Memorandum 1
Submission from the Engineering Council
UK (ECUK)
SUMMARY OF
OUR SUBMISSION
1. Strengthening the apprenticeship system
would almost certainly lead to more opportunities for apprenticeships
to be recognised as leading to professional status, and ECUK would
welcome this.
2. Our comments chiefly focus on areas where
greater clarity in the draft Bill could help achieve the Government's
objectives in apprenticeships:
— the employed status of the apprentice;
— attainment, employment, competence
and a need to define "work";
— progression opportunities—level
4 and beyond;
— equality and inclusion;
— impact on structures—issues
of expert advise and of multiple "sectors"; and
— maintaining quality above quantity.
ABOUT THE
ENGINEERING COUNCIL
UK
3. The Engineering Council UK (ECUK) regulates
the engineering profession in the UK by licensing 36 professional
engineering institutions which are then able to place suitably
qualified members on ECUK's Register of Engineers. The Register
has three sections: Chartered Engineer, Incorporated Engineer
and Engineering Technician. The UK's Register of around 250,000
professional engineers and technicians is the largest such register
in the developed world.
4. ECUK has developed standards for registration
which reflect employer needs. We work closely with employer organisations,
and with the education sector, to ensure that the competences
needed to practice engineering are understood, and that qualifications
to underpin these are identified, and where possible accredited
or approved.
5. Completion of an advanced apprenticeship
can lead an individual directly to membership of a professional
engineering institution and registration with ECUK as a professional
Engineering Technician (EngTech). ECUK has also recently received
approval to establish a standard and register for professional
ICT Technicians (ICTTech).
6. ECUK works with national regulatory bodies
in many parts of the world, and has a good understanding of the
standards applied in other developed and developing countries.
INTRODUCTION
7. Engineering Council UK (ECUK) generally
welcomes this draft Bill. Apprenticeships have a major role to
play in the continuous enhancement of the UK's skills base. Equally
importantly, they can be an important vehicle for individual development
and fulfillment, since they provide a means of learning through
active engagement in work, supported as appropriate by formal
learning. We therefore welcome the move to give them a secure
legal status.
8. The engineering profession recognises
the value of good quality level 3 apprenticeships as part of its
requirements for professional registration. Under the UK Standard
for Professional Engineering Competence (UK-SPEC), completion
of an appropriate apprenticeship can lead an individual directly
to membership of a professional engineering institution and registration
with ECUK as a professional Engineering Technician (EngTech).
Professional status gives added value to completing an apprenticeship,
since it requires the individual to commit to lifelong learning
and maintenance and development of professional competence, as
well as to professional codes of conduct and ethics. Strengthening
the apprenticeship system to achieve the Government's objectives
in world-class apprenticeships would almost certainly lead to
more opportunities for apprenticeships to be recognised as leading
to professional status, and ECUK would welcome this. The comments
on the draft Bill which follow concentrate on areas where greater
clarity could help achieve these objectives. They mainly relate
to the Committee's question "Is there anything missing from
the draft Bill?" although some comments on other matters
are also included.
THE EMPLOYED
STATUS OF
THE APPRENTICE
9. The LSC 2007 statement, echoed in World-class
Apprenticeships, has our full support:
The preferred Apprenticeship route is now,
and will continue to be, direct employment from the beginning
of the Apprenticeship until its completion.[1]
We will protect the Apprenticeship brand,
reforming so-called Programme-led Apprenticeships to strictly
specify the acceptable minimum level of tie-in with employers.[2]
10. The need to reform programme-led apprenticeships
has been further underlined by the recent Ofsted report[3]
on them, which included disturbing accounts of young people engaged
in long hours of unpaid "work-experience". It is therefore
of concern that while the terms "work" and "working"
are used a number of times in the draft Bill (eg in sub-clauses
1(2)(c), 3(2), and 3(3) ) these are not clarified. Although it
would appear from the proposed new 3G(1)(a) of the Learning and
Skills Act that employment is a requirement of an aged 16-18 apprenticeship,
the requirement for employed status of apprentices (from beginning
to end) is not sufficiently clear and should be made so.
