Contesting Competence as Australia enters another Round of Training Reform. Ian Hampson and Anne Junor The University of New South Wales Paper Prepared for the 28th International Labour Process Conference Rutgers, the State University of New Jersey 15-17 March, 2010 Since the late 1980s the Australian vocational education and training system has gone through successive waves of reform, in an effort to create a quality system offering national vocational qualifications. Each reform round has been a response to a ‘quality crisis’ in a system marked by jurisdictional fragmentation, competing employer agendas, and (since 1996) marginalisation of organised labour from policymaking and governance. These waves are summarised, and issues arising from reliance on competency based training and assessment in the context of market-oriented training reform are analysed. Resulting difficulties are illustrated in two 2009 initiatives: the attempt to create a new internationallyharmonised qualifications framework, and the development of a framework for recognising workplace learning. Both initiatives grappled with definitions of skill level and with ways to incorporate ‘informal’ and ‘non-formal’ learning and socalled ‘generic’ or ‘employability’ skills into qualifications. Drawing on theories of workplace learning and work process knowledge, the authors’ own researchbased conceptualisation of ‘skills of experience’ (Hampson and Junor, 2010, forthcoming) is used to suggest that training outcomes need to be understood in a context of the organisation of the labour process. The problem of defining the exact nature of human capacity that is the object of skills development, and building that into recognition structures, is a problem that confronts any national training system: how it is resolved is determined by the relative power of the social partners. Introduction Since 1987, there have been successive Australian attempt to shape a National Training system, out of a state-segmented pattern of funding, regulation and training delivery, within the fragmenting tendencies of a liberal market model. Each reform period was triggered by fears of skill shortages and by concerns over training quality and the integrity of vocational qualifications. The paper backgrounds the most recent attempt, since 2007, to establish a national training system. It argues that a system for the stable and ongoing generation and recognition of high-level skills will require a change of employer orientation. For well over a decade, there has been a marginalisation of the union vision of national capacity-building through skill-based career paths. Rather than ‘growing’ skills, employers have relied on recruiting a mix of contingent labour and ready-formed ‘talent’. Competency based training has tended to privilege assessment over learning, as employers have sought to ‘buy in’, ready-made, both technical skills, ‘employability’ skills – the capacity to function in the workplace that has become a precondition for employment. Yet much of this is work process knowledge, acquired, often collectively, in situated contexts (Lave and Wenger, 1990; Brown and Duguid, 1991; Boreham et 1|Page al., 2002). Whilst welcoming present efforts to set up a national qualifications framework that will regulate quality and assist workforce development through a stronger skills recognition architecture, the paper argues that the new framework will fall short of clarity in conceptualising skill levels, until ‘skills of experience’ are better defined. The first section of the paper outlines, from an institutional and policy perspective, a succession of efforts to forge a national VET system in Australia, and draws out the antecedents of the present restructure, which is outlined in the second section. The third section highlights theoretical difficulties within the concept of behavioural competence, and their practical implications for the problem of assessment. The fourth section draws on the authors’ research (Hampson and Junor, 2010) to suggest that there is still an inadequate classification of the process skills currently referred to by terms such as ‘soft’ or ‘employability’, and also that there is a need to differentiate two conceptualisations of skill level that are at present being run together – occupational skill level and level of practical expertise. The fifth section is a critical examination of how these difficulties have been addressed in new proposals for restructuring the Australian Qualification Framework, and for recognising workplace learning. The concluding section suggests that successful training reform will depend on a willingness by employers to organise the labour process in a way that allows workers to develop autonomous and collaborative skills, and to apply this learning in jobs and job sequences that draw on and build this skill development. Early Reforms: Development and Fragmentation of a National VET System in Australia The Australian VET sector is located in the ‘varieties of capitalism’ literature at the ‘Anglo’ end of ‘liberal market’ training systems, although Bosch and Charest (2010, p. 3) caution against too functionalist a reliance on typologies, reminding us that Australia once had an apprenticeship system in which unions had some influence. Cooney and Long (2010, p. 27-28) identify ‘segmentation’ as the defining characteristic of the Australian training system. Hampson and Morgan (2009) use the terms ‘institutional ‘inadequacy’ and ‘decomposition’ to describe Australia’s failure to develop a stable settlement around training policy. This has resulted from three factors: structural features of Australia’s government; the strategies of Australia’s employers and their organisations; and (particularly since 1996) the marginalisation of organised labour from training regimes. Development of a national approach to training policy and governance has been impeded by jurisdictional competition. Australia’s federal system of government, has historically allocated most power over training and education to five states and two territories states. Thus each state has had its own Technical and Further Education (TAFE) system, and its own State Training Authorities. Their sometimes very different approaches to training policy have hampered national portability of qualifications. Still, since the 1980s state systems have been increasingly reliant on federal funding, while ‘deregulation’ (market-based regulation) has resulted in an even more fragmented, employer-led VET system (Cooney and Long, 2010, pp. 27-28). Employers too have divided interests regarding training, as the structure of their interest representation underscores. The 100 largest firms, mining and finance capital, are represented by the Business Council of Australia (BCA), which has sought to preserve employer prerogatives over training. The Australian Chamber of Commerce and Industry (ACCI) has a larger constituency of medium to small capital more focussed on manufacturing, and dependent on the public training system. 2|Page Before the 1980s, training was mainly built around the trades apprenticeship model, in which young, usually male, apprentices served their time under tradesmen, usually unionised, and attended technical colleges. Unions and the industrial relations system restricted trade entry and helped regulate the quality and content of training and assessment. Awards (Australian industrial instruments which regulate the conditions of work) preserved industrial demarcations along skill based lines. Workplace training was often unsystematic, cursory and dangerous. In 1983 unions entered into ‘corporatist’ arrangements for the first time, under an ‘Accord’ with the Australian Labor Party (ALP), As economic liberalisation and ‘reform’ progressed through the 1980s and the need for industrial dynamism became uppermost, three issues emerged. A genuinely national qualifications structure was required, to support national labour mobility (OECD 1988). There was a need to upskill workers to utilise new production concepts. With the growth of service employment and increasing female employment, women and wage-restrained workers sought skill recognition as a means of pay equity and upward labour market mobility. By 1987 ‘Accord’ arrangements included negotiations for a ‘National Training Reform Agenda’ (NTRA) (Hampson, 1996). Unions proposed a national training fund, into which employers would contribute, and draw from for structured