In the Beginning

Now there’s a challenge. Anyone remember the old Observers Books ? Observer’s Book of Pond Life, Insects and Birds etc. I still have a fair collection myself but I’m going to have to write this one given the dearth of official information on the subject. First some background information to save the reader having to visit several web pages.

When I wrote to the Minister of State for Work to try and obtain information on Work Experience, a reply came directly from the HSE (inappropriate) and the bulk of that reply answered a question that I did not ask. One of the two questions I did ask was not answered or even referred to but I’ll deal with that again. However the answer to the question I did not ask can assist us here and is set out below in italics:

Quote: First, it may be useful to explain why the Health and Safety Executive (HSE) considered changes to ACS were necessary. The scheme was initially established to assess the competence of trained, experienced gas fitting operatives and not as a route for entry to the gas industry. There are other schemes, such as those that lead to a vocational qualification, that are more suited for the training and assessment of new entrants to the industry (Editor’s Note – S/NVQ).

That said, if people decide to enter the industry by way of the ACS route it is the view of the HSE that for training to be appropriate it needs to include ‘on the job’ experience. The Approved Code of Practice ‘Standards of training in safe gas installation’ was drafted on the premise that training should include practical ‘on the job’ experience because it is this element coupled with knowledge and practical skills that helps determine competence.

In assessing installation businesses seeking entry to the statutory register CORGI needs to ensure that the operatives employed by the business, or in the case of a sole trader that person, are competent to undertake gas work safely. To this end, evidence of practical ‘on the job’ experience is necessary as well as operatives having been through assessment and granted a certificate of competence. My contact with operatives leads me to believe that some training organisations have misled trainees into believing that registration by CORGI is automatic once assessment is completed and a certificate of competence issued. Unquote

I confirm for the record, when I wrote to the Minister, in my first paragraph I emphasised that we do not have a problem with the principles of the new ACS (August 1 2003) regime which we have dubbed ACS II. That is not the problem. That never was a problem. The problem was and still is getting information, any sensible information, about on-the-job-training or Work Experience.

Although the HSE did not have the good manners to refer to my question on Work Experience, the letter no doubt prompted Corgi to publish some additional information on December 22 2003, in the form of a press release. We were not told about that but discovered the information in a routine scan of the Corgi website. All information referred to above is contained in our ACS 2003 section and this page (Comment 50) will be included in that section ultimately.

The last sentence of the italicised text above does not in my view accurately reflect the truth. It was always my understanding that having passed ACS, Corgi registration was virtually automatic. I suppose that is based upon the knowledge that I have not heard of anyone who has not had registration confirmed and obviously I don’t know everyone who has passed ACS.

That said, it was always widely understood to my certain knowledge that applicants for ACS were required to have a proven background of expertise. We now know that people have been admitted to ACS training and assessment who fell far below the prior expertise standard required, with the full knowledge and consent of the Training Provider. In one case I am personally aware of, via a Centre of Excellence (Local Authority) establishment. In other words I do not just point an accusing finger at Independent Training Providers (those only doing ACS).

It could reasonably be argued that by undermining the spirit of ACS, Training Providers have made a rod for their own back and have only themselves to blame for the recent draconian changes. This has to be tempered with the knowledge that some official fast-track schemes have sought to create Registered Gas Installers in as little as 28 weeks, enrolling people with no prior experience whatsoever. We include some welfare-to-work candidates. Let us not forget who created those schemes in the full light of day and it was not the Independent Training Providers. The authorities surely must have been fully aware of those schemes, which makes all this now seem more than a little hypocritical.

Remember also the HSE Gas Safety Review Working Group 3 (Operative Competence) list of members, which tells us a great deal. Hardly the most appropriate line up.

Understanding Work Experience

Given what we already know for certain, including information received since we started our ACS II Appeal, it appears the authorities are doing their utmost to make life as difficult as possible for anyone they choose. We can only speculate on the reasons for that maladministration. Rest assured we will do our best to correct it even if we do not discover their agenda.

