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Sheila Marsh,
Consultant, OPUS Training and Design


Len Holmes, Senior Lecturer, The Business School, Polytechnic of North London (at time of presentation)

Presented at conference 'A Qualified Success? Critical Perspectives on Competence Based Education and Training', held at Polytechnic of North London, 27 September 1990


The Training and Development Lead Body (TDLB) has recently published for consultation a set of documents setting out its framework of occupational 'standards' for training and development occupations. According to the TDLB's timetable, the finalised framework will be published early in 1991, and new qualifications will be based on this framework of standards. In this paper we will subject the TDLB's 'Training and Development Standards' to critical examination, identifying what we believe to be serious flaws. Moreover, we shall take the TDLB's work as a case study of the wider national programme ('Standards Programme'). This was initiated by the Manpower Services Commission (MSC) to develop such a framework for all occupations and facilitate the development of new national vocational qualifications (NVQs) for all sectors of industry.

In this paper we examine critically this work, taking it as a case study of the broader programme of work currently being undertaken by the Training Agency and NCVQ, and of the wider debate on the 'competence' approach to vocational education and training (see figure 1). Because of the central role of trainers in the delivery of the vocational education and training required to link with the NVQs system being established, the development of occupational standards for trainers may be seen as an exemplar for the overall programme. So, by examining this particular area we hope to draw out some major problems we perceive in the overall programme, as well as specific flaws in the 'standards in training and development'. We shall proceed by first examining the TDLB Standards in terms of their face validity, ie the extent to which they match the claims made by TDLB, the Training Agency, and NCVQ. We shall then examine the Standards in more depth, by considering the extent to which the perspective on the nature of training and development work, and the nature of competence in such work, is adequately and accurately 'captured' by the TDLB Standards. This will provide an opportunity to examine the assumptions about human work performance and competence in general on which the Standards Programme is based. Finally, we shall examine the context in which this particular public policy initiative has been developed.


There has been considerable critical examination of competence based approaches to vocational education and training, mainly in the US. However, it is important to be clear about the particular features of the current UK initiative rather than attempt merely to apply general criticisms about competence approaches. The Standards Programme forms part of the government sponsored 'reform' of vocational qualifications, set in motion by the 1986 White Paper, 'Working Together Education and Training'. In that White Paper the Government announced its intention to establish the National Council for Vocational Qualifications (NCVQ). In future, only those qualifications which receive the endorsement of NCVQ will be recognised as 'national vocational qualifications' (NVQs). Such qualifications will be based on 'standards of occupational competence', to be determined by industry training organisations. The MSC (now the Training Agency) was required by the Government "to take the lead in stimulating" such industry training organisations to develop such standards.

The emphasis on 'competence' has been a key feature of MSC, and now Training Agency (TA), policy since the publication of the New Training Initiative in 1981. It is defined by the TA as
"the ability perform the activities within an occupation."
The notion of competence is contrasted with what is presented as (mere) knowledge.
"That is the role of the vocational qualifications system which must test and record not just knowledge and understanding but also skills and competence in applying such knowledge." (DE, 1986, p.16)
Overall competence in a particular occupational area is deemed to be capable of being 'operationalised' by
"... deriving a set of individual elements of competence and their associated performance criteria." (MSC, 1988, p1.)
Elements of competence will be grouped together into units of competence which
"... make sense to, and are valued by employers so that they warrant separate accreditation." (ibid)
A National Vocational Qualification (NVQ), constituting a statement of occupational competence, will be made up of a number of related units. Thus overall competence in an occupation will be subject to a process of disaggregation into units and elements of competence (see figure 2).

The Training Agency has decided that one particular method will be used to 'disaggregate' overall competence, functional analysis. Functional analysis involves identifying or defining the key purpose or function of an occupation, then sub dividing or disaggregating the key purpose/function to establish the purposes or outcomes which must be met for the key purpose to be achieved. So an inverse tree like structure is obtained, matching the framework of NVQ competence statement, units, and elements of competence applied by NCVQ. Rules for disaggregation have been developed, so that the technique appears to be an objective, systematic method for analysing the work which is required for competent performance.

The notion of competence is translated into the notion of 'standards', a standard being an element plus the performance criteria. The Standards Programme has diligently attempted to avoid being caught up in a debate about the nature of competence.
"A competence is a description of something which a person who works in agiven occupational area should be able to do. It is a description of of an action, behaviour or outcome which a person should be able to demonstrate." (Training Agency, 1988, p5)

"While an individual may be deemed 'competent', 'occupational competence' relates to the functions associated with an occupation. Standards of competence are used to describe characteristics of the function(s) and so are independent of the individual." (Stuart, 1989, p.11, empphasis added)