training (ACTU/TDC, 1987). This was subsequently implemented through a ‘training guarantee levy’, which was poorly supervised, resisted and abused by employers, and abandoned in 1994. The NTRA included competencebased training as a central plank. Those who implemented it saw it in an industrial context as a way of delivering skill-based wage rises and career ladders, without worrying about its pedagogical implications (Ewer and Ablett, 1996). Qualifications would be awarded on the basis of Competency Based Assessments of work performance to the level defined by industry standards. They would be integrated across the economy through an Australian Standards Framework (ASF), ensuring labour market mobility (Ewer et al., 1991, ch. 7). A new National Training Board (NTB) would oversee this system, known as the National Framework for the Recognition of Training (NFROT). A nationally integrated training system did not, however, come to fruition. Large employers in particular resisted and undermined the requirement to spend on training, and the incursions into their prerogatives implied by union involvement in training. The NTB lacked the authority to impose ‘national’ training requirements on recalcitrant state governments as well as on employers. Moreover, after one important realignment of minimum rates in male and female dominated industries in 1987, the industrial relations system itself fragmented: from 1991 unions increasingly turned their attention to enterprise-based productivity bargaining (Ewer et al., 1991; Junor, 1998). Meanwhile high youth unemployment resulted in recommendations for a national system of traineeships, designed to provide on and off the job entry-level training at the two lowest qualification levels, articulating into higher-level training (Committee of Inquiry into Labour Market Programs 1985). In the face of slow traineeship take-up and recession, there were proposals in the early 1990s for universal vocational preparation based on pathways through combinations of school, VET and employment. Seven key vocational competencies, were proposed, defined at three levels (for example teamworking, problem-solving, communication) (Employment and Skills Formation Council 1992). Meanwhile under ‘Working Nation’ policies. employers were offered generous subsidies and the right to pay ‘training wages’ on condition that they provided nationally-recognised ‘structured training’. In reality, this could be ‘supervised practice’, indistinguishable from cheap labour (Campbell, 1994, p. 15). 3|Page The 1993 establishment of the Australian National Training Authority (ANTA) began a new stage of national regulation. ANTA was governed by a Council of Ministers of Education, Training, Employment and Youth Affairs from state and federal jurisdictions – a cumbersome governance structure that was nevertheless necessary for managing inter-state rivalries After 1994, state TAFE systems competed for contestable federal funding with private ‘registered training organisations’ (RTOs) – in-house or for-profit providers of training and assessment. Emergence of this training market necessitated national regulation and quality assurance of competency-based assessments and qualifications. Accordingly, the states agree to mutual recognition of qualifications. An employer-led, market-based national training system developed further from 1996 to 2007, under a Liberal-National government. Industry Training Advisory Bodies (later, Industry Skills Councils), which were increasingly employer-dominated, developed training packages. These specified competency standards - statements of training outcomes, setting out required standards of performance. They also identified qualifications to which the competency standards might contribute. Finally, they included assessment guidelines. Thus training packages contained no specific guidelines on learning and teaching. This role was delegated to the RTOs. Indeed some private RTOs offered assessment services only. As the quality of both training and assessment emerged as an issue, from 2000 ANTA used an Australian Qualifications Framework (AQF), in endorsing the training packages. The Liberal-National government created New Apprenticeships, negotiating with the states to integrate traineeships and apprenticeships within the AQF and covering both by training packages (Cooney and Long, 2010, p. 48). Between 1996 and 2003, traineeships grew by 300 per cent, reaching double the number of apprenticeships (Brooks, 2004). Whereas traineeships had originally been envisaged as providing Certificate I and II level training as the basis for labour market entry and further training, by 2003 they were taking the form of specialised, sometimes organisation-specific, Certificate III qualifications, in fields such as transport and storage, hospitality, retail, and health and community services. By 2003, of over 1.3 million total VET enrolments inside the AQF, just under half were evenly divided between Certificate I-II and Certificate III levels, and just over 20 per cent were evenly divided between Certificate IV (the traditional tradesperson level) and Diploma level or higher (Cooney and Long, 2010, p. 39). By 2005, slightly more than half of all training contracts were held by women, and 20 per cent were held by people aged 45 and over (Cully, n,d, but 2006, p. 24). Traineeships were not addressing their original purpose: 15 per cent of 15-19 year olds were still outside full-time employment or education. Employers were significant beneficiaries of the 1996-2007 changes. By 2004, annual transfers of public funds to an estimated value of $750 million were going to employers, through a combination of incentive payments, wages bill savings (the training wage was below the minimum wage), and access to ‘User Choice’ allowing them to negotiate arrangements with a preferred RTO (Cully, n.d. but 2006, pp. 8, 13). A 1998 rule change allowed employers of people already employed to claim government training incentive payments, and by 2003 onethird of traineeships were going to existing workers (Dumbrell, 2004, p. 13). In this training market context, the AQF was used to secure a degree of national consistency within each VET qualification, and also to differentiate qualification levels. But without a basis in training duration or identification of required skill sets, it was hard to establish equivalence across industry fields and education sectors. The number of AQF qualifications expanded from 4|Page 12 to 15, because of difficulties in aligning new qualifications with existing ones (Cooney and Long, 2010, pp. 30-31). Schofield, in reviewing traineeships in three states, found a number of strengths but also significant problems with User Choice and shortfalls in employers’ and RTOs’ ‘legal and moral obligations to apprentices and trainees’ (Schofield 2000, Vol. 1, p. v). High non-completion rates were attributed to poorly supervised training, wholly on-the-job ‘training’, and exploitation through excessive hours and unpaid overtime (Dumbrell, 2004, p. 22). Training access for Australia’s large casual and contingent workforce remained a problem (Hall et al., 2000). By 2000, the marketised system was beset by reports of system-rorting by some private RTOs (non-existent facilities, sub-standard resources, visa scams, issuing of false qualifications), brought to light in a Senate inquiry (SEWRSBERC, 2000; Schofield, 1999, 2000). The politicisation of these concerns led the government in 2001 to reengineer the regulatory system by creating an Australian Quality Training Framework (AQTF), and introducing new quality assurance standards for use by State Training Authorities in registering and auditing RTOs. Ongoing problems with the integrity both of qualifications and of training provision led to the establishment in late 2005 of a National Quality Council (NQC) as a committee of the federalstate Ministerial Council for Vocational and Technical Education (MCVTE). Bringing together nominees from industry, unions, governments, equity groups and training providers, the NQC had decision-making powers in the endorsement of Training Packages, and a wide quality assurance advisory role. Thus by late 2007, persistent concerns about quality, equity and coordination had arisen in the Australian training system Nevertheless a series of high-level and OECD reviews had reaffirmed the value of industry-developed, nationally recognised qualifications linked to the AQF. This