The asbestos training architecture is fixed by legislation, but with the new year upon us, is this going to remain the case? For those of us with possibly too much time on our hands it is becoming increasingly obvious that huge changes are coming our way and it is all being done by stealth.
Everyone is familiar with how it is at the moment:
Three day New Operative/Supervisor course followed by an annual refresher every year. This is mandated by Regulation 10 of the Control of Asbestos Regulations and it has been ever thus. However the standards of the training courses are often less than we would like.
Single class refresher training by large providers for multiple clients can not possibly provide the tailored approach required and can degenerate into an off the peg approach that most can sleep through and still ‘pass’.
Then there are the corrupt organisations that we’ve all heard about – where if you turn up to collect your certificate you are the star pupil.
Some of the smaller independents make a good stab at a bespoke course, but are hampered because they are never provided with detailed Training Needs Analysis (TNAs) by the client.
With some considerable justification the HSE are dissatisfied with the quality of training that has been churned out over the years. Where do we go from this not very satisfactory state?
Whilst change is needed, the drive for change is producing unfocused solutions and a great deal of vested interest.
The method by which change is coming about is the root of the problem – the vexing phrase ‘competence’. This has been a commonly used but little understood phrase in the industry for a decade or more. It is now being used to sneak in the transformation with precious little consultation and less representation by those affected. And because it is little understood, the solutions could be missing the mark.
Lets first explore where the change is coming from.
The Approved Code of Practice (L143 – the ACoP) tells us:
Para 40
Any reference in this document to competence, competent persons or competent employees is a reference to a person or employee who has received adequate information, instruction and training for the task being
Innocuous enough.
However;
Para 226 extends this with the following:
… and can demonstrate an adequate and up-to-date understanding of the work, required control measures and appropriate law.
“And can demonstrate” – leads an employer to ask how can the employee demonstrate this, when must they demonstrate it – all of the time? Annually? … And how can we as employers be confident that they can demonstrate it?
Para 227 then hits us with – ‘A training course on its own will not make an employee competent’.
Where on earth does that leave us? A situation where the only guidance available is for formal set-piece training courses, but then the ACoP tells us that it isn’t good enough – and then doesn’t help us with how!
Big changes are coming that without careful planning may cost a lot of people a lot of money. Licensed Contractors, employees, clients and trainers themselves will all be affected. The shifting landscape may very well destroy the latter.
Next time – what form the change is taking – unless we’re very careful!
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