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P228 WASTE MANAGEMENT ISSUES REGISTER

P228 Waste Management

Summary of findings and advice

P228 Waste Management Qualifications and Units

CPP Property Services Training Package

The Issues Register records issues raised throughout the consultation, development and validation processes.

Issues raised by subject matter experts and stakeholders, and the consequent actions are to be recorded in this Issues Register.

Issues register contents:

Delivery issues.......................................................................................................................................................................................................................3

General issues.......................................................................................................................................................................................................................4

Equity issues..........................................................................................................................................................................................................................4

Qualification issues: Certificate II in Waste Management.....................................................................................................................................................5

Qualification issues: Certificate III in Waste Management....................................................................................................................................................8

Qualification issues: Certificate IV in Waste Management.................................................................................................................................................11

Qualification issues: Diploma of Waste Management.........................................................................................................................................................16

Unit of competency issues: General...................................................................................................................................................................................18

Unit of competency issues: CPPWMT2001 Prepare for work in the waste management industry....................................................................................21

Unit of competency issues: CPPWMT2034 Maintain equipment and consumables storage areas...................................................................................22

P228 Issues Register Final V2 Page 1


Unit of competency issues: CPPWMT2047 Assist with resource recovery operations......................................................................................................22

Unit of competency issues: CPPWMT2048 Prepare work areas for waste sorting............................................................................................................23

Unit of competency issues: CPPWMT2049 Assist with response to waste emergencies..................................................................................................23

Unit of competency issues: CPPWMT3014 Manually sort waste.......................................................................................................................................25

Unit of competency issues: CPPWMT3017 Store waste....................................................................................................................................................26

Unit of competency issues: CPPWMT3018 Dispatch waste...............................................................................................................................................26

Unit of competency issues: CPPWMT3019 Prepare waste for reuse................................................................................................................................26

Unit of competency issues: CPPWMT3023 Maintain waste disposal sites........................................................................................................................27

Unit of competency issues: CPPWMT3042 Follow environmental policy and procedures when transporting waste.........................................................28

Unit of competency issues: CPPWMT3044 Identify wastes and hazards..........................................................................................................................28

Unit of competency issues: CPPWMT3054 Maintain credit control....................................................................................................................................30

Unit of competency issues: CPPWMT3063 Apply safe operational practices when vehicles contact overhead wires......................................................31

Unit of competency issues: CPPWMT4001 Plan waste audits...........................................................................................................................................33

Unit of competency issues: CPPWMT4002 Carry out waste audits...................................................................................................................................34

Unit of competency issues: CPPWMT4003 Evaluate waste assessment findings.............................................................................................................35

Unit of competency issues: CPPWMT4006 Organise waste recovery operations.............................................................................................................36

Unit of competency issues: CPPWMT4007 Implement waste management plans............................................................................................................37

Unit of competency issues: CPPWMT4022 Monitor waste disposal sites..........................................................................................................................38

Unit of competency issues: CPPWMT4027 Select and obtain waste management plant, equipment and materials........................................................39

Unit of competency issues: CPPWMT4030 Plan waste management services.................................................................................................................40

Unit of competency issues: CPPWMT4032 Educate clients on waste management.........................................................................................................41



Unit of competency issues: CPPWMT4035 Undertake waste process audits....................................................................................................................41

Unit of competency issues: CPPWMT4037 Conduct minor maintenance and repairs on waste processing plant and equipment...................................42

Unit of competency issues: CPPWMT4050 Deliver training in hazard identification and waste emergency response......................................................43

Unit of competency issues: CPPWMT4060 Apply lean management techniques..............................................................................................................43

Unit of competency issues: CPPWMT5004 Develop waste management strategies.........................................................................................................44

Unit of competency issues: CPPWMT5031 Prepare waste management service tenders................................................................................................45

Unit of competency issues: CPPWMT5033 Educate public on waste management issues...............................................................................................46

Unit of competency issues: CPPWMT5036 Develop waste management plans................................................................................................................49

Unit of competency issues: CPPWMT5043 Develop and implement environmental management strategies...................................................................50

Unit of competency issues: CPPWMT5045 Develop waste management site safety plans..............................................................................................51

Unit of competency issues: CPPWMT5057 Develop landfill rehabilitation plans...............................................................................................................52

Unit of competency issues: CPPWMT5058 Develop waste management emergency response plans.............................................................................53

Unit of competency issues: CPPWMT5061 Plan resource recovery operations................................................................................................................54

Delivery issuesNo delivery issues were raised.



General issuesNo Date Type of Stakeholder

(e.g. RTO)Issue Comment/Action

1 12.11.15 Alan Daniel, Business Industries Curriculum Maintenance Manager, Victorian STA

Qualification Mapping InformationI know the Qualification Template asks to specify code and title of any equivalent qualification and if no equivalent state ‘No equivalent qualification’You know that and I know that but the user does not.Recommend you state what the new qualification is equivalent to or something to that effect.

Thank you for your feedback.All waste management qualifications have been deemed “equivalent” and list the code and title of the superseded qualification in two places: under the heading “Modification History”, and under the heading “Qualification Mapping Information”.

No further action.

Equity issuesNo equity issues were raised.



Qualification issues: Certificate II in Waste ManagementNo Date Type of Stakeholder


1a 18.11.15 Robyn Addie, TAFENSW

Change qualification titles to • Certificate II in Waste Operation

Thank you for your feedback.This has been a redesign project to align to the COAG approved revised Standards for Training Packages. Unfortunately, changing the qualification title is outside of the project scope as it would require detailed occupational analyses and stakeholder consultation process. Your feedback will be listed for consideration as part of any future review of the qualifications.No further action.

1b 18.11.15 Robyn Addie, TAFENSW

Description: The description is clear and precise. No regulatory framework mentioned, POEO (Waste) Regulation 2014?

Thank you for your feedback.To accommodate licensing and regulatory requirements for plant and equipment operation, the following statement has been written into the qualification description section of all qualifications:‘Licensing, legislative, regulatory or certification requirements may apply in some States where a licence is required to operate various plant, vehicles or equipment used to transport, shift, load, unload, lift, compact or otherwise process waste. Relevant state and territory regulatory authorities should be consulted to confirm those requirements.’No further action.

1c 18.11.15 Robyn Addie, TAFENSW

Packaging rules: These look like they will cover various waste management businesses, from liquid waste through to solid, landfills and hazardous waste.

