8 April 2011

Department of Education, Employment and Workplace Relations

RE: FEEDBACK AND RESPONSE ‘A SHARED RESPONSIBILITY - APPRENTICESHIPS FOR THE 21ST CENTURY’

The Master Plumbers’ and Mechanical Services Association of Australia (MPMSAA) is a registered national employer organisation providing representation and extensive services for a broad base of members in the plumbing and mechanical services sectors. The principal activities of the Associationare to provide business services, industry representation, training and advice on industrial relations and employment to the membership. Our members represent a powerful and reputable group to lobby government in support of various plumbing, business and environmental recommendations.

MPMSAA is a strong supporter of the apprenticeship training system as an effective means of developing work based skills. As such, MPMSAA commends the Department of Education, Employment and Workplace Relations for commissioning this expert panel to review the Australian Apprenticeship system. Reviews of this nature focus attention on the apprenticeship system which will work to refine and improve it for employers and apprentices alike.

MPMSAA welcomes the opportunity to respond to the 14 broad recommendations made by the expert panel in the report ‘A shared responsibility, Apprenticeships for the 21st Century’. Given our business operation, MPMSAA provides the following comments from the perspective of the plumbing industry. Naturally we cannot comment on issues that may affect other industry sector apprenticeship or traineeships in different ways.

Please do not hesitate to contact MPMSAA should further information on our submission be required.

Ken Gardner

Chief Executive Officer

03 9321 0701

‘A shared responsibility - Apprenticeships for the 21st Century’

Feedback and response from the Master Plumbers’ and Mechanical Services Association of Australia (MPMSAA)

Recommendation 1 - Establishment of National Custodian

MPMSAA supports the concept of a federal framework that removes duplication and confusion from the Australian Apprenticeship system. However, we have significant concerns that the establishment of a National Custodian will actually result in a further layer of bureaucracy on top of the state jurisdictions rather than a more streamlined approach. We note that ANTA was not able to achieve such an outcome.

Recommendation 2 - Clarify and consolidate stakeholder roles and responsibilities

MPMSAA offers in principle support for this recommendation. The Australian Apprenticeship system would certainly benefit from clarification of stakeholders’ roles. However, significantly more consultation is required to identify how this would occur, who would be responsible and how it would be funded.

Recommendation 3 - Employer accreditation

MPMSAA opposes this recommendation. Unfortunately the inappropriate actions of a small number of unsuitable employers mar the system for the majority of employers who ‘do the right thing’ by their apprentices. We believe an employer accreditation system would create another barrier to all employers and may actually dissuade some employers from participating further. MPMSAA also queries which body would be qualified to manage and police such a system.

Recommendation 4 - Structure support for employers of eligible apprentices

MPMSAA offers in principle support for this recommendation. MPMSAA acknowledges that the availability of good mentoring support and pastoral care have a positive impact on apprentices. We also acknowledge that employers will require support mechanismsand/or training in order to provide mentoring and pastoral care to their apprentices. We note that this recommendation relates to employers of ‘eligible’ apprentices based on the Specialised Occupations List of which plumbing is one.

Recommendation 5 - Redirect employer incentives to support services

MPMSAA strongly opposes this recommendation. Incentives are an important enticement for employers to engage apprentices. MPMSAA does note that the development of structured support services for employers and apprentices would be beneficial to stakeholders (noted above) but this should be funded by sources other than redirecting employer incentives.

Recommendation 6 - Employer contribution scheme

MPMSAA strongly opposes this recommendation. This will be viewed by employers as a tax and a burden on their business, particularly in the early stages of an apprenticeship when an apprentice is less productive in the workplace. We believe this would dissuade many employers from participating in apprenticeship training.

Recommendation 7 - Flexible approach to training during periods of economic downturn

MPMSAA sees merit in this recommendation. However, MPMSAA stresses that the value of the apprenticeship system is in the development of workplace skill and competency in conjunction with theoretical learning. A system that allows more flexible off the job training at times of economic downturn would be acceptable so long as adequate time is allowed to develop and assess workplace competence once the apprentice returns to work. This strategy would require excellent communication between employers and RTOs to achieve the necessary flexibility. It would also require close monitoring by industry stakeholders to ensure it is used judiciously and managed effectively.

MPMSAA does not support a ‘front loaded’ apprenticeship training system which might see apprentices complete all their off the job training in an upfront block and then commence workplace training.

Recommendation 8 - Regulate quality of VET in Schools programs

In a perfect world the AQTF and associated audit processes should be a sufficient regulator of quality apprenticeship training and delivery within the school sector. However, the significant level of concern expressed by industry in the lack of consistency or quality outcomes from VETiS programs indicates that the AQTF is inadequate. MPMSAA doubts that developing an additional regulatory framework for quality in VETiS would work either. The system requires redesigning not additional regulation.

MPMSAA supports the development of pathways that will encourage the participation of new entrants in the plumbing sector whether these are young people, non traditional learners or those seeking career change. Our views are provided here.

