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P230 Access Consulting ISSUES REGISTER P230: TPR#3 Access Consulting CPP Version 6 Issues Register – first draft Summary of findings and advice Issues register contents: Delivery issues..............................................................................................................3 Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)..........................................3 Delivery of Certificate IV core and elective units:........................................................................................................................................................................................................................................... 3 Ms Joe Manton (Director) and Michael Wheeler [IATA (RTO)]........................................................................3 Financial and learning demands of the 7 audit units in Certificate IV in Access Consulting................................................................................................................................................................... 3 General issues...............................................................................................................6 Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)..........................................6 CPP40516 Certificate IV in Access Consulting general issues:..................................................................................................................................................................................................................... 6 Alan Daniel, EO (Business Industries CMM Victoria)...............................................................................6 Qualification Mapping Information................................................................................................................................................................................................................................................................ 6 Eric Martin, Director (Eric Martin and Associates on behalf of Australian Institute of Architects National Access Work Group)....7 General comment on suite of access qualifications...................................................................................................................................................................................................................................... 7 Ms Joe Manton (Director) and Michael Wheeler [IATA (RTO)]........................................................................7 Cert IV General issues other comments.......................................................................................................................................................................................................................................................... 7 Equity issues...............................................................................................................10 None............................................................................................................................10 Qualification issues........................................................................................................11 Murray Mountain, Access Design Solutions (Disability Services and Support Organisation).........................................11 CPP50316 Diploma of Access Consulting Other comments:...................................................................................................................................................................................................................... 11 Murray Mountain, Access Design Solutions (Disability Services and Support Organisation).........................................11 CPP80116 Graduate Diploma of Access Consulting general comments:................................................................................................................................................................................................. 11 P230 Issues Register 25.11.15 Page 1

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P230 Access Consulting ISSUES REGISTER

P230: TPR#3 Access Consulting CPP Version 6 Issues Register – first draft Summary of findings and advice

Issues register contents:

Delivery issues.................................................................................................................................................................................................................................................. 3Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)........................................................................................................................................3

Delivery of Certificate IV core and elective units:....................................................................................................................................................................................................................... 3Ms Joe Manton (Director) and Michael Wheeler [IATA (RTO)]......................................................................................................................................................................................3

Financial and learning demands of the 7 audit units in Certificate IV in Access Consulting...................................................................................................................................................... 3

General issues.................................................................................................................................................................................................................................................. 6Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)........................................................................................................................................6

CPP40516 Certificate IV in Access Consulting general issues:................................................................................................................................................................................................. 6Alan Daniel, EO (Business Industries CMM Victoria).................................................................................................................................................................................................... 6

Qualification Mapping Information.............................................................................................................................................................................................................................................. 6Eric Martin, Director (Eric Martin and Associates on behalf of Australian Institute of Architects National Access Work Group)...................................................................................7

General comment on suite of access qualifications................................................................................................................................................................................................................... 7Ms Joe Manton (Director) and Michael Wheeler [IATA (RTO)]......................................................................................................................................................................................7

Cert IV General issues other comments.................................................................................................................................................................................................................................... 7

Equity issues................................................................................................................................................................................................................................................... 10None............................................................................................................................................................................................................................................................................ 10

Qualification issues........................................................................................................................................................................................................................................ 11Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)......................................................................................................................................11

CPP50316 Diploma of Access Consulting Other comments:.................................................................................................................................................................................................. 11Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)......................................................................................................................................11

CPP80116 Graduate Diploma of Access Consulting general comments:............................................................................................................................................................................... 11

Unit of competency issues............................................................................................................................................................................................................................ 12Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)......................................................................................................................................12

CPP80116 Graduate Diploma of Access Consulting elective units:........................................................................................................................................................................................ 12Alan Daniel, EO (Business Industries CMM Victoria).................................................................................................................................................................................................. 12

Range of conditions in all units:............................................................................................................................................................................................................................................... 12

P230 Issues Register 25.11.15 Page 1

P230 Access Consulting ISSUES REGISTER

Alan Daniel, EO (Business Industries CMM Victoria).................................................................................................................................................................................................. 13Knowledge evidence in all units............................................................................................................................................................................................................................................... 13