ultimate endorsement remained, even in a highly critical 2008 OECD ‘external’ review of the Australian training system. This review found that there were serious problems with training packages. which had become ‘long and complex’, and were unable to be adjusted quickly in response to occupational and industry change (Hoeckel et al, 2008). Thus even critical reviews reaffirmed the role of training packages, provided they were reworked to recognise shifting industry boundaries and reach people without jobs, and as long as they improved pathways, and above all, were streamlined (Schofield and McDonald, 2004; Hoeckel et al., 2008). In the first two years of the new Labor government (2008-2009), how have these concerns been addressed? Reform in Australia since 2007: A New Integration? The new government has foreshadowed bold changes. The December 2008 Final Report of the Bradley Review of Australian Higher Education recommended that the Australian government assume full responsibility for the regulation of both VET and HE by 2010, with a common regulatory and quality assurance agency covering both sectors (Bradley, 2008). Beginning in 2008, steps to consolidating a real national system were taken, through new governance structures and compacts with the states. In April 2008 COAG agreed to a new Ministerial Council for Tertiary Education and Employment (MCTEE), covering both the VET and Higher Education (HE) sectors, with the stated purpose of achieving better articulation between the competency-based VET and merit-based HE systems. A renewal of active labour market policy saw the development of compacts with young people and retrenched workers. 5|Page Whilst market-oriented and industry-led logics remain, there was a renewed focus on the use of nationally planned workforce development targets to address skills shortages, business cycles, and productivity and equity objectives. These objectives were pursued in 2009-2010 through National Partnerships based on the Productivity Places Program, and through a two-year $6.7 b. National Agreement for Skills and Workforce Development. This was based on the Bradley 2020 target of halving the proportion of 20-64 year olds with qualifications below Certificate III, and doubling diploma and advanced diploma completions. The planning role was assigned to Skills Australia, a new statutory advisory body established by legislation early in 2008. In March 2010 its Australian Workforce Futures: A National Workforce Development Strategy, set six targets for building a skilled, sustainable and inclusive workforce (Skills Australia, 2010). Skills Australia also tackled the long-running question of the governance of a national training system. A September 2008 Discussion Paper, produced a flowchart of current structures (a slightly simplified version is reproduced as Figure 1), in order to argue that ‘governance arrangements could currently be considered congested’ (Skills Australia, 2008, p. 6). A follow-up governance paper, Foundations for the Future (Skills Australia, 2009) recommended the eventual merging into a new single regulator of the NQC and the National Audit and Regulatory Agency (NARA, recently created to manage cross-jurisdictional quality control). This was in line with the Bradley proposal for the gradual integration of the national regulation of VET and HE, once consistent national frameworks are in place. It is too early to say whether these proposals will address VET sector institutional ‘inadequacy’. Figure 1 National Governance Arrangements for the Australian VET Sector, 2008 As if to illustrate Skills Australia’s claim of ‘congested’ governance structures, in 2008 and 2009, several players were addressing longstanding quality issues. In May 2008, the NQC, working with a COAG Skills and Workforce Development Subgroup, began a Review of VET Products for the 21st Century, which reported in mid-2009. Its terms of reference were to 6|Page improve the design of units of competency, training packages, VET qualifications, accredited systems and recognition. It began by addressing two very fundamental questions: Whether the current approach to competence and its assessment was sufficient to satisfy key workforce development objectives - filling gaps in foundation skills and equity requirements, and meeting future skill needs; The relevance of existing qualifications to diverse groups of learners and enterprises, and whether they could be consistently and reliably assessed (NQC/COAG, 2009, pp. 10-12). Further considerations were the incorporation of employability skills and the need for a greater emphasis on cognitive skills (NQC/COAG, 2009, p.9). This working group acknowledged that a second body – the new AQF Council - was also looking at the issue of skill-based pathways, and suggested a joint approach (NQC/COAG, 2009, p. 17). In a separate 2008-2009 project, the NQC also explored frameworks for the recognition of skills acquired outside formal education and training. (NQC, 2009). The main work on competency recognition and skill-based pathways was however being done by the new body, the Australian Qualification Framework Council (AQFC). Established by the Ministerial Council for Employment, Education, Training and Youth Affairs (MCEETYA) specifically to advise on the architecture of the AQF, it contributed to the Bradley review goal of an integrated regulatory framework for the tertiary sector. The centrality of the AQF to integrated tertiary education regulation is suggested by the choice of AQFC chair - John Dawkins, who had overseen the creation of a Unified National System of higher education, during the ‘clever country’ days of the late 1980s. The AQFC was charged with recommending a qualifications ‘architecture’ that would ensure international harmonisation of qualifications, promote cross-sectoral recognition of qualifications, and provide for recognition of informal and non-formal learning (including workplace and professional learning). If lifelong learning was to be promoted via greater connectivity and easier movement between the VET and HE systems, a common language of human capacity and achievement needed to be developed. The VET sector relied on the language of ‘competence’; the HE sector on levels of ‘knowledge’ expressed in degrees. VET was vulnerable to the criticism that it sometimes failed to provide underlying knowledge; HE to the criticism that its knowledge lacked application. Both were seeking a language to express ‘generic skills’: ‘employability skills’ in VET, ‘graduate attributes’ in HE (AQFC, 2009a). Thus competency, assessment practices, generic skills and skill recognition were under serious scrutiny. The next two sections provide a brief overview of the issues, and the authors’ own research-based approach to resolving them. Disarray in Conceptualising and Implementing Competency, ‘Employability’ and Assessment Competence Contested conceptions of ‘competence’ have been among the key drivers of training system reviews. These conceptions have taking a cross-national dimension since the 2000 Lisbon agreement sought the ‘harmonisation’ of skill recognition arrangements in a new European Qualifications Framework (EQF) (Rauner, 2008; Sellin, 2007/2008). Despite differences in prevailing notions of competence, in particular between Britain and Germany (Clarke and 7|Page Winch, 2006), the Australian, US ‘Euro/German’ models have all recently experienced some convergent rethinking (ACER 2001; Mulder et al., 2007). New conceptualisations of service skill have contributed to a consensus that the concept of ‘competence’, and its assessment, need to change. From 2002-3 in Australia, it became clear that competence increasingly entailed a number of illdefined ‘soft skills’ (ANTA, 2004). This understanding was expressed through contested notions of ‘employability skills’. In the UK, Labour Process theorists noted how employers were seeking to build employee compliance into expanded definitions of skill (Warhurst et al, 2004). In this section, we draw out the significance of debates, in each reform phase, over the balance between observed performance and more tacit processes of learning, cognition, interaction and work organisation in defining performance standards and assessing competency. We begin the Australian account with the adoption, in the late 1980s, of the British model of competency. Defined in terms of observable behaviours and performance, this model resulted in the attempt to create