CHAPTER 5 - FIRST AID TRAINING APPROVAL

ARRANGEMENTS

The Legal Requirements

1.             The research specification did not include an assessment of the current arrangements where HSE gives approval to training providers. Nevertheless this is an important issue that should be considered in parallel with the other training issues in this Discussion Document.

2.             The current training arrangements require that first-aiders hold a valid certificate of competence in first aid at work, issued by an organisation whose training and qualifications are approved by HSE.  This is to meet the requirements of Regulation 3 of FAW that a person is not suitable as a first-aider unless “he has undergone such training and has such qualifications as the Health and Safety Executive may approve for the time being….”. 

3.             HSE has interpreted this requirement as requiring approval of the providers of training courses in first aid at work. This system is administered through a special unit within HSE, the First Aid Approvals and Monitoring Section (FAAMS), working with HSE’s external contractor, the Training Approval Services Consortium (TASC). There are currently around 1500 approved training organisations, with new applications running at 8-12 per month. HSE has charged training providers for the administrative costs of approvals since October 2000.

4.             A specific consequence of this interpretation is that trained first-aiders from Northern Ireland, and from other EU states, including the Republic of Ireland, are prevented from practising in Great Britain. At present, if such trained individuals wish to become first-aiders in Great Britain they are required to re-train. This can have the effect of placing a burden on both the employer and the employee. 

5.             The current arrangements for first aid training approvals have been in place for a number of years. Administrative approval and monitoring arrangements of training providers are in place to ensure there is consistency of standards across the country. However, HSE considers that other methods of meeting its obligations under the Regulations may be more appropriate and would like to explore these other options.  Moreover, within the current approval and monitoring system the area of work that results in the largest amount of enquiries relate to qualifications and experience required to be a trainer or an assessor. The current approvals system is described in Annex 4.

Qualification Standards for Trainers and Assessors

6.             The approval and monitoring of training organisations involves a check, covering the previous three years, of the qualifications of the trainers and assessors they use. The checks cover both training and assessing skills, and first aid skills and competencies. These checks are needed because of the wide variety of backgrounds of those who become first aid trainers and assessors. It is also because the range of qualifications accepted is broad. HSE would like to see the introduction of a nationally agreed qualification for both trainers and assessors, and the names of qualified people to be held on a national register.  This would enable training providers to recruite trainers or assessors from the register knowing that they fulfill the necessary qualifications and experience criteria. 

Options for a First Aid Training Approvals System

7.             Outlined below are some specific options on which HSE would like to receive your comments. In Chapter 4 you were asked to consider alternative options for approved first aid training courses. The impact of any changes in the approvals process on first aid courses or vice versa would of course be carefully considered as part of any change process.    

8.             Whichever option for a first aid training approval system is finally agreed upon, the arrangements will need to continue to deliver the required assurance that appropriate first aid training is being delivered. Also, if a need is identified for more detailed guidance for training providers, then HSE will consult with the first aid training industry on how this can be met.   

Option 1         HSE approves training providers

9.             This option is to continue with the present system of HSE approving training providers as operated by FAAMS and including the use of an appointed external contractor who conducts monitoring visits on behalf of HSE. 

10.         Although this system has been in use for some years, HSE has concerns that the administration of a database of training providers is not consistent with our core business. The system is burdened with an increasing administrative workload which includes monitoring of training providers, re-issuing of certificates (where a change of name or address has occurred), updating the electronic record system and also dealing with complaints as both arbiter and enforcer.  HSE does not favour this option and would like to use this opportunity to explore alternative approaches which are more in line with modern training practices.

Option 2         HSE approves structure and syllabus of training

11.         We have explained that HSE has interpreted Regulation 3(2) of FAW as requiring HSE approval of the providers of training courses. It is equally valid under the Regulation for HSE to approve instead the structure and syllabus of first aid training courses rather than the training providers themselves.  Proceeding with this option would therefore require the introduction of a new monitoring system to ensure that standards of training were maintained.

12.         Such a monitoring system would not be administered by HSE but by an independent monitoring body which could, for instance, be appointed from within the first aid training industry itself. This option would require external accreditation of the system as a whole, conducted by the United Kingdom Accreditation Service (UKAS) or similar organisation. If this option were to be pursued, employers could themselves determine whether an individual trained within the EU was adequately trained to meet the requirements of the Regulations as described by HSE. 

Option 3         No approval system. This is a longer-term option, as it would require amendment of the Regulations

13.         Under FAW employers have a duty to provide appropriate first aid equipment and facilities to give first aid to their employees as required. It is their responsibility to ensure that their first-aiders are adequately trained. If the current approvals system was withdrawn HSE would continue to provide guidance about the requirements of FAW but would not be concerned directly with the content, quality and consistency of training courses or providers. This would be consistent with HSE practice in most other areas of health and safety; that is HSE provides guidance on how to meet duties under regulations but is not itself responsible for any approvals system helping employers to meet those duties. If this option were pursued, employers could themselves determine whether an individual trained within the EU was adequately trained to meet the requirements of the Regulations as described by HSE.

14.         If Option 3 were taken forward the proposals for training courses in Chapter 4 would not be pursued.

15.         Whichever option for the first aid approval system is finally agreed upon, there are three features that will have to be included:

·         Any new arrangements will need to continue to deliver the required assurance that appropriate first aid training is being delivered.

·         HSE will consult the first aid training industry if a need is identified for more detailed guidance for training providers.

·         There should be a nationally agreed qualification for both trainers and assessors, and details of those qualified should be held on a register.

Questions

Q11. We would welcome your views on the advantages and disadvantages of the options outlined above, in particular whether the first aid training industry could regulate itself as outlined in option 2 and ensure training is delivered with consistency and to the required standards.  We would also welcome suggestions for other options that could be considered.

Q12. Do you see a benefit in setting up a nationally agreed qualification/register for first aid at work trainers and assessors?

Q13. If you are a training provider, do you think the guidance given by HSE needs to be expanded - particularly if HSE’s involvement is reduced?    

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