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Certification Scheme

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Certification of Site Contamination Practitioners Scheme

The effective assessment and remediation of contaminated sites is a complex and challenging task.  Globally, there is a growing realisation that only appropriately qualified personnel should undertake this task and a number of countries are developing certification schemes to provide increased assurance for site owners, regulators and communities.

Following feedback and support from participants, CRC CARE has taken the leadership role in developing a Certification of Site Contamination Practitioners (CSCP) Scheme for Australia.

CRC CARE published a consultation document and invited comment from all stakeholders with an interest in contaminated sites in Australia. 

Download the consultation document here.

CSCP CONSULTATION PAPER FEEDBACK AND RESPONSES

A substantial amount of feedback was received in response to the consultation document.  We have reproduced a number of the questions and comments below (“Q”) with our responses (“R”) including changes we have made or are intending to make as a result of the feedback.  Some of the feedback is still under consideration and additional questions and their answers will be posted as we work through them.

Q.  Competency level descriptor feedback.

A.  A wide range of comments were received relating to the competency level descriptors, why are there 4 (rather than say 2) etc.  Following consideration of the feedback, the levels proposed in the consultation paper will be replaced with the following levels:

  • Developing (replaces inadequate)
  • Functional (replaces basic)
  • Proficient (replaces competent)
  • Advanced (replaces expert)

A number of comments were also received concerning the need to provide further quantitative measures of competency to ensure consistency in assessment.  These comments are being considered in developing more detailed guidelines for the assessment panels.

Q.  The consultation paper asked for feedback specifically on the three options for the competency level required to achieve certification. 

A.  A variety of feedback was received however the majority of feedback favoured option C and this will be the standard of competency set for Certification.  In light of the changes above to the competency descriptors, the nomenclature is as follows: Practitioners are required to demonstrate a minimum “Proficient” level in competency elements 1,2,3 and 6 together with a minimum “Functional” level in competency elements 4 and 5.


Q.  Scheduling of interviews – will regional centres, particularly in NSW, be considered?

A.  At this stage we are planning on capital city interviews only but we will consider scheduling interviews in regional centres if there are a number of applicants in the region. 

 

Q.  Assessment process – an applicant should have the right to object to individuals on the panel.

A.  Applicants will have the opportunity to ask for a review of their assessor panel where they can demonstrate a genuine conflict of interest.

 

Q.  Assessors – assessment by peers should be considered rather than paid assessors, to reduce the cost of the scheme.

A.  Once the scheme is established and has a cohort of senior certified practitioners, the scheme will consider modifying the assessment process as suggested. 

 

Q. Client reports – the requirement to provide client reports to support your application will be very difficult to achieve in practice.  Clients are extremely reluctant to air their dirty laundry in public; for instance I had a very hard time in getting client to provide reports in support of my Auditor application.  (There were also other similar comments relating to the difficulty in meeting this requirement for practitioners in large consulting organisations.)

A.  The client report requirement has been altered where applicants are not able to obtain 2 relevant client reports.  Alternative study or technical reports can be provided in these situations.  The reports or studies should be substantial and should provide evidence equivalent to the expectations of client reports and should have been completed within the two years prior to your application.

 

Q.  Concern regarding the need to be competent in all areas e.g. niche areas such as vapour sampling. Would lack of vapour sampling skills result in applicant being deemed inadequate?

A.  Attachment 2 of the Consultation document, entitled “Competencies for Certification”, describes the approach to assessing the level of competence for each competency element i.e. “It is proposed that a single rating be given for each element cognisant of the levels demonstrated in each activity or sub element but not tied by formula or a reductionist approach to the rating of each sub element.  The rating is to be given using an on balance approach.” 

 

Applying this to the specific question regarding a lack of vapour sampling skills, the competency assessment would take into account the competency of an applicant in sampling methodology and design across all media, in conjunction with all the other sub elements of competency element 3.  The outcome would be a balanced consideration of all the sub elements, so a lack of vapour sampling skills on its own would not prevent assessment at “proficient”.