a form of assessment based on outcomes so clearly specified that judgments about whether they had been achieved would be straightforward (Wolf 1995, p.1). The claimed advantages of behavioural notions of competence – their contribution to valid and reliable assessment, requiring only a few days’ training in generic assessment skills – were however critiqued in the education literature as chimerical, as there is no single model of competent performance (Ashworth and Saxton, 1990; Wolf, 1995, p. 17). The specification of training outcomes in the form of behavioural learning objectives was critiqued as denying broad, conceptual and ‘incidental’ learning (Wolf, 1995, p. 85-86). Moreover, industrially, pay equity practitioners were seeking to ensure that less observable service skills were codified in competency standards (Hall, 1991; Burton, 1995). In response, the original body set up to endorse Australian competency standards, the National Training Board (NTB), advocated a ‘broader’ model of competence, embracing not only ‘task skills’ but ‘task management skills, contingency management skills, and job/role environment skills’(NTB, 1992, p. 29). The Board called for competency analysis to include ‘organising and coordinating skills’ and ‘communication and interpersonal skills’., noting that the former were not restricted to middle management jobs as ‘many jobs require constant rearranging and reprioritising of tasks and team work coordination’ (NTB, 1991, p. 7). In 1994, the relevant Ministers adopted the following proposal from the Australian National Training Authority: Standards should encompass all aspects of competency, including underlying knowledge, ability to transfer skills to new applications, literacy and numeracy competencies (ANTA, 1994, p.9). This broad concept of competency has superficial similarities to that in the US management development literature, where competence is seen as ‘an underlying characteristic of an individual that is causally related to criterion referenced effective and/or superior performance in a job or situation’ (Spencer and Spencer, 1993, p. 9). This more extended ‘attribute’ model of competence presents significant problems of assessment, which are avoided in the behavioural model at the price of comprehensiveness. Arguably, the expanded notion of competence also lends itself to the forms of employer domination such as personality testing identified by Labour Process theorists (eg Brown and Hesketh, 2004). 8|Page Defining employability skills Any notion of competence which includes motives (Spencer and Spencer, 1993) is problematic on two counts. First, it leads to employer domination of ‘skill’, and second, it leads to incoherence, by failing to differentiate between work-related knowledge, skills and aptitudes on the one hand, and motivation/commitment on the other (Nordhaug 1999, p.19). Managers can then define people unmotivated to perform in the desired way, not simply as uncooperative, but as incompetent. The formulation, ‘I am competent to do x, but I lack the motivation to do it’ is rendered contradictory, because competence is made to entail motivation. Resistance and recalcitrance are thus redefined as incompetence. For similar reasons, several commentators have identified as problematic the tendency for ‘skill’ definitions to embrace ‘a spectrum of knowledge, capabilities, traits, and attributes – including discipline, and conformity to norms of physical appearance’ (Keep and Mayhew, 1999, p. 10). Crouch et al (1999, p. 222) note employers’ increasing desire for ‘social skills’ that may include anything from ‘the ability to coordinate and secure cooperation, through ability to communicate effectively, to simple willingness to obey orders’. Lafer (2004, pp. 117-8) documents how discipline, cooperation, and compliance (and even freedom from substance abuse problems!) have been defined as ‘skills’. Thus, ‘skill’ threatens to mean nothing more than ‘what employers want’. These tendencies surfaced in Australia between 1998 and 2003, when employer organisations redefined the generic skills of the Carmichael Report, as ‘employability’ skills (Sheldon and Thornthwaite, 2005). These were described as ‘skills required not only to gain employment, but also to progress within an enterprise so as to achieve one’s potential and contribute successfully to enterprise strategic directions’ (ACCI, 2002, p. 3). Many of the generic skills listed would be familiar to an international audience: communication, team work, problem solving, initiative and enterprise, self management, learning and technology (ACCI/BCA, 2002). But the BCA and ACCI added a number of desirable ‘personal attributes’: loyalty, commitment, honesty and integrity, enthusiasm, reliability, personal presentation, commonsense, positive self esteem, sense of humour, balanced attitude to work and home life, ability to deal with pressure, motivation, adaptability (ACCI, 2002, p.5; ACCI/BCA 2002, pp.6-7). Fortunately, in the version finally accepted by the Government, personal attributes were not included as part of the employability skills framework. In 2003-04 a major ANTA Review of Australian training packages found that there was a need for a rethink of the assumptions underlying competency based training. The review gravitated towards an expansive ‘collective’, or ‘integrative’ notion of competence, criticising what it saw as an Anglo view of competence as being held by individuals. It argued that the Anglo model fails to recognise the ‘context-dependent’ nature of competence: the conditions of a competent performance may not reside entirely within the individual. An alternative approach would see competence as ‘... the interaction of individual, group, managerial, and technological systems which when brought together affect organisational competence. It is never individual but collective’ (ANTA, 2003, p. 20). The Review went on to argue that ‘…collective competence depends on each person having a shared understanding’, citing Boreham et al (2002) as representative of this essentially ‘European’ perspective: Work process knowledge is defined as an understanding of the labour process and the production process in the organisation as a whole. Knowledge of this kind is needed by employees of flexible organisations to enable them to deal with new situations and work across boundaries. Work process knowledge is also crucial wherever communication and 9|Page information technologies are introduced to make better use of knowledge assets (Boreham et al, cited in ANTA, 2003, p. 20). Despite their collective, contextual and processual understanding of skills, the Review authors ultimately accepted the employers’ conception of these broad human capacities: Technical skills are insufficient; cognitive skills, together with an array of generic skills and dispositions, are of equal importance. Attributes such as problem solving, continuous learning, communication and teamwork, are joined by others such as curiosity, motivation and risk taking (ANTA, 2003, p. 4) This quotation brings back ‘dispositions’ and motivation, alongside ‘technical’ and ‘cognitive ‘skills. This is a long way from the Carmichael Report notion of generic skills as foundational to further learning – problem solving, continuous learning, communication and teamwork. In fact, these are neither attributes nor skills, but activities enabled by cognitive and non-cognitive skills. Nor need they be ‘basic’: levels of capacity for reflective learning and problem-solving are deepened through experience and practice over time. It is important to clarify the confusions, both about the content and about the level of these skills, and we do this in section five.. Embedding (and ignoring) employability skills In May 2005, the National Training Quality Council (NTQC), the fore-runner of the NQC, endorsed the incorporation of employability skills into training packages. Industry Skills Councils (ISCs) received funding to review all existing training packages and modify competency standards to incorporate ‘employability skills’ as required (NQC, 2006, p. 4).. On the one hand, they would be listed alongside the technical competencies in the training package, and could be isolated. But on the other hand, they were to be embedded in individual units of competency – they would be ‘contained in the units of competency as part of the other performance requirements that make up the competency as a whole’ (NQC, 2008, p. 