carpentry qualifications - draft development … qualifications - draft development strategy...

Carpentry Qualifications - Draft Development Strategy Feedback Register

Carpentry Qualifications Draft Development Strategy - Feedback Register External Document 31 03 15 Version 2

Draft Development Strategy – Carpentry Qualifications Framework

Table of Contents

Certificate III in Carpentry .................................................................................................................................................................... 2

General Feedback Raised by RTOs .............................................................................................................................................. 2

General Feedback Raised by Industry, Regulators, Associations, Others ................................................................................... 28

Certificate III in Joinery ....................................................................................................................................................................... 43

General Feedback – Raised by RTOs ......................................................................................................................................... 43

General Feedback Raised by Industry, Regulators, Associations, Others ................................................................................... 46



Carpentry qualifications – Training Package Redesign

Training Package: CPC08

Certificate III in Carpentry

General Feedback Raised by RTOs

No Date Type of Stakeholder (i.e. RTO)

Issue

1. 16.12.14 RTO, VIC

Combine CPCCCM2010 Work safely on scaffolding above 2 metres with CPCCLSF2001 License to erect scaffolding and

create a module QUOTING, which would include maths and plan & organise work.

Good to see roofing & ceiling framing combined.

2 19.12.14 RTO, ACT Packaging rules - 22 competencies

15 core, 7 electives

Core: CPCCMN3XXX New WHS unit to be based on CPCCOHS2001A Apply OHS requirements, policies and procedures in

the construction industry (will include writing SWMS)

CPCCCM2010B Work safely at heights XXX

CPCCCA2002B Use carpentry tools and equipment

CPCCCM2007B Use explosive power tools

CPCCCM2001A Read and interpret plans and specifications

CPCCCA3002A Carry out setting out

CPCCCA3023A Carry out levelling operations



CPCCCA3003A Install flooring systems

CPCCCA3004A Construct wall frames

CPCCCA3006B Erect roof trusses

CPCCCA3008B Construct eaves

CPCCCA3010A Install windows and doors

CPCCCA3001A Carry out general demolition of minor building structures

TLILIC2005A License to operate a boom type elevating work platform with a boom length of 11m or more

CPCCLSF2001A License to erect, alter and dismantle scaffolding basic level

Group A Formwork electives

CPCCCA2003 Erect and dismantle formwork for footings and slabs on ground

CPCCCA3018 Construct, erect and dismantle formwork for stairs and ramps

CPCCCA3019 Erect and dismantle formwork to suspended slabs, columns, beams and walls

CPCCCA3020 Erect and dismantle jump form formwork

Group B General electives

CPCCCO2013A Carry out concreting to simple forms

CPCCCM2002A Carry out excavation

CPCCCA3013A Install lining, panelling and moulding

CPCCCA3017B Install exterior cladding



CPCCCA3012A Frame and fit wet area fixtures

CPCCCAxxxx Construct pitched roofs advanced

CPCCCA3005B Construct ceiling frames

CPCCCA3016 Construct timber external stairs

CPCCCA3015 Assemble partitions

CPCCCA3014 Construct bulkheads

CPCCCA3022 Install curtain walling

2.1 19.12.14 RTO, ACT

I would like to add the perspective of my experience in the cottage industry and as an educator. As you would be aware a

large number of carpenters work in the cottage industry supplying new housing, knock down rebuilds, and extensions and

renovations. From reading the development strategy workplace functional analysis I feel this sector is under represented.

My experience as a carpenter required skills in constructing the elements of enclosure for domestic housing. These

elements are the floor, the walls and the roof. To achieve the outcome of a floor you rely on the knowledge of excavation,

levelling, subfloor elements and floor construction including engineering requirements to support the other 2 elements.

It is pleasing to see that Construct wall frames remains in the core. However it is disappointing that the third element the roof

is also optional. I understand that it is difficult in many regions to gain on the job training for pitched roofing as roof trusses

are predominantly used.

The design, planning and execution of pitched roofing extends the depth of structural knowledge that a carpenter requires

and this knowledge flows back into other carpentry skills supporting higher standards ie calculation, measurement, planning

and organising .

I am buoyed by Doug Malones comment on the importance of Advanced Roofs in the high end market. The educational

progress for Advanced roofs flows on from the knowledge of pitched roofs. I believe if these were to remain elective then

they should be combined as one flows into the next. Also Ceiling frames should remain separate to reflect the separation of

roof elements and ceiling elements.

Erect roof trusses the alternate roof element is most likely the predominate structure used for roofing across all regions.

Therefore to complete the elements of enclosure this should be added to the core. This would also make sense of having



Construct Eaves as a core as eaves are an element of the roof.

My opinion is that Install flooring systems, Construct wall frames, Erect roof trusses, Construct eaves remain core units. Also

Pitched roofs and Advanced roofs are combined and Construct ceiling frames remains standalone within the electives.

Further I would like to comment on Use carpentry tools and equipment. Every layman needs a starting point when

entering a trade. This starting point should be the respect and understanding in the use of the hand and power tools used as

part of the trade. It makes no sense and is also dangerous to assume that tools can be applied to an activity without rigorous

training in there use and application. Use carpentry tools and equipment is probably the most abused competency of all as

we cannot be confident that those who hold the competency actually hold the skills to safely use even the most common

carpentry tools and equipment. I believe that Use carpentry tools and equipment needs to be re written to AQF level 3

specifying a core of tools and equipment that must be trained and assessed in with a further group of options in the range

statement. The strengthened unit should be included in the core along with the WHS unit as the starting point of training.

Therefore my opinion is that a strengthened Use carpentry tools and equipment at AQF L3 be included in the core.

Also I note that Work safely at heights appears to have changed to Work safely on scaffold above 2m. I believe that the

current Work safely at heights is broad enough and should include training in working on scaffold above 2m.

By name alone and without knowing the content of Work safely on scaffold above 2m it sounds restrictive in the context of

broader height safety. If working on a scaffold above be 2m is to be prescriptive as part of Height safety then maybe a

broader ranging name could be applied. Work safe at height including scaffolding. Should be a core unit.

I welcome License to erect, alter and dismantle scaffolding basic level as a replacement of restricted height scaffold and

would also support License to operate a boom type elevating work platform boom length 11 metres or more as a

replacement of Operate elevated work platform up to 11 meters.

Also core competencies

The inclusion of CPCCJN 3001, 3002, 3003, 3004 seems unnecessary in the cert III Carpentry as they sit within Cert III

Joinery. Carpentry in my view is about onsite activities, installation as opposed to manufacture

In light of the introduction of foundation skills into units, the embedding of the soft or underpinning competencies into work

out come competencies has merit with the exception of Use carpentry tools and equipment. WHS underpins all

competencies and is included in there outcomes. This model could be used to embed the soft competencies in a similar



manner.

Embedding competencies raises the question of nominal hours. Embedding underpinning outcomes will increase the

content within the curriculum therefore nominal hours would need to be increased to accommodate the extra work and time

involved in delivering and assessing competency.

Lastly the comment on getting the balance right between rigorous assessment requirements and enabling RTO’s to use

simulated workplace assessment strategies must be considered through consultation with both Public and Private providers

to support practical and workable options.

3 5.1.14 RTO, NSW Packaging rules: I am not sure what the point of having the option to select units from another Cert ii qualification is, if the

goal is to include only units that reflect a job role, which are at an AQF level 3 to “ensure the integrity of the AQF alignment”,

perhaps the packaging rules should state that “up to 4 units may be chosen from other qualifications in the CPC Training

Package that are at least an AQF level 3 or higher”. Considering that the list of Cert iii Carpentry electives are considerably

reduced in numbers, limiting the option to import units to no greater than 2 might also help maintain the integrity of the

qualification, because allowing an elective importation of 50% of the total electives seems quite flawed and has the potential

to dilute the integrity of the qualification considerably, in fact I would suggest that due to the overall lower number of units

and the outlined approach to having a more robust qualification, it would be more prudent to not import units from other

qualifications at all because 4 imported units and 18 units from the Cert iii Carpentry qualification means that the imported

units represent almost 25% of the actual Qualification units, however I think that importing 2 units from other qualifications

could be consider a maximum.”

3.1 5.1.14 RTO, NSW Number of units: Unit number is not an issue as long as content and qualification integrity is upheld, however I believe the

same outcome may be achieve by simply deleting the units that are intended to be embedded from the current packaging

rules and leave the remainder of the current packaging rules the same with the exception of having a reduced number of

core units and perhaps reducing importation allowances.

The number of units allowed to be imported from other qualifications is an issue as I mentioned previously:-

3.2 5.1.14 RTO, NSW Core units - “Construct Ceiling frames and pitched roofs” should remain as Core Unit/s because it is illogical to keep

“Construct Eaves” as a core unit and not pitched roofs, having understanding and skills in pitched roofs is essential to

constructing eaves, the calculations found in pitched roofs are foundational for calculations in eaves, the eave overhang is

governed by the method of eave construction but also the section size of rafter which would only be determined in the

pitched roofs unit through the use of A.S.1684 span tables for rafters, the same can be said in relation to keeping “wall

frames” as a Core Unit because it is necessary to know “load widths” of roof area’s to know what section sizes of wall frame



members to select from A.S.1684 span tables for wall frame members, “Install Flooring Systems” should also remain as a

core unit for the same reasons, these units are closely interlinked and entwined in nature. ( in summary, reinstate Ceiling

Frames, Pitched Roofs and Floor Systems as Core Units )

Remove CPCCLSF2001 “License to erect, alter and dismantle scaffolding basic level” this should not be a Core Unit, as this

is a Licencing Unit of the High Risk variety and not necessary for the majority of scaffold applications encountered,

particularly in domestic construction, reinstating the existing unit “Erect and Dismantle restricted Height Scaffold” as a core

unit is more than adequate for the majority of applications encountered and should remain as a core unit because it allows

the competent person to erect scaffold to 4 metres having CPCCLSF2001 is of little benefit

CPCCCM3001 “Operate elevated work platforms up to 11 metres” should be a general elective not a core unit, elevated

work platforms are largely used in commercial construction only and the unit requirements already flagged in the draft unit

consultation will disadvantage the majority of those in the residential sector by overloading candidates that are never likely

to use them, however it should remain as a general elective

Reinstate “Excavation” as a core unit as this ties in with excavating footings to slabs and also to levelling and setting out for

excavating and cutting sites to reduced levels and covers many safety aspects specific to excavations that would not

otherwise be covered, limiting transferability

These suggestions will mean that the number of core units will increase while the number of electives may decrease

3.3 5.1.14 RTO, NSW Elective units - Group A formwork electives could be reduced to one unit ( Erect and Dismantle Formwork for Footings and

Slabs on Ground ) considering that the remainder of these units are far better suited in a “Formwork and False work”

qualification, if the group were to remain the General elective unit “CPCCCA3020 Erect and Dismantle Jump Form

Formwork” should also be within this group, but as I suggested previously, all these should be in the Cert iii Formwork and

False work qualification not in Cert iii Carpentry with the exception of CPCCCA2003.

