The discussion of Australian occupational health and safety (OHS) education and accreditation continues in the academic press. A recent contribution is from Pam Pryor, Registrar of the Australian OHS Education Accreditation Board (AOHSEAB) entitled “Accredited OHS professional education: A step change for OHS capability” (paywalled). Pryor continues to make the case for the necessity of accreditation for university OHS courses but evidence seems to remain thin and an arbitrary differentiation between competence and capability is hard to understand outside of academic discourse.
Competence or Capability
Pryor differentiates between a safety professional’s competence and capability. She uses the following definitions, with her emphases, starting with Competence and then Capability:
“The consistent application of knowledge and skills to the standard of performance required in the workplace. It embodies the ability to transfer and apply knowledge and skills to new situations and environments.”
“The applied theoretical knowledge that underpins practice in occupations and professions and also the industry specific knowledge and skills that transcend particular workplaces and the tacit knowledge of the workplace.”
Limiting Competence to the workplace denies the opportunity for Competence to grow and expand its relevance into the OHS profession. It also fails to acknowledge the layperson’s definition of competence as someone being able to do a job well. In fact, Pryor inverts the hierarchy of what most people would understand as Competence and Capability.
Pryor insists that Competence is a component of Capability, but this is contrary to common parlance and longstanding social expectations. A worker may be capable of performing a task but only a competent worker could perform the task well. There is a qualitative element of competence that Pryor seems to ignore.
Why has Pryor felt the need to introduce an extension of Competence rather than encouraging the evolution of, or broadening of, Competence to address perceived holes in the OHS profession?
Pryor includes in the research paper a “generic model to inform thinking on capability” but one that fails to include Competence even though elsewhere, Pryor describes competence as “a necessary part of capability”.
One of the most common flaws in OHS management is the introduction of additional controls, which could be new policies, procedures or other measures, without considering how those controls fit in the existing processes or whether the strengthening of existing controls could be just as effective. Capability could be seen in these terms.
Evidence and claims
Pryor makes several claims that are difficult to justify. In the abstract, Pryor states that
“In the last two years Australia has seen a step-change in Occupational Health and Safety (OHS) professional education with the implementation of the OHS regulator-funded OHS Body of Knowledge project.”
Online dictionaries provide the definition or synonym of a step-change as “a paradigm shift”. The introduction of the OHS Body of Knowledge is no step-change unless the step is very small, and no paradigms have shifted. The OHS BoK is one source of safety management information amongst entire OHS libraries, online and internet sources of OHS information. It can be argued that the limited production and dissemination of the OHS BoK has restricted its potential influence. Recent research by Gunther Paul and Warwick Pearse has cast serious doubts on the relevance and level of authority and influence that Pryor gives the OHS BoK. (A SafetyAtWorkBlog article on this research is being prepared)
Pryor’s argument is severely weakened by her reliance on “anecdotal reports”. She writes
“Information to date indicates that the accreditation process is impacting on both the content and educational quality of OHS qualifications. Anecdotal reports indicate that the process of preparing the application contributes to the general quality review process by the university with the accreditation report often resulting in broader change. One example of such changes has been the total revision of a quantitative research methods unit to address a broader range of research methods suitable for OHS and workplace-based research. This unit was then found to be a valuable contribution to the study program for other disciplines.”
Throughout the paper Pryor uses the term “impact” without acknowledging its neutrality. She repeatedly fails to state whether the impact is positive or negative and it is a mistake for the reader to impose a positive interpretation on the verb. The first sentence of this quote is a perfect illustration.
The rest of the quote references anecdotal reports. It is very rare for an academic research paper to include anecdotal information and then to provide an example based on anecdote to justify the value of the program, particularly if the journal is called Safety Science. Anecdotes should not be used as evidence.
Pryor concludes
“The concept of capability, rather than competency, creates a more encompassing framework for development of OHS professionals and recognition of the profession.”