31). The justification for embedding generic skills was that they are developed in association with these other skills because they have a mediating and transforming role and are the vehicle for their development’ (NQC, 2008, p. 31). Despite the logic of this argument, the effect of not assessing generic skills separately is likely to be their undervaluation. To roll them into the competency standards makes them specific to a work process, and no longer assessable in their own right at their actual performance level. Yet, to take one example, the skills of communication are likely to be exercised at different levels (and possibly in different ways) in different qualifications at the same level – for example at Certificate III in Business Services, Aged Care Work and Transport and Logistics. Arguably, what is needed is a method of assessing the levels of what are called employability or generic skills independently of the technical or functional skills with which they are intertwined in any particular work process. Thus the push for employability skills to be ‘embedded’ in training packages has posed further problems, in particular, a possible difference in skill level between the qualification itself, and the ‘employability’ skills it requires. Jobs at similar qualification levels may require varying levels of teamwork, communication and so on. Proposed solutions to this have not been convincing. ‘Embedding’ prevents any possibility of recognising the ‘uncodified’ skills separately from the work process in which they are embedded, and thus prevents these skills from being certified in themselves, and rewarded (Hampson and Junor, 2009). If appropriatelyspecified ‘generic’ skills were available separately for use across training packages, this might 10 | P a g e achieve two purposes: contribute to the desired streamlining of training packages, and aid career mobility by identifying common element and transferable skill requirements in jobs that are apparently quite different. In fact, however, the opposite occurred, making it harder to recognise workplace learning As the problem has not been overcome in the most recent attempt to conceptualise levels in a proposed renovation of the Australian Qualification Framework, we return to it in section five. Assessment quality and the expertise of assessors The 2008 OECD Review of Australian training commented on ‘the lack of standardised national assessments [which] means that there is no standard to ensure that a particular set of skills has in fact been acquired’ (Hoeckel et al, 2008, cited in Guthrie, 2009, p. 13). Only RTOs can issue nationally recognised qualifications. But to do so they need to meet certain standards. Marketisation created an increased need, via the AQTF, to ensure that these standards were met in diverse RTOs but quality assurance mechanisms have been deeply flawed (Guthrie, 2009, p. 28). Weaknesses in the training and qualifications of trainers and assessors have been well documented. The qualifications for becoming a workplace assessor are set at Certificate IV level – considerably below the graduate diploma or degree level qualifications required of school teachers. The main assessor competencies have been set out in a succession of workplace training and assessment training packages, but anecdotal evidence suggests that learning time in assessor courses can be quite varied, and may have diminished. In addition, workplace assessors are required to have ‘relevant vocational competencies at least to the level being assessed’. Between 2001 and 2010, however, there was an escape clause in this requirement. Assessors lacking the vocational competencies being assessed could work with someone who had these competencies while they conducted assessments (AQTF 2001, p. 17). This ‘let-out’ clause in practice led to people assessing outside their areas of competence. If valid and reliable assessment was to be achieved, much turned on the meaning of the phrase ‘work with’. It is hard to understand how as assessor with a background in clerical skills could assess the underpinning knowledge of an automotive skills candidate, even when working with an automotive practitioner. The escape clause remained through several revisions of the AQTF (AQTF, 2005; 2007, p. 4) although it has been eliminated from the most recent version (see AQTF 2010, p. 6; NQC 2009, p. 4). This recent change can be seen as an admission of a significant previous quality gap. Anecdotal evidence on the training, assessing and work content expertise of assessors was gathered during a small-scale project supervised by the authors in 2008-2009 (Cheng et al., 2010). This interview-based project analysed assessors’ experiences of making a judgment of competence. One-off assessment events were common, and there was not a particularly strong consensus that the divide between ‘competent’ and ‘not yet competent’ was clear-cut. Nor were assessors particularly consistent in the evidence and criteria they applied. Some required an assessee to be able to describe and articulate what they were doing – even though ironically, assessors were not themselves always able to articulate their own practice. Approaches to moderation of assessments by interaction with peers varied greatly. 11 | P a g e Pressures for grading within competency based assessment The project also collected evidence of pressure for graded assessment, challenging the binary ‘competent/not yet competent’ approach of CBT. Can a work job be performed competently, but at different levels of competent performance? The usual objection to the binary approach came is that it discourages the pursuit of excellence (Pennington 1992). Despite difficulties in explaining the distinction between ‘highly competent’ and ‘competent’, graded assessments were fairly common among the interview sample. Some RTOs even kept two sets of records, one displaying the required binary ‘competent/not yet competent’ assessment, one with grades. Such practices may have reflected little more than attempts by RTOs, particularly within the private training market, to gain competitive advantage through credential inflation. It is to be presumed that graduates issued with grades enjoyed some advantage in the labour market, and this practice thus created inequity for those not issued with grades. Overall, the research supported the view that there is a wide variety of assessment practices across the system, and considerable problems of reliability and validity. It is likely, however, that a desire to grade performance also reflects a real dilemma – a desire to document varying levels of skill in workplace practice. Varying levels of performance within a job are likely to reflect experience in the job – in other words, levels may reflect stages of nonformal learning, on the journey from novice to expert. In this context, graded assessment may have the perverse effect of rendering the credentials of novices less competitive in the recruitment market, reinforcing the recent employer tendency to give preference to experienced workers and to shirk the obligation to provide induction and workplace training. Arguably then, the practice of graded assessment within CBA is problematic, Graded assessment may reinforce the labour market disadvantage of first-time labour market entrants. The dilemma of how to recognise performance levels within a qualification is part and parcel of the dilemma of how best to recognise the generic skills that make for effective work performance. An Alternative Conceptualisation of Generic Skills and their Levels Building on Boreham et al. (2002) we would redefine employability skills as capacities to engage in or contribute to work processes. An economical yet comprehensive research-derived list of such process skill sets, classified into elements, is set out in Table 1 (New Zealand Department of Labour 2009). This list was seen by co-authors Junor, Hampson et al. as the irreducible minimum of hitherto under-specified skills enabling effective work performance, identified by coding accounts of work activity recorded in 57 lengthy job analysis interview transcripts and 94 position descriptions. The skills are basic in the sense that they are indispensible to work performance, but they are not ‘elementary’. They are ‘generic’ in that they are transferable from one situation to another, but they are not undifferentiated at the point where they are applied in specific contexts. For example the