In summary :- remove CPCCCA3020 from general electives altogether or insert in Group A Formwork electives or only

include CPCCCA2003 in this group and remove all other formwork units

Operate elevated work platforms up to 11 metres should be a general elective

Construct Ceiling Frames and Pitched roofs should be separate units and included in the Core Units as I stated earlier in

“Core Units”, these units are closely related but the content of each would be too much to amalgamate into 1 unit, using the



A.S.1684 span tables for each of these units are complex and would prove incredibly challenging if carried out in 1 unit

Install floor systems should be reinstated as a core unit for the reasons I expressed earlier in “ Core Units”

Remove CPCCJN3001, CPCCJN3002, CPCCJN3003 and CPCCJN3004 from the general electives as these units are more

appropriately suited to the Cert iii Joinery qualification

3.4 5.1.14 RTO, NSW

Other comments - The current packaging rules are adequate and could be modified to exclude 6 core units that are

intended for embedment ( carpentry tools and equipment, carpentry materials, work effectively, plan and organise, carry out

measurements ) reducing the core to 16 and retain 8 electives with the enhanced WHS unit replacing “apply ohs

CPCCOHS2001 within the Core units

Cert iii Carpentry, Cert iii Formwork and False work, and Cert iii Joinery should be separate qualifications in their own right

as each are specialised fields within an industry sector, the Cert iii carpentry and Joinery should be deleted altogether, and

Cert iii Joinery (Stairs) should also be deleted and Cert iii Joinery should include Stairs as core

In relation to Core Units, it may be more appropriate to have two groups of core for each qualification, the first group of core

units would be the common core units to all the qualifications similar to what is shown on page 29 with the exception of

“Install Lining Panelling and Mouldings” and a second group of Core Units specific to each Qualification, these could be

seen as 1. “Sector Core” meaning common core units to Carpentry, Formwork Carpentry and Joinery Carpentry, and 2. the

Qualification Core for each Sector qualification

From my experience many apprentices are employed and put on as Carpentry and Joinery apprentices only because the

term is familiar with most employers because that is what they did, increasingly more are now signed up as Carpentry

apprentices because many employers are starting to realise that much of the joinery skills are not required for their

operations unless they are actual joineries and perhaps that has not yet translated well for the operations that are actual

joineries because they perhaps still think that a Carpenter and Joiner is the same qualification that it was years ago

A comment on the Initial Stakeholder Survey (Appendix 1)

It appears many of the responses were very subjective and contradictory, this is most likely to do with personal

interpretations rather than a true reflection of the current training package

I already believe that much of the suggested changes already exist in the current training package qualifications i.e. where

it is suggested that the Australian Standard 1684 must be used, is already covered where units indicate “to standards,



regulations and legislation”, also writing SWMS are already required where units state “follow OHS policies and procedures”

these days the WHS policy for every workplace dictates that a hazard identification / risk assessment process be in place

which includes SWMS and the writing or creation of SWMS

7 16.01.15 RTO, QLD Packaging rules - # of electives is not reflective of most apprentice’s workplaces. 99% of our apprentices which covers

areas all Qld to Central Qld and west Qld to SE Qld, plus central NSW, Hunter, Sydney & Illawarra could only find 5 suitable

electives.

Most of these apprentices do not get access to EWP’s, limited use EPT where they have been replaced by specialist fixings.

Other comments. I read the sample info from surveys and it was not representative of most apprentices. It is fine to teach

many of these Units in classroom however where a student is required to assess skills that have been demonstrated in the

workplace these would be a non-event.

Being a former TAFE teacher of 25 years and workplace training for 15 years I see the units offered as not reflective of

skills/Units/tasks the are commonly undertaken for most of the apprentices.

I agree with having roofing as an elective and addition of commercial builders units. There could be extra units for them as

well eg facades, metal wall frames etc

Other comments on the development strategy: Development strategy was good however the depth of the survey of

apprentices is not wide enough. The surveyor needs to ascertain where most of the apprentice’s workplaces e.g. domestic

builders, contract carpenter gangs where they arrive on site after slab is completed. Most of them do not see concrete apart

from walk/working on hardened concrete. Sure there is the specialist boutique builder who needs refurbishing windows

advanced roofing, creating mouldings however this is not the norm.

What provision has been made for the apartment carpenter where 40% of all persons will be living in say 10 years or so?

I also work with apprentices and builders who do everything including run the electrical wiring, tiling, plumbing, roofing,

painting, plastering. Yes a complete house out in the bush. However these are not the norm either.

The package needs to be future proof. Seeing the units structure as it stands increases my blood pressure and I feel there is

insufficient width in scope of skills to be realistic. As I have been told by apprentices in some modern trade you have to lie

on your record of training to pass the course. This needs to be addressed here

8 19.01.15 RTO and Industry, Packaging rules - Happy with number of core and electives. Like the idea of embedding soft skill units into other units.



NSW Assuming that Work safely on scaffold above 2 metres is a direct swap with Working Safely at heights. Would change name

back as it looks like there is a double up on Scaffolding.

Would put Operate Elevated Work Platforms back as an Elective and place Carry Out Concrete to simple forms in as Core.

As per existing Carpentry and Formwork Qualifications.

Other comments -. What happened to Carry out Excavation? Will it be embedded into CPCCCA2003 Erect and dismantle

formwork for footings and slabs on ground?

Why not make CPCCCM3001 Operate elevated work platforms up to 11 metres into a License Unit (above 11 metres),

same as Scaffold. Industry wants Licenses not Qualifications.

Other comments on development strategy - Glad to finally see that Qualifications at Cert 2 level will not directly line up

with Cert 3.

Could never work out how Schools could deliver ‘Trade’ Quals with having no ‘Trade’ Qualified Teachers. Industry will be

very happy with this, especially with Competency Based Wage Progression.

Will stop unscrupulous RTOs fast tracking Cert 3 qual delivery and only delivering the ‘Soft’ Units for quick money.

Will ‘Nominal Hours’ or ‘Recommended Delivery Hours’ be included? Concerned that some RTOs might see it as a way

trying to deliver trade under two years.

9 20.01.15 RTO, NT Packaging rules - The proposed two new units are not necessary and will not add value to the quality of the training and

assessment.

The Units of competency as they stand in the current Training Package should continue to be used. These Units should be

reviewed to maintain currency with the industry.

I’ve found that holistic delivery of the Units of competency in the current Training Package sufficiently enables our

apprentices to achieve the necessary industry required knowledge, skills and practice.

Other comments - I do not support a reduction in the number of core Units. A reduction in core units will not improve

qualification outcomes for the industry, particularly in the Northern Territory.

To improve the quality of training and assessment, the Unit of competency and Assessment documentation should be more



prescriptive to enable trainers/assessors to accurately interpret and deliver the training and assessment required by

industry.

The current qualification overly relies on the interpretation by the RTOs trainers/ assessors. “It is no longer appropriate for

trainers and assessors to determine success through their personal interpretation of competency as currently stated in the

units”.

The qualification documentation must be more prescriptive to clearly direct the trainers/assessors to deliver consistent high

quality training and assessment. “The Unit of competency and Assessment documentation in the Training Package sets the

benchmarks for training delivery and the performance of the trainer/assessor and ultimately the outcomes for

apprentices/trainees and industry.”

10 21.1.15 RTO, VIC Packaging rules - 22 units of competency, l would prefer to see 18 core 4 electives if you intend to down size. their are a

number of core units that must be kept .

Other comments - Units such as: calculations, pitched roofs, trusses, flooring and ceiling frame l still think they need to be

core units not electives. Apprentices need to know these units if they are to be competent in carpentry.

11 21.1.15 RTO, WA

Other comments on the development strategy:

1. Given that W.A is to be the most effected by the deletion of the Cert III in Carpentry & Joinery (p19) it is worrying that the

WFA was only conducted in Victoria, NSW and QLD. Building techniques and practices vary across states and given the

possible effect on W.A it would stand to reason that more should be done to understand what is needed in this state.

11.2 21.1.15 RTO, WA

2. I deliver in a regional area which is serviced predominately by small builders who require their carpenters to have ground

up general/broad based carpentry skills. Additionally many of my apprentices are employed by contractors and

subcontractors who operate only small teams. Given the WFA focused mainly on larger businesses (which were Eastern

states based p3) most of which were in proximity to a CBD it is highly questionable how accurately the WFA represents the

skills required in regional areas.

113. 21.1.15 RTO, WA

3. Was the question ever asked - where are carpenters employed and in what numbers or proportions. What proportion

of carpenters are employed in small business, big business, city areas, rural areas, residential new, renovation, high-rise or

commercial. Do the greater number of carpenters require general skills or specific?

Without answers to these questions how can the quality of the businesses chosen and the skills observed in undertaking the



WFA be considered appropriate or relevant to todays majority of carpenters.

11.4 21.1.15 RTO, WA

4. Additionally the WFA was only conducted at five sites which represents an extremely small sample group (miniscule in

percentage terms) given the intention of the study is to determine the actual real life skills required by all carpenters and

there by the apprentices they are training. To put this in perspective the table on page 20 of the report states that in 2013

23494 apprentices were employed. These apprentices are working with carpenters on many thousands of sites located

across the country – to reference 5 sites with a view to presuming that the information gathered accurately represents the

skills needed in the broader industry is simply statistically unsound.

It is well recognised that in order for information taken in a study or survey to be accurate the sample size must be

sufficiently large enough – the size of the sample must be developed in reference to -

1. The size of the population being studied.

2. Margin of error – Confidence Level & Standard deviation. Does a sample size of five(5) sites provide the accuracy required in the context of the actual size of the national

industry and distribution of carpenters throughout that industry?

The project team believe that the information gathered represents “strong evidence for the analysis and recommendations

provided in this paper” I would ask by what measure?

These are nationally recognised qualifications – should it not follow therefore that any information collected with a view to

altering the content or design of the qualifications should be collected using a uniform and national approach?

11.5 21.1.15 RTO, WA

5. The industry survey was undertaken “to indicate broad issues the project should be made aware of when

considering the direction of changes to the qualifications and units.”

Given the results of the industry survey are to be relied on to provide direction for the changes it is particularly concerning

to see in appendix 1 that “All completed responses were from RTO’s ….. and no feed back was provided on

Cert III in Formwork/Falsework

Cert III in Joinery (Stairs)

Cert III in Joinery

RTO’s, largely due to a well acknowledged lack of currency of lecturing staff, are not well placed to provide feedback on the



relevance of qualification content, as it relates to skills needed/used on site today.

No completed responses were received from industry (p33)– The survey was passive – and not a suitable method of

extracting the required information from the industry (proof is in the pudding so to speak)

As a carpenter and builder with over 20 years on site experience and who is new to training, I can assure you that to get at

the opinions of the broader industry it is necessary to be more proactive – many in construction (including those who have

apprentices) wouldn’t know who the CPSISC were, evidenced in the extremely low response rate of the industry survey. Is

there any intention to use another method to get this very important information?

Given the complete lack of information received from the construction industry I would ask how the direction for the project

was decided?? Combine this with the fact that only five employers were consulted for the WFA and one could easily

conclude that the development strategy is not fulfilling it’s own brief and is proceeding on information collected from a

narrow range of stakeholders.

11.6 21.1.15 RTO, WA

6. The development strategy does make some very sound suggestions and speaks in broad terms that appear to suggest a

move in the right direction. My concern is how the lack of comprehensive national industry consultation may result in content

changes to units that will not reflect the actual needs of the carpenter in todays Australian construction industry.