Thank you for your feedback.

1d 18.11.15 Robyn Addie, Core units: The title of CPPCMN3001 may be Thank you for your feedback. CPPCMN3001B is a P228 Issues Register Final V2 Page 5


Qualification issues: Certificate II in Waste ManagementNo Date Type of Stakeholder


TAFENSW detrimental to uptake. common unit in the core of the existing qualification. As a re-templating project with the intent to align to the Standards for Training Packages, the new iteration of that unit remains in the core of the new qualification, however its modification is outside the scope of this project.No further action.

1e 18.11.15 Robyn Addie, TAFENSW

Elective units: The units all have value for various waste management enterprises, but would need to be tailored to suit specific businesses in private training, or more broadly, removal of certain units to reflect a wider scope for the CERT II level. i.e. driving a forklift would be more useful for this level than driving a truck.TLIC2002A, TLIC2003A, TLIL2014A and TLIL2015AAlso, it would be unlikely that a waste labourer would be servicing vehicles. Smaller enterprises use contractors or offsite maintenance, and larger enterprises tend to have their own mechanics.TLIB2003A

Thank you for your feedback.The packaging rules allow some flexibility in the choice of electives.No further action.

1f 18.11.15 Robyn Addie, TAFENSW

Other comments:It was good to see that imported units ‘from outside these qualifications … will reflect their current endorsement status in their respective Training Package’, because course completions can be effected if this update does not occur.




Qualification issues: Certificate III in Waste ManagementNo Date Type of Stakeholder


1 4.11.15 Kevin Peachey, EUPA Training Council, WA

I find the packaging rules for the below confusing and find myself working backwards from the totals to establish where I get the units from.Packaging RulesTo achieve this qualification, competency must be demonstrated in: 17 units of competency: 5 core units, 12 elective units.The elective units must ensure the integrity of the AQF alignment and contribute to a valid, industry-supported vocational outcome and are to be chosen as follows: no less than 4 units from Group A, of which

up to 2 may be from the Group A elective units listed in CPP4XX16 Certificate IV in Waste Management

up to 8 units may be chosen from Group A or Group B

up to 2 units may be chosen from other Certificate II, Certificate III or Certificate IV qualifications in CPP, or another current Training Package or accredited course, provided they do not duplicate the outcome of another unit chosen for the qualification.

You choose 4 units from group A, you choose 4 units from group A to make up 8 (up to 8 units

Thank you for your feedback. The packaging rules and structure of the qualification have not changed since the 2011 review, with the exception of updating units to the current/new versions. No units have been removed.Recommend clarifying packaging rules as follows with regard to selecting 12 elective units:The elective units must ensure the integrity of the AQF alignment and contribute to a valid, industry-supported vocational outcome and are to be chosen as follows: 4 units from Group A – up to 2 of these 4 units may

instead be chosen from the Group A elective units listed in CPP40916 Certificate IV in Waste Management

8 units may be chosen from Group A or Group B – up to 2 of these 8 units may be chosen from other Certificate II, Certificate III or Certificate IV qualifications in CPP, or another current Training Package or accredited course, provided they do not duplicate the outcome of another unit chosen for the qualification.

No further action.





may be chosen from Group A or Group B), 2 units (up to 2 units may be chosen from other Certificate II, Certificate III or …) Total = 10 units do you choose 2 from B to make 12?


Title: Clear and concise. Change qualification titles to • Certificate III in Waste Operation

Thank you for your feedback.This has been a redesign project to align to the COAG approved revised Standards for Training Packages. Unfortunately, changing the qualification title is outside of the project scope as it would require detailed occupational analyses and stakeholder consultation process. Your feedback will be listed for consideration as part of any future review of the qualifications.No further action.


Description: The description is clear, but limited – maybe some direct roles needed to specify where this cert is aiming in the marketplace?There is a growing emphasis on composting of green waste A statement referring to this may be of assistance ( even though the units are imported from RTE ).Change the 1st sentence of qualification description to :This qualification reflects a number of roles in the waste operations where operational skills and knowledge are required in a wide variety of work contexts

Thank you for your feedback.Recommend changing the description to: “This qualification reflects a number of roles in the waste management industry where operational skills and knowledge are required in a wide variety of work contexts and emerging industry skill areas, such as composting of green waste.”As the qualification title is not changing, it is recommended that the description continue to refer to “waste management”.No further action.


Packaging rules: Very large course Thank you for your feedback. Changes to the packaging arrangements/size of the qualification are outside the





scope of this project, however will be noted for future reviews of the qualification.No further action.

2d 18.11.15 Robyn Addie, TAFENSW

Core units: CPPCMN3004 Great for the sales administratorThe other units would suit the site foreman, supervisors etc



Elective units: Good units, cover more specific roles like the site foreman, yard supervisors and labourers wanting to move upwards etcThe electives imported from RTE: RTE 3323A, RTE 3512A, RTE3513A & RTE4519A are very valuable for this qualification due to more emphasis being placed on this process in the waste management industry



Other comments: It was good to see that imported units ‘from outside these qualifications … will reflect their current endorsement status in their respective Training Package’, because course completions can be effected if this update does not occur.


Qualification issues: Certificate IV in Waste ManagementNo Date Type of Stakeholder


1a 4.11.15 Kevin Peachey, EUPA Training

I find the packaging rules for the below confusing and find myself working backwards






Council, WA from the totals to establish where I get the units from.Packaging rules:To achieve this qualification, competency must be demonstrated in: 18 units of competency: 7 core units, 11 elective units.The elective units must ensure the integrity of the AQF alignment and contribute to a valid, industry-supported vocational outcome and are to be chosen as follows: no less than 4 units from Group A, of which

up to 2 may be from the Group A elective units listed in CPP3XX16 Certificate III in Waste Management

up to 7 units may be chosen from Group A or Group B

up to 2 units may be chosen from other Certificate III, Certificate IV or Diploma qualifications in CPP, or another current Training Package or accredited course, provided they do not duplicate the outcome of another unit chosen for the qualification.

You choose 4 units from group A, you choose 3 units from group A to make up 7 (up to 7 units may be chosen from Group A or Group B), 2 units (up to 2 units may be chosen from other Certificate III, Certificate IV) Total = 9 units, do you choose 2 from B to make 11 ?