activities enabled by the ‘Interacting and relating’ skill set can be defined quite precisely, depending on context. Nevertheless there is a wide number of activities in which the same skills can be used. This is important for recognition: skills learned in one work, community or domestic setting can be applied to other work situations. Thus the skill element ‘Communicating verbally and non-verbally’ can be applied, at varying levels of complexity, to produce the following list of concrete work activities: Interpret the needs and intentions of people who have restricted verbal language; 12 | P a g e Use silent friendly listening, allowing people to talk through their concerns; Use reassuring and respectful touch (when appropriate), to convey or gain information; Pace communication to the varying attention spans of different listeners; Pitch language to people with varying levels of under-standing. Overcome miscommunication problems by ‘translating’ eg between children and experts. Solve technical problems for non-experts by using symbols or familiar comparisons, to identify the problem and communicate solutions. Coin catch-phrases that will serve as a shared guide to action. Crystallise the views of a diverse audience, with apt or memorable language or images. Use understanding of community issues to ensure communications gain acceptance by a range of audiences (New Zealand Department of Labour 2009). Table 1 Three Sets of Work Process Skills A. Shaping awareness: Capacity to develop, focus and shape own and others’ awareness, by A1 Sensing contexts or situations A2 Monitoring and guiding reactions A3 Judging impacts B. Interacting and relating: Capacity to negotiate inter-personal, organisational and inter-cultural relationships by B1 Negotiating boundaries B2 Communicating verbally and non-verbally B3 Connecting across cultures C. Coordinating: Capacity to organise own work, link it into the overall workflow and deal with obstacles and disruptions, by C1 Sequencing and combining activities C2 Interweaving own activities with others’ C3 Maintaining and restoring work-flow Source: NZ Department of Labour, 2009 This list is a composite compilation of activities described by the jobholders interviewed, all enabled by the same underpinning skill. Many further examples could be identified in other contexts. Few of these activities require skills that can in any sense be seen as basic or elementary. They may involve many cognitive, ethical, or motor behaviours, which may be unseen by the observer, or even tacit (unnoticed by the performer). Proficiency in them is built up through experience – that is through informal learning in the workplace and in other work settings, domestic or community-based. Routine performance of work activities may draw on skills that have become so highly practised as to have become automatic, until a challenging situation occurs, requiring a switch to conscious, reflective performance. Whilst a work process skill may be observable only when applied in a concrete situation, this situation may be one of many contexts in which it is applied. This is the sense in which work process skills are generic. The contextual application has to be learned, so it is misleading to see generic skills as widely available ‘off the street’. However complex and specialised are the 13 | P a g e applications, of generic skills, it may be reinventing the wheel for each Training Package to write its own version of them. This is why regret was expressed above at the decision to embed employability skills in functional competency units, rather than codifying them separately. Had elements and units been available for inclusion in a range of functional training packages, it would have been easier to map similar skill demands in different jobs, allowing a new approach to job families and career paths. Such an approach may also have helped address the criticism that training packages are over-burdened. Table 2 identifies five levels of proficiency at which these work process skills were found to be deployed in the workplace (NZ Department of Labour, 2009; Hampson and Junor, 2010). This concept of proficiency level or workplace learning level is finer-grained than the notion of qualification level or occupation level. Within a given occupation, job or qualification, there may be a range of levels of expertise, differentiating the expert from the novice (Dreyfus and Dreyfus, 1986). The desire of assessors to grade candidates’ performance is likely to be a reflection of differences in learned proficiency, based on work and life experience.. Table 2 sets out a framework for recognising growing levels of expertise within a job, based on research conducted by the authors and their colleagues. Table 2 Learning Levels within a Job - Definitions and Basis Descriptor Basis Familiarisation Automatic fluency Proficient problemsolving Creative solution sharing Expert systemshaping Participating as a novice, by building expertise through observation, practice and reflection Participating as a practiced performer, independently applying operational knowledge to the point where activity is automatic Participating as an experienced problem-solver, carrying out operations already learned, whilst applying experience to creating new solutions Participating as a sharer of practical knowledge, in the exchange of stories or notes about trial-and-error solutions Participating as a knowledge creator or system innovator, helping to spread or change a system of work or knowledge Source: NZ Department of Labour, 2009. Table 2 suggests that recent efforts to identify levels of employability skills at the point of job entry reflect the problem that in the past two decades, employers, by seeking to recruit people with ready-made problem solving or teamwork capabilities, have been able to use screening processes to ‘buy’ rather than ‘grow’ advanced level skills. This may become harder to do. Looming skills shortages are likely to give a competitive advantage to employers who are willing to provide post-entry induction training to help recruits move through a period of familiarisation and automatisation through practice, to Learning Level 3, where they are solving new problems in the course of routine work. Pressures for the identification of ‘levels’ of employability skills (ACER, 2008) would seem to be problematic, to the extent that school leavers are expected already to have the skills that they will in fact need to learn on the job. Figure 2 illustrates the distinction between levels of expertise, derived from workplace experience, and qualification or occupational levels. Stages though which work process skills are deepened WITHIN an occupation or qualification level, are represented along the horizontal 14 | P a g e axis, while the qualification level within which the occupation sits is represented by the vertical axis. The following section presents evidence from new research, suggesting a way through the conceptual morass. While in fact the concept of experience levels can be applied to functional, as well as generic skills, here we apply it to the latter. This analysis could provide the basis for a more adequate approach to the assessment, both of employability/generic skills, and to the assessment of non-formal and informal knowledge, discussed in section five. It may help resolve the difficulty that current mechanisms for recognising prior learning face, in going to competency standards as a basis for assessment. Figure 2 Qualification Levels and Levels of Experience/Informal Learning With these considerations in mind, we finish by examining the recent overlapping attempts by the new AQFC and the NQC (the latter slated for absorption into the new pan-tertiary regulator) to achieve a genuinely national and reliable qualifications framework, and to provide an equitable system for the recognition of formal learning and workplace expertise. New Qualification ‘Architecture’: Can it deliver a Quality National System of Equitable Workforce Development? We turn now to the centrepiece of the Labor Government’s skilled workforce development project - the strengthening of a genuinely national Australian Qualifications Framework. The purpose is to harmonise Australian qualifications internationally and across states and sectors, allowing career mobility to be based on learning outcomes. For pathways to operate equitably, there need to be consistent ways of recognising both the behavioural and less observable cognitive aspects of learning outcomes, whether based on formal, non-formal or informal education, training and work or life experience. The new Australian Qualifications Framework Council (AQFC), charged with this architectural design challenge, produced two consultation papers (2009a; 2009b). We analyse the strengths of their proposed model, but also some incoherences, particularly relating to the thorny issue of levels. 