Based on the information provided in the Development Strategy I would urge the development team to reflect on the

evidence being used and question whether it accurately reflects the diversity of an industry containing massive numbers of

sole traders, sub-contractors, contractors, large and small builders, commercial sectors, residential, cottage, high end and

maintenance sectors and how this effects the skills as practiced by carpenters across this diversity of environments in what

is becoming an increasingly nationalised construction workforce.

14 27.01.15 RTO, NSW Packaging rules - As a Builder I would expect any carpenter on one of my sites to be able to perform a variety of tasks.

These tasks must include the ability to: lay bearers & joists, construct wall frames, pitch a roof, put up roof trusses, install

exterior cladding, do a complete internal fix out, construct an external set of stairs. This is the absolute minimum I would

expect. Based on that expectation, I have the following points to make:

1. Operate elevated work platforms should not be core.

2. Frame and fit wet area fixtures should not be core. This should be embedded in wall framing anyway.

3. Construct a pitched roof must remain core.



4. Construct ceiling frames must remain core.

5. Roof trusses must remain core.

6. Install flooring systems must remain core.

7. Construct timber external stairs should be core.

8. Renaming CPCCCM2010B is nonsense. “Work safely on scaffolding above 2m implies that if it is below 2m it will always

be safe, which is not true!

Other comments on draft strategy:

The compression of the course from 30 units to 22 units may seem a practical way to save money in delivery, but what it

does is jeopardises the apprentices ability to take on the tasks that are expected of them. We are definitely ‘short changing’

our clients.

I have not yet discussed the absolute core skill requirements of plan reading, calculation and geometry. Yes, these skills are

embedded in the units we deliver, but if we retain them as ‘stand alone’ units, we have the opportunity to flag students with

LLN needs at an early stage of their training.

Not sure who developed these drafts, but surely people at the ‘coal face’ of delivering these units need to be included, i.e.,

tafe teachers- who have all come from industry and many still work in industry.

15 28.1.15 RTO, QLD Packaging rules: I think the idea of embedding stand alone units (1000 and 2000) were appropriate is a very good idea.

These units are required by and generally covered across the 3000 units anyway. This will result in fewer units of

competency but will make them more relevant and appropriate to the trade. With this in mind, the number of total units

seems fine, although as outlined below, there could be more core units and less electives.

I also feel that the choice of 4 elective units from another CPC qualification is too much. This has the potential to decrease

the specific carpentry skill and knowledge requirements of participants, given that a number of previous core units are now

electives.

I think that the core unit selection is a bit off the mark. I do not understand the reasoning for removing standard residential

carpentry activities such as floor framing, roof trusses and roof framing from the core units of the qualification. I understand



that traditional roof framing is less popular today than it has been but every dwelling must have a roof.

I can also count on one hand the number of carpenters that I have assessed that are required to use elevated work

platforms. This is not a core requirement for a carpenter.

Other comments: I do not see the relevance of the included core units CPCCCM3001 and CPCCLSF2001. It is very rare for

a carpenter to use an elevated work platform and even rarer for them to build scaffold. I have always felt that the current

restricted height scaffolding unit was not really relevant in its current form. It may be allowable for a competent person to

build a scaffold up to 4 metres but what builder is going to let anyone other than a licensed scaffolder do it. Carpenters

definitely work on scaffold and I think that CPCCCM2010 is a good inclusion. Operate elevated work platforms and basic

level scaffold licence should be elective units.

I have a major concern with the removal of the roofing and flooring units from the core units. I have not come across a

house yet that doesn't have a roof or a floor. Even dwellings that are of concrete slab construction can often be two storey

and include a timber floor structure. Also, timber decks are an extremely common activity. Also, roofing, either trusses or

traditional, are common place is new construction, renovation work and multi-residential (unit or townhouse) work.

I think the inclusion of windows and doors and installing lining and panelling, etc into the core units in good as these are

common tasks for carpenters.

I question the need for explosive power tools as a core unit. Again, it may be common for formwork or commercial

situations, but it is not very common in residential work today. They are just not used. It would be a good elective unit. I think

that installing exterior cladding is a more common activity.

From my experience, framing and fitting wet areas is more common for carpenters in the project home industry but not as

common as roofing, so I do not understand its inclusion as a core unit in place of roofing.

Page 9 of the Development Strategy outlines the various activities undertaken by a carpenter, including "framing, flooring,

wall cladding and roofing". It also states that "the carpenter constructs the frame, lays flooring, external framing and installs

roofing and eaves." Finally, it states that "Roofing is an essential part of the residential carpenter’s work". Why then would

roofing and flooring be removed from the core units?

The formwork elective stream is a good idea but a person in this field will still need to do a further 5 elective units which,

apart from 2, generally do not have a lot to do with formwork. I understand this is a difficult one and it would be easier if

there was a licensing authorities created a formwork licence, rather than the one carpentry licence.



Finally, I think that the joinery machine elective units are not relevant to a carpenter. It would be extremely rare for a

carpenter to use such machines. They are more likely to install joinery items, such as cabinetry, vanities and even kitchens.

15.2 28.1.15 RTO, QLD Other comments on Development Strategy:

From a carpentry perspective, I have concerns about the Workplace Functional Analysis and the choice of organisations

that were visited.

For carpentry, 2 commercial projects were visited (both of the same builder) and only one residential project was visited. The

residential project was renovation work.

I am concerned that research was not undertaken on more residential projects and in particular, no new project housing

projects which are a major employer of carpenters.

According to a Queensland Ministerial Industry Commission Annual Skills Priority Report 2014, it is the residential

construction sector, and in particular the lower level residential housing sector that is forecast to have by far the most

growth. I would suggest that this would be fairly consistent across the country with the slowing of the mining sector, where a

lot of carpenters disappeared to.

I don't think that the proposed unit structure of the qualification recognises this and I believe it is more in line with the

commercial sector.

I do not think that the industry was properly represented in the WFA. Three sites - two of them commercial - is not a true

reflection of the carpentry trade. I think that this is also reflected in the proposed core units.

I have been a carpenter/builder for over 20 years and I have been involved in the training and assessment of the carpentry

qualification for the past 7 years. In that time, I have visited very few carpenters that work in the commercial sector. There

have been a number in the multi-residential (unit or townhouse) sector but most in the single dwelling residential sector.

I do, however understand that the commercial carpenter exists and needs to be reflected in the qualification. Their roles are

by including panelling, moulding and doors and windows in the core units. I don't think that 3 new core units around working

at heights is reflective of any carpenter.

With all due respect to the Project Reference Group, I do not feel that industry has been fully represented here either. There

appears to be only one representative that is actually working in the industry proper and they are a stair company. Great for

joinery but not reflective of carpentry. If the qualification is being revised and updated to reflect current industry practice,



shouldn't there be current industry practitioners in the reference group. I am not sure of the relevance of a union

official/representative for a trade qualification. Again, I mean no disrespect to any of the reference group members and I

thank you for the opportunity to provide feedback.

16 28.1.15 RTO, NSW Packaging rules:

1. Add an introductory unit where students gain basic Carpentry skills & knowledge with tools, equipment and materials. This should be basic to all training and completed before all other units are engaged. This creates the opportunity to gain

experience in a range of tools, equipment & materials handling and allows students to practice the safe set up, use &

maintenance of tools & equipment before embarking on the other units of study.

2. Add a unit of study addressing maths, calculations, geometry & sketching. Many students suffer with low level scholastic skills with literacy, numeracy and geometry. These are building blocks and

underpin cognitive connection to principals that apply to much of the knowledge and application in Carpentry work. I cannot

number the amount of times workers communicate with 3D sketching to help interpret orthogonal site drawings. It is so

important to develop this skill as a communicating tool and it takes some time to achieve. Employing this unit of study at the

start will help improve the NCVER completion rates of apprenticeships which is below 60% and support the current

application of LLN.

3. Make all the framing units core including floor, wall, ceiling, roofing and eaves as well as trusses. a. Note: Frame & fit wet areas to be incorporated into wall framing; this unit is develops no Carpentry further

skills compared to framing; it only develops knowledge of fitments, their required setout and any accommodating blocking, trimmings, cut outs etc. to support the finished product installations.

An employer has reasonable expectations that a Carpenter can perform any framing work on a job site.

4. Add enough joinery units to help develop fine motor skills and broaden the training and practice with tools & equipment. Include manufacture components, assemble components, and prepare for off-site manufacturing & use of static machines.

All Carpenters should be able to complete a fixout including refurbishing any joinery items and make adjustments to joinery

items on site using both portable power tools and basic static machinery.

5. External stairs & balustrading must also be core to the skills of a Carpenter. This unit helps develop many skills relating to setting out, geometry, levelling and calculations. It also helps develop

understanding with external materials, treated materials, fastenings and their protective coating systems, weathering &

corrosion and forces and loads on balustrades. Stairs are required on job sites as temporary as well as permanent and help

with site safety and temporary access during a job. So it is important that a Carpenter can make a set of stairs and it is



reasonable that the employer can expect the same.

6. Windows, doors, cladding & lining. (Also eaves construction is required here) These units become holistic because they all come together and must be considered in the process of addressing flashings

and finishes to a variety of different structures and material combinations. Add to this the need to address load paths, eaves

finishes, deflection, required gaps, installation requirements with different products to different materials and structures, the

drop off and bellcasting mean the eaves construction and roof finishes become part of the holistic consideration when

leaning how this all relates.

7. Formwork & falsework units of stairs & ramps and elevated slabs, columns, beams & walls. These units provide so much knowledge and skill development with levels, setting out, angles, slopes, sketching, working

back from the finished product, load path principles, stripping and demolishing, reclaiming materials, calculations and so

much more. These skills can be applied to many areas of building that they help develop the holistic carpentry skills and

improve the output of a Carpenter. These units as core also mostly address the formwork and falsework course skills

especially when they are supported by the other units in the course.

16.2 28.1.15 RTO, NSW Other comments: Core units must include:

1. Introduction to Carpentry a. This maybe the Undertake a basic construction project unit>

2. Maths, calculations, geometry & sketching 3. Read and interpret plans and specifications 4. Carry out setting out 5. Carry out levelling operations 6. Carry out excavation 7. Carry out concreting to simple forms 8. Place and fix reinforcement materials 9. Install flooring systems 10. Construct wall frames 11. Construct ceiling frames 12. Construct pitched roofs 13. Construct eaves 14. Erect roof trusses 15. Manufacture components for door and window frames and doors or

16. Manufacture joinery components 17. Assemble components 18. Prepare for off-site manufacturing process 19. Use static machines



20. Refurbish timber sashes to window frames 21. Install lining, panelling and moulding 22. Install and replace windows and doors 23. Install exterior cladding 24. Construct timber external stairs 25. Construct, erect and dismantle formwork for stairs and ramps 26. Erect and dismantle formwork to suspended slabs, columns, beams and walls 27. Work safely at heights 28. Basic licence scaffolding.

16.3 28.1.15 RTO, NSW Other comments on Development Strategy:

I have just spoken to a small builder on the Northern Sydney Peninsula and shown him the draft copy of the new Carpentry

course. He is very unhappy with the draft especially if it is close to the final product.

I have taught Carpentry for over 20 years and had a builders since 1983 and cannot believe that this draft is worthy of

consideration at all. It is a waste of time when the draft is not even close to what the current caretakers of industry training

should be administering.

