Anonymous - 23

Response:

The role of industry needs to be strengthened and expanded across the VET system. Currently the role is mostly limited to the development of the qualifications and units for each industry, without influence over delivery, assessment and funding. This needs to change and industry input needs to be more highly valued, particularly when it comes to recommendations that simplify and improve the efficiency of delivery without affecting the job roles involved. It is also critical that the system incorporates the capacity to develop nationally consistent assessment and training resources to encourage RTO delivery and improve graduate quality.

The approaches related to industry involvement in the VET system need to be considered on an industry basis. While the current approach may provide consistency across industries and may meet the needs of many of the industries that work with VET, it does not meet the needs of each industry. There are no one-size-fits-all solutions that allow the broad variety of industries to achieve the same benefits. Increased flexibility needs to be built into the system.

The Racing and Breeding industry is a regulated industry, with licensing requirements in each State and Territory. All States and Territories have Racing Ministers and formal regulatory bodies which oversee the industry, known as Principal Racing Authorities. There are tribunal structures supported by formal legal avenues of appeal, and serious penalties can be imposed for breaches within this system. In addition, each code has a State/Territory body that oversee racing operations that operate within the jurisdiction, as well as National/Australasian bodies. 

Principal Racing Authorities have specific requirements for industry consultation and engagement. These requirements are formally established under relevant legislation and are taken seriously in all jurisdictions and in all codes. Regulation is increasing as concerns such as animal welfare and gaming issues are identified, mainly through the work of the Racing and Breeding industry with contributions from professionals, media and community groups. There are strong industry association bodies working with the Principal Racing Authorities. 

The Racing and Breeding IRC works very closely with Principal Racing Authorities and should be able to take greater advantage of the established consultation avenues available in the industry. When Principal Racing Authorities support a proposal, they do so with the benefit of both extensive knowledge of the industry and legislative authority. There are times when the integrity of the sports require Principal Racing Authorities to make decisions that are not always fully supported across the industry, and it is important that the work of the Industry Reference Committee supports implementation of those decisions through skills development. The Industry Reference Committee has also developed strong connections with industry association bodies, employers and other stakeholders.

Given this, in Racing and Breeding, industry engagement and the connections between industry and the VET system could be built through the Principal Racing Authorities, and a national body similar to the current Industry Reference Committee covering all codes and jurisdictions would be ideal for industry engagement if it: has formal status with both the Authorities and the VET system; is supported by an SSO; and has involvement in all elements of the VET sector. This proposal is similar to a Skills Organisation described by the Joyce Review, except it would be mainly established through regulatory rather than employer channels in the industry. It would still include representation from employer and employee groups as the current IRC does. This approach would have the benefit of embedding considerations of education and training requirements in all elements of the Racing and Breeding industries. 

Also, connections can be built between the various Participant Bodies/Associations (i.e. ATA, AJA, Breeders, etc. and the VET system.

Response:

Yes

Response:

There are major gaps in the effectiveness of industry engagement in meeting our industry needs. This arises because of the limited roles that currently exist for industry participation across the whole training journey from industry entrant to industry participant and advanced participation.

The current arrangements relating to industry involvement in the development of industry skills standards work very well, but are undermined by the actions of decision-makers and rigid application of standards that are not necessarily relevant to the Racing and Breeding Industry. An example was in our work in developing RGR20218 Certificate II in Racing Industry. In the initial design, the new qualification did not cover the greyhound industry. Subsequent feedback from RTOs confirmed by employers and the Principal Racing Authorities is that a relatively minor change to the structure of the qualification would broaden its application to include greyhound racing, and therefore improve the career pathways for industry entrants in line with Ministers priorities. Instead of being allowed to make this change, the STAs (subsequently endorsed by the AISC) are forcing the issue through a full consultation process, not for any industry or training-based reason, but because the change to move a unit from core to elective is a "major" change. In the meantime, the IRC are being asked about low enrolment numbers in the Training Package, but this action which would improve enrolment numbers is being delayed.

Using the measure of low enrolment numbers is a poor assessment of quality VET – if there is a need for skilling workers, whether there are 100 in Australia requiring the skills or 100,000 there often will be no difference in the importance of the training.  

