Professional registration under SAQA, not SANAS
There has been a major paradigm shift in skills development with the introduction of the Quality Council for Trades and Occupations (QCTO), writes Institute for Work at Height (IWH) president Brian Randall in an analysis of construction legislation.
QCTO is the result of the streamlining of the SETA ETQAs into one body to ensure three main purposes;
Occupational training to address skills needs of the labour market
Learning experience being structured, appropriate and purposeful
Occupational qualifications reflecting occupational competence.
These three purposes are reflected in three Quality Assurance (QA) processes under a set of principles that inter alia stipulates that it must “provide sufficient standardisation to achieve credibility” and “use existing expertise and structures”.
To achieve credibility, the design process of the QA must be “expert driven and practice driven”. In order to ensure that “occupational qualifications reflect genuine occupational competence”, the assessment processes should “be standardised nationally”.
Thus, competence in any job requires the input of the industry affected by that job. It could not be determined by a small, special interest group or a selected group with vested interests.
A professional body requires broad consultation, especially from their client base and organised labour, in the process of defining occupational qualifications.
There are eight points listed in a summary of the change to the new system, under the heading ‘major shift’. Two of these points hold specific relevance to construction; “Streamlining SETA ETQAs into one QCTO” and “Recognising the need to work with professional bodies to improve the quality and relevance of training”.
The current legislative environment for construction includes;
• Occupational Health and Safety Act (85 of 1993)
• National Qualifications Framework Act (67 of 2008)
• Skills Development Amendment Act (37 of 2008)
• Accreditation for Conformity Assessment, Calibration and Good Laboratory Practice Act (19 of 2006), commonly named ‘SANAS Act’
The OHS Act sec 8, 9, 10 stipulate various duties of various role players, held responsible for health and safety of persons affected by their actions.
Thus a construction manager has specific health and safety responsibilities, a builder, formwork supplier, scaffolder, designer etc, all have a duty of care that can not be ignored nor passed onto another person. A ‘16.1 appointee’ can not avoid the responsibility of being a ‘16.1’.
Competencies in NQF Act
Logic dictates that if persons are held responsible and accountable, they should have the necessary competencies and resources at their disposal to perform those duties. Competencies take us to the NQF Act (67 of 2008).
This Act provides inter alia for the responsibilities of the Minister of Education, the South African Qualifications Authority (SAQA), Quality Councils, and Professional Bodies. It defines a “Professional Body” as “any body of expert practitioners in an occupational field, and includes an occupational body”
Chapter 6 of the NQF Act stipulates that a professional body must co-operate with the relevant Quality Council in respect of qualifications and quality assurance in its occupational field. The Professional body must apply to SAQA for recognition.
The recognised professional body will then apply to the SAQA for registration of a “professional designation” that it would bestow, being “a title or status conferred by a professional body in recognition of a person’s expertise and right to practice in an occupational field”.
Skills Development is regulated
Chapter 5 of the NQF Act states that the Quality Council for Trades and Occupations (QCTO) is provided for in the Skills Development Act (37 of 2008). This Act provides for the change in the skills development framework, including provisions for the QCTO.
Under its definitions, “occupational qualification” means “a qualification associated with a trade, occupation or profession resulting from work-based learning and consisting of knowledge unit standards, practical unit standards and work experience unit standards”.
Three standards of competence
Competence in any occupational field thus stands on three legs; knowledge, skill, experience. When a professional body formulates a qualification for registration with SAQA, it must address all three criteria. Competence at all but the lowest NQF level, could not come from a one day lecture, or a two week course.
Competent people should be trained and measured against nationally standardised processes, which are the responsibility of professional bodies that address industry requirements and are developed by their own body of experts after broad consultation with industry.
The objective of this process is to produce “genuine occupational competence”, defined as an occupational qualification against knowledge unit standards, practical unit standards, and work experience unit standards.
Thus any occupation in building or construction, including safety officers, must be regulated and placed under the auspices of industry specific professional bodies, charged to ensure “sufficient standardisation to achieve credibility” in every profession.
The construction industry demands coherent decision making processes in all construction trades, occupations and professions, which brings us to the Accreditation for Conformity Assessment, Calibration and Good Laboratory Practice Act (19 of 2006), SANAS Act.
SANAS is “recognised by the SA government as the single National Accreditation Body that gives formal recognition that Laboratories, Certification Bodies, Inspection Bodies, Proficiency Testing Scheme Providers and Good Laboratory Practice Test Facilities (GLP) are competent to carry out specific tasks”.
“SANAS is responsible for the accreditation of Certification bodies to ISO/IEC 17021, ISO/IEC 17024 and 65 (and the IAF interpretation thereof), and laboratories (testing and calibration) to ISO/IEC 17025. Inspection Bodies are accredited to ISO/IEC 17020 standards. GLP facilities are inspected for compliance to OECD GLP principles”, in the words of the SANAS website.
SANAS is thus not an occupational verification authority, neither does it regulate activities or the competencies of persons operating in trades, occupations or professions. It is not the appropriate authority to accredit institutions which are de facto professional bodies. Such accreditation is the function of SAQA.
* Brian Randall is president of the Institute for Work at Height.