Rethinking Electrical Contracting with Electrical Licence to Practice 2017 Progress Report

14th December 2017

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Table of Contents

1.0 Introduction Pg. 3

2.0 The Purpose of Licence to Practice Pg. 3

3.0 Progress Update Pg. 4

4.0 Upskilling & Progression Pg. 5

5.0 Sector Specific Qualifications Pg. 5

6.0 JIB and LtP Pg. 7

7.0 3rd Party Accreditation & LtP Pg. 8

8.0 Accountability Pg. 9

9.0 Features and Benefits Pg. 11

10.0 Fake Qualifications Pg. 12

11.0 On-Site Audits Pg. 12

12.0 Audit Findings & Feedback Pg. 13

13.0 Summary Pg. 15

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1.0 Introduction

The aim of this report is to provide an insight into the progress and effect that Electrical Licence to Practice has had on the Northern Ireland construction industry since its formal adoption by Public Sector Clients in February 2016.

The principle objective of Licence to Practice is to overcome recurring factors contributing towards reduced productivity and poor performance in the electrical installation sector. The system has been designed to assist Public Sector Clients appoint Main Contractors who enter into subcontract arrangements with Licenced Electrical Contractors who only employ Licenced Electrical Workers.

In 2009, responsible stakeholders within the industry commissioned research into an Electrical Licence to Practice solution, as concerns regarding the negative impact of unqualified and underqualified workers entering the sub-contract supply chain continued to grow. The development and facilitation of the online system was directed by the Electrical Training Trust, an established industry led charitable trust.

The unique system provides project stakeholders with a means to view the skills composition of the Electrical Contractor’s workforce by individual worker Licence type on a project by project basis. By providing online visibility into the identity and competency of Electrical Workers, the system seeks to overcome longstanding workforce development inertia and move the industry forward towards higher standards of competency on behalf of its Clients.

2.0 The Purpose of Licence to Practice

The main purpose of the system is to provide Client organisations with increased visibility into the competency of workers employed to install and maintain electrical systems on government construction contracts. Systematic decline in the uptake of electrical apprenticeships by school leavers and growth in the number of underqualified and unqualified Electrical Workers entering the supply chain prompted development of the system. Improving sustainability, productivity, quality, safety and standards feature as the essential outcomes.

Electrical Licence to Practice sets out to re-establish the identity and value of the industry’s best asset – the Electrical Worker. A fixation with H&S accreditation at the gate has obscured the place of the vocational credentials and identity of Electrical Workers in the contemporary industry.

SparkSafe monitors, audits and provides end to end online visibility of the competency of each manual worker engaged in electrical installation and maintenance services. From inception through to the completion and handover, Project Managers have increased transparency and visibility of each individual worker by electrical Licence type.

3.0 Progress Update

The online system requires Electrical Workers to register for one of three Licence types. These are QE (Qualified Electrician), REW (Restricted Electrical Worker) and AE (Apprentice Electrician) (Fig. 1).

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Qualified Electrican

Restricted Electrical Worker

Apprentice Electrican Electrical

Worker Licence Types

Fig. 1 Electrical Worker Licence Types

56%

31%

13%

Approved Licence Types

To date, 1124 Electrical Workers have applied for one of the three licence types available. A breakdown of Electrical Worker Licence approvals is provided in Fig. 2.

Fig. 2 Breakdown of Electrical Worker Licence Approvals

AE Licence

REW Licence

QE Licence

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QE REW 20% of REW's progressed to a QE Licence in the period

4.0 Upskilling & Progression

The REW Licence is awarded to Electrical Workers who are underqualified or who do not have the capability or willingness to progress towards gaining a QE Licence. Continuous professional development is an essential feature in achieving the overall objective of improving the performance and productivity of the industry.

By specifying the LtP requirements in contract award documentation, the Client has produced an important stimuli for upskilling within the industry. In the period, a fifth of those who were initially awarded an REW type licence, have successfully progressed to a QE Licence based on the recommendations and progression routes provided by the scheme provider (Fig. 3). These QE Licence holders now meet the national occupational standard and are now recognised as fully Qualified Electricians. The rapid movement in progression from REW to QE is unprecedented and welcomed by the industry as an important step towards increased productivity in the sector.

