CARA's “supervisor qualifications” rejected
Queensland Teachers' Journal, Vol 126 No 7, 8 October 2021, page no.24
The QTU has rejected the “supervisor qualifications” section of the CARA guidelines as it forms an unsafe system of work for school leaders and teachers.
On 27 August, QTU General Secretary Kate Ruttiman wrote to Deputy Director-General Shannon Cook to inform the department that the Queensland Teachers’ Union does not support the release of any of the CARA guidelines as they stand.
The statement below and associated advice ostensibly places principals at risk by indicating that they can make judgements about the competency and skills of staff.
“Principals make final decisions in determining supervisor capability (competence, relevance and currency) and are responsible for encouraging and enabling school-based activity supervisors to raise their qualifications to improve safety standards.”
The wording makes the principal responsible for deciding whether a person has the competencies to ensure safety in activities that are medium to high risk. The risk is further exacerbated by wording like “encouraging and enabling”. At the very least, this should read “provide time, training and resources to the teacher to ensure they have the requisite knowledge and skills to supervise or deliver the medium to high risk activity before being assigned to supervise or deliver”.
S19 (3) of the Work Health and Safety Act 2011 (Qld) makes it clear that under the primary duty of care, the person conducting the business or undertaking (PCBU) “must ensure, so far as is reasonably practicable:
(c) the provision and maintenance of safe systems of work
(f) the provision of any information, training, instruction or supervision that is necessary to protect all persons from risk to their health and safety arising from work carried out as part of the conduct of the business or undertaking.”
Principals do not have the training or knowledge to assess the competency of a non-subject specific teacher to deliver a safe working environment in curriculum areas delivering medium and high-risk activities, nor should the principal be given to believe they do. It is for the department (the PCBU) to provide a rigorous process and source appropriate training to ensure that only skilled practitioners deliver medium to high risk activities in schools.
A strong safety pedagogy is missing when a registered teacher without subject expertise is placed as the supervisor of someone with industry experience and an “appropriate qualification”. As an experienced hospitality teacher said: “I can hear safety, I can see safety, I can smell safety”. The risk to principals, teachers, and students is foreseeably greater in rural and remote schools with changing leadership teams and changing staff.
Furthermore, there are significant issues re the holding of VET certificates. The very fact that a teacher is managing a medium to high risk activity “through” someone who is not trained to teach foreseeably increases risk. The qualification and industry experience do not equip the person to instruct students safely. Further, it may be that the instructor has acquired inappropriate industry “short cuts”. The registered teacher, although providing direct supervision, would not be aware that the process is unsafe.
A person working in industry with a Certificate I or II in Hospitality is expected to be either closely supervised or supervised when undertaking their actual hospitality role. The same proviso is likely to apply to a Certificate II in Agriculture. Where such limitations are captured in the CARA recommended qualification, it becomes clear that the certificate is not at the requisite skill and knowledge level.
The “Supervisor qualifications” section is not conducive to a safe system of work. The department has the duty to adopt safe systems that ensure that someone has the appropriate training and instruction before they are assigned to undertake the work.
The QTU will continue to advocate for changes to the proposed CARA guidelines that will protect school leaders and teachers of activities that are medium and high risk. The Union will also advocate for appropriate resourcing for schools to ensure that the costs of compliance and training are provided by the employer and not passed onto the school, creating an additional workload and budget pressure for school leaders.