This article is written end January 2024 to answer questions about this letter
This has been touched on before in other articles on this website, but let’s expand on it.
This questions stems from this letter.
QCTO should release an explanation or update on it, but here we take a quick look at it and discuss it. The letter is signed by the current (at time of writing) CEO of QCTO. The letter is addressed to the former director general of the department of labour, and cc’s the former chief inspector.
The text that raises questions starts at paragraph 3 and includes point a,b, and c below it.
Firstly, what is meant by “regulated training” needs to be understood. This means that training takes place and the training that takes place is required, by legislation, to have regulation made on it. For example: OHS act states that the minister (of the Department of Employment and Labour) must make regulation on first aid training. That is a legislative requirement.
Regulated training has two components
The letter’s intention seems to be to absolve QCTO of the responsibility of quality assuring any training that DEL (the Department of Employment and Labour) already quality assures.
The problem is that QCTO and DEL are not talking to each other in any meaninful way that results in decisions being made.
And not understanding what they are created to do.
As an example, what that looks like when it works is as follows:
The QCTO will develop and manage a curriculum (e.g. for first aid) and quality assure it. They will ensure training providers train properly and learners achieve the outcomes of the curriculum before receiving a certificate.
The DEL will regulate the training (e.g. first aid) by ensuring learners receive a license to be a workplace first aider, and then ensure the learner’s certificate is renewed every 12 months, and that they achieve the correct level of first aid for the job at hand.
DEL quality assures very little training. They used to do first aid, but the outcomes were definitely not proven by sufficient evidence through the requirements of the course. That is, again, because DEL is the incorrect tool for the training and education component, QCTO is. And, QCTO are the incorrect tool for the regulation component because they are not legislated the responsibility of handling licenses. The QCTO courses do not have an expiry date on the learner’s competence. That is the job of regulation.
There are exceptions. For example, DEL manages the training and education component, as well as the regulation component of commercial diving. However, a QCTO curriculum was created to remove DEL as the education and training component of this, and to have them only manage the regulation component of it (e.g. issuing DEL diving tickets that expire). They are doing it, but just haven’t got there yet. But you can see the intent in commercial diving, and in other training as well.
The letter that sparked this discussion should say that QCTO will handle the training and education component, and then work with DEL who exercise regulation on the training. As things stand (at time of writing) SETA handles the education and training component of first aid. DEL then requires SDP’s to apply for DEL FATO (first aid training organisation) approval as well. That’s correct. SETA doing the education and training component, DEL doing the regulated component.
They just need to apply this to the new curriculums which are being developed by the QCTO (as they should be) which then need to have DEL make regulation on (as they have not yet done for any QCTO skills program that I am aware of, including first aid).
I have asked members of QCTO and DEL if they have sat down and talked about this with each other. They have not. The discussions, if they happened today, would be at least 2 years late. To date I still request they have this discussion and actually make decisions (otherwise the talk is meaningless) but they have not. The public pressures them, but still this has not been concluded for QCTO skills programs (not even one yet as far as I know).
If and when they do, there is plenty of evidence to show their respective organisations KNOW what they are MEANT to do, because there are examples of them doing it (or at least trying or moving in the right direction). E.g. commercial diving, and first aid.
The letter this article is about says the opposite though. It shows a lack of understanding of what the QCTO and DEL are the instruments of.
How will this affect training providers? The collective intention of the law is that these two organisation do what they are mandated to do.
So keep encouraging QCTO to write curriculums. Despite the letter, they are doing it, even for regulated training courses. E.g. they developed the first aid curriculums which definitely fall under regulated training / licensed courses. OHS courses are in process. They know what they must do despite this outdated letter. Keep encouraging the DEL to make regulation on the courses I line with legislation (e.g. as they must do on top of the QCTO training courses as they did with the SETA first aid training).
