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Sleep, transitions and transportation safety – have your say on the NQF Consultation Regulation Impact Statement pt 3

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CELA has analysed the National Quality Framework Consultation Regulation Impact Statement (CRIS) which covers a wide range of areas for improvement on which your opinion is sought.

We are specifically seeking your feedback on three key areas, which are being covered in a series of Amplify articles.

In this, our final article of the series, we highlight key issues related to safety, health and wellbeing which are being addressed in the CRIS, and ask key questions on which we would welcome your feedback. The key areas covered are transition between services, sleep, transport and multi storey buildings.

By Megan O’Connell, CELA Research and Policy Manager


The review of the National Quality Framework is a significant milestone in the quality journey for early childhood education and care.

The review commenced with an issues paper in 2019, but was placed on hold due to COVID-19. A Consultation Regulation Impact Statement (CRIS) has been released, which contains a wide range of issues on which your opinion is sought by the end of April.

Why your opinion is vital

Now is the time to ensure our sector is well placed to deliver on the vision contained in the NQF of continuous improvement in the provision of quality education and care, and improving outcomes for children.

In this Amplify we highlight some of the key issues related to general child safety, health and wellbeing which are being addressed in the NQF CRIS, and ask key questions on which we welcome your feedback. The key areas covered are transition between services, sleep, transport and multi storey buildings.

If you have something to say, please click on our survey link at the end of the article. You can answer as many or as few questions as you like. You are also welcome to complete the CRIS survey or provide a submission yourself.

Area 1: Safety of children during transitions between services

Many children go missing each year transitioning between services, particularly in school and out of school hours care. Options for change that have been examined include legislative requirements to require either schools or services to supervise, national regulations and/or guidance.

CELA believes that an element of flexibility is needed given the different arrangements and structures of OOSH. Legislating for schools or ECEC to be legally responsible is difficult given the myriad of circumstances. We believe that regulations and guidance, including formal transition arrangements, would support services to develop policies and procedures to suit their local context.

Consideration needs to be given to requiring transition agreements to support children who transition between services, to ensure that responsibilities of parents, service providers and schools are clear.

Key questions you can answer in the survey at the end of the article which relate to this topic include:

  • What measures do you currently use to mitigate the risk of children going missing?
  • Are missing children a significant risk in your service?
  • How would you respond if the duty of care for children transitioning between services was made a legislative responsibility of ECEC?

Area 2: Sleep and rest requirements

Although Approved Providers must ensure that the service has in place policies and procedures in relation to health and safety, there have been 7 sleep related deaths in early childhood education and care since 2011 and a recent study shows most services breach sleep guidelines at times. This may place children at a higher risk of SIDS. Options for change range from training, guidance, policies and procedures and risk assessments to legislative change to require that sleeping and resting children in education and care services are within sight and hearing distance of an educator at all times.

CELA notes the significant risk of children being harmed through unsafe sleep practices, and is concerned at the high level of non-compliance with safe sleep practices. Given this, CELA believes a wide range of measures should be introduced to ensure children are protected including specifying when checks need to be in person rather than using technology.

 We are seeking feedback to understand whether all options have been explored, and to ensure measures implemented best reduce the risk of harm.

Key questions you can answer in the survey at the end of the article which relate to this topic include:

  • What practical measures would support you to ensure the safety of children during sleep and rest?
  • Would it be feasible for you to have an educator supervising sleeping children at all times?

Area 3: Improving children’s safety during regular transportation

There is a heightened risk of harm to children during transportation. This risk is both during transportation and the period of embarkation/disembarkation. New regulations have been implemented requiring a risk assessment for services transporting children and written authorisations. It is currently unclear how centre based educator ratios should apply during transportation. Options for change include introducing ratios requirements for travel (and potentially excluding school aged children from these requirements), introducing a ratio for embarkation and disembarkation, legislative requirements for drivers to undertake training such as first and or guidance and risk assessments regarding transport.

CELA notes the proposals for change are aimed at addressing the serious risk to children, both during and after transportation. CELA believes that duty for care of children must be prioritised, including ensuring children travelling independently do not go missing, whilst noting the importance of transport in supporting children in rural and regional areas to attend services.

We welcome feedback from members who transport children regularly.

Key questions you can answer in the survey at the end of the article which relate to this topic include:

  • What additional training should the driver of a vehicle have (such as first aid, anaphylaxis, asthma management etc)?
  • Should ratios be applied to transport?
  • If ratios are applied, should the driver should be included in ratio calculations?
  • If adults are supervising transport, should they hold qualifications?

Area 4: Improving children’s safety during emergency evacuations from multi storey buildings

Although a minority of services are in a multi storey building, they pose a significant evacuation risk. Around 13% of all confirmed breaches of the National Regulations relate to emergency and evacuation procedures so the likelihood of harm arising is significant. There are added complexities in Victoria and the ACT, whereby buildings can meet planning approval but not service approval due to evacuation procedures, natural light and outdoor spaces. Options relate to amending emergency and evacuation requirements to expert oversight of evacuation drills, pre-approval of services, and strengthened building approvals.

CELA notes the proposals for change may have significant cost and time implications on services, both in the planning process and in an ongoing manner. However, the risks associated with evacuating in particular non-ambulatory children are significant and the expertise around evacuating a multi-storey building is likely to be found outside of a service.

We welcome feedback from services in a multi storey building.

Key questions you can answer in the survey at the end of the article which relate to this topic include:

  • Do you believe further guidance in the NQF on the nature and content of emergency and evacuation procedures would assist you to better meet the national regulations?
  • What other suggestions do you have regarding evacuations and emergency procedures?

 

Have your say via this survey link


Child safety: Have your say on the NQF Consultation Regulation Impact Statement pt 2

In last week’s Amplify we covered the topic of Child Safety. If you haven’t had a chance to review and share your opinion yet, we invite you to read last week’s article and share your thoughts.

 

Share your views on Child Safety

Workforce: Have your say on the NQF Consultation Regulation Impact Statement Pt 1

A couple of weeks ago we covered the topic of Workforce. If you haven’t had a chance to review and share your opinion yet, we invite you to read the Workforce article and share your thoughts.

 

Share your views on WorkForce
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