Additionally, due to the great cost associated with RTOs complying with the requirements of accredited training, (particularly for thin market) there are a number of situations whereby the units designed in Training Packages may be delivered and assessed outside of the VET system to reduce costs.

The cost of enrolment is another  reason that may prevent individuals in enrolling in the courses/units.  Whilst the Horse and Greyhound Training Award requires employers to pay enrolment, this is only relevant when the learner is already employed, often people with no experience undertake training prior to employment should training be available
Another gap is in establishing the modern conditions for apprenticeship and traineeship arrangements that suit both the needs of training responsibility and supervision, and modern methods of work including employment models. Many in the racing and breeding industry are unable to meet the employment requirements of apprenticeships and traineeship because much of the work is more suited to self-employment, seasonal, casual and gig economy arrangements. While some of these barriers have been addressed in our larger training programs, many have still not been addressed, and this issue is particularly critical in Regional, Rural and Remote Australia where the benefits would be most welcome. The Racing and Breeding industry has extensive knowledge of these issues, however apprenticeship and trainee models are designed on a more generic basis unsuitable for this industry.  




The Racing and Breeding industries have a record of employing people from disadvantaged backgrounds and have job roles suitable for many. However, as a professional sports occupation, some job roles require specific physical and intellectual capacities. These exemptions are recognised by the various formal equity/non-discrimination bodies in Australia. However, there have been recent moves by State and Territory funding bodies to insist on enrolling students who cannot realistically meet job requirements, as they see "education and training" as separate to industry participation. They are applying equity rules from the education and training sector where accessibility is a major priority. As a result, some RTOs are being directed to enrol students even though the students will not be able to participate in their selected job role. The Racing and Breeding Industry strongly supports equitable participation subject to having the capabilities to participate in the selected job role. Many people of varying capabilities can participate as a stable hand, but very few can participate as a jockey, which remains one of the most dangerous occupations in Australia.  

The effectiveness of industry engagement where it is recognised as part of the system is very high, however there are far too many parts of the system where industry engagement is hampered, rejected or not available. 

Response:

The Racing and Breeding IRC has experienced difficulties while trying to meet the Ministers' Priorities and utilise imported and cross-sector units. Collaboration across industries requires some level of similarity between the industries, not just a broad skill alignment.

The RGR IRC endeavours to work with the Animal Care and Management IRC, however, despite the commonality of a horse in many job roles across both training packages, this has not worked particularly well.  For example, horse breeding has been moved out of the ACM training package into Racing and Breeding in an endeavour to make the Breeding qualifications more relevant to the major horse breeding enterprises in Australia – the Thoroughbred and Standardbred sectors.  

However, as a highly regulated industry, there is a need to ensure that industry participants are appropriately trained in the skills needed for animals, sports, personal health and fitness, work safety (in a particularly high risk sector), administration (for regulatory purposes) and integrity. Many of the job roles are quite unique and job specific skill sets would be more suited to many – enabling those moving to different job roles to add specific skills as they require them.  Trying to add more learning to existing qualifications would make the qualifications unreasonably large and complex.

In the Certificate IV Racing (Jockey) the IRC approved a substantially streamlined degree and followed the advice to use BSB units rather than develop business skill units for racing industry participants. The skill level, learning requirements and safety considerations mean that the jockey qualification must sit at AQF level IV, but units used at AQF Level IV in BSB (or FNS) qualifications have proven to be totally unsuited  for jockeys and Harness Race Drivers who are sole traders who do not attend an office to undertake their financial management in the manner that the BSB units appear to be written for – yet many jockeys have significant income and have to return BAS statements etc . As a result, there is much within the BSB units that is irrelevant and the nature of the learners needs is making it impossible for RTOs to effectively deliver the units. 

This issue is making delivery difficult and may prevent completions, yet the learner may be a very successful jockey who requires the qualification for licensing. The ideal would be to modify an existing RGR unit to include relevant skills, but this would not comply with the Ministers Priorities relating to duplication. After discussions with the relevant industry bodies (Trainers and Jockeys) and the Principal Racing Authorities, the IRC has decided that the best available option is to remove the relevant complex from the core and list them to be electives. This would not affect the actual job role of jockey. Again, despite the simplification in delivery that would result and the lack of effect on the job role, as well as support from the Employer/Employee associations, the Principal Racing Authorities and some STAs, some State Training Authorities objected to an accelerated process because of the change to core units, and the AISC supported that position, delaying this change.

