It would be daft to turn the Richard Review into a holy text which we can never deviate from. It wasn’t written that way, it won’t bear that weight, and I’m sure Doug Richard himself would say he meant it to be a framework not a straitjacket.
And the trouble with holy texts is that different people interpret them differently, all too often turning their interpretation into a doctrine. That’s exactly what BIS has done. Doug Richard is an entrepreneur, so when he took a swipe at the way qualifications have been misused in the past, it was exactly that, a swipe, not a detailed, exhaustive, critique. It was a well-aimed swipe, to be sure, but it’s a mistake for BIS to turn it into a new doctrine.
Let’s look at what he said. First, that the notion of a successful apprentice ‘graduating’ to the next stage of their career has been lost, replaced by a “welter of qualifications that … serve to support the apprentice’s progress often without ever declaring their final competency”. (Note that ‘often’: he’s not saying ‘always’). He wants each occupation defined by a standard, and the Trailblazer reforms grant his wish. I’ve no problem with that.
Second, he finds the qualifications on offer confusing and unreliable: “we need clear, effective and trusted qualifications”. He’s saying “improve them”, not “bin them”. Indeed, he talks about the new apprenticeship standards he advocates as “new qualifications”. He’s not agin qualifications.
And third, he’s concerned that “overly detailed specifications for each qualification” constrain employers and constrain innovation. That’s a complaint about badly-designed qualifications, not about qualifications per se.
These are all important concerns, but none justify BIS taking so strongly against including qualifications in new-style apprenticeships. They do accept them in certain circumstances, but objected to the inclusion of a number in one of the draft standards for the shipping sector, including the “Entry Into Enclosed Spaces” certificate.
That really annoyed our working group. Entry into enclosed spaces is the most common cause of death on board a ship (because of depleted oxygen). It’s a one day course, and we readily agreed to include it in the standard, to ensure that every apprentice would complete it at the start of their career to learn to keep themselves safe. It’s not confusing, it’s not overly-detailed; it’s the industry-standard course, accredited by the well-respected, employer-led, Merchant Navy Training Board.
But BIS said no. “The MNTB Entry into Enclosed Spaces certificate is not a regulated qualification, so while we accept the need for it as part of this role it cannot be included as part of the standard”.
Doug Richard said nothing about preferring regulated qualifications over others. What he did say was that “It is complicated and off-putting to an employer to have to undertake paperwork gymnastics to pigeon hole their system into a pre-defined set of curricular approaches”.
Here’s one last quotation from the holy text. “In taking forward the recommendations made in this report, Government must be mindful to protect what works … ensuring that change is led by employers”.
In this case employers (and our trade unions) are adamant that they want to include this qualification.
Surely what BIS should do, with us and with others caught up in their doctrinaire approach, is accept the settled will of employer groups when they say they want to include qualifications along the way to an agreed standard. Test our assertion by all means, but in the spirit of employer leadership, ultimately they should embrace it. Amen.
 The Department for Business, Innovation and Skills, which is leading apprenticeship reform in England.
NB The above formed the basis of an article published by the TES in April 2016 (not available online). I have not attempted to update it for recent changes.