Employers have an expectation when a certificate 3 qualified Carpenter works on a job. Employers do not request the

transcript checking to see what units of study have been completed so they can work out what Carpentry work they are

equipped to perform. Employers cannot and do not work this way as stated to me by the small builder.

The employer requires a Carpenter to have a full and broad range set of skills accompanied with the knowledge to help

problem solve a vast range of issues that arise on any job. Problem solving improves with greater knowledge and skills. This

improves productivity and efficiency as well as keeping a safer site. It also reduces mistakes, improves customer service,

and reduces insurance issues and increases taxes to the economy through increased profits. Truncated training truncates

the economy which will be the outcome from this draft if it is anywhere near the final product. Proper training improves the

economy.

Every small builder that I have had the privilege of dealing with over the years has the reasonable expectation that a

qualified Carpenter can complete any framing work, a fair amount of formwork, setting out, levelling, basic concreting and

reinforcement, most on site joinery work which includes full fixout, manufacturing components or adjusting components on

site using power tools & equipment as well as refurbishing frames and sashes. They also expect the carpenter to be able to

clad and line, address flashing with the installation of windows and doors.



The 28 core units help develop a true Carpenter with a broad range of basic skills & knowledge expected by small business

industry. Any other skills will be specific and can be met through the consultation and set up as commercial offerings.

Anything less than this will damage small business and the economy.

18 29.1.15 RTO, NSW Packaging rules - The proposal put forward by TNE base the Certificate III in Carpentry qualification on the fundamental

skills and knowledge for a residential carpenter as described by licencing regulators.

Packaging rules. To achieve this qualification, competency must be demonstrated in:

22 units of competency

18 core

4 elective Proposed core units (18)

CPCCOHS1001A Work safely in the construction industry

CPCCCA2002A Use carpentry tools and equipment

CPCCCA2011A Handle carpentry materials

CPCCCA3002A Carry out setting out

CPCCCA3003A Install flooring systems

CPCCCA3004A Construct wall frames

CPCCCA3005A Construct ceiling frames

CPCCCA3006A Erect roof trusses

CPCCCA3007B Construct pitched roofs

CPCCCA3008A Construct eaves

CPCCCA3023A Carry out levelling operations



CPCCCM1015A Carry out measurements and calculations

CPCCCM2001A Read and interpret plans and specifications

CPCCCA3010A Install and replace windows and doors

CPCCCA3013A Install lining, panelling and moulding

CPCCCA3016A Construct timber external stairs

CPCCCA3018A Construct, erect and dismantle formwork for stairs and ramps

CPCCCA3017A Install exterior cladding

Electives (4)

4 units may be chosen from other Certificate II, III and IV qualifications in CPC.

18.2 29.1.15 RTO, NSW Other comments - A YouTube video was produced in consultation with highly regarded carpenters from both metropolitan

and regional NSW. The level of concern in relation to CPSISC proposed Certificate III in Carpentry is high; the video

received 123 views within the first 24 hours. We strongly encourage the Skills Council to view the video and refer to the

comments from the various construction industry representatives.

23 30.1.15 RTO, QLD Packaging rules - High concern regarding the lack of 1000 & 2000 series units for Stage one or School-Based apprentices.

It would be difficult for these apprentices to progress and satisfy 3000 series units’ competence as they require basic training.

The proposed Level 3 OHS unit would be difficult for School-Based or Stage one or two apprentices to demonstrate competence. We agree writing SWMS should be included in the apprenticeship however, believe it is more suited to be included in a unit which involves high risk activities. E.g. erecting roof trusses.

Stage one & School-Based apprentices need basic training in safety, tools and material handling. Employers require this for peace of mind, in knowing that their apprentice is safe to work on the worksite.

It is strongly recommend CPCCCA2011 Handle carpentry materials & CPCCCA2002 Use carpentry tools and equipment be included as core units.

Read and interpret plans and specifications should remain as a 2000 series unit as it is an introduction to stage one apprentices and provides a basic understanding. The 3000 series concepts of plan reading and specifications are already included in 3000 series units eg CPCCCA3004 Construct wall frames.

CPCCCM1015 Carry out measurements and calculations needs to remain as a core unit, as it introduces apprentices to the basic concepts and formulas in stage one. This allows the apprentice to build underpinning skills and knowledge



required to successfully understand basic formulas. This leads to greater understanding and implementation of more complex calculations in the 3000 series units.

CPCCCM2002 Carry out excavation needs to be included as an elective. Desirable unit for the residential industry.

CPCCCM3001 Operate elevated work platforms up to 11 metres should be an elective. The experiences and exposure of an apprentice would be limited for this unit if the in the employer was a residential carpenter. This would result in apprentices needing to be hosted out to other employers for the range of work.

CPCCLSF2001 License to erect, alter and dismantle scaffolding basic level is over kill for carpentry apprentices and should not be a core. Most apprentice carpenters will not be exposed to cantilevered materials hoists with a maximum working load of 500kg, ropes and gin wheels, safety nets and bracket on-the-job as required by the unit. Suggest unit become an elective and existing CPCCCM2008 Erect and dismantle restricted height scaffolding be included as core unit.

Other comments

The proposed Certificate III in Carpentry qualification doesn’t allow for the majority of apprentices to complete the required number of units to meet industrial wage progression.

Due to the high risk involved with an apprenticeship, we need to be supporting, training and developing apprentices’ skills and knowledge for the Construction Industry. It is essential for Stage One apprentices to be trained in basic hand tools and safety units to ensure they are able to work safely to industry standards

It is unrealistic to expect Stage one apprentices to gain competency in six 3000 series units of competency that is

required for wage progression. The suggested core structure does not suit residential builders, who train the majority of

Australian Carpentry apprentices. Advice was received from CSQ that approximately 80% of apprentices are employed

by residential Carpenters/Builders.

25. 30.1.15 RTO, NSW I strongly object to the statement (p19) The Certificate III in Carpentry would also encompass the units necessary for a

carpenter to undertake joinery activities required as part of a fit-out in a residential setting and also accommodate the

importation of shopfitting units that would support specialist functions in the commercial sphere.

There is already a well-established Shopfitting training package (currently under redevelopment by CPSIC) designed

specifically for the requirements of Shopfitters working in the commercial sphere.

The issue is that the proposed Carpentry qualification is in danger of becoming a one size fits all course, to the detriment of

apprentices from the Shopfitting trade. Potentially, students will learn generic Carpentry skills with a few specialist

Shopfitting units tacked on.

The result is likely to be the erosion of the specialised skills base of a trade already identified as a skill shortage area.

I support the deletion of the Carpentry and Joinery qualification as there is a clear distinction between Carpenters and



Joiners in the current workplace. The packaging rules will allow enough flexibility for the small number of apprentices who actually do work across both trade areas.

26. 30.1.15 RTO, NSW Packaging rules are fine. (14 Core & 8 Electives)

Selected Deletion:

Relocate the following 3 core units into elective group;

1. CPCCCM2010 Work safely on scaffolding above 2 metres 2. CPCCLSF2001 License to erect, alter and dismantle scaffolding basic level (NB not to be redesigned) 3. CPCCCA3012 Frame and fit wet area fixtures

Selected Additions:

Promote the following 3 electives to the core group:

1. CPCCCO2013 Carry out concreting to simple forms 2. CPCCCA2003 Erect and dismantle formwork for footings and slabs on ground 3. CPCCCA3016Construct timber external stairs

Incorporate all electives into one group.

Other comments As a Carpentry discipline, the above recommended deletions and additions reflect the overall carpentry

scope of works in building and construction industry sectors.

Deleting Units CPCCCM2010 & CPCCLSF2001, eliminates the potential duplication and the likelihood of disadvantaging

participants from course completion as a result of high risk work licensing requirements. (WorkCover NSW)

30. 02.02.15 RTO Network, VIC Packaging rules - The proposed new core levels include, CPCCCM3001 Operate elevated work platforms and

CPCCLSF2001 License to erect, alter and dismantle scaffold basic level, these units should be electives as they would not

as important to the majority of apprentices as hand tools, install flooring systems or trusses.

30.2 02.02.15 RTO Network, VIC Other comments The Core Field of Work units define Certificate III in Carpentry: Construction and erection of frames,

trusses, eaves and roof field of work, they missed fixing and finishing.

Yet installing flooring systems, and erect roof trusses are not core units.

It is proposed that a numbers of units be deleted and embedded in relevant units of competency, the only units that I see



could be embedded are:

CPCCCA2011A Handle carpentry materials.

CPCCCA1012A Work effectively and sustainably in the construction industry.

CPCCCA1013A Plan and organise work

CPCCCA1014A Conduct workplace communication.

Two units that should not be deleted are CPCCA2002B Use carpentry tools and equipment.

CPCCCM1015A Carry out measurements and calculations.

The safe and correct use of hand and power tools cannot be embedded in other units.

We have a large number of apprentices who left or were not interested in schooling and have low numeracy skill levels and

need extra training in this area.

The WFA did not reflect where the majority of apprentices are employed, by small builders or sub-contractors who employ

one or two apprentices in the domestic housing industry. The WFA should have included RTO’s teaching the assumption

that Carpenters only do framing and the fixing tasks are done by Joiners and that Joiners come in to fit internal doors and

architraves is an incorrect one..

31 02.02.15 RTO and Industry

Association, SA

Thank you for the opportunity to respond to the draft development strategy for the Carpentry related qualifications. As the vast majority of our core business is related to employment of apprentices in Certificate III Carpentry, I have limited my initial response to this qualification only.

31.2 02.02.15 RTO and Industry

Association, SA

AQF Level 3 - The concept of lifting the majority of the units to a level 3 is in principle a sound move. Myself and field officer

staff often find ourselves dealing with host employers who are disheartened by the lack of underpinning knowledge and skill of a new apprentice who has been deemed “competent” by an RTO in a level 1 or level 2 unit but cannot demonstrate this skill in at a level required in the work place – CPCCCM2001 Read and Interpret Plans is a classic example where the level of the unit is below that of the real work outcome. My main concern lifting to all level 3 units is that there is still a recognised pathway for VET students to follow. This may require a mechanism for recognition of underpinning knowledge and skills achieved in a lower level unit completed outside of the apprenticeship without the unintended disastrous consequences of previously achieved units impacting on starting pay scales under the Competency Based Wage Progression (CBWP) clause introduced to the Building and Construction General On site Award, effective January 1, 2014.




Association, SA

Deleting of Asterisk marked units

My concern here lies specifically with the removal of CPCCA2002B Use Carpentry Tools and Equipment as a standalone unit. Many RTO’s preferred to conduct the training of this unit over a period of time during several other carpentry specific units and I can see the logic in the proposed embedment of this unit into other units of competence. The main issue in the past from an employers’ point of view is that this could be across several years of trade school. With the change in WHS regulations this unit, if front loaded into the Delivery plan, has assisted many employers with injury prevention / reduction and / or showing best practice / compliance if in the unfortunate event of a post injury enquiry. This is a difficult one for carpentry apprentices as they tend to come across a diverse range of hand power tools very early in the apprenticeship in order to be “useful” on site.


