Competency (Training & Verification)
Competency is the demonstrated ability to apply knowledge and skills to perform a task safely and effectively in a specific work environment. It goes beyond simply holding a qualification—it requires your workers to prove they can do the job now, under your site's specific conditions.
What is Competency?
You might assume that if a worker holds a High Risk Work Licence or a trade certificate, they are "competent." In the eyes of the law, this is often insufficient. Competency is a dynamic state—it is the combination of skills, knowledge, experience, and attitude applied to a task.
While a qualification (like a White Card or Forklift Licence) proves a worker met a national standard at a specific point in time, competency confirms they can safely operate today. This distinction is critical because skills decay over time, and site conditions vary.
A worker competent in a warehouse may not be competent in a mine or on a complex construction site, despite holding the same licence. Your legal obligation under the PCBU duty of care requires you to ensure workers are competent for your specific workplace.
How it works: Key components
Effective competency management involves three distinct phases to ensure your workforce remains compliant and safe:
1. Acquisition (Training)
The worker learns the skill through formal instruction (e.g., a course with a Registered Training Organisation) or structured on-the-job mentoring. This provides the baseline qualification.
Training alone doesn't guarantee competency—it's simply the foundation. A worker who completes a forklift course knows the theory, but may not be ready for the tight spaces, uneven surfaces, or specific machinery in your facility.
2. Assessment
Evidence is gathered to prove the worker meets the standard. This evidence must align with the Rules of Evidence set by the Australian Skills Quality Authority (ASQA): it must be Valid (relevant to the task), Sufficient (enough to prove skill), Authentic (the worker's own work), and Current (recent).
Assessment isn't just watching someone perform a task once. You need evidence that demonstrates consistent competency across the range of conditions they'll face in your workplace.
3. Verification (VoC)
This is a periodic "health check" of skills. Verification of Competency (VoC) does not necessarily involve re-training but confirms that skills have been retained and can be applied to your specific plant and equipment.
A valid VoC process is not just a "letter from the boss." It typically involves:
- Evidence Review: Checking licences, logbooks, and training records
- Theory Check: Verifying knowledge of critical safety controls, site rules, and machine limits
- Practical Observation: Watching the worker perform the task in your workplace to ensure they operate safely
- Outcome: Determining if the worker is Competent, Conditionally Competent (requires supervision/gap training), or Not Yet Competent (requires full retraining)
The VoC bridges the gap between what a licence says someone could do years ago and what they can safely do today on your equipment.
Automate compliance tracking, expiry alerts, and evidence management for your entire workforce.
Why it matters
Legal Compliance
Your organisation has a primary duty of care under Section 19 of the Work Health and Safety Act 2011 (or Section 21 of the Victorian OHS Act 2004) to provide the "information, training, instruction or supervision" necessary to protect persons from risk.
Courts have ruled that relying solely on a licence does not discharge this duty if you "ought reasonably to know" a worker lacks current skills. For example, the Dreamworld inquest highlighted that a failure to verify staff competency in emergency procedures—specifically how to shut down a ride during a pump failure—contributed to a systemic failure. The training was deemed a formality rather than a genuine verification of capability.
Due Diligence
Officers (Directors and Executives) have a personal duty to exercise due diligence. This includes verifying that your organisation has a system to check that workers are actually competent, not just certified.
A robust VoC system provides the evidence needed to demonstrate you have taken "reasonably practicable" steps to ensure safety. Without this, officers can be personally liable for workplace incidents.
Business Value
Beyond compliance, competent workers are more efficient and cause less damage to plant and equipment. A verified workforce reduces the likelihood of incidents that lead to downtime, legal costs, and reputational damage.
Competency verification also supports your Safety Management System by ensuring that the controls documented in your Safe Work Method Statements and Permits to Work are executed by people who actually know what they're doing.
Common challenges
"Tick and Flick" Compliance
This is the most significant failure mode. It occurs when training is treated as a paperwork exercise—getting a signature on a register without ensuring the worker truly understood the instruction.
The Fair Work Commission has reinstated dismissed workers because employers could not prove that training was "meaningful" rather than just administrative. If you can't demonstrate genuine competency assessment, you expose yourself to both safety and employment law risks.
Skill Decay
Skills fade without practice. Research indicates that complex cognitive skills (like emergency response) decay significantly faster than routine motor skills.
A High Risk Work Licence is valid for five years, which does not account for this decay. A worker inactive for two years may be unsafe despite holding a valid card. Your VoC process needs to account for time away from the task, not just the expiry date on the licence.
The "Licensed but Incompetent" Gap
In Australia, many licences can be renewed without re-testing. A worker can legally hold a crane or forklift licence for 20 years without having operated the machinery for most of that time.
Relying on the licence alone leaves your organisation exposed to the risk of this "competency gap." You need verification processes that prove current capability, not historical achievement.