The packaging rules reflect those from the 2011 review and were unchanged in the first draft, with the exception of updating units to the current/new versions. As a result of one core unit being deleted from its parent Training Package (CPPCMN4006A), the final draft will see the packaging arrangements change to 6 core and 12 electives.

Recommend: 1. Changing packaging rules to 12 units comprising 6 core and 12 electives2. Clarifying packaging rules with regard to selecting 12 elective units:The elective units must ensure the integrity of the AQF alignment and contribute to a valid, industry-supported vocational outcome and are to be chosen as follows: 5 units from Group A - up to 2 of these 4 units may

instead be chosen from the Group A elective units listed in CPP30616 Certificate III in Waste Management or CPP50616 Diploma of Waste Management

7 units may be chosen from Group A or Group B – up to 2 of these 7 units may be chosen from other Certificate III, Certificate IV or Diploma qualifications in CPP, or another current Training Package or accredited course, provided they do not duplicate the outcome of another unit chosen for the qualification.

Implemented





1b 4.11.15 Kevin Peachey, EUPA Training Council, WA

Imported units are not the most current, see examples below. BSBHRM402A - Recruit, select and induct staff superseded by BSBHRM405A - Support the recruitment, selection and induction of staff, Is superseded by and equivalent BSBHRM405 - Support the recruitment, selection and induction of staffBSBHRM401A - Review human resources functions superseded by BSBHRM404A - Review human resources functions is superseded by and equivalent to BSBHRM404 - Review human resource functions

Thank you for your feedback. Action: Imported units will be updated as suggested.

Implemented

2 17.11.15 Robyn Addie, TAFENSW

Regarding additional core unit to replace the deleted CPPCMN4006A: If the industry did not raise this as an issue during the review then it can’t be a significant issue. From our point of view a bigger core = less flexibility so the Hunter is OK with the current document.

Thank you for your feedback. Relates to issue 1 above.Action: Recommend changing the packaging rules to require 6 core and 12 electives.Implemented


Regarding additional core unit to replace the deleted CPPCMN4006A: Western agrees with above comments.To leave the selection of units as they are gives us greater flexibility to meet student/local industry requirements.

Thank you for your feedback. Relates to issues 1 and 2 above.


Title: Change the title toCertificate IV in Waste Management Operation.

Thank you for your feedback.This has been a redesign project to align to the COAG approved revised Standards for Training Packages.





Unfortunately, changing the qualification title is outside of the project scope as it would require detailed occupational analyses and stakeholder consultation process. Your feedback will be listed for consideration as part of any future review of the qualifications.No further action.


Description: The description is clear and precise the qualification description could be changed to:This qualification reflects a number of supervisory roles in the waste operations where advanced operational skills and knowledge are required in a wide variety of work contexts.

Thank you for your feedback.Action: Recommend adding the word “supervisory” to the description as suggested.Implemented


Packaging rules: These look like they will cover various waste management businesses, from liquid waste through to solid, landfills and hazardous waste.The quantity of units for this and the diploma seem quite large, and if the course was done part time, it could potentially take several years, which may reduce waste enterprise individuals and organisations interest in undertaking it.

Thank you for your feedback. Changes to the packaging arrangements/size of the qualification are outside the scope of this project, however will be noted for future reviews of the qualification.No further action.


Core units: The title of CPPCMN4002 may be detrimental to uptake.

Thank you for your feedback. CPPCMN4002B is a common unit in the core of the existing qualification. As a re-templating project with the intent to align to the Standards for Training Packages, the new iteration of that unit remains in the No further action.

4e 18.11.15 Robyn Addie, Elective units: These units look good, and Thank you for your feedback.





TAFENSW applicable to industry – forklift licences would be a useful tool to obtain through the course.




Qualification issues: Diploma of Waste ManagementNo Date Type of Stakeholder


1 12.11.15 Alan Daniel, Business Industries Curriculum Maintenance Manager, Victorian STA

In the core of the Diploma the unit BSBOHS505B Manage hazards in the work environment, whilst on TGA is shown as current because it exist in a number of Training Packages it has in fact been superseded by BSBWHS504 Manage WHS risks

Thank you for your feedback. Action: Imported unit will be updated as suggested.Implemented


WA industry highlighted the growing demand for waste education roles and considered that the diploma could include more electives for those preparing for this role. All waste strategies have waste avoidance (behavioural change) at their heart.EUPA Comment: Whilst considering the feedback above, I would like the ISC to consider the relationship to TAE. What customisation of a CPP diploma would be suitable? Conversely,

Thank you for your feedback. This has been a redesign project to align to the COAG approved revised Standards for Training Packages. Unfortunately, the issues raised are outside of the project scope, however will be listed for consideration as part of any future review of the qualifications.No further action.



Qualification issues: Diploma of Waste ManagementNo Date Type of Stakeholder


would a waste educator be better customising a TAE qualification?


Description: The description is clear and precise. Thank you for your feedback.


Packaging rules: This is a very big course. How many years expected for completion?

Thank you for your feedback. Changes to the packaging arrangements/size of the qualification are outside the scope of this project, however will be noted for future reviews of the qualification.No further action.


Core units: Good core units, look to aim towards sales people and technical staff, floor supervisors.



Elective units: These units are good, but look to lead to government employment (local and state government), which is almost a contradiction to the core units.





Unit of competency issues: GeneralNo Date Type of Stakeholder


1 12.11.15 Alan Daniel, Unit Mapping Information: I know the Unit of Thank you for your feedback.P228 Issues Register Final V2 Page 14




Business Industries Curriculum Maintenance Manager, Victorian STA

Competency Template asks to specify code and title of any equivalent unit of competency and if no equivalent insert ‘No equivalent unit’You know that and I know that but the user does not.Recommend you state what the new unit is equivalent to or something to that effect.

All native waste management units have been deemed “equivalent” and list the code and title of the superseded unit in two places: under the heading “Modification History”, and under the heading “Unit Mapping Information”.No further action.

2a 15.11.15 Kevin Peachey, EUPA Training Council, WA

The group noticed that some units require the candidate to demonstrate the competency in ‘two jobs’. Others might ask for two separate occasions or two clients. The group was unable to reach a consensus of what ‘two jobs’ required.. Should this be two clients? Two employers? Two separate occasions?

Action: Change references to “jobs” to “separate occasions” throughout units to ensure clarification and consistency.Implemented

2b 15.11.15 Kevin Peachey, EUPA Training Council, WA

Has the ISC moved any of its units of competency away from passive language? Some of the performance criteria are horrible to read!!

