ARA recently made a submission to the National Occupational Licensing Scheme (NOLS) Taskforce, which as part of a long-running COAG process has sought public comment on the proposed arrangments for reducing the barriers that a number of trades face in working across Australian jurisdictions. ARA takes a different approach to some other stakeholders on the fundamental issue of which is the best model for the new occupational licensing scheme.
We essentially agree with the proposal favoured in the Regulatory Impact Statement (RIS) described as “Model A”. However we would like to see coverage of all working fluids, and urge that a crucial distinction needs to be made in respect of charge volumes, with work on systems containing small charges of hydrocarbons to be exempt from mandatory licensing requirements.
It is simply a mistake to view the ARC registration and certification scheme as an occupational licence, as it is established under legislation that is driven by environmental protection objects. Controls on which technicians are permitted to use the environmentally harmful ‘scheduled substances’ (CFCs, HCFCs, HFCs etc) are among the many measures it contains to achieve these objects (and how successful these are is another matter). No one should suffer under the misapprehension that the ARC scheme was established as a system for occupational licensing. Nor will it be feasible or practicable to evolve it into one, and certainly not without major reform of the Commonwealth OPSGGMA legislation and regulations, a matter that is very clearly stated at page 1 of the RIS as being completely off the agenda.
It is important to remember that this is a COAG process, not a Christmas wish list of how we’d like the world to look like in the morning.
That said, it is likely that we haven’t got every detail completely right, and there will no doubt be further opportunity to influence the process. We certainly welcome any feedback anyone may have on the recommendations and analysis provided in the ARA submission. Please leave a comment on our Facebook or LinkedIn pages if you’d like to participate in the discussion.