Fig. 3 Licence Upgrades from REW to QE

5.0 Doing The Right Thing With Sector Specific Qualifications

The current nationally approved qualification for the electrical installation industry is an NVQ Level 3 in Electrical Installation (Buildings and Structures). New entrants to industry are required to enter via the approved apprenticeship framework (No. 342 Level 3).

Some employers and training providers have elected to make use of Framework 12 (Engineering) Level 2 as an alternative to the electrical installation pathway. Framework 12 is designed for the engineering sector and is not considered to be an appropriate pathway for the award of Apprentice Electrician (AE) licence. The issue has given rise to difficulties for employers who erroneously depended on the framework to meet the LtP requirements for approved apprenticeship training.

Reliance by the industry on Framework 342 for industry approved apprentice outcomes is best practice and conducive to the DfE Sustainable Construction objectives.

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0 20 40 60 80 100 120 140 160 180

0 20 40 60 80 100 120 140

16 in progress

Electrical Contractors

Support for Licence to Practice by the Electrical Contracting community is indicated in the fact that 159 Electrical Contractors have applied for user certification in the period. Uptake of the system by the industry exceeds the anticipated number of registrants by circa 50%.

Fig. 4 Electrical Contractor Registrations

Main Contractors

The system and its requirements are becoming better understood by Main Contractors, evidenced by the threefold increase in the number who have applied to be SparkSafe registered since our last report.

Fig. 5 Main Contractor Registrations

49 in progress 110 completed

109 completed

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6.0 JIB and LtP

JIB

The JIB proposition is based upon an established plastic card system. The card is a vehicle for carrying an operative’s identity, grade, occupation and health and safety credentials. Many new occupational JIB card types have come into existence over the period.

However, with regards to electrical installation, there are five main occupational card types. These are apprentice, helper, electrician, approved electrician and technician. Each card is linked to designated pay rates and corresponding levels of responsibility as defined in the JIB Handbook.

In the UK, the JIB does not require ECS gold card holders to possess an accredited qualification covering the latest edition of BS7671. From the Client’s perspective, the relevancy of the JIB card lies with the following:

• Demand for the card at the gate

The card is usually requested as a means of attesting CSR/CSCS H & S credentials. Identity and occupational credentials are of minimal or secondary interest.

• The possession of the card by the person

Lost, forgot, out of date and fake cards feature in the challenge of the system in the modern era.

• Management of card by the Main Contractor

The plastic card system relies upon paper based management and static administrative control systems.

LtP

The Electrical Licence to Practice system makes innovative use of online technology. Plastic cards are replaced by online profiles. The online profile provides the name and photographic identity of the worker, as well as the workers licence type, membership number and expiry date.

In Northern Ireland, the LtP arrangements by Client demand, places a firm obligation on those who apply for a QE Licence to evidence the achievement of the latest edition of BS7671. The strength of the online Licence to Practice system lies with the following:

• Demand for the card at the gate

An online independently verified competency and photographic identity check for each worker is made available to key stakeholders from inception to final handover of the project.

• The possession of the card by the person

The issues of fake, lost and forgotten cards are replaced by the online system which can be accessed 24/7. The Electrical Worker is provided with a unique membership number and online Licence type which is matched to their identity, qualifications and experience.

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• Management of card by the Main Contractor

The administration costs and management time associated with recording and checking the Electrical Contractor’s workforce skills composition is made more efficient by the online resource.

Fig. 6 JIB and LtP Comparison Table

7.0 3rd Party Accreditation Providers

Third party accreditation is based upon an annual assessment of a few operatives including Qualifying Supervisors, who are employed to certify electrical inspection and testing outcomes.

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Central to third party accreditation of the self-certification process, is the competency and role of the person (Qualifying Supervisor) who supervises the gathering and certification of the electrical inspection and testing data.

This system does not assess the qualifications or competencies of each direct and/or indirect Electrical Worker.

The Electrical Licence to Practice system, by contrast, addresses the competency and identity of all the workers who install, fit, connect, repair, alter and maintain the electrical requirements of the Client.