Competence is to be attributed to an individual on the basis of assessment evidence. This assessment is to be concerned solely with whether an individual can undertake what is required by the element of competence, to the standard specified by the performance criteria. So performance evidence take precedence over any other form of assessment. "As competence is the ability to perform to the standards expected in employment, peformance evidence must be the prime candidate for consideration, with assessment in the ongoing course of work the one that is most likely to offer highest validity." (Mitchell, 1989)
Such performance evidence has to be obtained over a number of occasions, and in a number of situations:
"We do not want to attribute competence until we can be confident that they [candidates for assessment] will be able to perfrm to standard consistently, or across the requred range of situations. So before attributing competence we normally need evidence of repeated demonstrations to standard ..." (TA, 1989, p5)

So the overall public policy of developing a new qualifications system based on defined standards of competence is being implemented by the application of a specific method, functional analysis, which transforms the notion of 'competence' into one of assessed performance. The terms 'occupational competence', 'standards of competence' and 'standards of performance' are used interchangeably. Competence based vocational education and training thus becomes equated with performance based assessment.

Major claims are made about this initiative, particularly in respect of its ability to bring about improvements in economic performance and individual job satisfaction. The framework of standards are claimed to be clearly understandable by employers and employees. Amongst the list of uses claimed for standards is that of raising the quality of occupational training. In the case of the TDLB Standards, a claim is made that these reflect 'best practice'.


"Trainers have a critical role in helping people to achieve standards. It's only appropriate, therefore, that their performance and practice should also be led by nationally agreed and employment led standards." (Training and Development Standards: Guidance Notes; TDLB, 1990)

We believe this claim to legitimacy by TDLB is valid insofar as the fact that training (and vocational education) practitioners have a pivotal role in the implementation of any attempted national vocational education and training system. The knowledge, understanding and skills they develop, the meaning they attach to the nature of their work, the assumptions they have about their (legitimate) role in an organisation, all have an acute bearing on the quality of their work performance, and so on training as a whole. Any approaches to the development, assessment and certification of trainers must therefore take this into account.

It is clear that the TDLB, with Training Agency guidance, has treated the development of standards for the occupation of training and development as an exemplar for the development of standards in other occupations. The TDLB has diligently stayed with the view that functional analysis alone will be able to provide the basis for examining competence. This insistence on functional analysis alone has been described as 'fundamentalism', and there has been at least one resignation from the TDLB as a result. However, it is understandable, for unless the claim can be maintained that functional analysis alone is sufficient and valid for this occupational area, it would be difficult to maintain it for other occupational areas. Training and Development Standards thus become an exemplar for standards in other occupations.

However, we do not believe that it follows from a perceived need to enhance the competence of training practitioners that there is a requirement for 'nationally agreed' standards (of performance). Nor do we believe that the approach adopted for determining the nature of competence in other occupational areas may be adopted uncritically in determining the nature of competence in the occupation of training and development. Moreover, the emphasis by the Standards Programme on the separation of standards of performance from the learning processes by which competence is achieved is, in our view, unsustainable in the area of training and development. We will argue that
there cannot, and indeed should not, be a single set of 'standards' for training;
the application of functional analysis as the sole method for examining competence is flawed in respect of training;
process as well as outcome is an essential element in any valid approach to the development of trainer competence.

Because the TDLB has perceived the nature of the occupation of training and development to be essentially no different in character from other occupations, the TDLB Standards provide a useful starting point for a critical examination of the Standards Programme. So, rather than TDLB Standards being the exemplar for others, the critique of the Standards is the exemplar for the critique of other standards.


In developing our critique of the TDLB Standards we shall start with a consideration of their face value, before we move onto a more in depth analysis. An in depth analysis will tend, by its very nature, to be theoretically based. As such it is likely to be treated to cursory dismissal by the proponents of the Standards, who would emphasise the 'practical' nature of the Standards, based on the views of 'practical' people actually involved with the work of training and development, ie as practitioners and as employers as practitioners.
"The Training Agency has set up a nationwide initiative to establish clear occupational standards .... and to change the qualifications and training systems so that they are clearly based on what industry needs, rather than what educationalists and trainer assume we need....
It's not just an academic exercise it's extremely practical and worthwhile." (Training Agency:SFS, 1989, p2).
The language used in the booklet from which this quotation is taken (which accompanies a video on the Standards Programme) shows how the Training Agency attempts to equate educationalists and trainers' with 'academic exercises', making assumptions. Whereas 'we' are more concerned with what is 'practical and worthwhile'. In a similar fashion, the TDLB states that
"For many years we have been concerned about the quality of performance of our workforce. Employers have frequently voiced their disappointment in the ability of the young people coming out of vocational education and training to perform in a job." (TDLB:CD, 1990, p.1)
The 'commonsense', 'practical', 'worthwhile' nature of the Standards Programme, as claimed by its proponents, presents a major obstacle to the presentation of an in depth critique.

