Vocational Education and Training and the Development of Safe Workers

Vocational Education and Training (VET) plays a significant role in the development of work ready individuals and a significant component of a work readiness is the ability to undertake work in a safe manner. This discussion paper aims to outline the various roles played by stakeholders in the VET sector in shaping the development of “safe workers” and increasing the effectiveness of training provided by the VET sector, particularly related to licenced outcome training. The discussion investigates methods to manage and integrate stakeholder expectations and requirements across the various con-tributors to the training and assessment processes. Current practices are noted and considered with an identification of potential gaps, particularly in stakeholder communication and knowledge, including the dissemination of relevant information. Issues related to the complexity created where the training and assessment practices are regulated by multiple regulators are highlighted as a primary focus of the study. The paper concludes by propos-ing establishment of an independent group of technical experts across the range of applicable regulations requirements to provide authoritative support to the VET sector.


Introduction
This paper firstly establishes the clear need for effective training and assessment related to health and safety in the VET sector and follows with an examination of current delivery practices. This examination leads to a discussion of the potential barriers to system effectiveness and concludes with a range of recom-

Method
This study employed an interpretive approach which is based on a qualitative research paradigm utilising a critical approach as the aim is to provide a grounding for change rather than developing a means of control and prediction that occurs with empirical research. The interpretive approach is one in which the researcher uses their skills to understand the subjective worlds of others and the critical approach aims to improve the quality of human life through social action, as noted by Connole (in Smith et al., 1990). This is a similar notion as advocated by Eisner (1985: p 154) in his discussion on the use of qualitative forms of evaluation for improving educational practice. It outlines the role of the researcher using this methodology as: "The critic's task is neither to use the work as a stimulus for psychological projection, nor is it to be the subject of judicial pronouncements. The function of the critic is to illuminate, to enable others to experience what they have missed".
Qualitative research methodology, therefore, allows inquirers to emphasis the importance of context in understanding and the historical conditions within which events and situations occur (Eisner, 1985). Moreover, as argued by Eisner (1985), qualitative methods occur such that pieces of an event or situation cannot be understood apart from the whole in which they participate. Alvermann and Mallozzi (2010) suggest that researchers using an interpretive approach aim to uncover meaning toward a better understanding of the issues involved.
The method, then, allows the study to subjectively, whilst maintaining credibility and validity, provide new interpretations of current knowledge and beliefs thus initiating improved practice. For this to occur, the researcher commenced by laying a foundation through literature of published research related to current practices in training and assessment of health and safety components, whether integrated or explicit, utilised in the VET sector in preparing participants for job readiness, noting that some units of competence have been designed to explicitly and discreetly address health and safety where other units include health and safety. As an example, an explicit unit is TLIF1001 Follow work health and safety procedures, whereby the focus of the unit is "skills and knowledge required to follow and apply work health and safety (WHS)/occupational health and safety (OHS) procedures when carrying out work activities in compliance with the relevant WHS/OHS regulations and procedures" (Australian Government, 2020a).
On the other hand, a unit such as TLIA1001 Secure cargo, integrates health and R. Skiba DOI: 10.4236/ce.2020. 119118 1619 Creative Education safety requirements as the focus is on "skills and knowledge required to secure cargo in accordance with procedures and regulatory requirements as part of work activities within the transport and logistics industry" (Australian Government, 2020b) rather than specifically health and safety. Health and safety requirements are integrated into the activity of securing cargo.
The literature review was then interpreted by the researcher and discussed in terms of the findings presented here with an aim to persuade and enlighten readers through rhetorical argument.
The interpretive research approach as presented by Eisner (1985: p 182) suggests that: "Educational criticism typically takes the form of a written document whose aim is to help others see, understand, and appreciate the quality of educational practice and its consequences". Eisner (1985) also informs that the written document produced as a result of a research activity has three aspects, namely, descriptive, interpretive, and dealing with the task of making value judgements about the educational merits of what was described and interpreted. The first of these aspects is addressed within this research by presenting direct quotations and referencing work writers in relevant areas by means of literature review. The use of literature review allows formation of a propositional description of the characteristics of the situation about which the criticism is written. The following aspect, that of interpretation, is one in which educational critics account for the interactions they perceive in educational situations (Eisner, 1985). In order to facilitate this aspect, the paper attempts to make links between presented theory and the activities currently practiced, again, as derived from relevant literature. The third aspect of educational criticism presented by Eisner (1985) is related to discerning the educational value of the perception of the events which are addressed by applying a methodology suitable to the research and accepted within the norm of educational research.
The method utilised allows the study to apply a qualitative paradigm to a social situation, which cannot be delineated into simple variables that can be manipulated. As such, the method focuses on providing a ground for change rather than a means of control and prediction and the role of the interpretive research in this study is to describe a social situation through convincing argument based on an interpretation of other researcher's expositions. These expositions are used to outline health and safety knowledge and skills, and their application in the workplace, as a fundamental tenement of work readiness.