8.0 Accountability

Prior to the formal adoption of Electrical LtP in February 2016, most public sector Client organisations have been obliged to work with a weak trust based system when employing the services of workers via an Electrical Contractor.

Many Electrical Contractors rely on a few direct employees and a supply chain of preferred and/or transient ‘subbies’ to meet contract obligations.

The LtP system fulfils an online competency gatekeeping and monitoring function of Electrical Workers on behalf of the Client, effectively improving accountability over those who are doing the work.

Traditional PQQ enquiry and focus on the supply chain normally stops at the corporate credentials of the Electrical Subcontractor. Dependency by the construction industry on agencies and the false self-employment supply chain, has made it difficult to distinguish between those who are qualified, and those who are not.

The Electrical Licence to Practice system provides responsible Clients with online access to the appointed Electrical Contractor’s nominated workforce.

This appears in the form of a unique on-line workforce composition report (Fig. 7) providing the Client with visibility, transparency and reporting tools that deters fraud and encourages productivity and contract performance.

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Fig. 7 Online Workforce Composition Report

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9.0 Features & Benefits

SparkSafe provides project stakeholders with an easy to use online resource that offers increased transparency and visibility of each worker by Licence type, from inception through to completion and handover. A summary of the systems features and benefits is provided in Fig. 8.

Fig. 8 Features and Benefits of the LtP System

Reporting Tools: Project stakeholders have access to an online Workforce Composition Report that details the name and Licence type of each Electrical Worker assigned to a project.

Find a Worker: The “Find a Licenced Electrical Worker” feature on the homepage allows users to view the identity and Licence type of individual Electrical Workers. No more lost, fake or forged plastic cards.

Independent Validation: Each piece of evidence submitted in support of a Licence application is examined for authenticity and proof of ownership. The hard work is done for you – we check dates, numbers and signatures.

Online Visibility: The system provides Client organisations with an online identity and competency check for Electrical Workers. Plastic Cards are replaced by online profiles.

Onsite Auditing: The outcome of the audit is a Client focussed report detailing the level of compliance with obligations relating to the composition of the Electrical Contractor’s workforce.

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10.0 Fake Qualifications

Client organisations with electrical maintenance or installation requirements usually contract for the services of qualified electricians. However, in reality, many are being provided with Electrical Workers who may be self-designated, underqualified or unqualified.

Such workers can be concealed behind a few qualified operatives who front the day to day contact with the Client. Most employers in the electrical contracting sector do not possess sufficient knowledge and/ or resources to operate procedures to routinely scrutinise the qualifications of existing or new entrant workers. Electrical work, and in particular inspection and testing work undertaken by those who rely on fake qualifications can produce serious disruption for Client organisations.

The LtP system obliges each applicant to provide evidence of achieving accredited electrical qualifications. All electrical qualifications used to support LtP applications are scrutinised for authenticity and proof of ownership. During the period, we have detected a number of suspected fake electrical certificates which has resulted in QE licences being declined. The discoveries of suspected fake electrical certificates include NVQ Level 3, AM2, Inspection and Testing and 17th

Edition qualifications.

The existing trust based system is unreliable. The authenticity of electrical qualification certificates cannot be taken for granted. Even bon-a-fid Electrical Contractors can be duped by those in the supply chain who make use of a plastic card printing machine, high definition colour photocopiers and document manipulation software.

11.0 On-Site Audits

A chief complaint of many in the industry, is that there is a lack of ‘boots on the ground’ when it comes to policing who is doing commercial and industrial electrical work.

Part of our public interest and service obligations is to audit and report on how Main Contractors and the appointed Electrical Contractor/s achieve compliance with the requirements of PGN 01/16.

Procurement Guidance Note (PGN 01/16) Licence to Practice Initiative for Electrical Workers sets out the scope and application of the Electrical Licence to Practice requirement.

During the period, SparkSafe has completed circa 100 site based audits. The outcome of each audit relies on data gathered via the online system, as well as responses and evidence provided by the Main Contractor to 14 points of compliance derived from the requirements of PGN 01/16.

A pass/fail audit report with recommendations and/or commendations is forwarded directly to the Client following the audit. Recurring unsatisfactory audit reports may lead to quality improvement notices or possible sanctions being recorded and imposed against failing Main Contractors.