However, we believe that the TDLB Standards are, in fact, open to immediate criticism in terms of the claims to validity presented by the TDLB. The consultation on the draft standards has been undertaken over the summer, and was due for completion in September. A series of questions were posed by the TDLB, under six headings:
1. Are the Standards clear?
2. How would you use the Standards?
3. Are the Standards comprehensive?
4. Are the Performance Criteria accurate?
5. How do they relate to other Standards?
6. Are the Standards strategic?
Clearly, these questions provide an indication of the face validity criteria set by the TDLB, and the consultation process is intended to generate feedback to enable the TDLB to improve the draft Standards so that they meet these criteria more completely. Moreover, the publication of draft Standards indicates that the TDLB believes that these criteria have, to a significant degree, been met. They therefore set the basis for an immediate examination of the face validity of the Standards. We shall here consider the first four, ie clarity, usefulness, comprehensiveness and accuracy.


In order for the standards to be meaningful to their intended users, the language must be easily accessible. However, the initial impression one gets from the language used is of its overwhelming obscurity. The very first performance criterion, for the very first element (A.1.1.1) reads
"proposals to key policy makers contain complete, clear and accurate information which identifies the relevant features and characteristics of reactive and proactive training and development inputs which are potentially applicable to the organisation."
The double subordinate clause ("... which identifies...", "...which are potentially...") make it difficult to see what exactly are the measures of competent performance. The desire to be all inclusive yet unequivocal seems to have led the TDLB to construct sentences of gothic complexity, eg element C.1.2.3 :
"Negotiate contracts for the supply of learning resources which meet quality, delivery, and cost specifications and training and development requirements."

Morever, the TDLB have faced the problem of non standardisation of terminology in the training field, which arises in part because of differences in approach in the field. Some terms, such as 'stakeholder', have very little common use. At times the term 'stakeholder' and 'client' seem to have similar meaning, yet no indication is made of significant differences. Terms such as 'strategy' seem to be used in different ways. Thus unit A.1.4 refers to the 'strategic direction' of the training and development function, while B.2.2 refers to the design of a programme to 'deliver an agreed learning strategy'. Indeed the term 'learning' is used in a highly questionable manner, often being a substitute for 'training', eg B2.1 "Identify and agree learning strategies that meet client requirements". From the context it is clear that what is being referred to in unit B.2.1 is the plan which will be adopted to attempt to bring about some specified learning. But this is not in itself a 'learning strategy' since neither the training practitioner nor anyone else but the learner her/himself can agree and implement a 'learning strategy'. (This assumes that learning strategies can be made explicit, rather than that the term is a construct referring to what is assumed to be taking place when learning occurs.)

The overall effect of such cumbersome, non standard wording, often ambiguous or multiple meaning, is to render the Standards user UNfriendly. One of the key criteria for acceptance of the Standards is thereby unmet, reducing the face validity of the Standards.


In order for the Standards to be useful (to practitioners and their employers), they would need to reflect accurately the nature of training and development practice. The basis of disaggregation must be coherent with the distinctions which actually occur. The initial disaggregation for the TDLB Standards is on the basis of the 'training cycle', a concept which has widespread acceptance within the training field. There are various ways in which the training cycle is presented, but the TDLB has a four stage model:
identify training and development needs;
design and update training and development strategies, plans and systems;
provide learning opportunities, resources and support;
evaluate the effectiveness of HRD (human resource development) strategies, plans and systems.
This four stage model was then used to four separate functional areas (coded A, B, C, D) each of which was then disaggregated further. However, this four stage model proved to be insufficient, the TDLB introduced a fifth area (E),
establish and maintain effective communications and feedback systems.

Now despite the widespread acceptance of the concept of the training cycle, the implicit assertion that it provides a useful basis for analysing the competence required by training practitioners is by no means self evident. Indeed, the usefuness of the concept of the training cycle has itself been questioned recently (Donnelly, 1985). Research on the actual work of training practitioners indicates that they are less concerned with the following of such a sequential cycle of activities, and more concerned with obtaining and maintaining legitimacy within their particular organisational setting (Megginson,1973; Pettigrew et al, 1982). Indeed, this very issue was raised by the MSC's Training of Trainers Committee (MSC, 1978), and in the report 'A Challenge to Complacency' (Coopers and Lybrand, 1985). There is implicit recognition of this area in the TDLB Standards, with eleven units using the word 'negotiate'. However, the notion of negotiate used gives little recognition to its dynamic, equivocal and essentially interpersonal nature. Although the TDLB Standards were tested out by reference to self reports of training practitioners, no direct observation of training jobs was carried out.
The problem this raises is that, being divorced from the real nature of training practice in an organisational setting, the TDLB Standards provide, at best, little useful guidance in enabling training practitioners, and trainers of trainers, to develop the competence actually required. Indeed, we believe that by its focus on the aspects of the formal, ideal model of the training cycle, the Standards will divert attention from crucial areas of understanding and skills required. Throughout the claim is that the approach adopted is linked to the real demands of employment as expressed by employers and practitioners. However the overwhelming result is that, in order to meet the Training Agency's fundamental insistence on the application solely of functional analysis, an ideal is imposed, forcing reality to fit a model (the training cycle) which provides specific outcomes eg training plans. But this then has to be added to, since it does not reflect reality sufficiently, significantly in the area of process issues such as communication and negotiation. Whilst this might be useful in meeting the requirements of a qualifications system which emphasises immediately observable outcomes of performance, it has little utility in developing an approach which enhances the ability of real training practitioners to enhance their 'successfulness' in real organisations.

