A SHARED RESPONSIBILITY
APPRENTICESHIPS FOR THE 21ST CENTURY

Submitted by:

MOTOR TRADE ASSOCIATION OF SOUTH AUSTRALIA INC

LEVEL 1, 81 GREENHILL ROAD

WAYVILLE SA 5034

Telephone: (08) 8291 2000

Contact Person:

Anna Rau

Manager Legal and Workplace Relations

E:

APPRENTICESHIPS FOR THE 21ST CENTURY – A SHARED RESPONSIBILITY

FINAL REPORT OF THE EXPERT PANEL

Thank you for the opportunity to consider and comment upon the above report commissioned in July 2010 by the Hon Simon Crean, former Minister for Education.

The Motor Trade Association of South Australia (MTA) represents over 1000 membersengaged in all aspects of the retail motor trades across the State. These members are predominantly small businesses and multi-site owners (with 2000 separate sites in South Australia). Half the membership is regionally based. The retail motor trades are extremely diverse, providing consumers with a range of products from fuel, new and used cars, car parts and accessories, servicing and maintenance, and crash repair. The industry has an annual turnover of about $8 billion, and gives direct employment to 30,000 South Australians in a wide range of skilled trades.

The MTA plays a key role on behalf of members in planning the future development of the retail motor trades and their place in the economy; in liaison with the State Government to protect and advance the interests of the retail motor trade and its customers in the legislative and policy-making process; and in enhancing training and developing work opportunities in the sector, working with Governments, trainers and unions.

We are now in a position to provide you with the following response to the 14 recommendations arising out of the report of the Expert Panel:

  1. ESTABLISHMENT OF A NATIONAL CUSTODIAN

There is insufficient information available to gain a complete understanding of how the establishment of a National custodian would fit within the system. The report does not address the requirement for a new custodian as opposed to the utilisation of Skills Australia.

Creation of a task force is a necessary precursor to the effective establishment of a new national governing body. This task force must be comprised of members both internal and external to government. The criteria and process for selection of the representative union and employer body is critical to the effectiveness of the group once established.

  1. CLARIFICATION AND CONSOLIDATION OF ROLES AND STAKEHOLDERS

In the past all employer groups have lobbied for some kind of consolidation, however it is not clear from this report exactly what form the proposed consolidation is likely to take, nor which bodies are to be consolidated. A ‘one stop shop’ for employers is

a positive concept but more detail is required before any further comment can be made regarding this recommendation.

  1. ESTABLISHMENT OF AN ACCREDITATION PROCESS FOR EMPLOYERS

Any proposed accreditation process linked to the pre-qualification and training of all employers of apprentices and trainees if not done exceptionally well is likely to be no more than an additional bureaucratic process that misses the mark. It will act as a further unnecessary deterrent to employers engaging apprentices and trainees. Recent changes to the Registered Training Organisation Guidelines have been designed to achieve a nationally consistent minimum standard of high quality training and employment.

MTA SA is supportive of the establishment of an Excellence in Employment Scheme to recognise and reward those employers who have consistently demonstrated their commitment to excellence in training.

  1. ESTABLISHMENT OF STRUCTURED SUPOPRT FOR EMPLOYERS

It is not clear from the report the kind of employer support envisaged. Mentoring and pastoral care are two concepts referred to. MTA supports the removal of current duplication with the system, with Group Training Schemes ideally positioned to do this by taking on work currently undertaken by Australian Apprenticeship Centres whilst AAC’s are document focussed it is the Group Training Schemes that provide the pastoral care and interest in individual apprentice success. MTA-SA agrees that both services are necessary but would be supportive of the government as service provider. Industry specific Registered Training Organisations such as MTA-GTS already offer this support. Any provision of the related services as proposed by the report should be tendered out to the relevant organisations.

  1. REDIRECT CURRENT INCENTIVES TO ELIGIBLE APPRENTICES AND TRAINEES IN OCCUPATIONS THAT ARE PRIORITIES FOR THE ECONOMY

MTA-SA has significant concerns in relation to the definition of eligible of apprentices and trainees as proposed within the report. Occupations of ‘high priority’ are cyclical and any focus on this as a determinant of incentive funding or provision of support is short sighted and dangerous. It is most likely to result in a disproportionately large amount of money being directed to the relatively small industries of mining and defence. Allocation of all funding to current high priority occupations is subjective and certainly not guaranteed to be of tangible and enduring value to the community.