Assessor Competence
A common pitfall is having a supervisor sign off on competency when they themselves are not qualified to assess. The Office of the Federal Safety Commissioner (OFSC) explicitly states that a letter signed by a supervisor is not sufficient evidence of competence unless that supervisor meets documented competency requirements to conduct assessments.
If your assessors don't know what "safe" looks like, they can't verify it. This creates a false sense of security and exposes you to regulatory scrutiny.
Best practices
Define the Standard
Don't just ask for "a licence." Create a Training Matrix that clearly defines the specific qualification and the verification method required for each role. Ensure this aligns with relevant Codes of Practice and the specific risks in your workplace.
Your Training Matrix should specify not just what qualifications are required, but also what site-specific inductions, equipment familiarisation, and emergency procedures must be verified.
Implement Risk-Based VoC
You do not need to conduct a formal VoC for every task. Focus your resources on high-risk activities (e.g., mobile plant, electrical work, working at heights).
The OFSC mandates VoC for mobile plant operators on federally funded construction projects. Use a risk-based approach to determine which roles require formal verification and how frequently it should occur.
| Risk Level | Examples | Verification Frequency |
|---|---|---|
| High Risk | Mobile plant, cranes, working at heights, electrical work, confined spaces | 2-3 years, or after extended absence (6+ months) |
| Medium Risk | Hand tools, light machinery, manual handling | 3-5 years, or when new equipment introduced |
| Lower Risk | General induction, office equipment | When significant changes occur or after incidents |
Use Subject Matter Experts (SMEs)
Ensure your assessors are competent. Ideally, they should hold the TAE40122 Certificate IV in Training and Assessment or be verified Subject Matter Experts with significant industry experience.
Your assessors must know what "safe" looks like to assess it effectively. This means they need both technical competence in the task and assessment skills to evaluate performance objectively.
Drill for Emergencies
Competency assessments should not just check "sunny day" operations. You must assess how the worker reacts to abnormal situations, such as a stall, a breakdown, or an emergency stop.
This ensures they can handle the pressure when things go wrong. The Dreamworld tragedy showed that workers who could operate equipment normally failed under emergency conditions because they hadn't been assessed on emergency procedures.
Keep Robust Records
"If it isn't written down, it didn't happen." Maintain signed assessment tools, logbooks, and gap training records. Ensure your evidence is valid, sufficient, authentic, and current to withstand regulatory scrutiny.
Your records should show not just that training occurred, but what was assessed, who conducted the assessment, what the outcome was, and what gaps were identified and addressed.
Automated alerts ensure your team stays current with certifications, VoCs, and training requirements.
Frequently Asked Questions
My worker has a current High Risk Work Licence. Do I still need to verify their competency?
Yes. A licence proves they met a national standard in the past, but not that they are competent now or on your specific machine. Under WHS laws, you must ensure they are safe to work in your specific environment. A VoC bridges this gap between historical qualification and current capability.
How often should we conduct Verification of Competency (VoC)?
There is no fixed legislative timeframe, but best practice is typically every 2 to 5 years, or whenever a worker returns from a long break (e.g., 2 years), is involved in an incident, or when new equipment is introduced. Use a risk-based approach to determine the right frequency for your operations.
Can a supervisor conduct a VoC?
Only if they are competent to do so. They must have the technical skills to operate the equipment and the ability to assess performance objectively. Ideally, they should hold an assessor qualification or be a recognised Subject Matter Expert defined by your company's standards.
References and Further Reading
Safe Work Australia: Model WHS Laws - The legislative framework establishing the primary duty of care and requirements for information, training, instruction, and supervision.
WorkSafe Victoria: Occupational Health and Safety Act 2004 - Victorian legislation outlining employer duties regarding worker competency.
ASQA: Rules of Evidence - The Australian Skills Quality Authority's standards for Valid, Sufficient, Authentic, and Current evidence in competency assessment.
Office of the Federal Safety Commissioner: Fact Sheet - Verification of Competency – Mobile Plant - Detailed guidance on VoC requirements for mobile plant operators on federally funded projects.
NSW Resources Regulator: Operating Mobile Plant - Verification of Competency - Practical guidance on implementing VoC processes for mobile plant operations.
ASQA Practice Guide: Assessment - Comprehensive guidance on conducting valid competency assessments aligned with national standards.
The Dreamworld tragedy: the Coroner's findings, the prosecution and lessons learnt - Case study examining how inadequate competency verification in emergency procedures contributed to a preventable tragedy.
Unfair Dismissal Case Highlights the Cost of Inadequate Workplace Training - MST Lawyers - Legal analysis of cases where "tick and flick" training was deemed insufficient by the Fair Work Commission.
Factors Influencing Attenuating Skill Decay in High-Risk Industries: A Scoping Review - Research examining how skills decay over time, particularly for complex cognitive tasks like emergency response.
Certifications vs. Competency: A Guide to Understanding the Difference - AlertForce - Industry perspective on the distinction between holding qualifications and being genuinely competent.