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11.0 Audit Findings & Feedback

The requirement of PGN01/16 Electrical Licence to Practice is specified at the PQQ stage and then carried through to the final award of contract. Main Contractors and Electrical Subcontractors are obliged to make all necessary provision to meet the contract LtP specification requirements. Resources including detailed online operating manuals and a help desk service form part of the support obligations placed upon the scheme provider by the tendering authority.

The system obliges Main Contractors to make an electronic connection with the appointed Electrical sub-contractor who must then make similar type connections with individually Licenced Electrical Workers.

The process of making connections must be made before Electrical Workers appear on-site to ensure that the competency and composition of the Electrical Contractor’s workforce are being matched to the needs of the contract. Failure to make timely electronic connections featured as one of the two main recurring infringements of PGN 01/16. The second common issue leading to audit non-compliance is failure to undertake random inspection and monitoring of the Electrical Contractors workforce.

Fig. 9 Audit Compliance Requirements

On the first occasion of site based audits, most Main Contractor representatives claim a lack of understanding with the requirements of the system. The approach by auditors on the first occasion is to inform and persuade the Main Contractors representative on the steps that they are obliged to take to achieve compliance at subsequent occasions of audit.

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Audit failure means non-compliance has been detected across a significant range of areas. Most Clients are prepared to tolerate a first-time audit failure occurrence providing that there is swift, appropriate and sustained remedial action by the Contractor. Failure to respond to non-compliance notices, however, will build a breach of contract risk and may jeopardise future PQQ and Invitation to tender opportunities.

Evidence of low level buy-in by some project funders contributed to an early period of positive behavioural impact on the contract delivery side. Findings also indicate that some Main and Electrical Contractors sat back and ignored the PGN01/16 requirements until improvements in funder engagement and the audit process were achieved.

The increased frequency, quality and usefulness of auditing reports appear to have kick-started engagement and compliance with the essential connection and monitoring processes that are necessary.

The scheme provider recognised the lack of early buy in and understanding of the LtP and its requirements. Accordingly, 16 training events were planned and delivered to Project Managers within CPD, Northern Ireland Housing Executive, Education Authority, NI Water, Translink and Health Estates.

These training events proved useful and provided Project Mangers with an opportunity to learn about the connection processes and gain an understanding of the mission to meet “quality improvement” and “sustainability in construction” objectives on behalf of the sector. To date, 259 projects across each of the Client organisations have specified the Electrical Licence to Practice requirement (Fig. 10).

Fig. 10 Breakdown of Projects by Client organisation

0

10

20

30

40

50

60

70

80

90

100

EducationAuthority

NI Water Health Estates DFPNI NIHE Translink

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12.0 Summary

During the period, SparkSafe Electrical Licence to Practice has demonstrated that it is not a cosmetic industry rebranding exercise. The system is designed to address serious foundational and structural difficulties that have emerged in the sector during the past twenty years.

Part of the solution of moving the industry off the lower slopes, is by increasing Client awareness of Electrical Worker competency on a project by project basis by means of an online visibility resource and on-site auditing.

Sub-economic tendering, use of low-cost, unskilled workers and no-cost trainees have progressively weakened the safety, productivity and outlook of the sector.

SparkSafe is an industry-led “no pain, no gain” corrective instrument aimed at addressing a recurring and endemic procurement Client blind spot, which has unintentionally contributed to undertraining and poor uptake of appropriate NVQ Level 3 electrical apprenticeships.

The system has been designed to function as a practical gatekeeper for the industry and as an online watchman for responsible Clients.

Supply chain awareness of the LtP system has been communicated during the period through online and printed media, training events and feedback from on-site compliance audits.

Client led, social and sustainable procurement policy is the main driver that underwrites the development and objectives of the Electrical Licence to Practice system. Going forward, the system will continue with its mission to bring Client attention to the importance and visibility of individual electrical competency and accountability.

Demand from Clients and Electrical Workers for a fourth and higher licence type, has prompted further development of the system. An additional higher Licence type is planned for early 2018.

The organisation has also been encouraged by positive soundings from many other parts of the UK to extend the beneficial use of the system beyond the present territory.