15 | P a g e The need for global alignment of qualifications led to a comparative study of international practice. This international comparison suggested that the AQF is behind international developments. While its qualification descriptors are ‘learning outcomes-based’, they are not explicit and consistent, and they are described differently in each of the education sectors. They are not hierarchical, or ordered in levels of increasing complexity or volume of learning. That is, the AQF as it currently stands, is not a genuine levels based system, although the language of levels (Certificate 1-IV, etc) gives that impression. There is no clear description of the relationships between the qualification types, nor of how they might be articulated. This is because the AQF, as it currently stands, does not include a common measure of value, inhibiting learning transfer and labour mobility. Nor does the AQF indicate how all forms of learning – formal, non-formal and informal – can be recognised (AQFC, 2009a). The AQFC consultation papers (2009a; 2009b) therefore canvassed ways of turning a loose credential hierarchy, analogous to a nominal scale, into an articulated framework of equivalent and substitutable values, analogous to a ratio scale. For this, it suggested three sets of criteria. The first was a common taxonomy for defining breadth and depth of learning outcomes (along the ‘dimensions’ of knowledge, skills and competences). The second was a common measure of value (a ‘currency’ for measuring ‘volume’ of learning). The third was a set of explicit reference points (‘levels’) for comparing volume along these dimensions. Chosen dimensions, defined in terms of learning outcomes, were: knowledge, skills and their application: what a person knows, understands, and is able to do as a result of achieving each qualification (AQFC, 2009b). These proposals are interesting in the light of the preceding discussion of competence, which has been the basis of the VET sector for over 20 years. Fundamentally, competence has been defined in terms of ‘what a person is able to do to the standards expected in employment’, independent of the time taken to achieve this capacity. In fact, one of the original rationales for the introduction of CBT was that it would liberate trainees from the tyranny of ‘serving time’, and allow progression up skills-based career ladders independent of formal learning, with provision for ‘Recognition of Prior Learning’ (RPL). Few recognised the difficulties this would give rise to in terms of articulation among qualifications, much less international transfer. While problems of articulation could, to some extent, be dealt with on an ad-hoc, case by case basis within national borders, the quest for international equivalence exposed this limit of the system. Of particular interest then is the proposed reintroduction (AQFC, 2009b, pp. 7, 13) of a measure of the volume of learning in each qualification type. This is advocated as a way of establishing whether learners have met the requirements for course entry or for the award of a qualification. It is seen as allowing for mobility across programs and for articulation among courses at different levels. It also allows for an assessment of the relativities amongst courses. The proposal draws on local and international HE practices, and suggests that CBT never really eliminated the concept of ‘student learning time’ in the VET sector. It uses the internationally familiar concept of credit points, linked to an abstract concept of average ‘student learning time’, a common rule of thumb being ten hours per credit point. This may be a welcome antidote to the thinning of curriculum in an assessment-driven competency-based approach. It does however raise questions about the process that will be used for establishing the equivalence of learning based on experience, although it does lend itself to recognising the deepening and broadening of workplace ‘skills of experience’. The May 2009 consultation paper (AQFC, 2009a) proposed a ‘KSC’ (Knowledge, skills, competences’) model, which 16 | P a g e … is applicable across all qualification levels and fields. It provides for the inclusion and assessment of the knowledge and skills achieved as well as for the complexity and breadth of the context in which they have been learned and assessed, and thus, by inference, can be applied. This is considered the minimum information required to fully explain the outcomes of a qualification and is becoming standard practice in all National Qualification Frameworks (CEDEFOP, 2006a, in AQFC, 2009a, p. 11). Learning outcomes could be captured as: knowledge, or what a student knows/understands in terms of breadth, depth and complexity; skills, or what a student can do; how knowledge and understanding is applied and competences. We welcome the explicit reintroduction of knowledge and skill into VET qualifications. The concept of competences, as used in the discussion paper, remains problematic. The AQFC suggested that competence is 'often referred to as the context in which the knowledge and skills can be applied'. But this is confusing: competence is defined as a learned outcome – and people carry learned outcomes into a context. Moreover, this dimension includes specific competences and can also include generic competencies. Alternatively, these could be classified separately as a fourth dimension (p. 11). The May consultation paper accordingly canvassed two options. In the first, ‘Competences’ would include both context AND generic skills (learning to learn, communication, technology etc) aka ‘employability skills’. In the second, competence includes context, with generic skills listed separately. We welcome the return to the terminology of generic, rather than employability, skills but find the conceptualisation of ‘context’ somewhat confusing. ‘Context’ is defined to include ‘autonomy’, or ‘the amount of supervision, guidance and the required clarity of parameters required for performance’, and ‘accountability’, or ‘the degree of responsibility able to be managed for their and others’ processes and output’ (AQFC, 2009a, p. 12). Perhaps the intention is to include collective learning (which we would applaud), or to signal that learning is situated in contexts and transferred to other contexts (with which we would also agree). Indeed both the linguistically loose term ‘context’ and the term ‘competences’ in the May consultation paper was replaced in the September consultation paper (AQFC, 2009b, pp. 13-16) with the clearer term ‘application of knowledge and skills’. Nevertheless the confusion remains, in the definition: ‘Application of knowledge and skills is the context in which a graduate applies knowledge and skills’ (AQFC, 2009b, p. 5). Moreover, this third learning outcome, ‘application’ is classified into levels on the basis of degrees of autonomy, responsibility and accountability, which at higher levels only are specified as including judgment and expert authority (AQFC, 2009b, pp. 5; 13-19). There are two problems with the use of these criteria to determine skill levels. Firstly, it accepts an individualisation of the employment relationship, and ties the definition of skill level to an employer-defined organisation of work. Secondly, and of fundamental importance, it is likely to result in a tendency to restrict recognition of independence and expertise to those possessing high-level qualifications, or located in highly-qualified occupations. These objections are considered in turn. In the employment relation, the context of an individual’s work is shaped by capitalist social relations. In labour process theory, the problem of the employment relation is to ensure the conversion of labour power into actual labour. The dominant feature of the ‘context’ at work is employer control over the labour process, and this either limits or affirms the extent to which individual employees can exercise their skills, and the ways in which they do so. The 17 | P a g e organisation of the labour