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Should training be compulsory for vehicle depollution and dismantling?

There is evidence to suggest that some employers may choose to narrow the scope of their workplace training to those elements that have a clearly defined legislative requirement. The motive for doing this is simple, cost. It can be costly to train and keep on training employees, so some operators try to squeeze training, by making training as short as possible or only covering the "basics". Then there are those who ignore training completely, who run the gauntlet, knowing the likelihood of an enforcement encounter is low. However, these people ultimately end up coming unstuck when they suffer a workplace accident and any short-term training cost savings are negated by the resulting higher insurance premiums, fines, workers claims or even their businesses going under.

There will always be opportunists within the sector and as such, there is a compelling justification for the implementation of mandatory training. Such an approach takes away employer guesswork, by spelling-out the minimum standards for health, safety and compliance. You either do it or you don't! And if you don't, the consequences should be severe. The disadvantage of a mandatory approach is that workplace training has to remain very generalised in order that it remain applicable to the safety and environmental considerations presented by a wide range of occupations and industries. These limitations would ultimately mean responsible organisations may look to provide additional workplace training (at additional cost) to wrap around the legislative minimum provided, and ensure their employees are fully capable of carrying out their work safely. If organisations are looking to offer more than the legislative minimum, then it could be argued that there is little value for mandatory training in the first instance.

So when evaluating whether or not training for vehicle depollution and dismantling should be compulsory, I keep coming back to the merits of employers being the ultimate decision makers on what workplace training is suitable. After all, no-one knows better what training is appropriate than the industry itself, right? But as already highlighted, this approach comes with a warning. We have to expect a mixed bag of approaches to training, with many organisations doing training really well, those who could do much better, and those doing nothing at all. Therefore, to prevent training being "watered down", we must insist on a starting point on which workplace training can be properly built - a strong foundation that defines a standard within that specific occupation, developed from best practice within the industry. Thankfully, these standards already exist for vehicle recycling. If you haven't heard of them before, they are the National Occupational Standards and they exist for many activities, not just vehicle recycling. The ones applicable to our industry include:

  • IMIVRC01 - Collect and transport casualty vehicles for salvage or recycling.

  • IMIVRC02 - Receive and inventory end of life vehicles.

  • IMIVRC03 - Depollute end of life vehicles.

  • IMIVRC04 - Dismantle end of life vehicles.

  • IMIVRC05 - Grade reclaimed vehicle parts

  • IMIEV02 - Provide a first response to a broken down or damaged electric vehicle.

  • IMIEV02a - Provide a first response to a broken-down or accident damaged electric vehicle.

  • IMIEV02b - Manage unstable high voltage systems in an electric vehicle.

  • IMIEV04 - Isolate and re-energise high voltage systems in an electric vehicle.

  • IMIEV06 - Test, remove and store electric vehicle high voltage batteries.

  • IMIEV09 - Recover a broken down or damaged electric vehicle.

  • IMIEV10 - Diagnose, test and rectify faults in electric vehicle high voltage batteries.

So armed with these standards, an organisation should be able to better evaluate what they currently provide in regard to workplace training against what they should be providing. They should be able to self-audit and if required, formulate what their future workplace training should look like. From these starting points, they can formulate what training is needed, identify the skills and knowledge needed for people to do their job in a safe and healthy way, compare these against people’s current skills and knowledge and identify the gaps. They should review their experience of injuries, near misses or cases of ill health, and look at their risk assessments to see where information and training have been identified as factors in controlling risk. They must also consider awareness training needs for everyone, including directors, managers and supervisors, including: how they manage health and safety; who is responsible for what; the cost to the business if things go wrong; how to and how often they identify hazards and evaluate risks; and the hazards encountered and measures for controlling them.

If you need a helping hand, any advice or support in formulating what your future workplace training should look like, please get in touch. We offer a series of ELV depollution and recycling training programmes aligned with the National Occupational Standards, and covering conventional and alternatively powered vehicles. We have also pioneered a world's first CIWM Level 3 Vocational Qualification for vehicle depollution and dismantlers, that can be conveniently carried out at your premises using your equipment.



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