“Network supports the introduction of regulation to the sector but we are aware that for many services this is not the case. OOSH services have been overwhelmed with change since 1997 as a result of changes implemented by the federal government. Many services are exhausted and morale is low, we therefore urge the Government to proceed with caution, taking the implementation of regulation in slow manageable stages."
Extract form letter to Minister for Community Services, Reba Meagher 25.9.06.
In May 2006 the Minister for Community Services announced the introduction of regulations into Out of School Hours Services with plans to commence consultation by late 2006.
Network of Community Activities as the peak body for the OOSH Sector in NSW has met with both the Minister for Community Services and the project reference groups to ensure that they are adequately briefed on the unique needs of the OOSH sector.
The introduction of regulations will be a challenging and exciting time for services. It is envisaged in early talks that the legislation will NOT be an extension of the Long Day Care regulations. It is also planned that the regulations will very much resemble the National Standards and NOT be based on an onerous amount of paperwork and red tape. Regulations will form the baseline from which all services will be required to operate. For the safety and security of all children and to ensure that viable and quality services are not undermined by unscrupulous “cash in hand” backyard operators regulation IS essential
Action To Date
In August 2006 the Network OOSH Reference group, made of regional OOSH representatives, met to discuss the possible impact of regulations. In reviewing the National Standards it was found that many services would be minimally impacted if they had successfully completed the OSHCQA process. The areas posing the most concerns were venues and qualifications. With over 70% of Co-ordinators in NSW currently qualified the majority of services will find that venues are the area of most impact and requirements for them will need to be modified. However, for some services they will finally be able to give a solid justification for being given buildings that meet a satisfactory standard, not just a building that no one wants!
A meeting of the Network OOSH Reference group was held on Wednesday 29 November and DOCS representatives met with regional representatives from the sector to brief them on the work of the project to date and accept the feedback from the representatives on the nature and scope of regulations.
In November the Department of Community Services released a discussion paper and draft legislation that reqiures all services to register. 19 submissions were received in regards to this legislation with only one dissenting voice among them. The legislation was subsequently passed and services will now be required to register.
Network negotiated in March for a working group of practitioners to review the registrations forms for the regulations and provide feedback. These forms are due for release in the coming weeks and services will have until July 1 to register. Jenny Gratton (SHARE, Summer Hill), Sue Kemp (SPLASH, Ashbury) and Wendy Castelao (Abbotsford Community Centre) kindly donated their time to participating in a feedback meeting at DOCS Ashfield. This consultation will assist to ensure that the forms going to the services are ‘user friendly’ and their input did result in a simplification of the paperwork services will be required to complete in the initial stage.
- We would anticipate in stage 2 that the regulations would be based on the work already undertaken around Quality Assurance, National Standards and the document not mentioned in the Regulatrory Imapct statement – the NSW Voluntary Code of Practice.
- In considering these three documents it would be wise for the Department to liase with the Commonwealth Government in it’s review of the Quality Assurance system to reduce duplication and to minimise confusion between the processes.
- A review of National standards by Network’s OOSH Reference Group in August 2006 showed that services would have major difficulty implementing the space requirements as given in the National Standards. Access to toilets and kitchen areas was also potentially problematic for some services.
- The requirement for qualifications would need to be a staged process and the review of the required qualifications completed to ensure they are the most up to date available.
- It is reasonable to expect that based on the experience of our colleagues in Queensland, and Western Australia funding would be available to assist services to meet the requirements.
- Network would support and argue strongly for a full and extended consultation process around the details of the regulation in the second phase. In order for an effective system the OSHC sector must feel ownership of the process and so this consultation should be provided in a variety of ways and be sensitive to the hours and work practices of services to ensure maximum consultation.
- All OOSH Services will be required to register their service with Department of Community Services by July 1 2007. When registering services will be required to complete a survey of the current operating standards they are using. This survey is very important – it will help shape the future of our regulations as it provides a an accurate record of what the current baseline is for service provision. By doing this the reality of what regulations can be implemented and what will cause difficulty for services will be highlighted.
- Network will continue to Liaise with the Dept over the implementation of regulations. We are currently working with the DOCS Regulation implementation team to deliver a seminar on the regs for the Friday afternoon of the conference. If successful we hope to repeat these seminars in metropolitan and major regional areas across NSW. A proposal has been put to DOCS for Network to conduct regulation registration information sessions. We are currently awaiting a response.
- Department of Community Services will commence consultation with the sector in July 2007 during which time services can look at the proposed detail of the regulation and comment on the appropriateness of it for the OOSH sector. Once again Network will provide sessions across NSW to discuss the regulations and assist services to formulate their own responses.
- Following consultation it is anticipate that regulations will come into place in 2008 with a phase in period of one to several years for any challenging aspects identified in your initial survey responses and through the consultation process.
Network of Community Activities will be posting regular updates on the regulations on it’s website www.netoosh.org.au throughout 2007.
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