process is not the prerogative of an individual worker. Certainly, there is ambiguity in the concept of ‘autonomy’, which can include both capacity (a learned outcome), and the permission to exercise that capacity (an aspect of work organisation). These two distinct meanings seem to be conflated in the AQFC definition. Similarly, ‘accountability’, seen as a property of an individual, is part of the tendency in the employability skills discourse and, more broadly, the Anglo notion of skill, to individualise responsibility for capitalist work organisation qua skill. It is also similar to how the managerial concepts of competence (eg Spencer and Spencer, 1993), collapse motivation within ‘competence’. The second problem is that criteria such as autonomy, judgment and expert authority are a priori ruled out of existence in lower-level qualifications, and by transference, in the occupations aligned to these qualifications. But this is to conflate a whole-job or whole-qualification conceptualisation of ‘level’ with the concept of work process skill level – it mixes the vertical and horizontal axes of Figure 2 above. There is really no basis for the assumption that, within any job or occupation, levels of formal knowledge, functional skill, and work process knowledge/generic skill are required at the same level. There is now considerable researchbased evidence (Junor, Hampson and Ogle, 2009; NZ Department of Labour, 2009; Hampson and Junor, 2010); that in low-status occupations such as community service and aged care work, staff with extensive life and work experience may be engaged in complex problem-solving and collective solution sharing. They may be required to exercise sophisticated judgment, and may be seen by peers as authoritative resources, even contribute to changes in workplace systems. Yet the new taxonomic framework is making it hard to recognise that such higher level learning outcomes may be required in jobs classified at lower qualification levels on the basis of formal knowledge requirements. The May AQFC consultation paper (2009a) revived the possibility of a separate codification of work process skills, lost in 2005 when employability skills were ‘embedded’ in competency units. The AQFC put forward two concepts of ‘learned outcomes’ for consideration: one proposed including ‘generic skills’ within ‘competence’, the other dividing employability/generic skills from the descriptions of other learned outcomes. This would have created problems of assessment and record keeping (Guthrie, 2009); but would have made it possible for generic skills to be registered and assessed separately from technical skills and qualifications. The version adopted by the AQFC (2009b) advocating the embedding of generic skills within competence – the so called ‘option B’ – is much the same as the NQC (2005) recommendation that employability skills be embedded within competency standards within training packages, and vulnerable to the same concerns. It will make it very hard to register ‘informal’ learning for credit apart from the qualification it is part of. This reinforces the failure, just discussed, to allow that generic or work process skills may exist at different levels to the functional or technical skills that they facilitate. In this respect, the AQFC proposals fall short of their objective of giving credit for non-formal learning (defined as ‘unstructured, intentional learning’) and for informal learning (defined as ‘unstructured, unintentional learning’), both of which ‘might be validated for credit’ (AQFC, 2009a, p. 22). It is to be hoped that another workplace learning recognition project is carried forward (NQC, 2009). In late 2008, the NQF Training Packages Standing Committee commissioned a scoping project to advise on a policy for the recognition of skills acquired through active workplace or community participation, individual and group activities, non-course workplace learning activities such as discussion groups, or non-recognised structured programs such as short 18 | P a g e courses. The purpose of such recognition was seen as extending beyond qualifications, by addressing employers’ need to meet quality assurance criteria and employees’ quest for job reclassification. Whilst Recognition of Prior Learning (RPL) was found to be the main Australian approach, the paper listed a range of others: credit-rating of workplace learning (Scotland), use of assessment centres (Mexico), international recognition exchange (Europass) and E-portfolios (UK). It was recommended that a national policy be established to provide for multiple recognition approaches – RPL; industry/provider/enterprise assessment systems; credit rating of workplace learning, and structure recording systems (NQC, 2009 p. 23). Whilst in their current format the proposals are over-reliant on assessment against training package standards, other assessment tools are now available, including job evaluation approaches and tools for identifying under-specified skills (NZ Department of Labour, 2009). It will be very disappointing if these insights and approaches are lost in the latest wave of qualification restructuring. Conclusion The current wave of training reform in Australia has set out to redress the problems of equity that have always plagued the country’s fragmented VET system. It has taken up and extended the national skill formation goals of the first wave of training reform, from 1987 to 1992. Workforce planning has been restored to some credibility, notiwthstanding the advocates of ‘market design’. There have been moves to address the regulatory and governance issues that between 1992 and 2007 compromised quality and equity in a marketised and decentralised VET system. These moves have been encapsulated within a foreshadowed restructuring of the tertiary education system. The pressing need for tightened quality assurance has been addressed by proposals for a national regulator across the VET and HE sectors. Proposals for enhancing international and national labour and career path mobility have taken the form of an attempt to create a nationally and internationally harmonised qualifications framework. A quiet restoration of the importance of knowledge and learning time may weaken the competency based system of VET delivery that has given primacy to employers’ demand for just in time staffing. The language of generic skills seems to be quietly replacing that of employability skills, particularly formulations of the latter that might lend themselves to screening employees for attitudinal compliance. There is some evidence that unfinished equity agendas are being picked up, with welcome attention to the recognition of skills acquired nonformally and informally. There has, however, been a reluctance to move too far from the neoliberal market-contractualist model of the past two decades. Arguably even in 1987-1992, the era when peak union bodies proposed national skill formation agendas/industrial relations agendas, it was the voice of employer organisations to which government was listening. From then till 2007, implementation of competency based training and assessment ran into contradictions that were partly the result of employers’ preference for labour market flexibility and reluctance to invest in training, and partly the result of quality issues in the operation and regulation of training markets and contestably-funded state training authorities. The other source of difficulty was a certain incoherence in the conceptualisation of competency, generic skills and skill levels. We have proposed an alternative approach to identifying and classifying skill levels in forms of learning based on life and work experience, and suggested how these could be incorporated into new approaches to recognition within the proposed new national system. 19 | P a g e The problem of defining the exact nature of the human capacities that are the object of skills development, and building those definitions into recognition structures, is one that confronts the participants in any training system. The relative power of the social partners is shifting as a result of emerging skill shortage. While union representation has been restored to some of the policy bodies shaping current agendas, the rebuilding of avenues for expressing employee voice is lagging some way behind the building of a new national tertiary education system and its recognition architecture. 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