Comprehensiveness and Accuracy

The questions for consultation pose the issue of 'accuracy' in terms of the performance criteria. However, we shall take the issue of accuracy along with that of comprehensiveness. To focus solely on accuracy of performance criteria would be to sidestep the important question of the accuracy of the Standards themselves, an issue which we partly addressed above.

One of the key issues upon which there has been considerable agreement over recent years is with regard to the relationship between training and development as an occupational area, and that of personnel management. The question of whether training and development is a specialist function within personnel management, or a separate function, has to a considerable extent been made redundant by the advent of the concept of 'human resource management'. Although there is no comprehensive agreement on the meaning of the term, the generally accepted basis of the concept is that the activities and functions traditionally undertaken in the specialist areas of personnel management, industrial relations and training and development, should be integrated into overall strategic management of the organisation. There are of course considerable questions which arise from this, not least with regard to the the treatment of people as 'human resources'. But if we accept for the present such a perspective, complete with its managerialist orientation, we can identify problems with regard to the TDLB Standards.

Critical issues in training

The TDLB claims that the Standards are intended to reflect 'best practice'. We might expect then that there would be clear reference to issues which are currently regarded as being critical in terms of best practice. We have referred to the emphasis on human resource management in recent developments in the training field. Another key area now seen to be of critical importance is that of quality. Although the Standards Programme is claimed to be about quality, little recognition is given to the way in which this is currently perceived in organisational management. Increasingly the emphasis is upon 'total quality', embedded into all the operations of the organisation. However, the TDLB Standards marginalise this issue of quality, mentioning only in the context of training (B2,5,4). This reflects not only a view of the training function as an add on to operations, but also a view that the contribution that training has to make is solely in terms of training quality. This separation of quality, training and operations is reinforced by the use of the word 'negotiate' implies an assumption of separate parties (training being one) rather than an integrated approach to the function, a cost not an investment, to be marketed (unit E1.2), where the costs are to be minimised. There are great assumptions too in the so called strategic competences in A eg criterion (c) for element A1.1.1 "options which have the greatest potential for success are positively promoted and recommended". The question "Success for whom?" and is not explored, nor is the the nature of promoting and negotiating for it in an organisation, when training is usually a staff/advisory function.

The issue of change is dealt with most peculiarly by the TDLB Standards. Whereas most commentators on the relations of (education) and training with change emphasise complexity and uncertainty, ie discontinuous change, the TDLB Standards treat change as merely a continuous process. Thus A.1.2.2 refers to 'identifying' the training and development requirements to 'support' those who are concerned with 'formulating and implementing' visions of change and growth. The performance criteria refer to sources of information relevant to potential and predicted change, information which is assessed for relevance and accuracy, and clear and accurate evaluations. This language used to describe the nature of change which organisations will face stands in stark contrast with that used by well recognised commentators, such as Alvin Toffler, David Schon, Tom Peters and Charles Handy, who place particular stress on the role that education and training practitioners can play in enabling individuals, groups and organisations to cope in the 'third wave', to 'thrive on chaos'. Such practitioners themselves have to be able to cope with uncertainty, to be open to change, and not to seek comfort in 'accuracy' and 'relevance' based on outmoded concerns and perspectives. Now although such views themselves may be subject to criticism, clearly TDLB Standards do not meet the criteria set of reflecting good or best practice as perceived by employers.

A further key issue of current concern within the training field is that of equal opportunities. However, in the TDLB Standards references to equal opportunities are incomplete, confused and unconvincing. Little is included in reference to the very many issues in training and development where equal opportunities must be considered eg assessment of prior learning or materials development where it is not mentioned. Specific references encompass providing for 'special requirements' in the context of information and resources for learning opportunities (C.2.2.1.(c)). This may be seen as implying eg disabled access and creche provision but it does not explicitly say so. In stating that 'relevant demographic characteristics, special needs and circumstances' of learners must be 'clearly stated' in order to assess learning strategy choice (B.2.1.2(a)) the TDLB appears unwilling to name the problem directly ie race, gender, and disability discrimination. This individualises and marginalises well documented, broad institutional discrimination issues. Only in D.2.1.2. are the issues spelt out : 'ensuring assessment methods do not discriminate'. This reflects the aim of the Standards Programme it is primarily about assessment and not about learning and its quality. Given the sensitivity of the MSC/ Training Agency in the past to claims that its equal opportunities commitment is 'luke warm' and the increased rhetoric and activity which resulted, it is acutely disappointing to see how little the TDLB's work deals with the structural issues which the training role has some power to challenge.