Alan Daniel, EO (Business Industries CMM Victoria).................................................................................................................................................................................................. 14Modification History information in all units.............................................................................................................................................................................................................................. 14

Ms Joe Manton (Director) and Michael Wheeler [IATA (RTO)]....................................................................................................................................................................................15Core unit Cert IV: CPPACC4002............................................................................................................................................................................................................................................. 15

Ms Joe Manton (Director) and Michael Wheeler [IATA (RTO)]....................................................................................................................................................................................15Elective units Cert IV:............................................................................................................................................................................................................................................................... 15CPPACC4009 Conduct transport premises access audits...................................................................................................................................................................................................... 20CPPACC4010 Conduct aged care facility access audits......................................................................................................................................................................................................... 21CPPACC4012 Conduct outdoor recreation area access audits............................................................................................................................................................................................... 21CPPACC4006 Conduct playground access audits.................................................................................................................................................................................................................. 22CPPACC4008 Conduct transport conveyance and boarding device access audits................................................................................................................................................................ 23CPPACC4007 Conduct streetscape access audits................................................................................................................................................................................................................. 24CPPACC4009 Conduct transport premises access audits...................................................................................................................................................................................................... 24CPPACC4011 Conduct educational facility access audits....................................................................................................................................................................................................... 25CPPACC4010 Conduct aged care facility access audits......................................................................................................................................................................................................... 25Prerequisite - Or Not???.......................................................................................................................................................................................................................................................... 26

Ms Joe Manton (Director) and Michael Wheeler [IATA (RTO)]....................................................................................................................................................................................27Certificate IV core and elective units listed in the Diploma...................................................................................................................................................................................................... 27

P230 Issues Register 25.11.15 Page 2

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Delivery issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

1A 12.11.15

Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)

Delivery of Certificate IV core and elective units:These sound good, but in reality they don’t go far enough. It’s great to have all the right terminology and speak it, but unless it is understood, especially the reasons why certain requirements are to be met and who is affected and how they are affected, e.g. the reasons why certain requirements are specified, but they weren’t told because the trainers just didn’t know. We were receiving phone calls from participants in the courses who stated how light weight it was and that no reasons were given as the presenters were unable to answer. This brings up the suitability of who the trainers were and their level of knowledge.In all cases we advised that they go back to the trainers and follow through on their requests; as an outcome we were approached to review a booklet on the “Why’s of Access”; which was a real eye opener that revealed the incredible lack of knowledge by the authors. We re-wrote the booklet, but only to the level as requested. There is still a lot of “Why’s” that need to be included.

The comment that the core and elective units sound good is noted, thank you.In relation to comments regarding the reasons for unit requirements, trainers’ underpinning knowledge and skills, and the suitability of trainers: these are implementation issues.Government Training Package policy requires the unit to clearly express the performance standard, specify the required performance in tasks and skills, and reflect the applied knowledge for competent performance. The content of the access consulting units complies with Training Package policy requirements.No further action required

4A 19.11.15

Ms Joe Manton (Director) and Michael Wheeler [IATA (RTO)]

Financial and learning demands of the 7 audit units in Certificate IV in Access ConsultingWere these requirements put out to

The government requires that all units of competency be re-templated to comply with the requirements of the templates associated with the Standards for Training Packages, which in turn must comply with changed government Training Package policy requiring that assessment

P230 Issues Register 25.11.15 Page 3

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Delivery issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

competitive tender as works to be undertaken, cost/budget estimates would conservatively vary from $30,000 to $50,000. Not only does this indicate a vast amount of hours required from a person/team already likely to have years of experience, but for a student (no pre-requisites required), the hours involved in undertaking these tasks, will at a minimum be doubled and more likely trebled.IATA has had feedback that the course requirements are already quite demanding.The Australian Qualifications Framework (AQF) states in its specification for Certificate IV that the following applies:

