’s Response to Recommendation 1

While ATV agrees that the system of apprenticeships in Australia should be harmonised, it disagrees with the proposition that a National Custodian for Australian Apprentices should be established.

While uniformity in legislation for apprenticeship is desirable, ATV believes that this is a process which should remain the province of a Ministerial Council. The system of apprenticeship within Australia is already overly bureaucratised; consequently, the last thing that is needed is yet another layer of supervision.

Similarly, ATV disagrees with the proposition that a taskforce be established to work with the eight jurisdictions as a first step in the establishment of a National Custodian, in particular, the composition of the taskforce. The notion of an independent taskforce so called, consisting of state and territory government representatives and a sole employer and union representative to take the lead on such an important issue is naïve. To expect the various industry sectors to support the views of a single union and employer representative whose experience may be limited to totally unrelated industry sectors is unrealistic.

If the views of employers and unions are to be sought, then the representation should be at peak national level that is, the ACCI, and the ACTU.

Recommendation 2

2. Enhance the quality and effectiveness of the Australian Apprenticeships system by clarifying roles and consolidating the number of stakeholders in the system, ensuring that services are provided by the most appropriate provider, duplication of service delivery is reduced and administrative processes are streamlined. The National Custodian would ultimately be tasked with this role and will require Australian and state and territory governments – in consultation with industry, unions and other key stakeholders – to work together. In the interim the independent taskforce would progress this work.


ATV agrees that the clarification of roles and the consolidation of the number of stakeholders within the apprenticeship system are desirable. Equally the elimination of duplication within the system and the streamlining of administrative processes are supported. It is significant that this recommendation contemplates a broad consultation with industry representatives both employer and union, and, while ATV does not support the concept of a National Custodian, it does support the widest possible consultation with industry sectors. In ATV’s view, unless this level of consultation in integral to the process, any proposed reforms are unlikely to be supported.

Recommendation 3

3. Establish a formal accreditation process for the pre qualification and training of all employers of‐ apprentices and trainees to ensure a nationally consistent minimum standard of high quality employment and training is provided. In addition establish an Excellence in Employment Scheme to recognise and reward those employers who have consistently demonstrated their commitment to excellence in training apprentices and trainees.


ATV supports the concept of recognising those employers who have consistently demonstrated their commitment to excellence in training apprentices and trainees. However, ATV questions the need, to quote from the recommendation, ‘to establish a formal accreditation process for the pre-qualification and training of all employers of apprentices and trainees’. In ATV’s view, what is required is an analysis of an employer’s capacity to provide a safe and well supervised workplace, with the necessary staff and equipment needed to adequately train an apprentice or trainee. Again, as a starting point, advice from the various industry sectors as to what constitutes appropriate standards for trainee and apprentice training should be sought. ATV acknowledges that apprentices and trainees should not be placed in workplaces that cannot provide a safe environment and training provided by appropriately qualified staff. However, the level of oversight needed to ensure appropriate standards are met, should not be overly complex or intrusive. If industry is to be encouraged to offer apprenticeships or traineeships such oversight should be more appropriately the province of the particular State Training Authority with the necessary input from the specific industry sector.

Recommendation 44. Establish structured support for employers to provide high quality employment and workforce

development experiences for eligible apprentices and trainees. The focus of Australian Government support should be on assisting employers to provide high quality on the job and‐ ‐ off the job training through support services such as mentoring and pastoral care‐ ‐


ATV supports the concept of structured support for employers to provide high quality employment and workforce development experiences. However, ATV’s proviso is that such support does not take a ‘one size fits all’ approach. While mentoring and support to apprentices and trainees is important, the support from Government to employers should focus on assisting employers to provide high quality on-the job training directly, not via support services.

Recommendation 5

5. Redirect current Australian Government employer incentives to provide structured support services to eligible apprentices and trainees and their employers in occupations that are priorities for the Australian economy. While a wide range of occupations should be trained through apprenticeship and traineeship pathways, Australian Government support should focus on occupations that have tangible and enduring value for the economy – both in the traditional trades and the newer forms of apprenticeships and traineeships, such as community services, health services and information technology.