But the research paper fails to convince the reader of this.
Pryor also states that
“The impact of accreditation is demonstrated by the cases where action was required to address deficiencies prior to accreditation being awarded and universities responded by reporting on the implementation of ongoing improvement plans.”
(“Impact” again?) Pryor’s paper makes much of a series of assessment reports of tertiary OHS courses during the accreditation process but there is no proof that such changes could not have occurred through a different process such as continuous improvement or response to regulatory or market forces.
Social-political context
Pryor also includes a flow-charted “conceptual framework for the OHS Body of Knowledge” which places Work as the starting point. Pryor summarises part of the framework as:
“Work impacts on the safety and health of humans who work in organisations. Organisations are influenced by the sociopolitical context.”
It is this point that illustrates a major handicap of the framework. By placing the social-political context at the organisational stage the framework misses out on considering the broad range of social and political factors affecting Work or Humans. If this is the framework on which the OHS Body of Knowledge is written, there is a problem. And if this is the OHS BoK on which OHS course accreditation is based, there may be a further problem.
Cost
A curious omission from Pryor’s discussion of the accreditation process is the issue of cost. Tertiary accreditation processes in Europe are often provided by government at no charge. In Australia, the Federal Safety Commission provides an accreditation process for government-funded construction programs at no cost to the stakeholders. However the AOHSEAB applies the fee structure below.
These costs are not minor. Universities have multiple OHS courses incurring repeated application fees. The commercial needs of the AOHSEAB may be justifiable but they are also a factor in the operation and acceptance of the accreditation process that should have been acknowledged in the research paper.
Pryor lists each element of the accreditation process such as a desk audit and review of online learning materials but fails to mention fees and costs.
AOHSEAB lists several reasons why universities should accredit their OHS courses. Its value statement states:
“Accreditation of OHS professional education provides guidance for students considering OHS professional education.
Accreditation of OHS professional education programs provides guidance for employers and recruiters in selecting OHS professionals and in supporting the professional development of personnel.
Accreditation of OHS professional education programs contributes to public assurance that graduates meet
certain minimum standards of knowledge and skills. Accreditation also contributes to community perceptions of OHS as a valued profession.Provider institutions benefit from having their OHS programs accredited through enhanced profile, reputation and standing with potential students and employers.
Provider institutions realise quality improvement in their programs by submitting their program to a self and peer assessment process.”
Almost all of these can be interpreted as marketing benefits for the universities or “provider institutions” and one element of AOHSEAB’s supporting evidence for the benefits to employers and recruiters is a remuneration survey by a recruitment firm!
Pryor’s paper overstates the importance of the work of the AOHSEAB. The abstract states that the research paper shows the potential for
“… an extrapolation to potential lessons for other countries”.
Like the use of “impact”, there is an implication that the lessons will be positive but this may not be the case.
The elevation of Capability over Competence is a strategic misstep and fails to consider how Australian business, communities and OHS regulators will interpret and apply Capability. The misplacement of the social-political context in the OHS BoK framework is disappointing and the inclusion of anecdotal reports, and the use of these as evidence, is very strange and weakens the case being put in the paper.
David, thanks for your detailed comments. There are lots of points I contest but I want to focus on a couple.
You say that accreditation of tertiary OHS courses has been required and that “In the absence of greater government regulation, the market does not magically deliver this”. I tried to make the point that it is on the proponents of accreditation to show the evidence that accreditation is a more effective method of improving the quality of tertiary course than what could have been achieved by market forces or the changing demands of the government and training/education regulators.
I don’t believe Pryor’s research has shown this and the lack of evidence behind several claims in the research paper was pointed out in the article above.
On the matter of Competence and Capability, I don’t think I can make my perspective clearer but do direct your attention to the quote from Pryor’s reaseach above:
Why complicate the established understanding and processes of Competence by imposing an additional concept that requires explanation and muddies the place of Competence in OHS training and regulation? Why wasn’t the issue of Competence (or incompetence) the focus of the HaSPA BoK process as WorkSafe Victoria expected it to be in the initial funding stage? Surely it would have been better to redefine or expand Competence rather than imposing an additional concept.