 

Q.  Demonstration of competency for component 1 to 3 might be difficult for risk assessors whom may not have had a lot or no experience on field work.  In addition, some individuals may specialise in areas of contaminated land support e.g. as auditor support and their recent experience may not cover the full range of competencies listed in the NEPM. Will these individuals be catered for as part of the CSCP scheme?

A.  The CSCP certification is awarded to professionals who have the ability to independently manage the full scope of a contaminated site project.  Unfortunately professionals who specialise in a specific area of practice and who are not able to demonstrate the required level of competence in all elements, will not be eligible for certification.  The scheme is considering future developments after the scheme is established and options for specialists may be an option in the future.

 

Q.  Complaints and conduct review – how would the practitioner be made aware of a complaint or suspension?

A.  The practitioner who is the subject of a complaint will be provided with a copy, during the initial review of the complaint, and asked for a written response.  If the complaint is found to be valid, following the detailed review process outlined in the consultation paper, the National Executive Committee (NEC) will give consideration to the appropriate action to be taken which may include one or more of the following:

  • A warning to the member together with corrective action required for future activities and/or additional professional development
  • Suspension of certification for a defined period of time
  • Termination of the member’s certification

The executive officer will provide written notification of the outcome of the review to the practitioner and the person who provided the notification.

The executive officer will prepare an annual statement of the reviews conducted and the outcomes.  The annual summary will provide summary information only and will not include the names of individuals or organisations.

 

Q.  Complaints and conduct review  several comments were made about aspects of the procedure including the proposal to include the outcome of each review on the scheme website.

A.  A number of adjustments have been incorporated into the procedure including removal of the publication of individual outcomes on the website.  The scheme will provide annual reports of investigations and outcomes but without identification of individuals.

 

Q.  Continuing Professional Development (CPD)  with respect to the 50 hours professional development, most consultants (possibly with the exception of auditors) are not going to have undertaken 50 hours/year for the past 3 years. As a result, I think there will be few people in a position to apply in the first few years of the scheme.

A.  As stated in section 3 of attachment 3 of the consultation document, “In the first year of operation of the CSCP scheme this requirement will be reduced to demonstrating 50 hours minimum for the year preceding the application”.

 

Q.  Continuing Professional Development (CPD)  the scheme requires 20 hours directly related to the six competencies, but this should be 50 hours.

A.  A number of comments were received relating to the 20 hour requirement and this has now been removed from the procedure.

 

Q.  Continuing Professional Development (CPD)  (comment from one of the ACLCA responses) some member companies found 50 hours per year for CPD to be excessive in term of professional development, others were happy with the proposed CPD input.

A.  A range of views were expressed both agreeing and disagreeing with the 50 hour requirement.  The procedure for CPD is being developed further taking the feedback into account and building flexibility into the requirements for CPD, particularly to ensure the provision of options which are available at low (or no) cost.

 

Q.  Governance – interim profits made by the scheme could be directly returned to membership through reduced fees.

A.  CRC CARE is financially supporting the establishment of the scheme in its early years with an expectation that it will, in time, achieve break even status.  If the scheme does eventually deliver a profit the NEC may consider reinvesting any surplus into further development of the scheme.  Reducing fees would also be an option.

 

Q.  Why a national executive committee (NEC) and not state/territory specific committees?

A.  The scheme aims to operate nationally and establish a nationally consistent professional standard.  This has been a fundamental objective of the organisations which have supported the development of the scheme.  Operating the scheme with a national executive committee is consistent with this objective.

 

Q.  Who will push regulatory authorities to require certification? Without regulators requiring the scheme there will be little incentive to join.

A.  A number of questions like this were received, relating to the mandating (or not) of certification.  Regulators have supported the development of the scheme and have contributed to its design. We expect that regulators will actively encourage use of the scheme.  The issue of mandating of the scheme and the timing of any such mandating is a matter for each jurisdiction to consider.