Training Framework and Regulation
In Australia, the Vocational Education and Training (VET) sector delivers workplace-specific skills and knowledge and covers a wide range of careers and industries, including trade and office work, retail, hospitality and technology.  (2017) found that RTOs act as "navigators" of the VET system, helping employers to identify their needs and the possible ways of meeting them. In doing so, RTOs are required to decipher the particular requirements of a range of stakeholders that prescribe their practices.

Work Related Injuries and Fatalities
Safe Work Australia produces several reports that provide information on the circumstances of work-related deaths in Australia (Safe Work Australia, 2019a).
The work-related traumatic injury fatalities data provides statistics about people who die each year from injuries caused by work-related activity. It includes fatalities that result from an injury sustained in the course of a work activity (worker fatality) and as a result of someone else's work activity (bystander fatality   Industries such as Manufacturing, Accommodation and food services, Health care and social assistance and Public administration and safety have low fatality rates but are included as priority industries due to high non-fatal injury rates (Safe Work Australia, 2018a).
The five year average fatality rates for Agriculture (13.8 fatalities per 100,000 workers), Road Transport (13.5 fatalities per 100,000 workers) and Construction (2.9 fatalities per 100,000 workers) sit well above the rates for the remaining priority industries, as well as the fatality rate across all industries (1.5 fatalities per 100,000 workers). Given that these three industries have the highest rates of fatality, they can be seen as the highest risk occupational areas and will be the focus of this discussion. Safe Work Australia (2018a) recognises the large share of fatalities in the Agriculture, Road transport and Construction industries is not due to industry size, but due to disproportionately high fatality rates for these industries. The three identified areas are also those that are generally subject to multiple regulation and include high risk licencing or heavy vehicle licencing managed by state and territory regulators. • 21 occurred in regional Victoria and seven in metropolitan Melbourne.
• A 12-year-old boy run over by a tractor towing a spreading attachment on a farm near Leitchville was the youngest.
• The oldest was a 77-year-old man run over by a trailer at a property at Ouyen.
• Nine occurred in construction and eight on farms.
• Nine involved machine and mobile plant, including cranes, excavators, tractors, spreaders and trucks and three involved trench incidents, including two collapses.
• All but two were male.
The number of injuries and fatalities outlined above indicate a great potential for improvement to reduce the occurrences.

Employer Obligations for Health and Safety Training
In Australia work health and safety is regulated by states and territories rather than by the Commonwealth of Australia. Health and safety obligations of employers include a wide range of requirements to help ensure a safe work site. These include providing necessary health and safety instruction, supervision and training, ensuring all staff understand their roles and responsibilities, providing necessary protective gear and equipment, consulting with staff regarding decisions that impact workplace safety, maintaining a register of all workplace injuries and offering return to work programs for injured workers.
Creating a safe work environment is a legal requirement based on the legislative instruments in place (Australian Government, 2020c). There is also legal requirement to provide training in workplace health and safety, in order to assist in achieving the duty of care for the health, safety and welfare of employees (Australian Business and Consultation Solutions, 2019). This is contained in the principal WHS/OHS Act in each state of Australia and includes: • undertake induction and workplace safety training for new workers • train workers for the specific tasks they will have to perform There are a broad range of training options accessible to employers within the assortment of formal, non-formal and informal training available. As an example, employers can send their staff to the above listed organisations for training, training providers can provide workplace training and employers can also deliver training internally, or in-house. Given the diverse range of training programs and providers, there may be significant differences in the quality of training with variation consistency between those providing the training. Australian Skills Quality Authority (2020a) provides that: "The variability in the levels of compliance with the standards results in inconsistency in the quality of HRWL training outcomes and confirms industry concern about the lack of consistency in competencies of employees who have undertaken HRWL training".