AQF level 4 criteriaSummary Graduates at this level will have theoretical and practical knowledge and skills for specialised and/or skilled work and/or further learningKnowledge Graduates at this level will have broad factual, technical and some theoretical knowledge of a specific area or a broad field of work and learningSkills Graduates at this level will have a broad range of cognitive, technical and communication skills to select and apply a range of methods, tools, materials and

requirements associated with a unit of competency specify the volume and frequency of required performance evidence and the breadth and depth of required knowledge evidence.The seven audit units in the Certificate IV are re-templated versions of superseded equivalent version. The skills and knowledge required in these units have not changed.Please refer to CPSISC statement on the project website regarding this body of work:Unlike previous CPSISC Training Package re-design projects which have seen a full review and redevelopment of qualifications, this body of work will be streamlined with the primary objective of redeveloping the above qualifications and their associated native units of competency to align to the Standards for Training Packages. This re-formatting work is expected to see no significant change to the structure of the above qualifications and little content change to their existing units of competency except for the inclusion of Foundation Skills and a more robust Assessment Requirement component of the units.No further action required

P230 Issues Register 25.11.15 Page 4

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Delivery issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

Information to:complete routine and non-routine activitiesprovide and transmit solutions to a variety of predictable and sometimes unpredictable problemsApplication of knowledge and skills Graduates at this level will apply knowledge and skills to demonstrate autonomy, judgement and limited responsibility in known or changing contexts and within established parameters

The word "broad" appears three times, and the phrases "further learning" and "limited responsibility" emphasise the idea that Certificate IV graduates are in a developmental stage of their learning.IATA believes its current work requirements of students are more than sufficient demonstration of this criteria. It also believes that to impose the work and assessment requirements as presently described in the Draft would be to impose unreasonable demands on students at this developmental stage.Recommendation: IATA suggests that where the access audit units are taught in a cluster (a minimum of two units), that the assessment requirements be modified or

P230 Issues Register 25.11.15 Page 5

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Delivery issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

sufficiently flexible to allow for more realistic demands to be made of students.

General issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

1A 12.11.15 Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)

CPP40516 Certificate IV in Access Consulting general issues:The 1st stage is to ensure that those teaching the course know their subject in full, not just some of it and make up the rest.

Thank you for your feedback. Trainer qualification is a matter for the RTO. No further action required.

2A 12.11.15 Alan Daniel, EO (Business Industries CMM Victoria)

Qualification Mapping InformationI know the Qualification Template asks to specify code and title of any equivalent qualification and if no equivalent state ‘No equivalent qualification’. You know that and I know that but the user does not. Recommend you state what the new qualification is equivalent to or something to that effect.

Acknowledged. No further action required.

3 18.11.15 Eric Martin, Director (Eric Martin and Associates on behalf of Australian Institute of Architects National Access Work Group)

General comment on suite of access qualificationsThank you for the opportunity to provide our comment on the three packages associated with disability access.

Thank you for the feedback. These are issues for the RTO to measure effectiveness of courses.No further action required.

P230 Issues Register 25.11.15 Page 6

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General issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

The views are a compilation of those of the Australian Institute of Architects National Access Work Group.We consider that the three courses provide a reasonable and adequate coverage for the industry.However they are only an initial part of the process of understanding access and developing the required skills to become an effective access consultant.It would be desirable to obtain feedback from those who participate in each course on effectiveness and usefulness of the course so the Institute can then assist as required to expanding them for maximum benefit to the architectural profession.It is desirable to promote the Graduate Diploma as this is where the most effective outcomes will be.

4A 19.11.15 Ms Joe Manton (Director) and Michael Wheeler [IATA (RTO)]

Cert IV General issues other commentsIATA believes that where we have indicated, the Assessment Requirements for the Certificate IV are onerous, often repetitive, and inflexible when delivering units in clusters and will disadvantage certain students. IATA further believes the Assessment Requirements go beyond the AQF requirements for a Certificate IV qualification.

Issues raised will be addressed within individual units of competency. See responses below.