  • MPMSAA does not support the use of School Based Apprenticeships as a pathway in the plumbing sector. These programs do not provide the apprentice with sufficient workplace exposure to adequately develop workplace competence. The nature of the program results in disjointed school based learning, trade training and workplace skill development which does not benefit the employer or the apprentice.
  • MPMSAA does not support the use of any qualification as a preapprenticeship pathway in the plumbing sector that provides direct credit transfer of units of competence from the Certificate III in Plumbing and Services (apprenticeship qualification). A preapprentice is not employed under a contract of training and therefore does not have a workplace, without which they cannot develop workplace competence. A preapprentice cannot therefore be assessed as competent in these units.
  • MPMSAA does support the development of a national plumbing preapprenticeship qualification that does not use Certificate III units of competence but offers skill and knowledge development that aligns with the apprenticeship. MPMSAA recently chaired the industry led development of the Victorian 22138VIC Certificate II in Plumbing (Preapprenticeship) which follows this model.

Recommendation 9 - Define preapprenticeship/prevocational training

MPMSAA does not view this recommendation as a high priority.

MPMSAA understands the term prevocational to refer to generic, foundation style training programs that prepare an individual for further training or general work. It includes details of a variety of industry career choices (possibly industry taster programs), basic employability skills, literacy and numeracy skills as well as training in general work skills and practices.

MPMSAA understands the term preapprenticeship to refer to qualifications that provide initial training and assessment in a particular industry or occupation. This includes skill and knowledge development to ensure the learner is ‘job ready’ for the industry they have chosen. A learner who completes a preapprenticeship may be eligible for advanced standing in an apprenticeship through an RPL process.

Recommendation 10 – Additional support services

MPMSAA supports this recommendation to improve the participation of disadvantaged learners in the plumbing sector.

Recommendation 11 – Market promotion

MPMSAA supports this recommendation for the trade apprenticeship system in general. MPMSAA notes that plumbing is in the fortunate position of being a highly popular career choice for learners. It experiences good levels of enrolments and excellent completion rates. This is due in part to it being a regulated industry.

MPMSAA would support the further education of careers teachers in the secondary system so they have a much improved understanding of the opportunities for career pathways and advancement in the building and construction industry in general and the plumbing industry in particular.

Recommendation 12 - CBC and competency wage progression

MPMSAA does not support a competency based completion (CBC) system in the plumbing sector. At this time, MPMSAA is concerned that this system is simply seen as a means of ‘fast tracking’ apprentices and potentially undermining the quality of the apprenticeship outcomes. There is considerable scepticism in the industry that this system will do anything to reduce skill shortages and it is not yet clear how the process will be implemented and adequately monitored. Employers have also expressed concern at the reduced return they may receive on their investment in training an apprentice if the apprentice completes early and seeks full wages.

MPMSAA believe that workplace skill and competence develops over time in a workplace as the individual matures personally and professionally. An apprentice may have completed their off the job theoretical training component satisfactorily but require additional supervised time in the workplace to fully integrate these skills to the level acceptable of a tradesperson. Generally this occurs in the fourth year of an apprenticeship and may take longer. MPMSAA acknowledges that a mature aged apprentice with existing life skills may be able to develop and demonstrate these skills more quickly. An early release process is already in place for these individuals with agreement from the employer.

MPMSAA does not support the introduction of a competency based wage progression system in the plumbing sector at this time.

Recommendation 13 – Improved RPL

The RPL system is based on the premise that individuals gain skills and knowledge from a variety of sources that should be recognised when they seek to undertake training. MPMSAA supports the concept of RPL in principle. However, given that plumbing is a regulated trade, is it unlikely that learning participants will front for RPL consideration in plumbing specific skills? The exception will be learners who complete a preapprenticeship qualification. These participants will be eligible to have their skills and knowledge recognised against the apprenticeship qualification on an individual basis. Note that undertaking an RPL may result in the reduction of off the job training requirements but will not reduce the contract of training period of an apprenticeship.

Recommendation 14 – Wage review by Fair Work Australia

MPMSAA does not believe that it is the role of the expert panel on apprenticeships to comment on wage reviews.

In closing, MPMSAA strongly refutes the figures expressed for construction apprenticeship completion rates as detailed in the expert report. Ideally, the different sectors of construction should be shown separately because plumbing apprenticeship completion rates in particular, are known to be high due to the regulated nature of the trade. MPMSAA acknowledges that the expert panel comment that the current system of tracking apprentice movement between employers is imperfect. However, this has been a known issue for some years and it has still not been rectified. It is considered inappropriate and misleading to use data that is known to be flawed in a report of this nature. It is hoped that the introduction of the unique student number identifier will go some way to improving this situation in the future.

THE MASTER PLUMBERS’ AND MECHANICAL SERVICES ASSOCIATION OF AUSTRALIA

525 KING ST WESTMELBOURNE 3003

PHONE: 03 9329 9622 FACSIMILE: 03 9329 5060

e-mail: info@mpmsaa,org.au