Thank you for your feedback. CPSISC policy and the unit template require passive language to be used for performance criteria.No further action.

2c 15.11.15 Kevin Peachey, EUPA Training Council, WA

Feedback relates to several units including: CPPWMT2001, CPPWMT30XX, CPPWMT3005CPPWMT3011, CPPWMT3014, CPPWMT3041CPPWMT3044, CPPWMT4006, CPPWMT4030CPPWMT4050Knowledge evidenceliquid: non-hazardous, e.g. chemical and aqueousThis knowledge requirement is used in all units identified above.


Action: Change references relating to waste categories throughout units to: “solid: non-hazardous liquid: non-hazardous





Feedback suggests that this statement needs to be amended. The example ‘chemical’ was considered by those that provided feedback to be more likely hazardous than not.EUPA Research: Source: Australian Govt, Dept of Environment. 1. Hazardous waste is defined as those belonging to Annex III and Annex I (where certain conditions are met) of the Basel Convention.2. Liquid waste is categorised as sewerage, trade waste and hazardous waste These appear to be the most consistently applied definitions across all states and territories. Solutions may include:1. Provide a better example(!) of non-hazardous liquid waste. After all, ‘chemical’ does not help and aqueous is really just a synonym for liquid! I honestly can’t think of a suitable/succinct way to describe non-hazardous liquid waste though.2. Define (or provide examples) only for hazardous waste. It is far easier to define hazardous waste as there is national, state and territory legislation.

hazardous: regulated, prescribed, dangerous goods, quarantined, medical and clinical

recoverable resources”Implemented

2d 15.11.15 Kevin Peachey, EUPA Training Council, WA

Feedback relates to several units including: CPPWMT2047, CPPWMT3046, CPPWMT4056CPPWMT4060, CPPWMT4062, CPPWMT5004CPPWMT5036, CPPWMT5043, CPPWMT5045CPPWMT5057, CPPWMT5061

Thank you for your feedback.Action: Change references to “renew, reuse and recycle” throughout units to: “reduce, reuse and recycle”





Knowledge evidencelifecycle of products: renew, reuse and recycle ‘Renew’ is not industry standard terminology. Depending on the intent of the knowledge statement, the word could be replaced with ‘repair’. Otherwise, the industry generally accepts the three r’s as reduce, reuse and recycle.

Implemented



Unit of competency issues: CPPWMT2001 Prepare for work in the waste management industryNo Date Type of Stakeholder



Range of conditions: Selling recoverable waste to the public.Applying the waste hierarchy, the sentence should read ‘selling reusable waste to the public.Recoverable is interpreted to mean waste that can be recycled. General recyclables would not be sold to the public.Performance evidence: • waste contaminants including:• exposure to sunlightExposure to sunlight is not considered to be a contaminant. It is a condition that affects some waste substances.

Thank you for your feedback.Action: replacing “selling recoverable waste to the public”

with “selling reusable waste to the public” deleting “exposure to sunlight” from all units where

it is listed as a waste contaminant.Implemented


Application: Change the Unit Title to: Prepare for work in the waste OperationChange the 1st sentence of the “Application’ to This unit of competency specifies the outcomes required to prepare to work in waste operations activities.

Thank you for your feedback.Refer to comments above regarding the titles of qualifications and the need to retain ‘waste management’ at this stage.No further action.

Unit of competency issues: CPPWMT2034 Maintain equipment and consumables storage areasNo Date Type of Stakeholder


1a 18.11.15 Robyn Addie, Application: Great unit, excellent. Something that Thank you for your feedback.



Unit of competency issues: CPPWMT2034 Maintain equipment and consumables storage areasNo Date Type of Stakeholder


TAFENSW is very needed in the waste sector1b 18.11.15 Robyn Addie,

TAFENSWElements: Clear and easy to work with.Technically, 3 should not be required, if you’re managing your stock correctly there will be no emergency??



Performance criteria: Good. Thank you for your feedback.


Foundation skills: Numeracy. Not sure that many labourers will be working out how to mix chemicals in most waste enterprises. Most of this is done by higher level staff, e.g. engineers and chemists.

Thank you for your feedback.Action: Change Numeracy skills requirements to “calculate stock quantities”.Implemented

Unit of competency issues: CPPWMT2047 Assist with resource recovery operationsNo Date Type of Stakeholder



Application: Great unit, excellent. Something that is very needed in the waste sector



Elements: Clear and easy to work with. Thank you for your feedback.


Performance criteria: Good, really clear and precise.




Unit of competency issues: CPPWMT2048 Prepare work areas for waste sortingNo Date Type of Stakeholder



Application: Clear, accurate Thank you for your feedback.




Performance criteria: Great criteria – needed in the industry.Maybe an extra component regarding what to do if you find a hazard? Sometimes there is no time to report, you need to act. Could fit in between 2.1 and 2.2

Thank you for your feedback.Action: modify PC 1.4. as suggested to: “Potential hazards and risks are identified and controlled, or reported to relevant personnel according to organisational and compliance requirements.”Implemented


Foundation skills: Good Thank you for your feedback.


Assessment conditions: Good Thank you for your feedback.

Unit of competency issues: CPPWMT2049 Assist with response to waste emergenciesNo Date Type of Stakeholder



Application: Good application for the course. clear Thank you for your feedback.




Performance criteria: Great criteria. Thank you for your feedback.


Foundation skills: Maybe observational skills could be added – to observe and identify potential

Thank you for your feedback. The foundation skills section aims to list foundation skills which are ‘implicit’



Unit of competency issues: CPPWMT2049 Assist with response to waste emergenciesNo Date Type of Stakeholder


hazards in the workplace in the performance criteria. For this purpose, foundation skills include core skills: learning; numeracy; oral communication; reading and writing, and employment skills: initiative and enterprise; planning and organising; problem-solving; self-management; teamwork; and technology. Observation skills are not considered a foundation skill in this context.No further action.


Range of conditions: Good Thank you for your feedback.


Assessment conditions: Good Thank you for your feedback.



Unit of competency issues: CPPWMT3014 Manually sort wasteNo Date Type of Stakeholder



Performance criteria 1.4 Sorting site set-up is organised to ensure safe and effective waste sorting according to organisational ad compliance requirements.Relates to performance evidence below. Performance evidence:• organise and set up the waste sorting site in a manner that ensures effective waste sortingThe sorting site is most likely already established and set up. It is considered unlikely that the person who manually sorts waste would be required to perform this task.