P230 Issues Register 25.11.15 Page 7

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General issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

At a time when the industry is in desperate need of qualified access consultants, the nature of the tasks will deter many potential students from enrolment. The Association of Consultants in Access Australia (ACAA) - the peak body for Access Consultants in Australia - has mandated that intending Associate Members must have as a minimum qualification the Certificate IV in Access Consulting. The intent is to ensure that the industry is served by professionals with a base level of knowledge. There are at present no licensing requirements for access consultants.Since being registered as an RTO in 2011, IATA has seen the majority of ACAA new members entering the industry do so as graduates of the IATA Certificate IV course.Finally, given that IATA is the only organisation to deliver this qualification it would have been an opportunity for direct consultation in relating to any proposed changes regarding the content on the qualifications.We have extensive knowledge and student and stakeholder access and feedback that could have assisted in this process. In addition, the two week turnaround for input is inadequate.

P230 Issues Register 25.11.15 Page 8

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Equity issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

None

P230 Issues Register 25.11.15 Page 9

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Qualification issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

1B 12.11.15 Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)

CPP50316 Diploma of Access Consulting Other comments:General Comments really relate to the Diploma in relation to the Certificate iv level; which really do not have a significant change from a Cert iv level to a Diploma level. Appears to be the padding of the same material used in the Cert iv course with some extra areas added.

Despite CPSISC having re-templated the superseded equivalent version of this qualification, CPSISC is not proceeding to seek re-endorsement of the Diploma of Access Consulting as it is clear that it does not comply with Standard 8.The packaging of the units of competency listed in the Diploma of Access Consulting requires intervention to align the qualification to its current Australian Qualifications Framework (AQF) level. This intervention was outside the scope of the original CPSISC project brief, which did not include reviewing the packaging of the units of competency to ensure that the qualification aligned to AQF level 5. The brief was in fact limited to a re-templating process so that CPSISC’s contractual requirements with DET could be met. Given the limited scope of the original CPSISC brief and the contractual time constraints on the work, unfortunately the breadth of consultation that would be required to enable extensive changes to the unit lists to ensure qualification compliance with Standard 8 was not possible. I therefore do not consider that this qualification meets Standard 8.No further action required

1C 12.11.15 Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)

CPP80116 Graduate Diploma of Access Consulting general comments:This is an excellent and much needed qualification for those professionals currently working in areas that now require a solid knowledge on Disability Access in the Built Environment and how to apply it.

Thank you.No further action required

P230 Issues Register 25.11.15 Page 10

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Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

1C 12.11.15 Murray Mountain, Access Design Solutions (Disability Services and Support Organisation)

CPP80116 Graduate Diploma of Access Consulting elective units:Well-chosen to meet the needs that will ensure the required knowledge is imparted to those working in the area of our Built Environment.

Thank you.No further action required

Former range statement items have been significantly reduced, in terms of the number and scope of range items, with respect to each of the superseded access consulting units.Range of conditions content in the re-templated access consulting units refers either to operating conditions or variables essential to the work environment, and so reflect the intent of the Standards for Training Packages and comply with policy requirements.No further action required

Comparison between re-templated and superseded units will see a reduction in the number of items included in the range of conditions in each unit, as well as in the size of those items. The range section is considered to comply with policy directives.Formatting such as bold italics is not the sole domain of the now defunct range statement. Current Training Package policy continues its convention to not mandate formatting conventions. Given this, developers are at liberty to exercise choice over formatting. Advice from stakeholders implementing CPSISC Training Packages is that the use of bold italics to indicate a term in the performance criteria later referred to in the range of conditions is a useful feature, and so has been retained. There are endorsed precedents using this formatting under the Standards for Training Packages.No further action required

2B 12.11.15 Alan Daniel, EO (Business Industries CMM Victoria)

Range of conditions in all units:I’m of the opinion that the manner in which this section is approached in many of the units is inconsistent with the intent of the new Standards for Training Packages.The new Standards deliberately removed the former Range Statements in favour of Range of Condition being an optional field which can only be used to list essential operating conditions and any other variable essential to the work environment.What appears (and even to retain ‘the bold italicised term’) is a total retention of the now defunct Range Statement.I note some ISC’s have retained the Range Statement but in the non-endorsed Companion Volume.