Association, SA

Development of Assessment Requirements

Again as per the Award and linked to CBWB, it is important to address the definition of “Competence” and “the standard of performance required in the workplace” when considering the assessment criteria in the training package. Most “Overview of Assessment” statements for each unit include “…could be assessed in the workplace or a close simulation”. As stated in the review – the mandatory conditions under which assessment is to be conducted and evidence gathered needs to take in to account the requirements of a workplace and so if the training and assessment are to be conducted off site in a simulated work environment by an RTO, then additional assessment requirements may need to be included in order to attain “Competency Achieved”


Association, SA

Packaging Rules

Page 9 of the Review document states “…recognises the requirement for contemporary construction techniques…” and “…flexible use of electives” It is vital that if appropriate core units are narrowed to specific units related to that field of work, then the selection of electives need to be flexible to allow recognition of skill and knowledge development associated with the type of work undertaken by the apprentice with their host / employer. Having the old packaging rules of only allowing 2 units from outside the included list is often counterproductive to meeting the needs of the workplace and forces apprentices to choose ‘non desirable/useful’ electives from a limited list. This an important change to made to keep the revised training package contemporary. Please see my comments below on some specific unit inclusions I feel are not appropriate in this draft review:


Association, SA

Core

CPCCCA3001 Carry out general demolition of minor building structures. Residential first fix framing and commercial carpentry is predominantly conducted on green field, new build sites. Include in Electives – not Core

CPCCCA300x Set-up Operate and maintain explosive power tools Explosive power tools have evolved to have a range of tools on the market from various manufacturers that operate as per a



gas gun for framing nails. This combined with many commercial sites insisting on exclusion zones and/or limited times of operation for risk minimisation has virtually made the old “explosive” style gun obsolete. Include in Electives – not Core

CPCCCA3012 Frame and fit wet area fixtures This is an outdated unit in contemporary house construction. Many project home builders and common practise amongst general building renovation involves bath frames to be built up from hebel (or similar) by the tiler. If a bath frame etc does need to be constructed by the carpenter, there is nothing much new here that isn’t covered in wall frame construction. Include in Electives – not Core

CPCCCA3013 Install linings panelling and mouldings. This unit needs to be revised to embed the mouldings component incl skirting, nosings and architrave as an integral part of CPCCCA 3010 Install windows and doors. The lining component can be incorporated in to an elective unit from the Wall and ceiling training package as an elective unit on the carpentry list. This would assist general builders and commercial builders with a relevant elective choice CPCCLSF2001 License to erect, alter and dismantle scaffolding basic level. With high risk licensing coming to the fore, I believe this is a positive step towards revamping the old restricted height scaffolding. However it does need to be considered with caution (or as an exit point from the carpentry qualification) where apprentices may be tempted to leave to chase short term higher paid scaffolding work instead of completing the carpentry apprenticeship / qualification Electives

CPCCCA 3020 Erect and dismantle jump formwork This needs to be included in the Group A Formwork electives CPCCCA 3021A Erect and dismantle slip formwork Is now not on list but should remain in formwork electives CPCCCA3005 Construct ceiling frames (and pitched roofs) The title descriptor should read the other way with a focus on Pitched roofs (incl Ceiling frames) CPCCCA3014 Construct bulkheads The evidence guide for critical aspects for assessment for this unit needs to be reviewed to remove the limiting parameters of curved, segmented and specific depth. Many carpenters construct bulkheads to hide mechanicals around room perimeters or in residential applications to lower ceilings over cupboards etc. there is good scope to assess this unit on those applications without the particular requirements of the existing unit. Other Electives to include on list Many Commercial builders and General builders in the residential sector that build from start to finish, engage carpenters and carpentry apprentices on a variety of aspects of the job and need to have flexibility in choice of electives to suit their workplace requirements. Some of these electives should include:



CPCPRF2022 Select and install roof sheeting and wall cladding. This unit dovetails nicely with CPCCA3017 install exterior cladding Note: It has a WHS prerequisite which could easily be considered is better than the existing CPCCOHS2001A currently included in the carpentry core units Various units from the Wall and Ceiling Lining package should be included on elective list to complement / replace linings, panelling & mouldings. Eg: CPCCPB3001 Fix standard plasterboard wall sheets CPCCPB3002 Fix standard plasterboard ceiling sheets CPCCPB3009 Finish plasterboard joins manually + more Thank you for your time and consideration regarding my input for this review. Please don’t hesitate to contact me should you wish to discuss any of the aspects mentioned above or any other points of interest.



General Feedback Raised by Industry, Regulators, Associations, Others

4 8.1.15 Industry Association,

SA

Packaging rules - Not having CPCCCA3005 Construct Ceiling Frames (and Pitched Roofs) as a core subject is a concern.

While I understand that the majority of roofs are truss frames i feel that the pitched roof construction needs to be a core

subject.

In order for the Carpentry qualification to be of value it needs to include all the subjects that enable an apprentice to

understand the whole framing construction process. This includes pitching roofs to join into existing roof structures.

CPCCCA300X Set up and maintain Explosive power tools could be made an elective or be included as a cert 1 subject

5. 8.1.15 Industry Association,

SA

Roofing should be a core subject. There is a belief that unfortunately is a fallacy that we no longer undertake pitched or cut

roofing, which simply isn’t true. In SA alone they still pitch about 40% of roofs, not to mention the use of cut roofs in the

renovation and extension market. That aside it is quite incomprehensible to think that we don’t even intend to include

erection of trusses as a core module; again particularly in SA where they have gone to such great lengths to make sure

that they are done properly following the coronial enquiry into the golf club collapse.

That aside, the one major reason however for the retention of roofing as a core unit is not related to roofing at all. When

we learnt to set out and cut a roof and without knowing it at the time, we were actually learning to solve 3 dimensional

geometry/trigonometric problems in a practical manner. In doing so it sets us up to be able to solve any problem that a

carpenter may encounter, be it formwork, splayed awnings and hoods to even planter boxes. So the thought process is the

important factor, not cutting the roof.

Finally there is an ongoing attempt to dumb down the industry because it suits some entities within the

industry. Irrespective of whether it be a Certificate 3 or 4; if this trend continues rightly or wrongly, it opens the door for

greater intervention via regulation of our industry by the bureaucrats and gives society the impression that we are all stupid

and uneducated rather than being the skilled industry we need to be. I think if we surveyed the right people in our housing

industry I believe most would hopefully agree with what we are saying.

6 14.01.15 Regulator, QLD

Packaging rules - As the building and construction industry regulator in Queensland, part of the Queensland Building and

Construction Commission’s (QBCC) role is to issue trade contractor licences to appropriately qualified tradespersons. The

licence allows that person to contract to a builder or homeowner to carry out building work. The client (the builder or

homeowner) will have an expectation that a licensed tradesperson will have the necessary knowledge, skill and ability to

perform their role. The technical qualification requirement to obtain a QBCC carpentry licence is the Certificate III in



carpentry.

We recognise the fact that the current qualification contains adequate core units across the trade to enable the person to

perform the role of a carpenter in the industry.

The core units, in this current draft however, do not cover across the range of work undertaken by carpenters sufficiently.

There is a gap in the core units that industry will expect carpenters to be skilled in.

The following units should be retained as core units –

CPCCCA3003 Install flooring systems

CPCCCA3005 Construct ceiling frames

CPCCCA3006 Erect roof trusses By including the 3 units above, you will be providing peace of mind to builders, homeowners, regulators and the industry

that the Cert III qualified carpenter has the necessary skills across a sufficient range of carpentry work.

You may elect to drop one or more of your proposed core units to accommodate the above request, for example –

CPCCCA300X explosive power tools

CPCCLSF2001 basic scaffolding It is imperative that Cert III level qualifications reflect the work undertaken by tradesmen and that the mix of core units

reflects the majority of the trade.

12 22.1.15 Industry, QLD Packaging rules:

Less core and more electives is a good thing

Pitched Roofs out of core is a good thing

The statement-“The elective units must ensure the integrity…” etc is too wafflely and open to interpretation and exploitation

4 electives may come from any other training package or course with no limits on mix of AQF levels is an invitation to some RTOs to pick a bunch of ‘soft’ Cert II competencies which will = 25% of the qualification and will not equal a carpenter.

There are so many performance criteria, critical aspects etc in each of the 1000 and 2000 units that they would have to be watered down to all be integrated in the “field of work” units

Reducing the overall size of the qualification cold invite state governments to reduce User Choice funding

Having wide differences in what the Cert III qual. Represents will present a problem to licencing authorities who base licences on a particular qual. Will they have to specify particular competency mixes?



Why have a competency related to just working safely on a scaffold instead of using the existing working at heights which covers all contingencies?

How much demand is there for curtain walling?

Why are there so many joinery competencies?

13 27.01.15 ITAB, NSW

New South Wales has averaged over one hundred Apprentice commencements in CPC31511 Certificate III in Formwork

and False Work over the last ten years and the forecast is that number will increase significantly between 2015 and 2020.

Considering the support that industry has given this apprenticeship and the forecast that this support will increase, the

amalgamation of this qualification as specified in the development strategy is not supported by stakeholders in New South

Wales.

Should the development strategy be implemented and the elimination of a standalone Framework and False Work

qualification occurs there will be considerable difficulty gaining New South Wales stakeholder support for the endorsement

of the new qualifications.

17 28.1.15 Industry, VIC Packaging rules - Although I am a Carpenter and Joiner by trade, I have specialized in Staircase building for the last 45

years and feel that I don’t possess the expertise to make comment on the proposed changes to Certificate III Carpentry

Package

19 29.1.15 Employer and RTO,

National

Packaging rules - Both CPCCC A2002B Power and Hand Tools and

CPCCC M1015A Carry out Measurement and Calculations withdrawn from Cert III curriculum in sample A.

Concern that removal of CPCCC A2002B Power and Hand Tools and CPCCC M1015A Carry out Measurement and

Calculations.

These particular modules establish foundation skills, underpinning knowledge and attitudes prior to progressing onto the

more technical training modules. They provide an indication of abilities and learning difficulties early in the initial stages of

the trade.

20 30.15.15 Industry, VIC Packaging rules - The Operating Elevated work platforms unit should not be included at all and especially as a core unit. It

is not a general requirement on most building sites or of any carpenter and would be done as site specific training.

Constructing floor framing should be a CORE unit and not an elective.

Other comments - Every carpenter should be trained in the construction methods and types of flooring which form a

fundamental part of every building. When erecting load bearing walls or pitching a roof why having a good understanding of



floor construction methods and their reasons is clearly described in AS 1684.4.

21 30.1.15 GTO, SA Packaging rules

• Measurements and Calculations needs to remain as a core unit however upgraded to include basic trigonometry as this is one area that most students struggle with

• Read and Interpret the Timber Framing Code to be core subject in Cert III Carpentry

• Why have two units of competency in the core units that involve scaffold above 2 metres AND licence to erect scaffold (above 4m) and no unit that covers working at heights i.e. use of harnesses on commercial buildings and structures ?