ATV reiterates its previous comment that employer incentives should be focused on direct support to employers to provide high quality training, not directed to support services. ATV agrees that Government support should focus on occupations that have tangible and enduring value to the Australian economy. However, it is also important that support is provided not only to the mainstream trades within the various industry sectors, but also to those numerically smaller but key specialised trades. As examples within the automotive sector, Automotive Electrical, Engine Reconditioning and Automotive Trimming are cases in point.

Recommendation 6

6. Reinforce the need for a shared responsibility for the Australian Apprenticeships system by establishing an Employer Contribution Scheme in which employer contributions will be matched by the Australian Government. Employers who meet defined benchmarks for training and support of eligible apprentices and trainees would have their contribution rebated, either in part or in full.


ATV queries the basis on which this recommendation is made, as no case has been made for what is apparently a re-run of the Training Guarantee Fund. It is difficult to see why industry is being asked to pay for ‘support services’ which are, in the main, community responsibilities.

Recommendation 7

7. Facilitate a cooperative and flexible approach by governments and industry bodies to allow for the continuation of both training and employment of apprentices and trainees during periods of economic downturn. Early intervention should be a key element of this approach. Support for a range of measures to be in place until economic recovery occurs could include: reduction of work hours offset by additional training increased off the job training‐ ‐ placement with other employers within the industry increased mentoring and support.


ATV broadly supports the concept of workable alternatives to enable an apprentice to continue in employment in times of economic downturn, in this context, wage assistance to employers is critical. Temporary assignment of an apprentice to another employer, while feasible, would need to be subject to strict guidelines. It would be undesirable if such assignments were used as an opportunity to poach an apprentice under the guise of providing assistance. The ability for businesses to retain apprentices under more flexible work arrangements that enable the successful completion of an apprenticeship during economic downturns should a priority for the industrial parties.

Recommendation 8

8. Formally regulate the quality of VET in Schools within the VET system to enhance the consistency and quality of training across all jurisdictions and to recognise the potential of VET in Schools as a pathway into an apprenticeship or traineeship.


VET in schools programs should conform to the same regulatory requirements demanded of other VET providers. In order to meet this requirement however, increased funding will be necessary, as will a much closer level of consultation with industry bodies as well as individual employers. A school seeking to maintain an effective pre-apprenticeship program must strike a balance in negotiating work placements in conjunction with local employers while addressing in broad terms the needs of various industry sectors. In order for a school to do this, an understanding of industry trends, and the technologies used by industry is a must.

If schools are to effectively deliver pre-apprenticeship programs there must be adequate levels of equipment and staffing available within the individual school. Equally, a student seeking to enter a pre-apprenticeship program must have the capacity to advance to an apprenticeship. That is, the student must possess the requisite skills in mathematics and English. Consequently, enthusiastic Careers Teachers who have a good understanding of a range of industry sectors, and the opportunities they offer, are a key part of successful pre-apprenticeship programs.

Recommendation 9

9. Increase national consistency in preparatory training by directing the National Quality Council to develop definitions for pre apprenticeship and pre vocational training‐ ‐


If consistency is sought in preparatory training by directing the NQC to develop definitions for pre-apprenticeship and pre-vocational programs, then clear links to industry Training Packages are required. Similarly, a high level of consultation with employers on the content of pre-apprenticeship and pre-vocational training combined with quality delivery is far more important than a set of definitions developed in isolation. Uniform content in line with employer needs and the provision of programs that will assist young people gain employment are the key. It is difficult to see why these basics would not apply to all young people whatever their background, if, as reflected in the Paper, foundation skills are an issue. Consequently, it is difficult to see how a uniform definition developed by the NQC will assist.

Recommendation 10

10. Provide additional support for apprentices and trainees who face specific challenges, such as: Indigenous Australians disability located in regional or remote Australia having poor language, literacy and numeracy skills.Australian Government support will be provided to these apprentices, trainees and their employers to assist in overcoming barriers to participation and completion of their apprenticeship or traineeship. Support will be through the provision of tailored structured support services and the continuation of some current Australian Government employer incentives.