High Risk Work Licencing
There are a range of high risk plant operated in the workplace that require focus.
A high risk work licence allows individuals to work with certain high risk and plant equipment such as forklifts, cranes, scaffolding, rigging and pressure In order to operate these nominated plant, new applicants or those wishing to apply for an additional class to their licence, will need to complete training via an RTO, meeting the requirements of the associated unit of competence, and then pass the licence assessment using a mandatory National Assessment Instrument.
As an example, for an individual to be able to operate a slewing mobile crane with a Maximum Rated Capacity (MRC) up to 60 tonnes, the individual would need to firstly complete the unit "TLILIC0013 Licence to operate a slewing mobile crane (up to 60 tonnes)" and once deemed competent, satisfactorily complete the "Licence to operate a slewing mobile crane (up to 60 tonnes)" National Assessment Instrument. This arrangement profiles the dual regulation as regulated by both ASQA and state and territory health and safety regulators, as training and assessment provided by the RTO need to meet the requirements of both the unit of competency and the licence.
Safe Work Australia (2019e) outlines that operating cranes is complex and dangerous and workers must have the necessary skills and capabilities to do it safely. Every year there are injuries and deaths from work involving cranes: • Between 2003-15 47 workers were killed in incidents involving cranes.
• On average there are around 240 serious injury claims every year.
• The most common causes of injuries are muscular stress while handling objects (21%), being hit by moving objects (16%), falls from a height (11%), being trapped between stationary and moving objects (8%) and being hit by falling objects (7%).
• The most common occupations involving crane incidents are machine and stationary plant drivers (29%), automotive engineering and trades workers (19%) and construction and mining labourers (12%). These statistics highlight the high risk nature of plant operation and demonstrate need for licencing in their operation and use. They also highlight the need for effective training to reduce the incidence of injury and fatality. RTOs are responsible for the provision of the training. High risk work licencing is managed by state and territory health and safety regulators. Workers undertake licence testing using mandatory National Assessment Instruments that are produced and maintained by Safe Work Australia. Training for high risk work (HRW) licences is undertaken by RTOs and assessment for HRW licences is undertaken by accredited assessors approved by health and safety regulators. The system is designed in a way such that learners complete the unit of competency prior to undertaking licence testing and the delivery of the unit of competency must As outlined by Workcover Queensland (2019), the RTO is responsible for issuing a statement of attainment. This requires an accredited assessor to undertake an assessment, using the mandatory assessment instrument.
Once the assessor advises the RTO that the person has satisfactorily com-  Where jurisdictions have a training requirement as a precursor to assessment and licence issue, in the majority of cases, this training is an approved industry course delivered via the VET sector (Austroads, 2018). The Transport and Logistics Industry Reference Committee and supporting Skills Service Organisation (Australian Industry Standards) are responsible for developing the units of competency that underpin heavy vehicle driver training. Austroads (2018), the peak organisation of Australasian road transport and traffic agencies, acknowledges that despite substantive efforts to achieve harmonisation, much of which has been successful and is to be acknowledged, there R. Skiba DOI: 10.4236/ce.2020.119118 1632 Creative Education remains considerable variation in jurisdictional practice with regard to heavy vehicle licensing. This includes variations in standard or "normal" licence progression arrangements, differing approaches to exceptions to the standard progression approaches, reliance, or not, on practical on road testing as the key mechanism for assessing competence, requirement for training as a pre-requisite to undertaking an assessment of competence and insourced versus outsourced assessment arrangements.

Heavy Vehicle Licencing
The lack of consistent state/territory approach to licence testing leads to a variation in the training and assessment delivered nationally. This is confirmed by the Senate Standing Committee on Rural and Regional Affairs and Transport (2016), when they note "… issue of concern from the incident on the M5 freeway was allegations that an RTO called 'ACT' in Tweed Heads, New South Wales had certified at least 111 drivers as competent to drive heavy vehicles without testing them for the necessary skills. This included the driver of the vehicle on the M5 freeway who had his Queensland drivers licence upgraded to a heavy rigid drivers licence on the basis of his certificate of competency from ACT". This highlights the confusion that can arise where a training provider navigates their way through multiple regulator requirements and the fact that these vary from one state/territory to another on the basis that the licencing requirements differ.
Nationally recognised units of competency, such as TLILIC2016 Licence to drive a heavy rigid vehicle, outline the competency based requirements for a person undertaking the licence, however, state/territory systems and/or licence testing may not align to the units specifying the standard. Austroads (2018) identify that ASQA auditors are unlikely to have any subject matter expertise in the training provided by the RTOs they review and that ASQA is wholly reliant on the approved training course specifying what is required to be delivered. This is based on the unit of competency requirements. Austroads (2018) continues to identify that ASQA does not look beyond what is documented to "intent" nor do they assess whether an approved training course is "fit for purpose".
ASQA assesses whether an RTO's training and assessment strategies are consistent with the requirements of the training product. They do not specifically check for compliance with other regulation, including transport regulation, although they will endeavour to make relevant regulators aware of any evident breaches so they may address them. This creates a situation where compliance requirements of one regulator's requirements may remain unchecked. Likewise, a single regulator is unable to determine full compliance of a training product's utilisation as they may not be fully aware of all the stakeholder requirements. Bowmen and McKenna (2016: p. 19) outline that "the purpose of developing national frameworks for VET products has been to ensure consistent training out-

