Subject matter experts from the private sector liaised with QCTO and HWSTETA to develop a vision screening test curriculum with the intention of having this established as a QCTO skills program. This process was funded by Education for Health Africa. Some effort was put into this by stakeholders. The curriculum was written and going through various approvals. At the Tenth (10th) Ordinary Meeting of the PBODO ETRC it was discussed with HPCSA, who elected to not support the program, and as such it is shut down and will not be established.
I have quoted two responses from members of the board below. Please excuse me if I have missed titles (such as Dr or Prof) I am working off the Teams profile names used in the meeting. The meeting was an hour or so, but these two quotes from the board are indicators of how the program came to be rejected:
At 49mins Cheryl Botha questioned the stakeholder motivation for the program as follows: “When you talk about a team effort with visual screening that includes optometrists I fail to see a necessity for a specific cadre doing screening when that falls within the skillset of optometry. And not only optometry, but also dispensing opticianry. There is a whole cadre of qualified professionals out there that can do this whole job that is within your proposal”
At 53mins Lawrence Sithole responded to motivation for the program by stakeholders with “One of the challenges with case detectors, and this is from research, especially in the context of Africa is the ever increasing advent of false negatives or false positives. And this is precipitated by inadequately trained personnel, such as, in this case, case detectors and screeners; and this is emperical research. Now, this on its own causes much bigger problems than solutions, especially due to under-referrals as I’ve indicated, thus exposing same workers to even more harm as they may be left being oblivious to potentially debilitating eye conditions once those conditions are missed”
Download copies of the draft curricula for the QCTO vision screening program that will not be supported by HPCSA, and therefore almost certainly not established by QCTO and QAP HWSETA:
Download the draft QCTO vision screening skills program curriculum here (NB this program is not promulgated / established)
Note by Angie Butkovic, honorary life member of SASOHN; OHN Consultant and Nurse Educator:
It is important to add that it was a courtesy that HPCSA was presented with the standardized SP as they only approve qualifications and not short courses and that VS screening competency training will continue as required legislatively in the OH field with the support of other stakeholders involved.
Addressed to HPCSA by OHP Consultant Lindie Jansen van Rensburg (EFHA, Emmica):
Thank you for your time in discussing the skills programme in vision screening. We really appreciate the time you took to understand the important of this short course. We would like to confirm that the short course developed for occupational health practitioners and their assistants and accredited through the QCTO—does not infringe upon the professional scope of optometrists, while fulfilling a crucial function within the domain of occupational health surveillance. We would like to re-iterate the following:
1. Clarity of Scope: Screening vs. Diagnosis
Vision screening is a non-diagnostic, preliminary procedure used to identify individuals who may have visual impairments that require further referral to an optometrist or ophthalmologist. The purpose is not to treat or prescribe, but to triage effectively and assist in fitness to work certification. This clear functional boundary does not encroach on the clinical or diagnostic scope reserved for optometrists registered with the HPCSA.
2. Legal and Legislative Framework
The Occupational Health and Safety Act (OHSA, 1993) requires employers to ensure that employees are medically fit for specific work exposures. According to the Occupational Health and Safety Act of 1993, the Occupational Health Practitioner—either a nurse specialist or a doctor with additional training in occupational health—is recognised as the competent authority to certify an employee’s fitness for work. Vision screening is an essential component in determining fitness to work, particularly in tasks where visual acuity is safety-critical (e.g., driving, machinery operation). This obligation falls within occupational health risk assessments, which are distinct from optometric care.
3. Skills Gap and Training Need
Currently, many occupational health nurses and practitioners conduct vision screening as trained on the old Unit Standard 116505 and are currently without standardised training or accreditation. This inconsistency risks poor quality assurance. A QCTO-accredited skills programme will ensure standardisation, competence, and legal compliance—without creating diagnostic authority, which remains the domain of the optometrist.
4. Precedent: Similar Accredited Skills Programmes
Skills programmes for first aid and spirometry are already QCTO-accredited (audiometry in process) and accepted in occupational health, even though diagnostic audiology and pulmonology fall under the scope of other HPCSA boards. The precedent shows that limited-scope screening activities can legally and ethically coexist with professional diagnostic roles, if properly bounded and regulated.
5. Collaboration, Not Competition
A screening programme does not replace optometrists but rather supports the referral pipeline. It strengthens interprofessional collaboration and enables early identification of visual concerns, enhancing employee outcomes through appropriate referral. Far from infringing on optometric scope, it increases demand for professional optometric services.
6. Alignment with QCTO Mandate
The QCTO’s role is to develop occupationally directed qualifications that address skills gaps in specific work contexts. In this case, vision screening is a task-based competency required in occupational health settings, and not a standalone profession. Accrediting the programme through QCTO ensures that practitioners are trained within scope of practice, fit for workplace-specific requirements, and under regulatory oversight.
A QCTO-accredited vision screening skills programme is legally compliant, professionally respectful, and operationally necessary within occupational health practice. Without this skills programme, there is no way to regulate vision screening training for occupational health practitioners or ensure the quality of services provided to employees in South Africa. This lack of regulation compromises the standard of occupational health services nationally.
By implementing and accrediting this skills programme, Occupational Health Practitioners (OHPs) and their assistants serve as the primary point of medical contact for employees, helping to prevent workplace injuries and diseases. This expands access to healthcare for many South Africans and reduces pressure on the already overburdened public health system. Failure to accredit the programme would disadvantage both employees and employers and hinder legal compliance.
We urge the HPCSA to formally confirm that such a programme, when clearly demarcated as non-diagnostic and referral-based, does not infringe upon the scope of optometry, and can be implemented to improve the standard of occupational health services in South Africa.
We welcome the opportunity for further engagement and collaborative framework-setting.
The funding for this project from the private sector came from Education for Health Africa. Education for Health Africa are also the reason the QCTO program “Occupational Screening Spirometry” exists.