P230 Issues Register 25.11.15 Page 11

P230 Access Consulting ISSUES REGISTER

Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

For most units the Range of Conditions is excessive in the extreme and the requirement of ‘must include’ effectively renders the units of competency not implementable.

This section is to be used to specify ‘different work environments and conditions that may affect performance; essential operating conditions that may be present (depending on the work situation … and local industry and regional contexts)’. Care was exercised to ensure that the items in the range of conditions were presented in a manner compliant with policy requirements and consistent with the unit context. Again, mindful of its requirement to cater for multiple contexts and industries, current Training Package policy continues its convention to not mandate specific wording in any Training Package component (other than equivalence statements), thereby allowing the developer flexibility to represent content in a manner suited to industry needs. With regard to the wording of the access consulting units’ range of conditions items, wording has been carefully considered on a case by case basis and chosen to reflect individual unit requirements (e.g. ‘xxx must include at least two of the following’). Again, there are endorsed precedents using this approach under the Standards for Training Packages.No further action required

Given this excessive treatment of Range of Conditions it is questionable whether the units deemed equivalent are in fact equivalent to the replaced units.

The vocational outcome of each unit has been analysed on a case by case basis and deemed to be equivalent.No further action required

2B 12.11.15 Alan Daniel, EO (Business Industries CMM Victoria)

Knowledge evidence in all unitsIn many units this section is extensive and would be difficult to implement.

Please refer to CPSISC statement on the project website regarding this body of work:Unlike previous CPSISC Training Package re-design projects which have seen a full review and redevelopment of qualifications, this body of work will be streamlined with the primary objective of redeveloping the above qualifications and their associated native units of competency to align to the Standards for Training Packages. This re-formatting work is expected to see no significant change to the structure of the above qualifications and little content change to

P230 Issues Register 25.11.15 Page 12

P230 Access Consulting ISSUES REGISTER

Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

their existing units of competency except for the inclusion of Foundation Skills and a more robust Assessment Requirement component of the units.In some instances knowledge items were expanded to reflect the depth and breadth now required by Training Package policy, but otherwise in large part the content of the knowledge evidence section is based on the superseded unit’s ‘required knowledge’.No further action required

2B 12.11.15 Alan Daniel, EO (Business Industries CMM Victoria)

Modification History information in all unitsIn the Modification History reference is made to:

This version first released with CPP Property Services Training Package Version 5. whereas the qualifications refer to Version 4

Thank you.Implemented response: Typo in Cert IV and Diploma to be corrected to reflect version.No further action required.

All units: Modification History info

I know the Unit of Competency Template asks to specify code and title of any equivalent unit of competency and if no equivalent insert ‘No equivalent unit’. You know that and I know that but the user does not. Recommend you state what the new unit is equivalent to or something to

All access consulting units are equivalent and so the connection to the equivalent superseded unit is explicit in each published unit’s modification history field.No further action required

P230 Issues Register 25.11.15 Page 13

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Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

that effect.

4A 19.11.15 Ms Joe Manton (Director) and Michael Wheeler [IATA (RTO)]

Core unit Cert IV: CPPACC4002Apply building control legislation to assess small-scale buildings for accessThere is now a requirement to assess both a residential small scale building for accessibility and a commercial small scale building. Given the opportunity to teach the course holistically, students will already have undertaken audits of several buildings or facilities.The need for the specific requirement for students to undertake and assessment of a residential building is unnecessary and redundant given the fact that there is no unit of competency relating specifically to residential classifications.Recommendation: that the requirement to assess a residential small scale building be removed.

No change to occur as this unit is about applying legislation. A small scale residential building is very different to commercial premises.No further action required

4A 19.11.15 Ms Joe Manton (Director) and Michael Wheeler [IATA (RTO)]

Elective units Cert IV:The redevelopment of the Assessment Requirements identifies very specific assessment tasks that must be undertaken by students. This has reduced the flexibility to teach these

This is a delivery issue. Holistic assessment is a decision that the RTO makes and is not a Training Package issue. Other RTOs entering the market later may choose other electives.No further action required