comes, so that individuals and enterprises do not face barriers in undertaking or
benefiting from training when moving between jurisdictions, qualifications or jobs". This as a cornerstone of the Australian VET system, is not the current situation where there are a range of state/territory regulator requirements applied to a range of units of competency. Consistency in training outcomes to a required standard may be perceived as an attribute of quality and a lack of consistency in a training system may be seen to impact the overall quality of the services provided by that system. Griffin (2017) notes that quality is as much subjectively in the "eye of the beholder" as it is objectively assessed through hard data, measures and surveys. Griffin considers the perspectives of five key stakeholder groups: learners, employers/industry, providers, government and regulators. For each of these groups, Griffin (2017) considers: what is important in regards to the VET system; what constitutes and promotes a good-quality VET system; and what are the enablers and barriers to having a system that meets their expectations. Griffin goes on to identify that quality is context-and purpose-specific and means different things to the five stakeholder groups and outlines that for students it is obtaining skills to get a job, or a better job; for employers it is staff with workplace skills; for providers it is optimal outcomes for all clients, along with provider reputation and viability; and for regulators it is all providers meeting and exceeding national standards. The common ground for all, including for governments and funders, is that learners are provided with the skills they are training for.
From this perspective, the quality of health and safety training and assessment in the VET sector is measured to different criteria dependent on the stakeholder. Griffin (2017) confirms that these multiple perspectives on quality operate at differing levels-at the training program, at employment outcomes and at higher systemic levels. The various benchmarks applied by the range of stakeholders make it very difficult for all stakeholders to ensure that the learners are provided with the skills they are training for. Industry employing new graduates cannot be sure of the quality of training received as it is often not clear which stakeholder's requirements received priority.
An example of this disparity is the strategic review undertaken by ASQA into the training and assessment of the Construction Industry Induction Card. ASQA initiated this review in November 2012 in response to persistent stakeholder concerns about the quality of training in the unit of competency "CPCCOHS1001A Work safely in the construction industry", also known as the "White Card" (Australian Skills Quality Authority, 2019b). This is a mandatory entry-level unit for people seeking to work on construction sites in Australia. The review was initiated based on concerns raised by industry indicating that people issued White Cards may not actually have achieved the introductory knowledge and skills to work safely on construction sites. In this review, ASQA sought the views of stakeholders including employers, unions, state and territory health and safety regulators and RTOs. The review found that Industry has lost confidence in White Card's value to assure workplace safety assurance for new entrants to the construction industry.
They also found the majority of training providers audited were not compliant with the standard relating to assessment practices and that there is great variety in state requirements for work health and safety regulation. ASQA concluded that a more consistent national approach to work health and safety regulation in terms of General Construction Induction training was required. This observation can be applied to many programs currently delivered in the VET system including those priority areas where significant injuries and fatalities are noted, such as agriculture and transport. This notion is consistent with the findings of the "Strategic Industry Audit of Units of Competency that lead to High Risk Work Licences" conducted by the Training Accreditation Council, as discussed earlier.
RTOs may focus on meeting the requirements of the health and safety regulator at the expense of the quality expectations imposed by ASQA, or meet both ASQA requirements and health and safety requirements and fail to meet industry expectations. Griffin (2017) postulates that measuring quality is deceptively difficult in that it does not simply involve interpretation of data and measures to produce widely available and understood market intelligence. Based on experience and perception, quality is also highly subjective and either drives or erodes reputation and overall trust, at all levels.
Sweeney (2017), cited in Griffin (2017), outlines that the VET information landscape is complicated and could be overwhelming, a context compounded by inconsistencies and questions over the credibility of sources. This confusion could arise from multiple stakeholder control within the VET sector and creates situation such as noted related to the delivery and assessment of White Card. Griffin (2017) states that it is reasonable to conclude that uncertainty about the quality of assessment, and a consequential lack of confidence that graduates have the skills for which they have been certified, is a barrier to employers being assured of work-ready graduates.
The disparity between the regulators in the VET sector, as applicable to heavy vehicle licencing and high risk work licencing for example, leads to a lack of holistic guidance to RTOs and ultimately industry and workers. Austroads (2018) recognise that dual regulation creates tension for outsourced providers and is increasingly moving away from the principal underpinnings of the National Heavy Vehicle Driver Competency Framework.
In 2008, transport ministers agreed that heavy vehicle reforms should deliver a consistent approach to assessment. Following on from the ministerial agree-