So even a cursory examination of the TDLB Standards raises serious doubts about their face validity, and therefore of the likelihood that they will achieve what they espousedly set out to achieve. We shall now examine the Standards in greater depth, considering the extent to which the nature of training and development work, and the nature of competence in such work, is adequately and accurately represented by the TDLB Standards. This will provide an opportunity to examine the assumptions about human work performance and competence in general on which the Standards Programme is based.


There are of course a wide variety of methods for analysing work performance, some long established (eg skills analysis, task analysis) and some fairly recently developed (eg occupationl training families). During the 1970s the MSC undertook an examination of North American approaches for skill comparison (Freshwater and Townsend, 1977). Pearn and Kandola (1988) present a variety of methods for analysing jobs, many of which are not primarily intended for training purposes. However, the Training Agency has rejected all of these in favour of the relatively new technique of functional analysis. Very little published literature on functional analysis currently exists. What does exist tends to be repetitive, and is mainly descriptive of how the method should be used and/or merely makes generalised claims about what benefits it will lead to. As yet, no substantial theoretical or empirical justification has been presented. The method seems to have been
"... developed over time and through close experience and involvement with standards development by a group of researchers and trainers at Barbara Shelborn Associates." (Mitchell, 1989)
When mentioning functional analysis in various documents the Training Agency takes pains to point out that it differs from functional job analysis developed by Fine in the USA. These references to Fine's work are the only references to any other approaches or other literature in this field. The impression one gains is that the Training Agency feels compelled to acknowledge Fine's work, as if to avoid the charge of plagiarism!

Arguably, any methodology for analysing human work activity will be theory laden and this is certainly the case with functional analysis. In order to examine the significance of this approach to the examination of competence, we need to consider the underlying theoretical assumptions. The notion of competence used by NCVQ and the Standards Programme is based on a number of assumptions. First, as we have already seen, competence is identified with observable (and assessable) performance. Overall competence is deemed capable of being be analysed atomistically into separate, discrete areas of performance which when, added together, constitute the totality of competence.

Moreover, competence is treated as consisting solely in the performance required to meet unequivocal organisational functions or purposes.
"Within any organisation whether business, commerce or public sector each individual contributes to the organisation performing effectively. They [sic!] do so by carrying out those functions which lead to the organisation satisfying its mission or purpose." (Training Agency, 1989)
In fact, the outputs which are required are not necessarily those produced by individuals. Mansfield, quoting an example ('reproduce copies of documents and information'), states that
"... the latter description is not an individual attribute. However, TDLB and the Standards Programme generally does not work along the lines indicated by Mansfield, but on the basis that the accomplishment of such purposes is totally dependent upon individual performance. Thus, for example, the element A.1.1.2, "Promote and support the commitment of key decision makers to agreed role and remit of training and development in the organisation", has two performance criteria which refer to what others do:
"Those at high level make organisation wide statements which clearly support training and development and positively promote it as part of the organisation culture; ...
"Physical resources money, time and materials are committed in support of training and development..."

Such a view of human work performance, as carrying out functions intended to achieve overall organisational purpose, is central to traditional organisational theory. This perspective has tended to dominate the managerial literature, but increasingly over the past two decades alternative perspectives have gained in prominence, even in managerial literature. Silverman's seminal book, published twenty years ago this year, set out the basis of an 'Action' approach as an alternative to the deterministic orientation of the dominant 'Systems' approach. More recently others have indicated a wider range of perspectives on organisations, notably in terms of underlying 'paradigms' (Burrell and Morgan, 1979) and 'metaphors' (Morgan, 1986). A common theme in such alternatives is a concern with understanding how human beings construct their social environment. Organisations are regarded as the outcome of social processes by which people generate and share particular understanding and meanings, and the intentional strategies they adopt in seeking to gain acceptance of their particular understandings. In holding to such a rigid, structural functionalist perspective on organisations and work performance within organisations, the Training Agency and TDLB has limited its ability to analyse real human work performance in a way which takes full account of its complex reality.

An example of this is the very first element, A.1.1, "Propose, negotiate and agree with key policy makers an appropriate degree of proactivity of the training and development input to organisational strategy". The performance criteria includes the following :
"...negotiations and agreements are conducted and concluded in a manner which promotes and maintains goodwill and trust."
This item is one which negotiated order theorists would find an area for considerable research in order to elucidate what is involved! The TDLB Standards are replete with such usage of the terms 'negotiate' and 'agree', with no recognition of the inter subjective, social nature of these activities. We shall attempt later to provide an analysis of competence which truly includes the social component which is an essential element in much human work performance, particularly in an area such as training.

The limited, functionalist perspective on the nature of work organisations implicit in the TDLB Standards is further shown in the extensive use of the words 'negotiate' and 'agree' (11 units). Such activities are seen as unequivocal and categorical. For example, element A.1.4.3 reads as follows:
"Debate and agree the issues with key decision makers which then set the broad parameters and direction of training and development activity."
The performance criteria for this are :
"a. all options are fully explored.
b. all key decsion makers are involved in the debate
c. the agreements reached incorporate the commitments of all key decision makers
d. the implications of the agreements for each decision maker are explored
e. the agreements reached are capable of implementation."

