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
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.
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:
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
Q. The consultation paper asked for feedback
specifically on the three options for the competency level required to achieve
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.
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.
– 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
- Suspension of certification for a defined period
- Termination of the member’s certification
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
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
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
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
Q. Why a national executive committee (NEC) and not state/territory specific committees?
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
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
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:
application fee for practitioners seeking certification will be reduced from
$1,000 plus gst to $800 plus gst
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
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
reports” should be termed “Statements of support”
A. This change has been adopted.
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
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
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.
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
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