Thank you for your feedback.Intention is for the learner to set up the site for effective waste sorting (rather than organise the site).Action: Edits to provide clarity of intention of the following: changing PC 1.4 to “Sorting site is set up to ensure

safe and effective waste sorting according to organisational and compliance requirements”

changing the related point in the performance evidence to: “set up the waste sorting site in a manner that ensures effective waste sorting”.

Implemented.



Unit of competency issues: CPPWMT3017 Store wasteNo Date Type of Stakeholder



Range of conditions: Typo: ‘Decomposting’ should read ‘decomposing’

Thank you for your feedback.Action: ‘Decomposting’ will be changed to ‘decomposing’ as suggested.Implemented

Unit of competency issues: CPPWMT3018 Dispatch wasteNo Date Type of Stakeholder



Range of conditions: Typo: ‘Decomposting’ should read ‘decomposing’

Thank you for your feedback.Action: ‘Decomposting’ will be changed to ‘decomposing’ as suggested.Implemented

Unit of competency issues: CPPWMT3019 Prepare waste for reuseNo Date Type of Stakeholder



Performance evidence• waste contaminants including:• exposure to sunlightExposure to sunlight is not considered to be a contaminant. It is a condition that affects some waste substances.

Thank you for your feedback.Action: Reference to “exposure to sunlight” will be deleted from all units where it is listed as a waste Implemented contaminant.



Unit of competency issues: CPPWMT3023 Maintain waste disposal sitesNo Date Type of Stakeholder



Performance criteria: Litter screens should be included (e.g. from earthen bund cells or movable litter screens). Performance knowledge1. Candidates must understand the types of vermin control methods and the potential impact on the environment/other species. For example, 1080 poison risks near suburban areas (dogs/cats) 2. Fire risk mitigation should be understood. This includes fire breaks, controlled burns, etc.

Thank you for your feedback.Action:1. Add “litter screens” to PC 4.2.2. Make the following changes to the knowledge evidence listing: “pest management techniques for managing vermin

infestations at landfill sites” will be replaced with:“vermin control methods and their potential impact on the environment and other species”

New point: “fire risk mitigation techniques, including fire breaks and controlled burns”

Implemented

Unit of competency issues: CPPWMT3042 Follow environmental policy and procedures when transporting wasteNo Date Type of Stakeholder



Performance evidence: Suggest rewording performance evidence statement to:‘explain to relevant personnel the impact of waste on the environment, the importance of waste management strategies and how they relate to the waste management hierarchy.’

Thank you for your feedback.Action: The statement in the performance evidence will be modified as suggested to: “explain to relevant personnel the impact of waste on the environment, the importance of waste management strategies, and how they relate to the waste management hierarchy”.Implemented



Unit of competency issues: CPPWMT3044 Identify wastes and hazardsNo Date Type of Stakeholder



Application: Good application, potentially huge scope.





Performance criteria: Perhaps some expansion with legislative responsibilities – anyone is liable for incorrect disposal ending up as contamination, including the labourer. They should have this information clearly spelt out and know their responsibilities.

Thank you for your feedback.Action: modify compliance requirements in the range of conditions to clarify WHS and environmental compliance requirements:“• commonwealth, state and territory legislation relating to waste management, including:

• environmental protection and incorrect waste disposal• work health and safety including hazardous substances and dangerous goods• industry codes

• licensing arrangements.”Implemented


Range of conditions: Legislative requirements are spelled out here. I think they should be specifically a part of the performance criteria – maybe an additional point following 2.1 – this criteria looks to only address WHS, not environmental acts in its current form.

Thank you for your feedback.Relates to 1c above.



Unit of competency issues: CPPWMT3054 Maintain credit controlNo Date Type of Stakeholder



Knowledge evidence: This feedback could result in a change to a different component of this unit of competency, but it seemed appropriate to make comment under ‘knowledge’ at the very least:There are no issues with the unit content except that it is extremely generic. In its current state, I would have thought the FNS training package might offer an existing equivalent unit. If this unit is kept, specific reference to landfill levies or other state/territory taxes/fees for different waste types might give more context to the unit.

Thank you for your feedback. This has been a redesign project to align to the COAG approved revised Standards for Training Packages. More detailed redevelopment of this unit to provide a waste management context is outside the project scope, however will be listed for consideration as part of any future review of the unit.Action: 1. Change the unit title to “Maintain credit control in waste management”, and2. Include the following point under knowledge evidence: “taxes and fees for different waste types”Implemented



Unit of competency issues: CPPWMT3063 Apply safe operational practices when vehicles contact overhead wiresNo Date Type of Stakeholder



General comment: The unit was considered to be reasonably good, but has some areas for improvement. Also, overhead wires should obviously be considered prior to getting in this predicament! It would be worth reminding workers to look up when they are going through OHS practices (entering, working in and leaving a specific worksite). Industry feedback definitely suggests ensuring this component of risk mitigation is found in the units that deal with hazard identification. With respect to the application in particular, the unit covers ‘where no potential threat is identified’. Without the attendance of appropriately skilled emergency/electricity supply workers, industry believes that their should always be a potential threat.Range of conditions: Exiting safely must include: This statement must include an alternative method for those that are unable to perform the bunny hops. Advice received from Western Power is that the candidate may shuffle, without breaking feet apart (crossing ‘step potential’)Performance evidence: Whilst the unit requires the candidate to perform the competency in both a non-threatening and threatening scenario, industry feedback recommends stipulating varying

Thank you for your feedback.Action: Modify the new core unit “CPPWMT3064 Contribute to workplace safety in waste management” to: require safe work practices to be followed, and incorporate knowledge of “safe work practices in

waste management, including looking for overhead wires when entering, working in, and leaving a work site”

Recommend also modifying CPPWMT3063 to incorporate feedback as suggested.