ATV supports the concept of additional support for indigenous, regional and disabled groups. However, ATV believes support for these groups should be by way of programs that will facilitate entry to an apprenticeship by those groups. The ‘work’ of providing appropriate support for those groups needs to be done first, not after an apprenticeship has commenced, particularly so in the case of individuals experiencing difficulties in LLN.

Recommendation 11

11. Implement a strategy to raise the status of apprenticeships and traineeships including promotion as a valued career choice for both males and females. This should be led by the Australian Government, in consultation with state and territory governments, industry bodies and unions. The National Custodian, when established will lead the ongoing effort to raise the status of apprentices and trainees.


Despite all the effort that has gone into attracting young men and women into apprenticeships, a very inaccurate picture of opportunities within the trades is still painted by secondary school careers teachers, who, apart from parents or guardians, are in a position to significantly influence the direction a young person takes in choosing a career. Whether this is done on the basis of a bias towards tertiary education or because of a lack of understanding of industry sectors on the careers teacher’s part makes little difference, as the result is the same-namely to discourage young people entering a trade.

In terms of attracting young people to consider a trade as a career starting point, the work of promotion is probably best left to industry to tell young people factually what an apprenticeship is all about. If Government wishes to support apprenticeships then it should assist industry associations and training bodies to get the message across.

As a consequence, the recommendation that the National Custodian should be involved in promoting apprenticeships is not supported by ATV.

Recommendation 12

12. Promote a culture of competency based progression in apprenticeships and traineeships, in partnership with industry bodies and employers. Additionally, a greater acceptance and achievement of competency based wage and training progression should be supported by all ‐stakeholders.


The COAG decision taken some years ago to shift to a competency based progression regime has been effectively undermined by some RTOs, who too often, have automatically equated competency based completions with a shorter term, usually three years. The same RTOs have not adequately consulted employers on the development of an appropriate Training Plan and have failed to work closely with employers in ensuring that an apprentice has achieved levels of real competency.

ATV is supportive of competency based completions that are based on a Training Plan that properly reflects the needs of a particular business and supports training progression that matches the capability of an individual apprentice together with regular and comprehensive assessments undertaken jointly by the employer and the RTO.

Competency based progression does not mean pushing an apprentice through regardless of achievement of real competency and presently it is too easy for an RTO to do this. If employers are to accept that competency based completions are the way forward, then employers are entitled to expect that apprentice training is done in partnership with an RTO who is prepared to ensure that a Training Plan meets the needs of a particular business and that the off the job training provided is comprehensive and assessments undertaken by the RTO are soundly based.

While acknowledging that employers are not presently particularly supportive of competency based progression, there has been insufficient support provided to industry associations and training boards to educate employers on both their rights and obligations in term of competency based apprentice training. CBP will be successful when it is based on effective partnerships between employers and RTOs.

Recommendation 13

13. Improve the implementation of Recognition of Prior Learning and Recognition of Current Competence and support provisions for such recognition in modern awards to ensure that flexibility and mobility are supported.


ATV supports the implementation of Recognition of Prior Learning and Recognition of Current Competence. However, ATV believes Australia has a long way to travel in terms of full implementation of RPL and RCC. Currently, there is a lack of uniformity in terms of assessing RPL and RCC between Training Providers. Employers are not well informed about the process and individuals seeking RPL assessments are often confused by the varying approaches and costs adopted by the particular assessing body when undertaking an RPL assessment. However, these issues have little to do with the IR system and it is doubtful that introducing award provisions that attempt to deal with RPL/RCC will assist while there is no uniform approach in assessing RPL and RCC. If it is a question of wage adjustment involving RCC and RPL then the adjustment must have a sound base that is accepted by the industrial parties.