 

Q.  Will there be mutual recognition of other accreditations/schemes?

A.  Where applicants have an existing accreditation/certification which demonstrates the achievement of certain competencies required for CSCP certification, these can be provided in an application for certification.  In time the CSCP scheme will seek to formalise mutual recognition of relevant competencies with other national and international schemes.

 

Q.  Will accreditation levels be published on the register? Once you have been accredited as basic, how do you go to the next level?

A.  The four competency levels are helpful firstly to intending applicants as they self-assess their levels in preparation of an application and then secondly in the assessment process to determine if an applicant has met the requirements for certification.  There is however only one level of certification i.e. you achieve certification or not.  A register of those individuals who have been awarded certification will appear on the scheme website.

 

Q.  Occasionally non-contaminated land consultants undertake site contamination consulting work. For examples, industry, state government and town planners have been known to undertake site contamination assessment. How will the scheme address this issue?

A.  The establishment of the scheme is intended to address this issue by creating a clearly identified cohort of suitably qualified practitioners,  through the certification process.  Each jurisdiction will decide how best to define the situations where use of certified practitioners (CPs) is required.

 

Q.  In the commencement phase, it will take time for personnel to become accredited and therefore, if endorsed by the regulators there may be a period where CPs are required, however there are insufficient accredited. Has a lag phase been considered between commencement of the scheme and requirements by the regulators? 

A.  A timetable will be published for the implementation phase of the scheme and will consider an appropriate “lag phase” in consultation with regulators.  In establishing the scheme it is considered important that competitive advantage is not provided to a few individuals who apply, and are awarded certification in the early stages of the scheme. Consequently, it is envisaged that adequate time (at least 6 months) will be provided to enable a critical mass of practitioners to be assessed and awarded certification, prior to publication of the register of certified professionals on the scheme website.

 

Q.  Fees  a number of comments were provided in the consultation paper feedback relating to the fees, mostly commenting that the fees are too high and also commenting that there will be costs associated with the CPD requirements.

A.  The scheme fees have been established to ensure the appropriate resources for a comprehensive assessment process and professional ongoing operation, which can achieve breakeven financial status.  The feedback in relation to fees has been considered in detail, resulting in the following  amendments:

  • The application fee for practitioners seeking certification will be reduced from $1,000 plus gst to $800 plus gst
  • The application fee for auditors seeking certification will be $200 plus gst
  • The annual fee for certification will be $400 plus gst
  • The detailed requirements for continuing professional development are being developed to enable as much as possible of the 50 hours being achievable at no or low additional cost
  • Development of additional benefits to certified practitioners to provide further value.

 

Q.  Is there an option for a reduced fee for part time employees or who take extended leave (i.e. maternity leave)?

A.  At this time there is no option for reduced fees.  However, consideration will be given in extenuating circumstances for individuals who have taken extended leave periods.

 

Q.  “Referee reports” should be termed “Statements of support”

A.  This change has been adopted. 

 

Q.  Professional Experience  certification requires ‘primary responsibility’ of assessment. Once the scheme is started, it may be difficult for non-certified personnel to undertake a project with the ‘primary responsibility’ due to the requirements of the regulators. The term ‘primary responsibility’ in Section 6.2 needs further definition.

A.  Agreed. Primary responsibility is a demanding requirement and probably too restrictive.  This has been changed to “direct” responsibility.

 

Q.  Professional Practice  this structure implies a significant project management component for those with 2 years experience. Is this realistic?

A.  The consultation document described a need for “at least 3 of the 5 years of experience … in roles with primary responsibility for recommendations or actions dealing with contaminated sites.”  Following consideration of other feedback received, the requirement for “primary” responsibility will be changed to “direct” responsibility, which will broaden the roles that will satisfy the requirement.  It should also be noted that 5 years is a minimum requirement and some practitioners may require longer than this to be involved in the range of experiences required to achieve certification.