Implemented



Unit of competency issues: CPPWMT3063 Apply safe operational practices when vehicles contact overhead wiresNo Date Type of Stakeholder


contexts, such as broken wires, fallen wires on the road, wires in contact with the vehicle, etc.Knowledge evidence: • electrical contact that does not comply with state or territory legislation. AND • low wire - wire or similar structure that has been erected or is suspended at a height that would permit contact with vehicle or load during normal collection operationsIndustry considered that this scenario should not occur as wires are suspended in accordance with minimum clearance (vertical and horizontal). Where wires were permited to contact a vehicle during normal operations it is likely that the asset owner would be in contravention of state/territory regulations. Alternatively, may be the meaning of ‘electrical contact’ is not clear enough. What does that mean? Knowledge should also include:• Cause and effect of electricity and • Step potential • Pyrolysis and tyres (including knowledge that a vehicle must not be moved if pyrolysis has occurred). Assessment conditions: ’The unit must say that assessment MUST be simulated!



Unit of competency issues: CPPWMT4001 Plan waste auditsNo Date Type of Stakeholder



Application: Great unit, excellent application. Thank you for your feedback.


Elements: Clear and easy to work with.I realise this is only the planning unit, but it would be good to have an element either addressing the results of the audit or actually conducting one. It feels like ¾ of a unit.

Thank you for your feedback.Conducting the audit is covered by CPPWMT4002.Implemented





Foundation skills: Written skills? The audit plan needs to be formalised on paper

Thank you for your feedback.‘Documenting’ the plan is already explicit in PC3.6, however there may be some implicit writing skills. Action: Recommend including under foundation skills “writing skills to: document a clear and sequenced audit plan that includes technical waste management vocabulary”.

Implemented1e 18.11.15 Robyn Addie,

TAFENSWRange of conditions: Yes – good, and quite in-depth



Assessment conditions: Computer needed, but no written skills required in foundation skills

Thank you for your feedback. Relates to issue 1d above.

1g 18.11.15 Robyn Addie, TAFENSW

Other comments: The knowledge and performance evidence seem quite detailed for the scope of the unit




Unit of competency issues: CPPWMT4002 Carry out waste auditsNo Date Type of Stakeholder



Application: Clear –suits the intended learner Thank you for your feedback.


Elements: Good. Thank you for your feedback.


Performance criteria: Good, straight forward. Thank you for your feedback.


Foundation skills: Good – no written skills. Thank you for your feedback.‘Documenting’ the plan is already explicit in PC3.6, however there may be some implicit writing skills. Action: Recommend including under foundation skills “writing skills to: document clear and sequenced audit data that includes technical waste management vocabulary”.Implemented


Range of conditions: Good. Thank you for your feedback.


Assessment conditions: Written/PC skills required, not part of foundation skills though

Thank you for your feedback. Relates to issue 1d above.



Unit of competency issues: CPPWMT4003 Evaluate waste assessment findingsNo Date Type of Stakeholder



Application: Clear. Thank you for your feedback.


Elements: Good elements, expectation of a completed waste assessment to work with2 – confusing wordingAre you trying to say you’ll conduct an analysis of the site where the waste is, or are you saying you’ll conduct an analysis of the waste from that site (or on your site)?

Thank you for your feedback.Action: PC 2.1 will be modified to clarify the intent: “Site analysis is conducted and possible causes of waste assessment findings are identified according to evaluation objectives”. The corresponding range of conditions item will also be updated.Implemented


Performance criteria: Good, 2.1 confusing wording.

Thank you for your feedback.Relates to 1b above.


Foundation skills: Good. Thank you for your feedback.


Range of conditions: Good conditions, meet the criteria well.




Unit of competency issues: CPPWMT4006 Organise waste recovery operationsNo Date Type of Stakeholder





Elements: Good elements. Thank you for your feedback.








Assessment conditions: Need some written evidence of data collection from the recovery

Thank you for your feedback.Action: Foundation skills section will be modified to: “writing skills to: document clear and sequenced data collected from the recovery”.Implemented



Unit of competency issues: CPPWMT4007 Implement waste management plansNo Date Type of Stakeholder





Elements: Good elements, but basically expects organisation to have existing plan – what happens when site is not that advanced? Will set students back, or they will have to work with hypotheticals, rather than the real thing.

Thank you for your feedback.The unit is an elective option which provides flexibility for students/sites without plans.No further action






Range of conditions: Good conditions, meet the criteria well.



Assessment requirements: Could be hard to achieve in the classroom.




Unit of competency issues: CPPWMT4022 Monitor waste disposal sitesNo Date Type of Stakeholder



Elements: Clearly defined, element 2 will be difficult to achieve unless this unit is done in conjunction with an agreeable landfill. Might be a hard one to get approval for insurance purposes unless students are working for the enterprise.

Thank you for your feedback.The unit is an elective option which provides flexibility for students/sites.No further action







Range of conditions: Good conditions, meet the criteria well



Other comments: Good unit, but I can see practical difficulties in actually applying this through an educator – it seems to be something that would work best with a large organisation with their own onsite educators, primarily to do access to required components.




Unit of competency issues: CPPWMT4027 Select and obtain waste management plant, equipment and materials

No Date Type of Stakeholder (e.g. RTO)

Issue Comment/Action


Application: Great, a good skillset to obtain Thank you for your feedback.











Assessment conditions: All conditions good. Thank you for your feedback.


Other comments: Seems like a well thought out unit




Unit of competency issues: CPPWMT4030 Plan waste management services No Date Type of Stakeholder





Elements: Good elements. Thank you for your feedback.


Performance criteria: Good, simple and straight forward.







Assessment conditions: Need some written evidence of data collection from assessment.

Thank you for your feedback.Action: Foundation skills section will be modified to: “writing skills to: document clear and sequenced service strategies that include technical waste management vocabulary”.Implemented



Unit of competency issues: CPPWMT4032 Educate clients on waste management No Date Type of Stakeholder



Application: Clear – absolutely suits the intended learner.












Other comments: Good well planned unit, great for establishing solid client relationships.


Unit of competency issues: CPPWMT4035 Undertake waste process auditsNo Date Type of Stakeholder



Application: Clear – absolutely suits the intended learner






Unit of competency issues: CPPWMT4035 Undertake waste process auditsNo Date Type of Stakeholder










Other comments: Good well planned unit. Thank you for your feedback.

Unit of competency issues: CPPWMT4037 Conduct minor maintenance and repairs on waste processing plant and equipmentNo Date Type of Stakeholder



Application: Clear – but would the lead role be maintaining equipment? It would be a labourer or mechanic.