There is no recognition in this analysis that in real organisations (as opposed to the ideal organisation) 'agreements' are, at best, seen as partial, temporary, and context bound. The 'political' nature of decision making (Pettigrew, 1973), the existence of competing coalitions (Simon and March, ), and the contested nature of organisations (Edwards, 1979) are ignored by such simplistic rendering of real life negotiation. The fact that a training practitioner may be attempting to implement a 'deviant innovation' strategy (Legge, ) cannot be handled by such performance criteria. Who is to judge 'competence' of such a practitioner? Those who are party to such a strategy (what is s/he is acting alone)? Or those whom the practitioner is attempting to influence? By its very nature, an influencing strategy is rendered inoperative once it is exposed (except in the utopian 'ideal speech situation': Habermas, ).

This is especially problematic in respect of 'standards' for the field of training and development, because it is precisely such an area which Pettigrew et al (1982) examined in their research on training and development practitioners in their organisational setting. They particularly examined the problems encountered by practitioners who were trying to change their role from that of a 'provider' to that of 'change agent'. A central issue was that of changing the base of their legitimacy, especially in terms of how they were able to draw upon sources of influence in their organisations. In order to understand such issues, and to devise training and development initiatives to enable such practitioners to make the transition desired (by them), interpretive approaches to understanding organisations were necessary. Clearly, TDLB has failed to incorporate such perspectives in the underlying theoretical base of the Standards. This does of course raise serious doubt as to the 'competence' of TDLB.

So, although Mansfield claims that 'standards' could equally well apply to a department, an organisation or an occupation, in reality the Standards Programme assumes that the achievement of the outcome or output stated in any standard is the result of individual performance. However, the nature of the individual is depersonalised. Standards, ie elements and their performance criteria, are treated as objective with no recognition being given to issues of values, preferences and what is often referred to as 'styles'. This is shown most clearly in the functional area B.2, "Design and update training and development strategies, plans, and systems". This whole area is treated as involving the application of merely technical knowledge and ability to meet technically definable ends. Learning strategies are 'identified and agreed', resources are 'specified', programmes are 'tested and revised'. Crucially, the unit B2.2, "Design a programme of learning opportunities to deliver an agreed learning strategy", is disaggregated into a set of elements which merely involve 'specifying', 'selecting', 'defining' and 'agreeing' objectives, methods, content, structure etc. No recognition is given here of the creative nature of training design (Binsted, 1979).

Burgoyne and Stuart (1977) examined the differences in programme designs in terms of implicit learning theories. Given the fact that there is no universally accepted theory of learning, but competing (some might say 'complementary') theories, the particular view of learning held by a particular trainer will significantly affect the formal design of the programme. Similarly, Brostrom (1979) identified four basic 'training styles' which had underlying theoretical bases. Although these learning theories may command some degree of cognitive assent, as there are competing theoretical claims the trainer is likely to be influenced by other factors in the development of whatever particular style s/he has, including experience, personality and values. This does of course raise problems of objective assessment, on which the Standards Programme insists.

The TDLB explicitly claim that the Training and Development Standards are not only based on actual performance of trainers now, but also 'provide a statement of good practice' [in Qualifications Structure in Training & Development, p4]. Moreover, the standards are claimed to be 'strategic', which appears to mean that they have
"...been designed to a specification which takes them beyond any particular employer or industry and helps set demanding targets for future capability in an increasingly competitive and fast training world." (TDLB: HTSAGT, 1990, p2)
This claim of representing 'good practice', extending across sectors and into the future, is reinforced by the inclusion of questions on this in the 'Questions for Consultation'.

Examination of the standards, particularly the performance criteria, shows a clear emphasis on approaches which are now conventional in the training field. These are those which the industrial training boards tended to promote, particularly emphasising Systematic Training and a systems approach, behavioural objectives, application of instructional technology, and objectives based validation/ evaluation. These are based in particular perspectives in the social sciences, especially behaviourist psychology and functionalist organisation theory. This rational technical bureaucratic model emphasises Taylorist approaches to the consideration of work performance, and a Tylerist approach to instruction. Such views may be found in many textbooks on training, even the most rcent.

However, alternative approaches to training theory and practice have certainly existed for many decades. Megginson (1973) identified four different orientations (later expanded to five, in collaboration with Boydell) to training within organisations, based on differences of underlying beliefs and opinions, the set of goals deemed to be desirable,the emphasis placed on various activities seen to be appropriate to these different goals, and the history of thinking behind the approaches. Burgoyne (1976) identified eight 'schools' of learning theory underlying management training and development practice.

