Training & Competency

Training qualifications in working at height and for accessing confined spaces are a key component for delivering worker safety, however it is strongly advised that operators also have the right level of both experience and skills to be able to safely operate in these environments. Importantly and often forgotten, the need for a rescue plan is also highly critical if something actually goes wrong.

Publications from state and territory governments, such as regulations and Codes of Practice as well as Standards documents, frequently reference the definition of a Competent Person to assist in this process.

A Competent Person is defined as:

“

‘A person who has, through a combination of training, qualification and experience, acquired knowledge and skills enabling that person to correctly perform a specified task.’.

This definition can be difficult for people to determine what a ‘competent person’ actually is. There is no trade qualification or degree in ‘height safety’ and therefore companies must reference other materials to assist them to assess if a person is competent.

Workers have to be competent to work at height and in confined spaces.

Height Safety and Confined Space Access does not require a License; there are presently no regulator requirements for a person to hold a height safety or confined space ‘license’, such as one that might be required for operating an elevated working platform (EWP), or for performing high risk work. But workers DO have to be competent to work at height and in confined spaces.

There are however other sources of information that can be used to assist in defining the minimum training requirements for operators:

ASNZS 1891.4 - Appendix E - Guidance for the provision of training & competency - This part of the Standard references the types of levels of training required for people to perform different roles when working at height, from operator to supervisor to manager level;
AS 2865 - Confined Spaces - Appendix D - Guidance for the provision of training & competency assessment;
Codes of Practice from regulators
Vocational Training - Delivered by Registered Training Organisations (RTOs), vocational training is available in short-course form for operators to gain the theory and practical training they need to perform work-at-height tasks. RTOs issue certificates of competency to individuals that can pass the theory and practical components of their training courses;
Experience through supervised work - Each site / structure / environment where height safety risks exist are unique. Given the different variable of fall risks on each site, vigilance is required to ensure the application of safe work practices is taken under the guidance of experienced operators. In essence, a supervisor with previous experience in working in these environments that understand the risk and how to mitigate them is essential to maintain the standard of safety on site. A log book of work undertaken or detailed experience in working in these environments may be the type of evidence that can be used to assess a person’s competence;
Reference to WAHA training course recommendation documents - although the above sources of information are useful, the competencies issued by RTOs do not extend to prescribing specific tasks that may be required to be demonstrated by an operator doing a competency based course. For example, the issue of a competency issued by one RTO is technically equivalent to that issued by another, however the course content is not prescriptive. One RTO may conduct a training course in 4 hours and issue a qualification that another RTO issues after 8 hours of training. This confusion is something the WAHA has addressed by issuing guidelines on:

- Minimum course content
- Practical exercises to demonstrate and assess
- Teacher-student ratio recommendations
- Course length recommendations

in 2020-2021

60% of fatalities in NSW construction

were related to a fall from heights*

Industry recognises vocational education training providers as generally the best source of formal qualifications in working at height, confined space access and rescue, as students are issued a certificate of competency for the qualification on successful completion of the training.

However, under the current RTO framework we are unfortunately left with a lot of grey areas: the competencies issued by RTOs do not extend to prescribing specific tasks that may be required to be demonstrated by an operator doing a competency based course. For example, the issue of a competency issued by one RTO is technically equivalent to that issued by another, however the course content is not prescriptive. One RTO may conduct a training course in 4 hours and issue a qualification that another RTO issues after 8 hours of training. This confusion is something the WAHA has addressed by issuing guidelines on:

Minimum course content
Practical exercises to demonstrate and assess
Teacher-student ratio recommendations
Course length recommendations

Despite having a national framework for education the impact of workplace fatalities continues to increase.

Median WCB Payout from 2000 – 2018** due to falls:

Fall from height

$5,800 – $16,800
Increase of 189%

Same level fall

$4,200 – $12,200
Increase of 191%

Median Lost time (weeks) from 2000 – 2019** due to falls:

Fall from height

5.6 – 7.9(fall from height)
Increase of 41%

Same level fall

4.2 – 6.4
Increase of 52%

Despite advancements in Equipment, Legislation and Standards, we seem to be getting no further ahead in protecting our workers, particularly with regard to injuries; The cost to business in terms of gaining ‘compliance’ is ever increasing.

Training is our outlier. It is simply not delivering the outcomes intended.

Training is the outlier.

There are hundreds of organisations offering training courses; how come workplace fatalities are still occurring within the working at heights and confined spaces sectors?

The core principles and design for heights and confined spaces training has not substantially changed in the past 25 years. However:

Courses are becoming condensed and commoditised.

Achieving a “ticket” has become the goal versus attaining a skill.

No consistency from training company to training company or often even within a single training organisation between instructors.

Workers lack the knowledge to apply core theories and techniques to changing situations. Companies must re-train workers to their site systems to ensure compliance.

Sadly, “Compliance Safety” has become commonplace.

But doesn’t our National VET system ensure quality training?

ASQA ensures that Registered Training Organisations comply to the ASQA standards and that courses meet the competencies on the RTO scope.

Nine Confined Spaces competencies on training.gov.au

DEFWHS010 Identify confined space

DEFWHS012 Test confined space environment

DEFWHS013 Control Entry to Confined Spaces

MSMWHS217 Gas Test Atmospheres

RIIWHS202E Enter and Work in Confined Spaces

RIIWHS401E Supervise work in Confined Spaces

PUASAR025 Undertake Confined Space Rescue

MSMWHS216 Operate Breathing Apparatus

PUAFIR207B Operate breathing apparatus open circuit

Five Heights competencies on training.gov.au

CPPCL03036 Clean at heights

UETTDRRF05 perform rescue from switchyard structures at heights

PUASES013 Undertake storm and water damage operations performed at heights

RIIWHS204E Work Safely at Heights

CPCCCM2012 Work safely at Heights

Whilst the aforementioned ASNZS 1891.4 and AS 2865 can be used to guide businesses and individuals to the minimum training requirements, they do not describe or prescribe how the training should be delivered and are therefore an informative appendices in a non-enforceable standard.

Just because an RTO trains a person and then issues them a certificate of competence in a height safety following successful course completion, this does not always mean their course is necessarily of excellent quality. Whilst ASQA generally oversees the quality systems of a training organisation. they do not perform a quality ‘test’ or assessment over the content of one course provided by an RTO, as the competency guidelines are simply too wide to evaluate. ASQA also oversees literally thousands of training companies and cannot possibly understand the strength of each due to a lack of the specific knowledge required.

For this reason, the WAHA has developed guidelines for RTOs to ensure they are offering minimum training content and practical assessments. This content is shown in the training recommendations section in this website.