Although the new ACS regime started on August 1 2003, Corgi have only recently published (22.12.2003) a table setting out the broad parameters of Work Experience. We know some Training Providers did not receive the same information until mid October. Altogether an odd state of affairs.

There are three Categories of applicant for ACS Assessment. Category I applicants are proven professionals, essentially renewing ACS. Category II and Category III applicants are taking ACS for the first time and need to demonstrate a qualifying portfolio of experience if they have not arrived at the ACS Assessment by the S/NVQ route. Basically Category III applicants need twice the qualifying Work Experience required by Category II applicants. The following official figures have now been provided.

[ Please note well the new information provided by Corgi on their website is, according to the headline paragraph, only intended to guide ACS applicants into the correct Category. It actually goes further but not far enough. ]

To be fair we understand that some overlap in training durations is possible. Therefore it is not necessary to undertake the above concurrently. In other words although the Category II applicant’s schedule adds up to 240 days, do not take that literally. Having said that 240 days is still far less than one year and not unreasonable on the face of it.

The snag now is determining what Work Experience means. How is that to be translated into popular understanding of work in the real world ? We are given some information that seems quite clear to us, which way the focus is pointing.

Training carried out in customer’s premises, under direct supervision of a competent operative(s) employed by a Corgi Registered Business. With the business ensuring that a sufficiency of the right type of gas work is completed and a record kept of that work.

(Right type of gas work means for example CCN1 and CEN1 installing and or exchanging a range of different appliance types, installation of gas pipework, testing and purging same, servicing, repairing and fault diagnosis of central heating boilers, calculating ventilation requirements, identification of unsafe situations etc).

I cannot find fault with the thrust of the above italicised text taken directly from the Corgi information. It seems to me to be clear from the point of view of understanding their objective. The quality of the information is good but the scope and volume is not.

Because it is only a guide and no more, difficulties have arisen between Training Providers and the authorities. To understand what those difficulties are we need to quote the following extract from the Corgi information:

Undertakes a training programme which is planned, managed and organised by a training provider. This training programme will incorporate both On and Off the Job training and experience with organisational support prior to the applicant taking ACS assessment. The On the Job training component will be carried out by a CORGI registered business in accordance with a training plan and programme designed by the training provider.

What this is saying is that Training Providers are now required to manage trainees from cradle to ACS Assessment. This is not something the Independent Training Providers (ACS only) have been used to and some no doubt have been finding it more difficult than others. In fact we now know that is true.

Many would argue the Independent Training Providers have had a comfortable existence so far. They arranged what were essentially ACS update courses and submitted those people for ACS Assessment. Hefty fees paid up front and a good money spinner ? - That bliss has now ended and Training Providers are obliged to do more and be seen to do more.

Clearly the huge obstacle they face is providing “Training carried out in customer’s premises, under direct supervision of a competent operative(s) … “. This is clearly where they have hit the buffers. Ordinarily, employers try to place trainees into training regimes. Now the Training Providers will have to try and place trainees with employers or at least “under the direct supervision of competent operatives “. Not an easy thing to do.

We understand that some Training Providers have perhaps been trying to negotiate alternatives to customer based placements but they are meeting resistance. We agree there can be no substitute for customer based placements. We also believe there can be no substitute for good old fashioned plumbing orientated placements. Not because it is good-old-fashioned per se, rather because that work is the most challenging. There are many imponderables to be managed that cannot be created within a College setting. To reproduce even a reasonable number of challenging scenarios would require acres of floor space. It would also in my view require expertise which some training providers do not have.

New build work offers some scope (pipework and boiler installations) but most new build site work (Housing) is incentivised and operatives working for a bowl of rice on basic rates will not accept being held back by trainees. There is no reason why they should. We should also remember that new homes do not include cookers. Most are fitted with gas hobs and electric ovens.

It is one matter to fit a boiler but entirely a different matter to convert an existing system complete with new boiler. Fitting gas fires in existing homes is also potentially challenging, bearing in mind popular perception of the cost of fitting a gas fire.