Such differences in approach can clearly be seen in the area of training design in the contrast between the instructional techniques (IT) approach promulgated by Training Within Industry (TWI) and many ITBs, and the experiential approach to human relations training. While the former would insist on clearly defined behavioural objectives, the later regard these as anathema for truly 'significant learning' (Rogers, ). Whilst IT would emphasise a clearly structured and pre designed programme of training, human relations training would tend to emphasise a learning programme whose design is emergent from the interaction during the 'event', as in, for example, a T Group. IT approaches would regard evaluation as the process of comparing measured outcomes against pre set objectives, whereas human relations training would emphasise evaluation as the the expression of perceived value irrespective of any prior intentions or expectations. So in making claims of representing good practice and encompassing the body of knowledge appropriate to the field of activity, the TDLB is effectively seeking to exclude alternatives with which they are not compatible.

This can also be seen in the case of evaluation. TDLB state that
"Although commonly accepted by practitioners as a key function, neither CSML nor ITS [consultants to TDLB] found extensive evidence that evaluation is common practice. In fact the evidence was so slight that there is a case for eliminating this function." (TDLB:UG, 1990, p6)
This statement indicates that TDLB's conception of evaluation is solely one of formal evaluation. No recognition is given to the informal process of evaluation whereby the various parties to any training intervention will make their own judgements, often unconsciously, about the intervention. Such judgements are often varied, even mutually contradictory, which emphasises the negotiated nature of the role of training within an organisation. TDLB's limited view is also shown by its reference to evaluation in terms of effectiveness:
"D. Evaluate the effectiveness of HRD strategies, plans and systems".
Strategies and plans are to be evaluated against objectives (D1, D2). Success criteria are to be 'defined' in consultation with stakeholders (D.1.1.1(a)). Assessment is done to individuals who have the results of assessment 'fed back' to them.

Such a limited notion of evaluation takes little account of developments in evaluation that have occurred over at least two decades. Even Hamblin's classic work (1972) provided a much more sophisticated account of the variety of factors involved. The development of alternative (again competing/ complementary?) approaches, in particular the qualitative or 'illuminative' approach seems to have been missed by TDLB. The very fact that formal evaluation along the lines presented in the Standards is recognised by TDLB to be little practiced should alert us to the possibility that such a formal, objectives based, effectiveness model has limited application. Rather than 'leading practice', in emphasising this model the TDLB is perhaps preventing much needed progress in the adoption of meaningful and helpful approaches.

In reality, training practices and the sets of perspectives and ideas which practitioners draw upon (at least to provide a rationale for their practice) are highly varied. Even those which are superficially similar may have significant variation. While it may be argued that such differences may be resolved by the application of an all inclusive situational model (eg Stuart and Holmes, 1982), such an argument might arguably be regarded as itself drawing mainly on the technicist perspective implicit in the IT approach. Yet there does seem to be a significant degree of linkage of particular approaches with particular training concerns. For training in technical skills, the instructional model appears to be widely adopted. For interpersonal and group relations training, the humanistic/ experiential model seems to be most widely accepted, although there are examples of instructional approaches, eg 'behaviour modelling'. The various approaches may be seen as competing or as complementary. Moreover, if we move beyond method and technique into the realm of values and ethics, the differences tend indeed to become mutually exclusive.

The implication of this plurality of competing/ complementary approaches is that there is no definitive statement of good practice. There are no clear cut answers, only ambiquities, uncertainties, even contradictions. The competing/ complementary models certainly emphasise difference in methods, as well as in underlying theory and values. The TDLB Standards therefore become caught in a dilemma: to choose decisively between competing models, and so become partisan, or attempt to retain a semblance of neutrality by encompassing difference approaches as complementary. But the latter option would effectively undermine the basis on which the Standards have been developed, ie the insistence on functional analysis as the only method needed to analyse occupational performance. The former course of action has been taken, and whilst the cumbersome phraseology appears to encompass the variety in practice, the structure of the elements and units, and the performance criteria clearly display a unitarist vision.

Contrary to the unitarist perspective displayed by the TDLB Standards, we believe that the notion of 'competence' as applied to training practitioners does and necessarily must account for such plurality in theory and practice. Training practitioners are not mere technicians, applying proven techniques as efficiently as possible. Their work may be described as 'professional' in the sense noted by the Hayes Report (DE, 1973), ie as exemplified by reference to a body of concepts and theory. They may be seen as 'reflective practitioners' (Schon, 1982) who reflect or theorise as they act, rather than act on predetermined, learned rules. Moreover, their work necessarily involves them in encounters with other human beings (as 'trainees', 'students', 'learners'). Since they are 'intervening in' (or 'interfering with'?) the learning processes of others, training practitioners expose themselves to ethical challenge, concerning the moral basis of the position of power from which they exercise their expertise. So any training for trainers, and assessment of competence, must address such ethical issues. This is of course an underdeveloped area of training theory (Snell, 1986).