P230 Issues Register 25.11.15 Page 14

P230 Access Consulting ISSUES REGISTER

Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

units in a holistic manner and unnecessarily increases and repeats the work requirements of both trainers and students.IATA teaches 4 Access Audits Units in the Certificate IV (and the Diploma). These include: Conduct a building access audit Conduct a transport premises

access audit Conduct an aged care facility

access audit Conduct an outdoor recreation

area access auditWhilst the content of each unit may vary, the process of auditing a building, facility, playground or outdoor area is fundamentally the same.Many of the legislative requirements relating to auditing of any buildings, (excluding Transport buildings and residential) are also fundamentally the same, regardless of whether they are commercial, aged care, education etc.IATA believes that in the Draft Access Consulting Qualifications (the Draft) there are strong reasons to believe that where several access auditing units are being delivered as a cluster, the

P230 Issues Register 25.11.15 Page 15

P230 Access Consulting ISSUES REGISTER

Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

Assessment Requirements and Performance Evidence are unnecessarily onerous.In order to demonstrate Competency, current IATA student work requirements for the Cert IV in relation to access auditing include:• Present a review of access issues

at various sites• Conduct a building access audit

and deliver a report• Identify key issues (transport

premises)• Identify key issues (aged care)• Develop an access audit checklist

(aged care)• Identify key issues and align with

human body functions (outdoor recreation)

• Develop an access audit checklist (outdoor recreation area)

• Present an access review of an outdoor area

Student feedback and industry input suggests that this work allotment is sufficient to satisfy the demands of the course. The tasks cross reference and reinforce each other to demonstrate both a specific and a broad awareness

P230 Issues Register 25.11.15 Page 16

P230 Access Consulting ISSUES REGISTER

Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

of access issues in each of these site areas.The building access audit requires students to demonstrate competency in carrying out the audit process. They must present an overview of the relevant legislation and the responsibilities of owners/managers/developers etc; they must outline the scope and benchmark of the audit; they must work with a checklist to address access issues associated with various building elements (such as stairs, ramps, principal entrances, hearing augmentation etc), in the process referencing the relevant Standard or legislation from whence the recommendation originates. Next, they must develop and present specific recommendations, assign priorities for works, and finally, present a summary of their findings in a report. They are also required to undertake an access audit of outdoor recreation areas including data collection, photographs, report development and presentation of findings.The IATA Access Audit report template that is used by students has been industry tested and is often specified in

P230 Issues Register 25.11.15 Page 17

P230 Access Consulting ISSUES REGISTER

Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

commercial tenders for access work.However, no matter what template is used, in carrying out any access audit, the process required is fundamentally the same, whether it is of a building or an outdoor recreation area. Moreover, the access issues themselves are frequently the same, again, no matter what the site. To the extent they differ, the current IATA tasks require students to both identify site specific issues and in their practice, to present solutions.This is not a silo approach where each access audit is taught separately and the same processes repeated from unit to unit. Instead, the IATA approach is that the same process applies to all units and is therefore taught holistically with specific requirements and presentations to ensure that the particularities of each situation can be identified.

P230 Issues Register 25.11.15 Page 18

P230 Access Consulting ISSUES REGISTER

Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

The Draft Access Consulting Qualification has adopted a silo approach in which the units are presumed to be taught separately and accordingly, each has its own specific work requirements that essentially repeat those of the unit preceding. In practice, this results in far more onerous demands that only serve to duplicate one another.

Units are designed to be delivered individually or, if an RTO decides, holistically (clustered). RTO decision.No further action required

For example, for the above units, the Draft requires:• for buildings, an audit of a building

or upgrade, development of a checklist and provision of a report (plus other requirements)

No change to be made as this is general statement.No further action required

• for transport premises, an audit of two buildings chosen from an airport, a train or bus terminal, or a ferry terminal; development of a checklist for each facility and provision of a report for each (plus other requirements)

CPPACC4009 Conduct transport premises access auditsImplemented responseIn the performance evidence, change the assessment requirement to audit of the different transport premises listed from two to one access audits.No further action required

P230 Issues Register 25.11.15 Page 19

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Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

• for aged care, audits of a low level care facility and a high level aged care facility, development of a checklist for each facility, and provision of a report for each (plus other requirements)

CPPACC4010 Conduct aged care facility access auditsRequirement to undertake both low level and high level retained, as low and high level aged care facilities are quite often housed in the same facility and therefore accessible to students.No further action required

Implemented responseChange ‘different facility’ to ‘facility’ to better facilitate the audit of both low level care and high level care taking place within the one facility.