Most modern boilers require a substantially upgraded gas supply. A combination boiler usually has at least double the gas input required by boilers they are replacing. The work involved in an existing home simply cannot be reproduced in the sanitised reality of a College. We therefore agree that customer based placements are a must. The question is, what should that include ?

We are given examples above “for example CCN1 and CEN1 installing and or exchanging a range of different appliance types, installation of gas pipework, testing and purging same, servicing, repairing and fault diagnosis of central heating boilers, calculating ventilation requirements, identification of unsafe situations etc “. As stated before this is clear enough but it is not complete enough.

For the playing field to be level, all Certification Bodies (BPEC, CITB, ERS, Flame Technology and Zurich Certification) must be using the same hymn sheet. It seems to us the Training Providers are not necessarily receiving all the support they should from their Certification Body. Why otherwise would they need to lock horns with Corgi in an effort to find common ground ? As one Training Provider has put it ‘they are also lost in the fog of bureaucracy’. That should not happen in the twenty first century but it is happening.

In our view UKAS has a role in all this as the Certified Bodies are in fact certified by UKAS. Supervision of Certified Bodies by UKAS can only have meaning if there is a common curriculum. Clearly there is no such meaningful curriculum. There may be a curriculum but the creators may be blissfully unaware of the nuances of Work Experience. Either that or they find it too difficult to comprehend and ignore the subject.

Someone surely must be responsible at the end of the day. The HSE create the rules and Corgi advise (only advise) the HSE. Yes there are so called stake-holders (Working Group 3) but there is currently no evidence that the various members have provided any useful influence in favour of common sense. And I mean common sense, not just in favour of Installers or prospective Installers. The information we have to date is woefully inadequate.

Some may feel it is time Independent Training Providers did more to earn their corn but in order to do that consistently they need clear and consistent information, which is not currently available. Who knows we may be witnessing an undeclared agenda to weaken the Independent Training Provider movement or even independently qualifying trainees, arriving other than by the S/NVQ route. Paranoid maybe but it is difficult to believe anything else at the moment. I suspect we are actually dealing with a case of Chronic Institutional Paralysis with no one prepared to accept responsibility.

It is a fundamental tenet of management that authority must be commensurate with responsibility. We would remind everyone in authority that accepting responsibility should also be commensurate with authority. Good old fashioned maladministration may be the key to all this but we aim to find out. We have not yet ruled out the National Audit Office (NAO).

The authorities have revised the system in such a way that ACS Assessors have responsibility for judging whether an applicant for assessment has sufficient prescribed experience. They presumably have guidelines on which to base their judgement. We need to have sight of those guidelines forthwith. We will never allow a subjective judgement. The judgements need to be capable of independent audit.

We are given full details of coursework theory in the form of substantial Certified Body course books and other material including normative documents. We therefore expect the same for practical work. We must know how to measure a trainee’s Work Experience standard so we know when is the right time for the trainee to apply for ACS assessment. If the regime cannot be properly quantified and audited then it should not have been introduced ?

We can say for certain that Her Majesty’s Government is currently losing revenue daily. We cannot be the only people stuck in limbo waiting for something to happen. The new regime appears on paper to provide opportunity for all but in reality the options are illusory. For all practical purposes alternative entry routes to ACS (other than S/NVQ and one or two privileged PLC) are closed. If anyone has discovered a route through the bureaucratic maze please bring us up to date.

This analysis provides a foundation for our submission to the Secretary of State. If this information is incomplete it is not for the want of effort on our part. It is abundantly clear what the problem is and we need to find someone with the backbone to tackle that problem. Enough is enough. There is one more step we need to take then we are going for the jugular. Meanwhile if any Independent Training Provider in Manchester wants some money, we have a willing customer. We can provide the required Work Experience if you can tell us what that means in English. Just give us a call.

One Independent Training Provider claims to be ‘empty’.