• Bulkheads should be combined with ceiling frames and not combine ceiling frames with pitched roofs. This combination misses ceiling frames with Trusses

• Wet Areas should be an elective

• External Cladding to align to current industry needs i.e. – Hebel type cladding products

• Steel Framing needs to be a stand-alone subject as an elective and not within Wall Framing

• More choice in the number of electives from other qualifications is a good move as training plans can be tailored to suit the particular requirements for the employer

• Move Process materials using static machines to Cert III Joinery

• Move Produce components with CNC to Cert III Joinery

• Move Manufacture joinery components to Cert III Joinery

• Move Refurbish timber sashes move to Cert III joinery

Other comments: Consideration should be given to the apprentice’s ability to move into different fields of work, post

apprenticeship and provide apprentices with core units that are considered to make a good all round Carpenter and not just

a specialist because of their host employer’s type of work. The choice of core units should be chosen as an Industry

reflection of contemporary work so a modern all round trades person has the ability to move into other areas of construction

where the demands exits.

A suggestion would be to broaden the number core units and lessen the electives to suit their employer’s requirements.

Other comments on development strategy

• At no stage should the trade qualification be watered down with less nominal hours however unit nominal hours will need to be upgraded to encompass embedded deleted core units

• Core Units that are not able to be consolidated on site may need repetition OFF SITE - funding issues for the RTO if an apprentice needs extra practice in line with CITB my profiling

• Not all core units in Sample A are experienced in the 2 main areas of employment of Carpentry apprentices in South Australia and are able to be consolidated on site i.e. 1st fix and 2nd fix



• More consultation with all Industry needs to be carried out as a full analysis of what are the ramifications of having pathways for VETis not aligned to the trade pathways needs to be considered i.e. SACE requirements, eligilibilty for funding, partial RPL for cert 3 units.

22 30.1.15 Industry Association,

WA

Other comments on development strategy: Firstly, we believe the whole idea of further diversification (Dumbing down)

of the Carpentry & Joinery qualification is a total waste of tax payers’ money. The views and comments are formed from

communication with apprentices, parents, industry members, colleagues, industry contact and employment, and years (in

some cases 50+ years) of first-hand experience and involvement in the B&C industry in WA. Secondly, it appears that the

whole concept mentioned in this epistle is flawed – to the extent that only five (5) industry practitioners have been sourced.

(out of how many in Aust.) – We also believe you have not attempted to ask the right people (carpenters ) for their

comments – other people (stakeholders) in the industry seem to be the only people sourced for surveys, with most having a

complete “conflict of interest” as there main input.(builders, private RTO’s and people that do not employ apprentices)

Thirdly, in our experience as industry practitioners we have found, over the years that if a tradesperson only has specific

“skill sets” e.g. only specialist skills and/or qualifications, their employability is very very limited – with the ups and downs of

the industry over the years. In saying this, what needs to be considered is, that there are only two avenues of employment

for people in the B&C industry – wages, not many positions, self employment is the only other option. In W.A we have

apprentices finishing their apprenticeship today, and becoming self employed sub-contractors the next day. All without any

business skills/training whatsoever. This situation is exceptionally good for the unscrupulous builders, who take advantage

of this situation. At some stage in the future we believe “registration” of all building trades in Australia will occur. Any further

“dumbing down” of the qualifications will prove detrimental to this end. Further comments can be provided at a later date

from Fred Sharp, [email protected] or phone 0427 084 991.

24 30.1.15 ITAB, QLD

Concerns that qualifications that currently have between 60% and 75% of competencies based on units coded 1000 &

2000 can be changed to having all 3000 series units without opportunity for progressive skills development.

The argument presented is that each competency should have a work level outcome equivalent to the qualification level. A

trade develops over a period of time at levels of work outcomes. As such an apprentice could not be expected to

demonstrate many of the higher level skills, knowledge and cognitive ability until half way through their training contract. A

qualification with only AQF Level 3 competencies would prevent an apprentice gaining recognition of national competence

early in their trade. This would mean they would not have portability of nationally recognised skills and knowledge until well

into their training contract.

This lack of portability could distract a career seeker from entering the industry.

Competencies are not intended to be delivered in isolation. They are considered to be included in a group of work tasks

that allows demonstration of the skills and knowledge over a period of time and a range of situations at the required level of

mailto:[email protected]



workplace competence.

The proposed package now has competencies that were previously integrated into higher level work skills (read and

interpret plans integrated into roofing competencies) being delivered as standalone AQF level three (3). Does this mean

they are still entry level competencies but now with a AQF level 3 classification?

Other comments - Carpenters undertake a broad range of tasks which include setting out, fabricating, assembling and

installing parts or components of building structures. The work of a carpenter has real-world application in the construction

or renovation of residential buildings.

Commercial companies indicated that ‘while the Certificate III in Carpentry is oriented towards residential carpentry work,

the fundamental skills and knowledge developed in the qualification, are transferable to a commercial building project’

The extensive description of what a carpenter does, including aspects of joinery and stair making is comprehensively

different to the role described for a commercial carpenter who does Formwork/ Falsework.

The intended package indicates that a commercial carpenter who develops fundamental skills and knowledge is qualified to

operate as a residential carpenter. The training package and associated assessment must ensure that if competency is

gained it must be demonstrated in an appropriate workplace over a period of time and a range of situations.

Table supplied indicated broad descriptions for carpentry, joinery and stair making. Again many of these attributes would

not apply to a form worker.

Evidence suggests argument evolving to support commercial construction worker as separate – same as joiner, stair

builder. Recommend: Certificate III in Carpentry – Commercial.

Other comments on development strategy: The six skills listed in the review document are integral to the development

of an apprentice over the life of their training contract. As developmental skills, the Training Package must enable

opportunities for these skills to be enhanced as the apprentice grows in the trade. The cognitive abilities required to be

demonstrated by a final year apprentice/tradesperson/worker seeking skills recognition are comprehensively different to an

early stage apprentice. Safe work practices underpin the daily life of a tradesperson but again there is a significant

difference in understanding and managing risk between levels of apprentices/tradespeople.

The consultation process does not demonstrate that a concerted effort was made to reach the major user group of the

qualification – Small to Medium Enterprise employers.



Queensland data indicates that a significant proportion of carpentry apprentices are employed by SME’s with either 1 or 2

apprentices. The nature of work conducted by these SME’s, which reflects the larger portion of Training Package users

would not require their workers to gain and maintain a scaffolding licence, or have a need to operate an EWP.

Summary

There is agreement that the qualification should be robust yet succinct.

Is ‘cutting and pasting’ the most appropriate way of developing a shorter but succinct course?

Should new competencies be developed within work groups that relate to ‘real site practice’

The data gathered from surveys is not considered comprehensive enough to represent the majority of the industry that

uses this training package, I.e., SME’s

Level 3 AQF requires a worker to demonstrate that skill/competence at that level 3. An apprentice would not be able to

demonstrate that level until the later part of a second year.

This would mean lack of portability for skills transfer – 18 months + before formal recognition can be given

RTOs could be forced into a competency ‘sign off’ to meet state funding models

To demonstrate AQF level 3 an apprentice will require considerable time on site to develop the skills and knowledge

required.

In reality will an apprentice carpenter on a commercial site gain that amount of off-site residential exposure required to

demonstrate competence.

The use of a license competency could not be justified on small residential builds – the major users of this package

Work Function Units are referenced for having 1000 &2000 series competencies embedded yet proposed model has

those competency titles identified as stand alone (eg. Read and Interpret Plans and Specifications

No clear evidence supplied for Pathways from entry level qualifications to Cert. III

27. 30.1.15 ITAB, SA The key aspects CITB is commenting on are about the Development Strategy. Accordingly, comments about the specifics of qualifications such as on the packaging rules are covered in the ‘other comments’ below. Key points: CITB cannot emphasise strongly enough, that the review of the Carpentry cluster of qualifications should not be

rushed through in its current form. Our principal concerns which are developed more fully below are:

SAFETY. There is very grave concern that the proposed structure poses risks to trainees employers and training

providers, with fundamental safety elements no longer front and centre in the consciousness of participants.

Underlying justification / reason for change. It is the conviction of stakeholders that the alignment between the

substance of the proposal and earlier industry input is not evident. Neither might we add, is the reason for the “streamlining



rules” in the first place.

Sequencing of change. Changing the end-state qualification first, followed by lower level precursor qualifications later is

neither logical nor sensible.

Need further research and to better consult with industry

27.2 30.1.15 ITAB, SA The Workplace functional analysis as described appears very limited. o We do not believe the sample size of entities consulted is big enough To derive valid conclusions to be applied

across the country. o In order to achieve its objective, (page 3 of the DS) a proper consultation with companies undertaking diverse work

across the industry, sub-contractors and trades in particular needs to be undertaken to understand the national picture.

o CITB would be willing to assist, as we have with a number of consultation matters, with a proper consultation outcome being attained in SA.

o Cannot see evidence that the CPSISC VETiS Report was part of the planning for this review – it appears to be absent. (J. Holst)

In consultation with the RTOs, we have become aware that the reported enrolments are wrong by substantial numbers. We are happy to provide any amount of detail you wish on this point.

Purpose of the particular proposed changes needs to be clarified

CITB cannot see alignment between the “over-riding consideration in proposing the strategy to redesign the qualifications …” ( p. 6 of the DS) and the review program proposed.

The key themes submitted by industry are listed (p. 7 of the DS), but the concomitant analysis and addressing of issues arising is missing in relation to: o the wider issues that necessarily arise from several of these points o the implications of the proposed changes in relation to these points

CITB’s view is that a very clear shared understanding of Purpose is going to be absolutely vital when it gets to drafting the Units to meet the new streamlining rules and getting it right. o The complexity of a mixed approach of restructuring and streamlining has not been adequately addressed and

the necessary resources to undertake the work properly appear to be missing. o There is no point in drafting the Units if the whole project needs to take a step back and address some key

matters fully before proceeding. o See p. 15 and p. 21 of DS, that the whole of the 1000 and 2000 Units are deleted or embedded into Units that

represent work outcomes How are you going to do this? We need more detail about how it is embedded (J. Holst + common point)

o Safety has been highlighted by the RTOs – see the next heading. Note that the specifics of these points will be addressed below.

Safety (John Holst raised this point and was endorsed by all present)



Safety needs to be addressed as a primary matter right up front in this review process.

In the current course, Carpentry tools and equipment, Handle carpentry materials, Work safely at heights and Apply OH&S requirements, policies and procedures in the construction industry are taught first to first year Apprentices so that they will be able to work safely on site.

None of this is evident in the new course. Competency-based wage progression (CBWP)

This is listed as the second point in industry feedback. o CITB sees CBWP as an industrial matter, with an industrial solution through the wording of the Award. SA, WA

and Tasmania have or are in the process of effecting remediation in this way. o The impact of CBWP is raised but not addressed in the proposal.

Has this influenced the proposed re-structure of the qualification in any way?

o We have not been advised if this is the case, although we note that it was raised in earlier correspondence. We would like to have been consulted about this and for the Development Strategy document to address how this issue has been dealt with in relation to the proposed changes.

o CBWP may be relevant to logistical matters such as scheduling of the completion of reviews of a number of related qualifications for example in terms of possible practical impact but not on the structure/content of individual qualifications themselves.

Sequencing of changes to Certificate 1 and Certificate 2s and the other trade qualifications in the package and

impact on VET in Schools and RTOs need to be addressed.