• for outdoor recreation, an audit of a city park or public landscaped area and a rural environment park or national park, development of a checklist for each and provision of a report for each.

CPPACC4012 Conduct outdoor recreation area access audits.No change as these are very different environments for access.No further action required

Essentially the requirements are the same for each unit, the sum total being:• audits of 7 sites• development of 7 checklists• provision of 7 reports.

No change as the audits required in the different audit units have different underpinning skills and knowledge and so the units need to be separate.No further action required

IATA believes that in some of the auditing units, the requirement to audit two sites is unnecessary and needlessly repetitive. In some instances it will undoubtedly impose

Units changed to accommodate changed Training Package policy directives regarding assessment requirements.No further action required

P230 Issues Register 25.11.15 Page 20

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Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

harsh and financially onerous logistical outcomes for certain students not within easy reach of such sites. Furthermore it makes further demands of all students who must obtain permission from operators to access these facilities.IATAs reasoning and recommendations are detailed below:In the conduct a playground access audit, two playgrounds must be assessed. This is needless repetition. IATA is somewhat unclear as to the definition of a playground "in a natural setting". We also believe that the requirement to develop a "recreation opportunity spectrum that lists all play experiences that can be gained from the playground" is beyond the scope of the industry requirements that this access auditing company has ever encountered. IATA has audited hundreds of playgrounds and has never once been required to develop such a spectrum. It is invariably local councils that issue tenders for such audits and although IATA has more extensive experience with local councils than any other access consultancy in the country, it has never

CPPACC4006 Conduct playground access auditsImplemented responseChange left column lead-in to the ‘Stations of playground’ item in range of conditions to ‘at least one of the following’ (from all the items in the right column).No further action required.

P230 Issues Register 25.11.15 Page 21

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Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

encountered such a request.

Recommendation:a) that only one playground be audited and

Implemented responsesRemove reference to ‘developed’ and ‘natural settings’ from the performance evidence.

Change evidence requirement to one playground audit.

Change the sub-list associated with that playground audit to ‘one of the following’.No further action required.

b) that the requirement to develop a "recreation opportunity spectrum" be omitted from the Draft.

The term “recreation opportunity spectrum” to remain. Research shows it should remain because it is a means of identifying and determining the diversity of recreation opportunities for a natural area or a group of natural areas – mainly used in USA, Australia and New Zealand.No further action required

The same applies to the conduct a transport conveyance and boarding device access audit unit. Here, there is a requirement to audit either a ferry and gangway, or an aircraft and aerobridge. Access auditors from inland Australia without ease of access to either of these facilities will be disadvantaged. This unit also requires an audit of either train and

CPPACC4008 Conduct transport conveyance and boarding device access auditsImplemented responseIt is accepted that current wording implies that a learner would be required to undertake audit of all transport modes (aircraft, buses/coaches, ferries, taxis, trains, trams etc, other rolling stock etc.).Change the following range of conditions items:• Transport conveyances provide a public transport service and must

include at least two of the following:P230 Issues Register 25.11.15 Page 22

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Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

platform/tram or light rail and platform/ bus or coach and ramp or hoist/ or taxi and hoist.Recommendation: that any one of the above six options would be a sufficient requirement.

• Boarding device must include at least two of the following:See also change to performance evidence below.

No further action required.

The same applies to the conduct a streetscape access audit unit. Here, students are required to audit one existing streetscape and one streetscape upgrade. In some locations, streetscape upgrades may be few and far between e.g. rural communities. An audit of an existing streetscape would be expected to identify the same key issues as would be identified in an upgrade.Recommendation: that an audit of an existing streetscape would be a sufficient requirement.