ATTAINMENT IN
APPRENTICESHIPS
11. The LSC report on programme-led apprenticeships
emphasised that:
The characteristic principle of "apprenticeship"
since its creation has been the acquisition of skills and competence
to operate in a designated employment trade by learning from those
already knowledgeable and competent and by practising and refining
these skills in employment.[4]
12. Competence is the key to registration
as a professional Engineering Technician. It is a combination
of knowledge, understanding, skills and attitudes and while some
aspects of it may be acquired through formal learning it cannot
be achieved without learning through work. It is however not mentioned
in the Bill, and nor is the validation of learning through work,
although the latter is implied in the explanatory notes (note
13). Instead the references to standards of attainment are related
to the acquisition of qualifications. It is understandable that
legislation should relate to tangible entities such as qualifications,
rather than to concepts such as competence, but there is a danger
that this could lead in the worst case to an emphasis simply on
theoretical learning. We hope that the Government will be willing
to give further consideration to how this important issue might
be covered in the Bill. In particular it should be possible to
recognise professional development pathways developed by professional
bodies, even if these do not lead to a formal qualification such
as an NVQ.[5]
PROGRESSION
13. The motor industry, engineering manufacture
and electrotechnical sectors have large proportions of level 3
apprentices (71%-81%),[6]
a wide range of Sector Skills Qualification Strategies within
engineering sectors are indicating shortages at level 4, and progression
opportunities need ensuring. However, whilst the explanatory notes
to the Bill (eg note 22) indicate that the Higher Level Apprenticeship
might be included under eg 12(1)(c), level 4 apprenticeship requirements
are not mentioned or specified within the draft Bill. This should
be rectified.
OTHER ISSUES
14. Some other matters are not explicitly
covered in the draft Bill and could usefully be:
(a) There is no requirement for statistics on
apprenticeship starts and completions, by level and sector, to
be made publicly available. This should be rectified;
(b) Given that World-class Apprenticeships
placed emphasis on addressing inequality in apprenticeships, and
this was more recently echoed in the House of Lords Economic affairs
reports,[7]
by the TUC[8]
and by OECD,[9]
omission in the draft Bill of reference to such requirements seems
a particular missed opportunity;
(c) The draft Bill does not include any reference
to Young Apprenticeships—these have been very successful
in engineering-related sectors and there is a concern that subsuming
them under Diplomas will result in loss of brand prestige and
thereby take-up.
IMPACT UPON
CURRENT INSTITUTIONAL
STRUCTURES
15. It is desirable that the NAS should
take lead responsibility for all apprenticeships, pre- and post-19.
Clarity is needed on who authorized persons and certifying authorities
(under eg clause 4) might be. Furthermore, the draft Bill does
not include explanation of how the Secretary of State or the "authorised
persons" will draw on relevant expertise in order to make
decisions about the quality, level and relevance of submissions,
or how quality of "delivery" and learning experience
will be assured within and between apprenticeship frameworks.
16. There are a number of references in
the Bill to "sectors" (eg clause 7) and an implication
that a framework will only be applicable within a particular sector.
While the current relicensing exercise for Sector Skills Councils
may help to clarify the definition of individual sectors, it has
acknowledged that there may be overlap between them. This is particularly
true in fields such as engineering, which spreads over a number
of different sectors, and increasingly so as technologies and
multidisciplinarity escalate. This needs to be recognised.
17. Articulation with Scotland and Northern
Ireland will be an important issue for major employers and for
organisations such as ourselves and other professional bodies
which work at a UK and international level.
IS THE
BILL WORKABLE?
18. It is by no means certain that it will
be possible[10]
for the NAS to find a quality employed place for every 16-18 year
old so qualified. In these circumstances the emphasis on quantity
might be counter-productive and come at the expense of quality,
especially for this age range.
September 2008
1 A Strategy for Programme-led Apprenticeships in
England 2007-10-LSC 2007 p 3. Back
2
World-class Apprenticeships: Unlocking Talent, Building Skills
for All p 6. Back
3
The impact of programme-led apprenticeships (Ofsted 2008). Back
4
A Strategy for Programme-led Apprenticeships in England 2007-10-LSC
2007 p 3. Back
5
And bearing in mind opportunities that may arise from recent change
regarding NVQ (Ofqual/08/3160). Back
6
Apprenticeship Pay 2007: survey of earnings by sector (DIUS,
2008). Back
7
Apprenticeship: a key route to skill (House of Lords Economic
Affairs Committee 2007) and follow-up report (June 2008). Back
8
Still more (better paid) jobs for the boys (TUC, 2008). Back
9
Jobs for Youth: UK Summary in English. OECD 2008-eg p 6. Back
10
Cf Apprenticeship: Recent Developments. House of Lords
Economic Affairs Committee 2008. Back
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