VETiS

Lack of pathway is the primary matter to be addressed (highlighted by J Holst)

Removal of Certificate 1000 and 2000 Series Units from the ‘Carpentry’ qualification(s) has an impact on VETiS. o If this is to be the final outcome, then a planning process needs to take place around introducing the changes so

that there is not unnecessary short term disruption through needing dual systems and temporary arrangements as essential components of a quality VETiS program dribble through in bits and pieces.

o The practical planning and awareness of needs must to be undertaken to address these issues as the downside risk to VETiS of poorly launched changes is substantial as would be the associated loss for the industry.

o In South Australia’s case we face the risk of an entire year’s worth of VETiS students being dislocated and cut off from the career pathway they signed up to.

Certificate I and IIs

With the restructure of the Certificate III(s) to Series 3000 Units and the removal of the ‘1s’ and ‘2s’ from the existing qualification, the current Certificate I and IIs qualifications need to be part of the same consultation and review process and not handled in a separate consultation so that ‘we’ have sight of where all 3 levels of qualifications are going before ‘we’ sign off on any one.



This could result in the lack of a cohesive pathway between VETiS, Pre-Apprenticeship pathways and employment within the industry. How would this pathway work? (J. Holst)

It appears evident that the current model of working through qualifications and fixing them up in ‘bunches’ will be manifestly inadequate in the face of implementation issues.

If the Cert III is changed first and the Is and IIs follow, there will be massive dislocation of candidates currently in training.

The use of the Certificate I and IIs for VETiS and Pre-apprenticeships needs to be endorsed and (a) listed as not a qualification that leads to an employment outcome and (b) the work to articulate it to a Certificate III comprised of ‘3s’ in place.

Implications for RTOs for delivery and for funding

Reduction in the number of competencies to 22 o Liaison with STAs ahead of any change is crucial. Under extant arrangements there is a high risk that funding will be

cut for the qualification o We need some information on how the hours associated with these proposed Units will be worked out particularly

given assumptions about what needs to be addressed within each of the new Units.

Implementation for RTOs is going to be expensive, disruptive and it must be said offers little in return.

o Development of earlier stage materials o Funding ‘drought’ if the trigger for payment is completion of Units. The RTO are being asked to bear an

inordinate amount of risk. o Support to change over and full planning of interim arrangements. There is no understanding of how this is supposed

to work. o Recruitment to the industry is an ongoing challenge. The training continuum is a key component of the process.

The risks posed by this process are considerable and the returns are neither evident or compelling.

28 30.1.15 ITAB, WA

Packaging rules - The issues we wish to raise are directly related to the Development Strategy, the lack of input from a

wide range of stakeholders and actual people such as sub-contractors who are most affected by the proposed changes

and the impact on articulation of Certificate II courses..

The size of competencies affected by embedding level 2 competencies is of concern as this also complicates any

articulation for courses such as WA VET in Schools and pre-apprenticeship programs.

We will cover other issues relating to packaging rules and specific qualifications in our further comments.

In WA, the major qualification is CPC32011, Certificate III in Carpentry and Joinery. This qualification was developed to suit the requirements for WA and stakeholders do NOT want this qualification removed.



Other comments on development strategy

The Construction Training Fund (the Fund) is extremely concerned that the review of the Carpentry cluster of qualifications

should not be finalised in its current state. There needs to be further research and wider consultation with industry.

The Workplace Functional Analyses (WFA) were far too narrow with only five business workplaces across three states

consisting of;

A small boutique builder undertaking a renovation.

Two business sites being the same company (including own RTP)

A small business in the stair manufacturing sector

A stair manufacturer that concentrates mostly on automated processes using a range of CNC machines.

This demonstrates a lack of adequate industry consultation, especially when a major recommendation is to reduce

competencies and qualifications outside the scope of the majority of the five businesses.

To achieve the Development Strategy (DS) objective (page 3) a rigourous consultation with companies undertaking a diverse range of work across the industry, sub-contractors and trades must be undertaken to encompass a national perspective and not focus on responses from a narrow and small group of industry participants and activity as gathered from the above workplaces.

The Fund and its associated Training Council are willing to be involved in a widespread consultation process in Western Australia.

Purpose of the proposed changes

The Fund and its key stakeholders do not clearly understand the link between the “over-riding consideration in proposing the strategy to redesign the qualifications …” ( p6 DS) and the program proposed.

The key issues and themes identified by ‘industry’ on Page 7 of the DS, but the analysis and addressing of issues arising is lacking in relation to:

o the wider issues that arise from several of these points

o the implications of the proposed changes in relation to these points

The Fund’s opinion is that a clear understanding of Purpose is going to be essential if new units are drafted to meet the streamlining rules.

Competency-based wage progression (CBWP)

The issue of CBWP appears to be a major driver in the industry feedback within the DS. The Fund asserts that this driver has influenced the structure of the qualifications and is therefore viewed as using the Training package and training system to deal with what is clearly an Industrial Award issue.

The development strategy therefore appears, and it is stated in the document (pages 3, 6, 7) to be attempting to



change the qualification and content of competencies to solve an Industrial Award issue (CBWP). The issue of CBWP can, and has been resolved in WA, SA and Tasmania using workable solutions within the VET Regulations. The training system should not be used to address perceived industrial issues particularly as the proposed solution creates more problems than it solves.

28.2 30.1.15 ITAB, WA

Changes to Certificate I, Certificate II and trade qualifications in the package and impact on VET in Schools and

RTOs must be addressed.

VET in Schools

Removal of level 1000 and 2000 units from the ‘Carpentry’ qualification(s) has an impact on VETiS.

The proposal to embed all level 1 (1000 series) and level 2 (2000 series) competencies into level 3 (series 3000) units is

not supported as this will have a highly detrimental impact on Certificate II VET in Schools and pre-apprenticeship

programs, especially in WA.

Although the content is expected to be embedded in level 3 competencies, there will be no clearly defined articulation value

from Certificate II qualifications. This will lead to duplication of training effort of RTPs as they cannot easily confer credit for

part competencies. This is a waste of training effort and funding.

Certificate II Qualifications

With the proposed restructure of the Certificate III(s) to be wholly level 3 (3000 series) units and the removal of the level 1

and 2 units from the existing qualification, the current Certificate I and II qualifications must be included in the same

consultation and review process and not isolated – they are a transitional part of the apprenticeship pathway and are

integral to good practice in VET in Schools and pre-vocational programs. The current Certificate III is integrated as part of

a work based training program within a training contract and should not be viewed as an isolated institutional qualification.

Implications for RTOs for delivery and for funding

A major concern for RTPs and in particular state training providers (STP) is the possibility of reduced funding by reducing

the number of competencies to 22 in a ‘one-size-fits all’ qualification. Consultation with the State Training Authorities (STA)

is required to ensure funding is not reduced for the qualification and that the actual delivery hours required is understood

and supported.

There is no evidence of how the competencies will be aligned to hours of delivery and this is of major concern to WA RTPs.

The RTPs are also concerned about large competencies that may span semesters or years and the implication this will

have on the flow of funding as it relies on ‘completion of competencies’

MAJOR SAFETY CONCERN

Implementation for RTPs is a major concern and includes as the priority issue SAFETY. This is paramount, without a

clearly identified progression and sign off of the competencies at lower levels there is no way of formally endorsing



competency in a progressive manner.

The cost of the changes to all RTPs will be substantial as all programs will need to be realigned, rescheduled and adjusted

to meet AQTF requirements. The alignment of learning resources alone will be horrendous.

There will need to be a support and planning process for transition to the new qualification and a strategy to deal with the

transition for existing students in Certificate II pathways programs and apprentices.

There has already been concern in the way that qualifications are going to be packaged and that it may be difficult to meet

the Carpentry and Joinery requirements in WA due to lack of sufficient electives.

28.3 30.1.15 ITAB, WA

Consultation Process – FEEDBACK from Stakeholders which the Fund agrees with:

The following is representative of feedback received from various sources

The existing qualifications use lower level competencies to identify, train, assess and deem competency in, Apply OH&S, Work Safely at Heights, Carpentry Tools and Equipment Handle Carpentry Materials and Work Safely at Heights. Policies and procedures in the construction industry are taught at commencement of first year apprentices so that they will be able to work safely on site. Removing these and embedding in other larger level 3 competencies will mean there is no way to address competency on a safe, progressive and identifiable pathway. These same competencies are taught to ALL students in VET in Schools and pre-apprenticeships in WA and this is the ideal progressive articulating pathway the industry needs.

Given that WA is to be the most affected by the deletion of the Cert III in Carpentry and Joinery (p19), it is worrying

that the WFA was only conducted in Victoria, NSW and QLD. Building techniques and practices vary across states

and given the possible effect on WA, it would stand to reason that more should be done to understand what is needed

in this State.

We deliver in a regional area which is serviced predominately by small builders who require their carpenters to have

ground up general/broad based carpentry skills. Additionally, many of our apprentices are employed by contractors

and subcontractors who operate only small teams. Given the WFA focused mainly on larger businesses (which were

Eastern states based - p3), most of which were in proximity to a CBD, it is highly questionable how accurately the WFA

represents the skills required in regional areas.

Was the question ever asked - Where are carpenters, and particularly carpenters and joiners (combined) employed

and in what numbers or proportions? What proportion of carpenters are employed in small business, big business, city

areas, rural areas, residential new, renovation, high-rise or commercial. Does the greater number of carpenters

require general skills or specific? Without answers to these questions how can the quality of the businesses chosen

and the skills observed in undertaking the WFA be considered appropriate or relevant to today’s majority of carpenters.

The WFA was only conducted at five sites which represents an extremely small sample group (miniscule in percentage

terms), given the intention of the study is to determine the actual real life skills required by all carpenters and there by



the apprentices they are training.

To put this in perspective, the table on page 20 of the report states that in 2013; 23,494 apprentices were employed.

These apprentices are working with carpenters on many thousands of sites located across the country – to reference 5

sites with a view to presuming that the information gathered accurately represents the skills needed in the broader

industry is simply statistically unsound.

It is well recognised that in order for information taken in a study or survey that the sample size must be sufficiently

large enough – the size of the sample must be developed in reference to -

o The size of the population being studied.

o Margin of error – Confidence level and standard deviation.

Does a sample size of five (5) sites provide the accuracy required in the context of the actual size of the national

industry and distribution of carpenters throughout that industry? Despite this the project team believe that the

information gathered represents “strong evidence for the analysis and recommendations provided in this paper” (p3).

We would ask by what measure?

These are nationally recognised qualifications – should it not follow therefore that any information collected with a view

to altering the content or design of the qualifications should be collected using a uniform and national approach?

The industry survey was undertaken “to indicate broad issues the project should be made aware of when considering

the direction of changes to the qualifications and units.” (p2)

Given the results of the industry survey are to be relied on to provide direction for the changes it is particularly

concerning to see in appendix 1 (p33), that “All completed responses were from RTOs….”

No feedback was provided on

o Cert III in Formwork/Falsework o Cert III in Joinery (Stairs) o Cert III in Joinery

RTOs, largely due to a well acknowledged lack of currency of lecturing staff, are not well placed to provide feedback

on the relevance of qualification content, as it relates to skills needed/used on site today.

No completed responses were received from industry (p33) – The survey was passive and not a suitable method of

extracting the required information from the industry.