Recommendation 14

14. Support a review of apprenticeship and traineeship provisions, wages and conditions by Fair Work Australia, considering: the removal of barriers to competency based wage progression in modern awards apprentice and trainee award pay compared to going rates of pay age, diversity and circumstances of commencing apprentices and trainees allowances (travel, tools, clothing, course fees) cost to apprentices and trainees of participation in an Australian Apprenticeship part time and school based arrangements‐ ‐ recognition of pre apprenticeship and pre vocational programs‐ ‐ supervision ratios for apprentices and trainees.


ATV does not support a general review by Fair Work Australia in terms of apprenticeship and trainee provisions that address issues such as supervisory ratios, part time and school based arrangements and so on. This is not FWA’s area of expertise, and training issues should be left to authorities experienced in these areas.

The following points are ATV’s responses to the questions accompanying the Recommendations of the Expert Panel.

QUESTIONS

Q1. What support does an apprentice/trainee or employer require: a) prior to starting an apprenticeship or traineeship (including pre-apprenticeship training

or Vocational Education Training in schools)? b) commencing an apprenticeship or traineeship? c) progressing through an apprenticeship or traineeship?

ATV Response

Young people seeking an apprenticeship or traineeship must accept that unless they have achieved reasonable standards of literacy and numeracy they are unlikely to successfully complete either an apprenticeship or traineeship.

Employers must accept that they have a real obligation to ensure that the young person they select for an apprenticeship or traineeship must be provided with real opportunities to learn their chosen craft.

Prior to the commencement of an apprenticeship or traineeship, both parties must be properly informed of the obligations of each and the respective commitments they make and which continue during the Contract of Training.

Q2. There are different arrangements for Australian Apprenticeships around the country. What has been your experience in engaging with these differing arrangements?

ATV Response

The lack of consistency and the incapacity of the various training systems to take into account the needs of employers has been a barrier to employers operating in a number of States to take on an apprentice or trainee.

Q3. How is the Australian Apprenticeships system confusing? How can it be improved?

ATV Response

The system of apprenticeship has become debased there are too many semi-skilled occupations that have been given the status of a trade.

Q4 What does high quality on-the-job training for apprentices and trainees look like?

ATV Response

Proper supervision, adequate equipment and opportunities to learn based on a comprehensive training plan and a close relationship with the chosen external training providers

Q5 What is high quality off-the-job training for apprentices and trainees?

ATV Response

Access to current technology, a preparedness to ensure that fundamental principles are taught and understood and a commitment to integrity in assessing an apprentice’s true level of competence.

Q6. How can employers and Registered Training Organisations work better together to deliver high quality training?

ATV Response

Move to a relationship based on commitment, sharing of information and trust.

Q7 How can government and industry organisations support employers to provide high quality training to their apprentices/trainees?

ATV Response

Provide accurate, factual and timely information that employers can access from a single source

Q8. In a tight fiscal environment, how should the Government target assistance to the Australian Apprenticeships system to support a skilled economy?

ATV Response

Consult industry bodies on the level and type of support needed provide support to those employers who have a proven track record in providing apprenticeships.

Q9. How should disadvantaged individuals be supported to engage in an apprenticeship or traineeship?

ATV Response

Start support processes for those individuals before they seek an apprenticeship or traineeship, not when they are starting employment. Address LLN issues early and work with industry on the approaches that could assist. Don’t rely on overblown subsidies and artificial make-work schemes.

Q10. What can be done to raise the status of Australian Apprenticeships? How can stakeholders participate in raising the status?

ATV Response

Secondary schools and colleges must be required to provide proper training for careers teachers and advisers. Careers advisers must be obliged to present an accurate picture of apprenticeship as a career option.

Q11. What are the barriers to more widespread adoption of competency-based progression in apprenticeships and traineeships? How can these barriers be overcome?

ATV Response

To reduce the level of opposition to CBP, stringent obligations must be placed on training providers to work with employers in developing appropriate Training Plans and maintaining integrity in assessments throughout the Contract of Training.

Q12. The theme of the Expert Panel report is ‘shared responsibility’. How can this be achieved?

ATV Response

By restoring employers’ faith in Australia’s education and training system.

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