WorkSafe’s concerns over the incompetence of some OHS professionals was the catalyst for the SIA/AOHSEAB/HaSPA program and Pryor’s research fails to provide evidence that the accreditation of OHS courses has improved professional competence.
On your responses to issues addressing the quality of the BoK, the research by Warwick Pearse and Gunther Paul has looked at this through their benchmarking process.
I look forward to any comments from the AOHSEAB and Pam
I would like to take issue with a few points in this piece Kevin.
Firstly, in regard to how the BOK stands up against it’s international counterparts – there are some strong opposing views to those which you present. Are you arguing that the years of work done by so many people on the BOK is washed away, or that it needs improvement ? In my view it is a great piece of flawed work, a living document which continues to need improvements and change, but critically important particularly to the OHS profession, which spends so much time worrying itself about what it is. If there was an equivalence of effort on continuing the work to improve and develop the BOK, than there is on its critique, we may well be in a much better position today as a profession. Also, the BOK obviously does not seek to make other pieces of work defunct. It is a broad based body of work which references vastly more content in the very broad body of external OHS knowledge and research, than it has content of it’s own so obviously is not designed to replace ‘vast libraries of OHS knowledge’.
Secondly, Accreditation: There would be very few people who would not have argued for many years, for the need for greater consistency of quality in the delivery of higher education in OHS in Australia – and you can’t do that without a system of doing it. In the absence of greater government regulation, the market does not magically deliver this. Unchecked, markets do as little as they can for the lowest price of doing it. Look at the current state of VET training.
The options on how to achieve these goals in higher education are limited. A successful model used across many professions and around the world, is accreditation. Accreditation is already working in this sector, raising the bar in key areas of the programs being accredited, and generating greater consistency across programs. Of the options available, I would argue that Accreditation is also the most cost effective. Drawing criticism on the cost is to me pretty extraordinary given the tens of millions wasted every year in the OHS training market on sub-standard training. If you want a scandal, go there and stand up for something better. The sector deserves it. Furthermore, Accreditation has always been since its inception, and continues to be, a net cost to the SIA – NOT a profit making activity. It is done as one of a number of things we do to advance the profession, and given the improvements that are occurring as a result of the work, we’re pretty happy with it.
Thirdly, on the issue of capability and competency: Ms Pryor did not invent these terms, nor the differences between them. Nor did she invent the now common usage of ‘competency’ in the context of the workplace, or the notion that capability comes from (different versions of, depending on the conceptual framework behind which occupation you are examining) a mixture of education and experience. I propose that it’s generally well understood that competence can also be built from experience outside of the workplace, and there is nothing in the framework presented which suggests otherwise.
How you can fairly draw from this article that the author is ‘elevating capability over competence’, is beyond me. Or even that it matter sin some way. Competency is commonly used to describe work based skillsets, and that in drawing on the broader capability term, additional things such as values, personal attributes, education, (and even social-political factors!) are being included as building capability. So what? I would have thought you would be cheering this one on. I believe that the broader definition being used around the term ‘capability’ is useful and insightful for the reader, and don’t think ‘competence’ is in any way being subjugated.
Finally I can personally relate to your concern about the importance of social/political factors on the individual. However, it’s one thing to think the framework could be improved by better positioning of this, but to suggest that potentially the whole premise of multiple BOK chapters is undermined ? Seriously?? Ms Pryor is not the author of the BOK. A very large number of OHS practitioners, professionals and academics are its authors of the BOK, and these people brought a range of different conceptual frameworks to its development. As it turns out, this is a criticism of the BOK from some – but I wonder if it is not a great strength.
Kind regards
Dave
Good work Kevin!