Effectiveness of VET Sector Safety Training and Assessment
Hale, Borys and Adams (2013) highlight that where two or more agencies regulate the same activity of a company, those regulations may overlap and even conflict. Aagard (2011) postulates that overlapping jurisdictions need not cause problems if the overlap is explicitly managed by the two agencies. The agencies can resolve inconsistencies in regulations, systematize regulation and its implementation, and remove gaps both in rule making and in inspection practice by collaborating explicitly. Aagard identifies that the need for explicit collaboration in order for this to effectively address gaps and differences amongst regulators and stakeholders. Hale et al. (2013) explains that an explicit mandate to manage the boundaries can reduce conflict between agencies and notes that this is harder when there are larger numbers of rules. Hale et al. (2013) accordingly state "the regulator is as human as the regulated and will have difficulty processing large and complex sets of information about rules and regulated entities". The difficulty in managing the complex requirements of multiple regulators for an RTO can then lead to compromise in the quality of the training and assessment provided.
To decide whether a person is competent, Assessors need a set of criteria or benchmarks against which to assess candidate's competencies (Department of Training and Workforce Development, 2016). In the VET sector, national competency standards, the smallest of which is a unit of competency, are the usual In the context of heavy vehicle licence training and assessment, Austroads (2018) outline that a training based approach to heavy vehicle driver skill development is recommended as a preferred approach, with the VET sector the best placed to offer this service with a caveat that Licensing regulators need to develop an ongoing active relationship with the Transport and Logistics Skills Service Organisation to ensure that the training courses reflect regulators' requirements.
The development of specific training to skill trainers and assessors in licensing competencies and requirements as well as a program of assessment moderation is also necessary. This notion by Austroads is reflective of the requirement for collaborative approaches by stakeholders in order to develop an effective system of safety training in this regard.
The VET sector, and in turn, it's work ready graduates, would greatly benefit from the establishment of an independent organisation or collective with technical expertise in all stakeholder segment requirements, including those derived from the VET Quality Framework, state/territory Health and Safety regulations, employer obligations and industry and association requirements, to facilitate communication and understanding between the various stakeholders. Such a body would be able to provide holistic guidance to all stakeholders and ensure consistency in the provision of health and safety training and assessment with a purpose to creating workers that are focused on workplace safety and ultimately reducing the occurrence of workplace incidents and fatalities. The independent organisation would not act as a regulator but rather provide an authoritative support structure to VET Sector stakeholders. The organisation would be positioned to summarise the key regulatory issues of each regulator and define the ways in which they interact and potentially conflict. This support could be provided in a similar way that a Training Consultant does to an RTO, and could provide the expertise to guide RTOs through the complexities created in multiple regulator environments with a view to reducing the levels of non-compliance against the various requirements with consistent and correct advice. This would result for improved training quality and subsequently improved workplace safety.

Conclusion
Structuring training and assessment activities to meet training package requirements can be a complicated and confusing task. RTO's are tasked with interpreting these requirements. They then formalise these into training and assessment systems based on their interpretation. The distinction between the various regulatory requirements may not be clear in some cases and as such, RTO misconceptions can tarnish their practices. Jurisdictional variation also creates an additional opportunity for difficulty in developing training and assessment tools and strategies. RTOs will significantly benefit from any assistance they can be provided with in this regard.
Confusion in a training system can lead to inadequate training which can ultimately result in health and safety issues in workplaces. Any contributions into a more effective training system, especially related to high risk work, are well valued and should be considered to be mandatory.

Conflicts of Interest
The author declares no conflicts of interest regarding the publication of this paper.