As a carpenter and builder with over 20 years of on-site experience and who is new to training, “I can assure you that

to get at the opinions of the broader industry it is necessary to be more proactive – many in construction, including

those who have apprentices, wouldn’t know who the CPSISC were, evidenced in the extremely low response rate of

the industry survey. Is there any intention to use another method to get this very important information?”



Given the complete lack of information received from the construction industry I would ask how the direction for the

project was decided? Combine this with the fact that only five employers were consulted for the WFA; one could easily

conclude that the development strategy is not fulfilling its own brief and is proceeding on information collected from a

narrow range of stakeholders.

The development strategy does make some very sound suggestions and speaks in broad terms that appear to suggest

a move in the right direction. Our concern is how the lack of comprehensive national industry consultation may result

in content changes to units that will not reflect the actual needs of the carpenter in today’s Australian construction

industry.

Based on the information provided in the Development Strategy, we would urge the development team to reflect on the

evidence being used and question whether it accurately reflects the diversity of our industry. An industry that contains

massive numbers of sole traders, sub-contractors, contractors, large and small builders, commercial sectors,

residential, cottage, high end and maintenance sectors and how this effects the skills as practiced by carpenters

across this diversity of environments in what is becoming an increasingly nationalised construction workforce.

29. 30.1.15 Union, National

CFMEU is supportive of the project and consultative process to date. Still discussing the paper but have not had a chance

to present a single position. Will continue to engage with the project and communicate with the project team and via the

Project Reference Group.



Certificate III in Joinery

General Feedback – Raised by RTOs

No Date Type of Stakeholder (ie RTO)

Issue

1. 5.1.14 RTO, NSW Packaging rules: I am not sure what the point of having the option to select units from another Cert ii qualification is, if the

goal is to include only units that reflect a job role, which are at an AQF level 3 to “ensure the integrity of the AQF alignment”, perhaps the packaging rules should state that “up to 4 units may be chosen from other qualifications in the CPC Training Package that are at least an AQF level 3 or higher”

1.1 5.1.14

Number of units - Unit number is not an issue as long as content and qualification integrity is upheld, however I believe the

same outcome may be achieve by simply deleting the units that are intended to be embedded from the current packaging rules and leave the remainder of the current packaging rules the same with the exception of having a reduced number of core units and perhaps reducing importation allowances.

1.2 5.1.14 RTO, NSW

Core units - Group B Stairs Electives should be included as Core units

1.3 5.1.14 RTO, NSW Electives - Shift Group B Stairs Electives to be Qualification Core units.

Other comments – see other comments in feedback for Cert III in Carpentry.

3. 20.01.15 RTO, NT

Packaging rules - Do not reduce the number of core Units. Other comments: Elective Unit options must be clear and prescriptive.

Other comments on development strategy: Whilst these issues address the required changes to training packages, it

must be mentioned that industry also has a responsibility to ensure the current and ever changing future of these particular

trades is strengthened. All stakeholders contributing to desired outcomes have this responsibility. Tempting as it is to remain

in discussions regarding packaging of qualifications, RTOs’ requirements and the expectations of industry, current and

future apprentices should also be consulted regarding their views and expectations of units, training and industry.

If gathered appropriately, this information would assist in the quality of outcomes.

4. 28.1.15 RTO, NSW Packaging rules:

Elevated Work Platforms (EWP)



I have over 300 apprentices each year and have taught more than 1000 students. I have not had more than two requests for

this unit, so I do not understand how this could be a core unit of study.

Elective units must be related to specific needs and packaged as skill sets over and above the training of a Carpenter. Any further study required by employment can be arranged on a needs basis and can be from any suite of units within the training package up to the level of the certificate. Many apprentices may well become contractors or sub-contractors after becoming a Carpenter. Anyone that has the desire to do this should be able to study basic business units to help develop competence in the setting up and running a business. This should not be offered until they first become a Carpenter as this is what they need to do first.

8 30.1.15 RTO Network, VIC Packaging rules - There needs to have more Joinery specific units to choose from, too many carpentry specific units to

choose from in a Joinery qualification.

A reduction of 30 units to 22 units is too much of a reduction as we will lose skills sets in the Joinery qualification.

Other comments - The unit CPCCCM2010 Work safely on scaffolding above 2 metres wouldn’t be a benefit for joinery

apprentices the CPCCCM2010B Working at Heights would be a better unit and listed as a elective not a Core unit.

Not having a CPCCCA2002B Use carpentry tools and equipment unit in the qualification is a big mistake as most

apprentices don’t have a background in a trade.

Other comments on the development strategy: From the CPC31912 course the following units could be embedded into

other units being:

CPCCCM1013A Plan and organise work

CPCCCM1014A Conduct workplace communication

CPCCJN2001A Assemble components

CPCCJN2002B Prepare for Off-site manufacturing process


So therefore a qualification of 25 units would suit the Joinery industry.

10. 30.1.15 RTO, NSW There is a misconception with the definition of Joinery. Joinery is defined in the development strategy (p10) as- typically



seen in the design, manufacture and installation of kitchen and bathroom cabinets, bedroom wardrobes and cupboards.

The training requirements for this sector of the industry are already addressed comprehensively by MSF31113 –

Cabinetmaking (kitchens & Bathrooms). Recent Joinery qualifications have actually been more suited to manufacturers

and installers of windows, doors and stairs.

I support the structure of the new Joinery package, particularly the proposal to embed the underpinning 1000 & 2000 coded

units.

The proposal to move the Stair units into joinery and delete the separate Stair course is a sound one and will not adversely

affect students.

13. 02.02.15 RTO Network, VIC There needs to have more Joinery specific units to choose from, too many carpentry specific units to choose from in a

Joinery qualification. A reduction of 30 units to 22 units is too much of a reduction as we will lose skills sets in the Joinery

qualification.

Other comments: The unit CPCCCM2010 Work safely on scaffolding above 2 metres wouldn’t be a benefit for joinery

apprentices the CPCCCM2010B Working at Heights would be a better unit and listed as a elective not a Core unit.

Not having a CPCCCA2002B Use carpentry tools and equipment unit in the qualification is a big mistake as most

apprentices don’t have a background in a trade.

From the CPC31912 course the following units could be embedded into other units being:

CPCCCM1013A Plan and organise work

CPCCCM1014A Conduct workplace communication

CPCCJN2001A Assemble components

CPCCJN2002B Prepare for Off-site manufacturing process


So therefore a qualification of 25 units would suit the Joinery industry.



General Feedback Raised by Industry, Regulators, Associations, Others

2 14.01.15 Regulator, QLD Packaging rules - This mix of units seems adequate for the purpose.

It is imperative that Cert III level qualifications reflect the work undertaken by tradesmen and that the mix of core units

reflects the majority of the trade.

5 28.1.15 Industry, VIC Packaging rules- At Slattery and Acquroff, we are very happy with the proposed course changes that allow more flexibility

in delivering a more specialized Training Package that meets the specific skills that our apprentices require. Other comments - With 12 Electives, we can cover 6 for Staircase and the other 6 from Joinery and related areas, such as

glass and steel which our people work with regularly. The only problem I see will be the availability of these units within the curriculum of our TAFE provider.

5.1 28.1.15 Industry, VIC Other comments on Development Strategy:

We at Slattery and Acquroff have been very happy to participate in having input into the redesign of the Certificate 111 in

Joinery.

As a stakeholder in this qualification, we feel we have an obligation to our apprentices to make sure that they obtain the best

and most relevant training to equip them with the skills they need to develop for this rapidly changing industry and present

them with a career path for Slattery & Acquroff and the wider building industry. As we do not have a stakeholding in the

Carpentry Redesign for the construction industry, I feel it would be better to leave those points to those who are actively

engaged and have the necessary experience to make decisions in that area.

After reading through all the information contained within the Development Strategy Document from November 2014, and in

particular Sample ‘B’ proposed Cert 111 in Joinery, I have these comments:

1. 10 Core 12 Elective, seems to me to be offering companies a lot of scope to be able to tailor make a course by using

the electives contained within CPC Qualifications or other training packages or accredited courses.

2. Some employers, who would rather the TAFE Colleges set the training agenda for their apprentices, would find this

flexibility quite daunting while on the other hand companies such as ours will welcome the opportunity to enhance

specialist training to our employees.

3. The proposed electives for Staircase Building contained within Sample ‘B’ changes to the qualifications have got it

pretty well “spot on”. There is not the duplication we have had with stairs such as composite, which is only using

different materials but the same setting out etc. we have in other units.

I am glad to see that geometric stairs are back in the training package although this is difficult to teach in TAFE

colleges, as there are not many teachers with this experience. But to a company like Slattery & Acquroff, we would feel

that we would have failed in completing the “Total Stair Builder” by not acknowledging that our apprentices attained all

the sections available within our trade and qualifications.

4. An area which could work well for us is to be able to have our apprentices complete some elective units in other training



packages. A perfect example would be Safe Handling and Fitting of Glass, which is an increasing part of our business

and which includes the installation of glass balustrade, stainless steel and steel products in general. Allied to these

materials we have special concrete fixings, glass fixings and fixing to steel work.

5. These are all required skills to master in our current industry and some crossover training from other trades is becoming

more relevant in the training and tasks of our apprentices into the future. This package is a good base to start from and

may need to be “fleshed out” a bit more as it evolves and keeps pace with the ever changing demands of our industry

6. Our basics are still the same and our hand skills and staircase knowledge have never been so important to learn, in

particular with the use of computerised machines, in that if you don’t have the basic staircase knowledge you can’t

understand how to relay those tasks to the machines and be able to pick up errors before they go out on site, which can

cost the business a lot of money.

7. So the old skills equip our staff to be able to master modern technology provided they learn the traditional skills which

have always been the basis of our trade.

I look forward to seeing the draft of the actual training packages.

6. 29.1.15 Employer and RTO,

National

Packaging rules - Both CPCCC A2002B Power and Hand Tools and

CPCCC M1015A Carry out Measurement and Calculations withdrawn from Cert III curriculum in sample B.

Concern that removal of CPCCC A2002B Power and Hand Tools and CPCCC M1015A Carry out Measurement and

Calculations.

These particular modules establish foundation skills, underpinning knowledge and attitudes prior to progressing onto the

more technical training modules. They provide an indication of abilities and learning difficulties early in the initial stages of

the trade.

7. 30.15.15 Industry, VIC Packaging rules - Less elective units and mostly core units would be better. The fundamentals of construction have not

changed. This would lower the cost of delivery and assessment. Everyone teaching the same thing and assessing the same

thing.

Other comments on Development Strategy:

This is only my opinion but a levy paid when lodging a Development application, like the long service leave levy, could help

fund the core units and reduce the cost of training. It appears that “industry” want a say in training but want the Government

and apprentices to pay for it. Sharing the expense would be a fairer model for all stakeholders.



9. 30.1.15 ITAB, QLD

The comments provided for Sample A apply to the same issues that are demonstrated in the document for sample B. The

feedback form appears more concerned about numbers rather than identifying if the qualification aligns to current industry

practice.

Having ten (10) Core units for Sample B and 14 Core for Sample A with only six (6)being the same does not appear to align

to the intended structure of new training packages that promote more flexible pathways between trades.

11 30.1.15 ITAB, WA

See comments made for Carpentry

12. 30.1.15 ITAB,SA

See comments on development strategy in carpentry comments

carpentry qualifications - draft development … qualifications - draft development strategy...

Documents