CONSULTATION ON FIRST AID GUIDANCE
Following your letter of 23rd November 2007 the Federation of First Aid Training Organisations (FOFATO) has undertaken a comprehensive consultation across all its members covering all areas in England, Scotland and Wales.
The Federation is continuing to grow and now has almost 200 paid up members. The membership is truly representational covering many different types of Training Organisations including Local Authorities, Hospitals, Colleges, Fire Service, Police Service, Trade Associations as well as a growing number of small, medium and large Independent Organisations.
As a whole the Federation is now representing in the region of 20-25% of the active First Aid at Work Training Organisations.
In this letter I have summarised the comments (which has been agreed by our members) but have also attached a further letter with individual comments against all the particular points of concern (WHICH HAS BEEN E MAILED TO ALL FOFATO MEMBERS)
THE FUTURE OF FIRST AID APPROVALS
We understand as a First Aid Federation why HSE wishes to remove itself from the monitoring and approval process in the future but FOFATO does not want HSE to go down the QCA/SQA route. We have spoken to our members on this issue (some of whom have been involved with the QCA/SQA as trainers for some of their qualifications) and there are many concerns about taking this route. We have listed a few below.
Firstly there would be far more bureaucracy involved and is very labour intensive and it would tend to become a paper keeping/paper chasing exercise.
Secondly we do not know the kind of costs that are involved but from the experience of some of our members they tend to be very costly.
Finally and probably the greatest concern is the QCA/SQA ability to effectively monitor the First Aid Industry.
FOFATO feels and wishes for the First Aid Industry to be monitored from within and we are convinced that an Industry Body (the very direction HSE said it wanted to move in the recent past) should be the way forward.
AN INDUSTRY BODY
We realise that our thoughts on First Aid Approval and Monitoring may not be those of the HSE (and may have an effect on the introduction date of the new courses) but bearing in mind the representation that we now have we want our views to be heard at the highest possible level within HSE.
As a strong Federation within the First Aid Industry we feel more than capable of producing our own Industry Body and consequently improving standards amongst our members.
We feel that in the short term (and as an alternative to the QCA/SQA route) this Federation could set up and operate an Approval and Monitoring system for the new Training Organisations who wish to run the new EFAW course (and in the longer term the FAW course) and consequently avoid any lengthy delay in its implementation.
This would be achievable within the First Aid Industry if this Federation and possibly others were named (as the route to Approval and Monitoring for Training Organisations) in the revised Guidance and ACOP in the same way that QCA/SQA are named in your current draft.
OCCUPATIONAL HEALTH PROFESSIONALS
There are some differing views within FOFATO regarding Occupational Health Professionals including some from Nurses and Paramedics overall however the feeling is that:
Doctors, Nurses and Paramedics can be exempt from having a FAW certificate providing they have and can show current competence of First Aid skills and consequently can be used as a First Aider in the workplace or as a Trainer/Assessor if they have the relevant qualifications to do so.
Doctors, Nurses and Paramedics can run in-house annual refreshers but again must be able to show current skill and competence. (The problem however is that if they are not linked to a HSE registered company who is going to monitor them.)
ANNUAL REFRESHER OF FAW OR EFAW
We feel that the wording should be stronger and made clear that although the certificate is valid for 3 years it will lapse after one year/two years if there is no evidence of an annual update.
NUMBER OF FIRST AID PERSONNEL/APPOINTED PERSON ROLE
The Federation feels that the new guide to the category and number of First Aid personnel is now more confusing and is giving employers a choice in some areas of whether to use a FAW or an EFAW First Aider.
Also as there are 3.7 million businesses in the United Kingdom and that there are 99% of them who employ less than 50 people a large percentage of the 3,663,000 may decide they do not need any form of First Aid training and just use the Appointed Person.
FIRST AID TRAINING STANDARDS
We are concerned that the HSE uses the Voluntary Aid Societies (VAS) manual as the Industry Standard for First Aid. We feel that there are other suitable publications on the market and that other publications could be listed in full or just a general statement without naming any individual publications.
FINALLY
Thank you for allowing FOFATO to be involved in your consultation process and if you require any further help or clarification please come back to us.
We would also willingly offer any further help in future consultations relating to the First Aid Industry or indeed any other points where you may need clarification from the Industry.
We await with great interest your response to the comments of this Federation.