Thank you for your feedback. Action: Application will be updated as suggested.Implemented


Elements: Elements 1 & 3 suit the intended student targetElement 2 suit the labourer as a target student









1f 18.11.15 Robyn Addie, Assessment requirements: Thank you for your feedback.P228 Issues Register Final V2 Page 38


Unit of competency issues: CPPWMT4037 Conduct minor maintenance and repairs on waste processing plant and equipmentNo Date Type of Stakeholder


TAFENSW Performance evidence: Access to these items is tricky in a classroom environment, would suit onsite training of employed students, rather than those looking for employment.Knowledge evidence: goodAssessment conditions: Need some written evidence of logs, schedules etc

Action: Foundation skills section will be modified to: “writing skills to: document maintenance and repair information in logs or schedules.”Implemented

Unit of competency issues: CPPWMT4050 Deliver training in hazard identification and waste emergency responseNo Date Type of Stakeholder



General Comment: Industry feedback received considered this unit too heavy on ‘organising training’ rather than delivering it.From EUPA staff perspective, the competency to deliver training sessions is contained in the TAE Training Package. There might be other reasons for not using this competency which would be worth understanding, however I would go to that training package for the ‘industry standard’ for delivering training sessions.

Thank you for your feedback.This has been a redesign project to align to the COAG approved revised Standards for Training Packages. Unfortunately, the issues raised are outside of the project scope, however will be listed for consideration as part of any future review of the unit or Certificate IV qualification.No further action.



Unit of competency issues: CPPWMT4060 Apply lean management techniquesNo Date Type of Stakeholder



Comment actually relates to the title of the unit:Stakeholders noted that this unit could have a clearer title such as ‘optimising waste management operations’.

Thank you for your feedback.Action: Recommend changing the title as suggested to “Optimise waste management operations” to clarify the unit outcome.Implemented

Unit of competency issues: CPPWMT5004 Develop waste management strategiesNo Date Type of Stakeholder



Application: Great unit, excellent application Thank you for your feedback.


Elements: Clear and easy to work with.Element 1 is a much needed tool in waste management and would provide more transparency between the waste enterprise and the client.






Foundation skills: Element 1 and the foundation skills are at odds with the performance criteria. They are more inclined towards providing a client with a clear legal quote for a technical job in waste management.A person in the waste sector would not need to provide a client with a waste management strategy unless they were dealing with their clients at a senior level, and usually these people

Thank you for your feedback.Action: Foundation skills for Technology skills will be changed to remove requirement to present to clients, ie: “use a computer and software to prepare waste management strategies”.

Implemented



Unit of competency issues: CPPWMT5004 Develop waste management strategiesNo Date Type of Stakeholder


would already have a degree qualification.1e 18.11.15 Robyn Addie,

TAFENSWRange of conditions: Yes. Thank you for your feedback.



Unit of competency issues: CPPWMT5031 Prepare waste management service tendersNo Date Type of Stakeholder



Performance criteria: The group also considered that changes to legislation or regulatory issues should be included as a preparatory step to developing a tender.This might be considered for inclusion in the PCs and/or performance evidence(?)

Thank you for your feedback.Action: Recommend modifying the performance evidence to add the following sub-point under “assess the viability of the tender to the organisation, with consideration of:” “changes to legislation and regulatory issues”Implemented


Application: Great unit, excellent application – again a much needed skillset in this sector.



Elements: Clear and easy to work with.The skill to read a tender response to the waste enterprise would also be very useful – understanding of all the technical and legal terms contained within these could make a big impact on employee’s confidence and business security when accepting tenders (I may be jumping the gun, have not read through all units yet).

Thank you for your feedback.New foundation skill included to cover the implicit requirement to understand technical and legal terms:“Reading skills to: understand technical and legal terms contained within tender documentation.”





Foundation skills: Yes – good cover. Thank you for your feedback.


Range of conditions: Yes. Thank you for your feedback.



Unit of competency issues: CPPWMT5033 Educate public on waste management issuesNo Date Type of Stakeholder



Comment regarding the title of the unit:Stakeholders would like to lose the word ‘issues’ from the title.Further comment:I’m not sure where you might consider including this suggestion, but waste audits are considered a key component of waste education. Perhaps this is to be included in performance evidence – knowledge?The group also noted the difference in educating groups compared to the education campaigns needed to educate the general public for events and public places.Performance criteria:Education requirements are identified from review of common public inquiries, public compliance levels and waste management trends and issues.Industry states that this is not a very effective method for determining education requirements as there is rarely adequate data from public inquiries, etc. Bin audits, surveys and community consultation is considered far more effective. The group would like to borrow language similar to that used in 4032 as follows:Education requirements are identified from research to identify waste management information requirements

Thank you for your feedback.Action Recommend: Deleting the word “issues” from the unit title Including “waste audit techniques” in the

knowledge evidence listing Modifying PC 1.1 as suggested to: “Education and

waste management information requirements are identified from research”, with research to be clarified in the Range of Conditions as follows:

“Research must include a review of at least two of the following: bin audits; common public inquiries; community consultation; public compliance levels; surveys; waste management trends and issues.”

Modifying the listing of “relevant personnel” in the Range of Conditions as recommended.

Modifying “compliance requirements” in the Range of Conditions to remove the words “education programs” as suggested, and include one additional point: “best practice guidelines for public education”

Including a new point under knowledge evidence as suggested: “best practice in waste management”.

Implemented





Range of conditions:1 Relevant personnel must include…:The group suggests adding state or territory government representatives and waste education practitioners/professionals.2 Compliance requirements must include:Commonwealth, state and territory legislation…The group have pointed out that the statement actually says the legislation relates to waste management education programs. They consider that the legislation does not relate to the education program, but to waste. Compliance to the following actually relate to education programs:• Federal and state/territory curriculum for preschool, primary, high school and tertiary institutions• Best practice guidelines• Federal, state/territory and local government strategies.Performance evidence:Prepare educational presentation on waste…Feedback provided demonstrated a preference to replace the word ‘presentation’ with ‘program’. The use of the word ‘presentation’ indicated a restriction to the type of program which might be suitable for the audience/situation.





Knowledge evidence:Candidates should be required to research best practice. This is obviously an imperative for public education. Perhaps this could be included as a bullet point under the last knowledge requirement?


Application: Unit leans towards government job, but clearly states application








Foundation skills: Yes – good cover. Thank you for your feedback.





Unit of competency issues: CPPWMT5036 Develop waste management plansNo Date Type of Stakeholder



Application: Sounds almost the same as CPPWMT5004…A strategy is not a whole lot different to a plan in a waste enterprise to client relationship – does the diploma need 2 of essentially the same thing?