CPPACC4007 Conduct streetscape access auditsNo change. Local councils do streetscape upgrades often and so they therefore they should be accessible.No further action required

The same applies to the conduct a transport premises access audit unit. Here, students are required to audit two of the following: an airport, train or bus terminal, or a ferry terminal. The need to audit two of these will also impose harsh and financially onerous logistical outcomes for certain students not within easy reach of such sites. As pointed out earlier, many of the access

CPPACC4009 Conduct transport premises access auditsImplemented responsePotential lack of access to assessment sites noted.Change performance evidence to require an audit of only one (not two) transport premises.

No further action required.

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P230 Access Consulting ISSUES REGISTER

Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

issues will also be duplicated.Recommendation: that an access audit of one of the above sites would be a sufficient requirement.The same applies to the conduct an access audit of an education facility. Here, the student is required to audit a primary or secondary school, and a higher education institution. Whilst there are undoubted differences in the access issues applying to each, the same principles of access apply, as does the methodology of conducting the audit. The same Australian Standards will also apply (by and large) to all three premises. Demonstration of competence in auditing one of these three types of premises should mean that another need not be audited. Failure to demonstrate competence will require in any case a resubmission of the audit. Again we are also faced with logistical issues - (it can be difficult to gain permission to audit such institutions) - and needless repetition.Recommendation: that an access audit of one of the above sites would be a sufficient requirement.

CPPACC4011 Conduct educational facility access auditsGiven that the difference between the two types of buildings is significant, as are the access needs of the people with disabilities using them, no change.No further action required

The same applies to the conduct an CPPACC4010 Conduct aged care facility access audits

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P230 Access Consulting ISSUES REGISTER

Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

aged care facility access audit. Here, students are required to audit both a low level and high level aged care facility.Whilst there are undoubted differences in the access issues applying to each, the same principles of access apply, as does the methodology of conducting the audit. The same Australian Standards will also apply (by and large) to both premises. Demonstration of competence in auditing one of these premises should mean that another need not be audited. Failure to demonstrate competence will require in any case a resubmission of the audit. Again we are also faced with logistical issues - (it can be difficult to gain permission to audit such institutions) - and needless repetition.Recommendation: that an access audit of one of the above sites would be a sufficient requirement.

Given the difference in the access issues that apply to low level and those that apply to high level aged care, and the fact that low and high level care are often located within the same facility, no change required.No further action required

Prerequisite - Or Not???A further issue is that for each of the access auditing units, the "person conducting the audits must: ........read and interpret building/aged care facility/outdoor recreation area/transport premises/.../.../....etc

CPCCCM2001A Read and interpret plans and specifications is designed for a qualification at AQF level 2. Given this, it cannot be included as a core unit in the Certificate IV. Further, if packaged as a core the assumption would be that all those enrolling in the Certificate IV in Access Consulting cannot read plans. It is possible that those seeking the access consulting qualification are from other occupational areas (e.g. town planners, building designers) who can in fact read plans.

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P230 Access Consulting ISSUES REGISTER

Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

plans".However, the unit "CPCCCM2001A Read and interpret plans and specifications", which teaches the base level skills for such a task, is an elective and has always been an elective. As there are no prerequisites for the course, it follows that if any of the auditing units are to be taught, so should be the reading plans unit, which fundamentally makes it an additional core unit that, in addition, must be delivered prior to delivering any of the auditing units.Recommendation: that whilst it may be desirable for students to be able to read appropriate plans, the use of the word "must" necessitates wholesale changes to the mandatory requirements of the Certificate IV.We recommend removal of the "read and interpret plans of a building.....” clause from those grouped under use of the word "must".We further recommend that a separate requirement be added, such as "In conducting the above access audits the person may be advantaged by reading and

No further action required

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P230 Access Consulting ISSUES REGISTER

Unit of competency issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

interpreting plans of......etc"4B 19.11.15 Ms Joe Manton

(Director) and Michael Wheeler [IATA (RTO)]

Certificate IV core and elective units listed in the DiplomaWhile Ms Manton and Mr Wheeler provided a separate feedback sheet on the Diploma of Access Consulting, it repeated the comments provided in the feedback sheet on the Certificate IV.

No further action required

P230 Issues Register 25.11.15 Page 27