Since submission of the Case for Change, the BSB units have been superseded or deleted and a change is required in any event – again a reason for industry specific units being more effective, and often cheaper for RTOs to maintain scope.

Response:

The current RGR qualifications are mostly fit-for-purpose with the main issues centering around getting RTOs to put the qualifications on scope. All qualifications have been updated in the last three years and have been significantly re-modelled and simplified. The training product development projects were undertaken professionally and made substantial changes to a training package that had not been properly reviewed for a decade or more.

Whilst it was known reviews were required, due to the current funding models and structures, the IRC was reliant upon the SSO to put forward business cases for review, and reliant upon what other projects in other industries were proposed, these were prioritised outside of the IRC remit.  The IRC understands that It is critical that all qualifications have a regular review, and a maximum of 3 or 4 years between updates would be ideal, however it was not possible for the industry, through the IRC to get the needs prioritised.. 

While the new qualifications are a substantial improvement on the previous situation, there have been issues arise during implementation and errors made which the IRC is now trying to correct. However, the system of change for Training Packages is not set up to allow for flexibility and agile development. There are no allowances made to address implementation issues as they arise and correct errors quickly. 

It is understandable that in larger training packages, there would be concerns about whether RTOs are aware of changes being made. In RGR however, there is a real struggle to get RTOs to operate in our small market, and the RTOs and schools that do deliver RGR training are small in number and well-known throughout the industry. For example, in relation to Certificate II in Racing Industry, the IRC were able to contact all RTOs with the qualification on scope, and received responses from all except one, which were supportive of the proposal now going through full consultation.

Major issues occur with the use of imported or cross-sector units, particularly if no contextualisation can be added for each industry. There is a lack of control or input into imported units, and these units are considered by IRCs in the context of their industry needs, not to meet the needs of other industries. In WA, an RTO was working to put a RGR qualification on scope but needed to deliver SSI Units to deliver the full qualification. The units had been deleted and non-equivalent units were created in the short period since the approval of the RGR qualification. The new units developed for SSI relate to coaching rather than to the athlete, making them unsuitable for use in RGR. Because the units were deleted, the SSO cannot put them on scope and so was unable to put the qualification on scope. 

The IRC will now need to review the available options, however the likelihood is that the best option will be modification of existing RGR units or creation of new RGR units, recognising that these options do not align to current policy settings. 

Response:

The Racing and Breeding IRC is a very functional group that has a good understanding of VET and represents the industry across all sectors very well.  There is a strong reliance on Farriers and Horse dentists for our industry to function, however responsibility for these qualifications sit in the ACM Training Package and are covered by the ACM IRC.

As a minimum there should be at least one member of the Racing and Breeding IRC with horse and one with Greyhound expertise sitting on the ACM IRC to ensure that units developed are at least considering a broader sector. 

There have been times when the Racing and Breeding IRC have identified work that it could have undertaken and funded by industry itself, however a requirement to work with the SSO and the processes and compliance they are required to follow prevent this occurring.

The Chairs of each IRC should have direct access to the AISC to ensure that the industry is able to prioritise their specific needs and move away from the one size fits all that appears to be occurring at present.  Policy discussion, TP and unit review etc. should be more openly considered to ensure that our industry is able to provide meaningful and timely advice.  There is a great deal of difference between VET needs for ‘office’ based work and the unique and often dangerous skills required for breeding, handling and racing animals.  
The cost of delivering and assessing VET is making thin market (particularly horse related) qualifications unappealing for RTOs.  The Racing Industry, through the IRC has repeatedly requested that funding should be provided to develop training resources, particularly assessment tools to be part of the endorsed product.

This has a number of benefits – it provides the RTO with tools, therefore cheaper to put the qualification on scope, the tools will be compliant (auditors only need to check they are used correctly) and an industry such as Racing would welcome the confidence that every Jockey ( has been assessed to the same standard.  Whilst in training a number of Apprentice Jockeys move between states and territories for show term secondments and long term – endorsed assessment tools that are common to all RTO would be of great benefit.