Thank you for your feedback.This has been a redesign project to align to the COAG approved revised Standards for Training Packages. Unfortunately, changing the qualification structure is outside of the project scope as it would require detailed occupational analyses and stakeholder consultation process. Your feedback will be listed for consideration as part of any future review of the qualifications.

No further action1b 18.11.15 Robyn Addie,

TAFENSWElements: The elements confirm this unit leads on from CPPWMT5004, however, I don’t see the need for both units. A true waste management plan incorporates a strategy for the client, which means both units are not really required.

Thank you for your feedback.See comment against 1a above.


Performance criteria: The criteria are clear, but this unit really aims more towards an environmental consultant rather than a waste enterprise or a government body.

Thank you for your feedback.See comment against 1a above.







Unit of competency issues: CPPWMT5043 Develop and implement environmental management strategiesNo Date Type of Stakeholder



Application: Good wording and a needed tool for waste enterprises and their clients.



Elements: Very clear, a very in-depth unit. Thank you for your feedback.




Foundation skills: What about literacy? The student needs to be able to write a clear and in-depth strategy – I would think literacy is a very important component!!!.

Thank you for your feedback.The foundation skills section aims to list foundation skills which are ‘implicit’ in the performance criteria. Many literacy skills are already explicit in assessing and documenting etc.Action:Recommend including under foundation skills:“reading skills to: interpret technical information contained in process models and existing environmental management datawriting skills to: document clear and in-depth environmental strategies that include technical waste management vocabulary”.Implemented





Unit of competency issues: CPPWMT5045 Develop waste management site safety plansNo Date Type of Stakeholder



Application: Good wording and a needed tool for waste enterprises, both onsite and at client sites.



Elements: Very clear. Thank you for your feedback.








Assessment requirements: Performance evidence: goodKnowledge evidence: The person needs to understand legislative conditions WHS, rather than waste specific knowledge for a safety plan. How to read an MSDS, what requirements are there for a MHF etc….

Thank you for your feedback.Compliance requirements have been modified to relate to “work health and safety and waste management”, and to add a sub-point “requirements relating to major hazard facilities (MHFs)”Foundation skills have been modified to include a new point: “reading skills to interpret safety data sheets (SDS)”Final knowledge evidence point has been modified to: “organisational policies and procedures and regulatory and legal requirements relating to work health and safety including the hierarchy of controls and its application, and requirements relating to major hazard facilities (MHFs)”.

Implemented



Unit of competency issues: CPPWMT5057 Develop landfill rehabilitation plansNo Date Type of Stakeholder



Application: Important for higher level waste management – at the strategic level. Generally, this type of thing would be conducted by an engineer.



Prerequisite units: Horticulture?? Thank you for your feedback. CPSISC policy discourages the use of prerequisite requirements within units of competency because it limits flexibility and accessibility. Well-designed qualifications articulate the skills and knowledge pathways through each AQF level.No further action


Elements: very clearElement 1 is a very big concept.Landfill rehab plans take a good 6-12 months to undertake between a team, not by one individual. I worry this unit is overreaching. There are landfills in dire need of rehab across Australia, however these are investigated by environmental consultants and then their directions provided to councils and waste management enterprises.

Thank you for your feedback. The unit has been modified to require the learner to work as part of a team to develop one landfill rehabilitation plan. Horticultural methods have been included in the knowledge evidence.No further action








Assessment requirements: Performance evidence: very large

Thank you for your feedback.See comments against 1c above.



Unit of competency issues: CPPWMT5057 Develop landfill rehabilitation plansNo Date Type of Stakeholder


Knowledge evidence: very broad – when are they being taught about horticulture? It isn’t listed as a prerequisite for the unit.Assessment conditions: good.

Unit of competency issues: CPPWMT5058 Develop waste management emergency response plansNo Date Type of Stakeholder



Application: Great unit – good application. Again – level being aimed at. A head teacher advised that he had done 4 emergency response plans for waste management enterprise and each one was done at a management level, by degree qualified chemists and engineers. However, these skills are not taught specifically at university (other than in focussed degrees), so it is a unique niche skillset.



Elements: Very clearReally good elements, great unit for a technical officer.



Performance criteria: Good.Love the hands on training aspect






1f 18.11.15 Robyn Addie, Assessment requirements: Thank you for your feedback.P228 Issues Register Final V2 Page 50


Unit of competency issues: CPPWMT5058 Develop waste management emergency response plansNo Date Type of Stakeholder


TAFENSW Knowledge evidence: Hazchem is important, but you also need to have the MSDS for chemicals/wastes that are stored onsite. There appears to be no mention of MSDS.Assessment conditions: good.

Reading skills have been included in the foundation skills section to require “reading skills to interpret safety data sheets (SDS) for chemicals and wastes stored onsite as part of safety audit.”

Unit of competency issues: CPPWMT5061 Plan resource recovery operationsNo Date Type of Stakeholder



Application: Not sure how the application suits the market. Unclear who this unit is aiming at.Resource recovery occurs at the MRF plant, and at the client site, it also occurs during the processing of wastes collected by the waste enterprise – it doesn’t require a detailed strategy unless it’s for a council or very large organisation. If you spent hours making a recovery strategy for each job you did, you’d be out of business pretty soon due to massive cost blow-outs on wages preparing said strategies.

Thank you for your feedback.This has been a redesign project to align to the COAG approved revised Standards for Training Packages. Unfortunately, changing the qualification structure is outside of the project scope as it would require detailed occupational analyses and stakeholder consultation process. Your feedback will be listed for consideration as part of any future review of the qualifications.No further action


Elements: Very clearI feel now you’re aiming at a government organisation, or a MRF? Maybe a big clean-up of a defunct site? Certainly not something that is commonly required in the everyday function of a waste enterprise.

Thank you for your feedback.See comments against 1a above.

1c 18.11.15 Robyn Addie, Performance criteria: Clear. Thank you for your feedback.



Unit of competency issues: CPPWMT5061 Plan resource recovery operationsNo Date Type of Stakeholder


TAFENSW1d 18.11.15 Robyn Addie,

TAFENSWFoundation skills: Clear. Thank you for your feedback.




Assessment conditions: Good. Thank you for your feedback.


Other comments: This unit seems quite involved for a 6 month delivery.



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