  1. ESTABLISHMENT OF EMPLOYER CONTRIBUTION SCHEME

This scheme establishes an employer levy to be distributed within selected industry. Only employers of ‘eligible apprentices and trainees’ will benefit from the support available as a result of the scheme. Only employers of ‘eligible apprentices and trainees’ will have access to any rebate of financial contributions made.

In a paper recently provided to the Training and Skills Commission MTA has recommended the creation of a dedicated South Australian Automotive Training Authority funded through levies on motor vehicle registration renewals. This authority would focus on attracting, training and retaining automotive industry personnel in a sector which continually suffers skills shortage, poaching and attrition. Such model already exists within the construction industry with the parliamentary establishment of the Construction Industry Training Fund.

  1. TRAINING AND EMPLOYMENT OF APPRENTICES AND EMPLOYEES DURING PERIODS OF DOWNTURN

MTA-SA is generally supportive of this recommendation.

  1. REGULATION OF VET IN SCHOOLS

The new guidelines for Registered Training Organisations delivering to schools should go some way to address this proposal. All strategies are not yet in place in relation to this recommendation making it difficult to comment further at this time.

  1. NATIONAL CONSISTENCY IN PREPARATORY TRAINING

MTA-SA is supportive of national consistency in preparatory training through the development of definitions fro pre-apprenticeship and pre-vocational training. Creation and implementation of these standards must involve industry consultation.

  1. ADDITIONAL SUPPORT FOR APPRENTICES AND TRAINEES FACING SPECIFIC CHALLENGES

This recommendation is supported.

  1. IMPLEMENTATION OF A STRATEGY TO RAISE THE STATUS OF APPRENTICESHIPS AND TRAINEESHIPS

MTA-SA is in support of this recommendation on the basis that there would be ongoing involvement with industry.

12.PROMOTION OF COMPETENCY BASED PROGRESSION IN PARTNERSHIP WITH INDUSTRY BODIES AND EMPLOYERS

This is likely to be a contentious recommendation with varied views across differing industries. It is a positive proposal in theory but will entail significant practical difficulties.

Definitions of competency are likely to be problematic across industry and risk attaches to any attempt at a “one size fits all” approach. There must be room for flexibility in approach across industry. Paper based competency would not be an acceptable model in relation to the motor trade industry. Any assessment would need to be based on industry standards as opposed to a theoretical competency.

  1. IMPROVED IMPLEMENTATION OF RECOGNITION OF PRIOR LEARNING AND RECOGNITION OF CURRENT COMPETENCE

MTA-SA holds similar concerns in relation to this recommendation as those outlined in recommendation 12. Implementation of Recognition of Prior Learning and Recognition of Current Competence are both positive proposals but must be determined by current industry standards.

  1. REVIEW OF APPRENTICESHIP AND TRAINEESHIP PROVISIONS, WAGES AND CONDITIONS BY FAIR WORK AUSTRALIA

Any consideration of the removal of barriers to competency based wage progression in Modern Awards is not seen to be the province of Fair Work Australia.

Any review of apprentice and trainee award pay based on comparisons to ‘going rates of pay’ is fundamentally flawed and should be competency based.

Supervision ratios for apprentices and trainees should not be determined by Fair Work Australia. In circumstances where an industry group training scheme outsources apprentices to host employers it is already a requirement of the ATQF standards that the RTO assess the suitability of the employer for training through its placement officers. This should continue to be a mandatory requirement as should the requirement for continuous evaluation of on the job training.

Non group training schemes apprentices and trainees do not have an equivalent level of ongoing supervision. The state authority Training and Apprenticeship Management Services assess the suitability of the employer in terms of equipment and supervision before granting approval to engage one or more apprentices. Unfortunately this system does not incorporate any mandatory follow up process in relation to training supervision. Consideration should be had to the role of existing industry placement officers within group training schemes receiving a subsidy to undertake such role.

A review of the recognition of pre apprenticeship and pre vocational training is supported but should not be conducted by Fair Work Australia.

MTA-SA is supportive of a review in relation to allowances, circumstances of and costs to apprentices and part time and school based arrangements.

Should you seek any further information in relation to the above please contact Anna Rau or Paul Eblen on 8291 2000.