 

Q.  Professionals in the industry accredited under CSCP should be able to clearly identify the path to Auditor accreditation.  CSCP CPD training and competency objectives should be consistent with those required of auditors. This should avoid disconnects between the schemes and misalignment of objectives.  

A.  Agreed.  Certification and CPD should support a pathway towards achieving Auditor accreditation and ongoing development of the scheme’s design will seek to achieve this.  However, the scheme will play an important role in industry as a stand alone initiative to recognise the expertise of individual practitioners working in the industry.

 

Q.  What level of competence will be assigned to auditors? auditor applications bypass the assessment stage of the application.

A.  The four competency levels are helpful firstly to intending applicants as they self-assess their levels in preparation of an application and then secondly in the assessment process to determine if an applicant has met the requirements for certification.  There is however only one level of certification i.e. you achieve certification or not.

 

Q.  Whilst providing a useful screening tool for self-assessment, there is a danger that an online test will become a de-facto training tool for potential applicants who do not otherwise have sufficient knowledge. What safeguards will be in place to prevent people “learning all the right answers” through the online test and then submitting an application which just ticks the boxes but does not have genuine depth?

A.  The online tool will provide details of the competencies required to satisfy the requirements of each competency level i.e. at a further refined level of detail than was provided in the consultation document.  It is therefore effectively a detailed list of questions, not answers.

 

Q.  Why are interviews required?

A.  The scheme aims to assess competency through a number of processes rather than rely on one or two.  A practitioner’s application will be supported by client reports, referee reports, a case study exercise and the interview.  Having multiple inputs increases confidence in the assessment being made for all stakeholders.  It also acknowledged that individuals perform differently in different assessment methods and considering the total evidence of all inputs provides a fairer assessment.  The interview process will enable the panel to seek further clarification of areas and evidence which may have been lacking on the earlier assessment tasks.  Further, it is envisaged that individuals applying for certification will be client/regulator facing and will have to formulate an appropriate response quickly and under pressure. Demonstrating quick access to knowledge is fundamental to the scheme.

 

Q.  Where training and improvement of the industry as a whole is the goal, the costs and frameworks need to be geared towards inclusion of all practitioners and provide a clear pathway for the core skills and competency the industry requires to service client needs. Propose impediment to joining is less – tiered fees and level of membership reflect level of competency.

A.  This is an important point.  While efforts are currently being directed to establishment of the certification scheme, the scheme will engage with training providers to develop and offer courses which will benefit the development of the sector and in time will establish a pathway to certification.

 

Q.  The last dot point states that membership of the scheme will provide access to training and development opportunities? It is unclear how this would occur unless CSCP only training/development is proposed?

A.  The scheme will seek to offer discounted access to training and development activities where possible.  In additional CSCP will be working with training providers to develop and offer courses which will benefit the development of the sector.

 

Q.  Who appoints the NEC and do they have operational Terms of Reference?

A.  In the first instance, stakeholder groups who have been involved in the development of the scheme, as outlined in the Consultation document, will be asked to nominate individuals to be appointed as their representative member(s) of the NEC.  It is expected that this appointment will be an initial term of 2 years.  Following this initial term, election of members of the NEC will be undertaken to maintain sector representation as outlined in the Consultation document.

Terms of Reference for the NEC have been established to allow it to govern the scheme and operate as an independent organisation.  These will be periodically reviewed with stakeholder sectors as the scheme develops.

 

Q.  Who appoints the Assessment Panel and how are they selected?

A.  A pool of certification panel members will be appointed by the NEC and assessment panel will be formed from the pool.  In the establishment of the scheme, an approach will be made to some of Australia’s leading Auditors to act as assessors.  In later years, once a pool of certified practitioners has been established, there will be an expectation for senior certified members of the certification scheme to act as assessors.


Want to know more

Opportunities to participate in various discussion forums about the CSCP scheme will be provided in upcoming events that will be added to the following webpage: Upcoming training and events