Despite the fact that vocational education and training has traditionally placed a heavy emphasis on methods for analysing work performance which are based on such functionalist assumptions, alternatives have been used. It seems to us that we can consider the nature of work performance in three ways. Firstly we can concentrate on the observable activities which are performed, treating the job as existing independently of the jobholder (the 'job' or 'technical' approach). Secondly we can focus on the performance of the individual within a social context, examining work performance as the enactment of role which emerges through the interaction between the roleholder and others with their varying perceptions, expectation, etc (the 'role' or 'social' approach). Thirdly, we can examine an individual's work performance in terms of its relationship to the real person with broader 'life' issues (the 'personal' or 'biographical' approach) (see figure #).

Significantly for the area covered by TDLB, the 'role' approach was adopted in the work of Pettigrew et al (1982), examining training specialist roles. They particularly focussed on the training and development issues arising for those who were attempting to move from 'provider' roles to 'change agent' roles. The important issues were those of 'fit' between personal style, role, and organisational culture, and of 'survival and influence', arising from strategies adopted for maintaining legitimacy, for managing role boundaries, and for accessing sources of power and influence. The research enabled the Chemical and Allied Products Industry Training Board, sponsoring the research, to develop workshops to help real trainers to develop their competence in the real organisational contexts in which they operated.

Similarly, the work undertaken by Walters (1979) on supervisory development in the hotel and catering industry focussed on a 'role' approach.
"The supervisor's relationships with other people at work are another important aspect of his job which cannot easily be determined from job descriptions and specification. Each of these people, whether they be managers, colleagues, specialists orm customers, will have expectations of the supervisor expectations of the way in which he conducts his work, of the way in which he interacts with them, and of his level of authority and power." (p.5)
A comprehensive approach to supervisory development was developed which started with a role analysis and role renegotiaton between supervisor and her/his line manager.

The 'personal' or 'biographical' approach can be seen in a number of initiatives. Cranfield Management School undertook research for the HCITB on the problems experienced by managers who were promoted, typically from managing a single unit to managing managers. They adapted the Kubler Ross model of the process of psychological transition experienced by terminally ill patients, to develop a model of transition. This described how the initial euphoria turns to feelings of confusion and incompetence, as the skills and behaviour patterns which had previously been successful now seem to be ineffective. Only by 'letting go' of past understandings and behaviour can the promoted manager begin to adopt new ways of understanding what is involved in being a manager in the new situation and what strategies are appropriate. This period of transition typically lasted eighteen months if the manager lasted that long! The 'Manager in Transition' development programme based on this research employed a range of approaches for developing greater self insight, for career review, and for devising strategies for gaining competence in the new role.

So, in our view, supported by mainstream theory and practice, 'competence' is not related solely to the work activities deemed to be required to meet unequivocal 'organisational goals', but is emergent in the complex of personal, social and technical factors in a dynamic social context. Moreover, linking with Burgoyne's examination of the notion of (managerial) 'effectiveness', we should note that the judgement of competence is itself not simple and unequivocal. Rather, such judgement takes place in a particular organisational setting and emerges from the social processes in that setting, so that it is always potentially subject to contestation. In other words, 'competence' is itself a social construct, not amenable solely to technical definition, but subject to the views of the actors involved, views which may, and often are, conflictual. Educational and training interventions which focus on only one aspect are likely to lead at best to limited competence, and at worst to disablement or lack of competence. Assessment and certification approaches which favour one particular aspect are thus attempts to enforce one perspective in such a contested arena.


Although the current Standards Programme was initiated by the Training Agency following the 1986 White Paper, its origins may be traced much further back, in public policy terms, to the 'Great Debate' on education launched by James Callaghan's Ruskin College speech in 1976. The explicit theme of the Great Debate, that education in Britain had failed to deliver what it promised, were later echoed in terms of vocational education and training. [The not always implicit theme, that the blame lay with teachers, has similarly been echoed by the suggestion that training practitioners are to blame for Britain's failure to train its workforce as well as competitor nations.]

The Great Debate was followed under the Thatcher Administration from 1979 by a steady stream of official documents and initiatives focused on labour market intervention. They began with the Central Policy Review Staff's report, 'Education, Training and Industrial Performance' setting out the problems as perceived, and proposing Government intervention to develop a national training system which was 'standards based'. The report referred to many existing apprenticeships as examples of 'restrictive labour practices'.
The relevant White Papers over the years of the Thatcher administration began with the New Training Initiative in 1981 which first set out the aim of comprehensive occupational standards to be developed to aid training and develop qualifications. This was amplified later by Review of Vocational Qualifications in 1985, and in 1986 the White Paper 'Working Together Education and Training ' announced the Government's intention to set up of the NCVQ. In addition, the Manpower Services Commission was required to take the lead in the development of occupational standards upon which the new qualifications would be based. The themes of standards for employment as expressed by employers and of transferability of skills recurred in these papers. These themes were also reflected in the welter of schemes and initiatives coming from the Manpower Services Commission and the Training Agency. The policy material however largely ignored the successful developments by many ITBs in introducing standards based training and qualification schemes. The EITB had introduced its standards based module scheme in 1968, and other ITBs had followed suit. Indeed in quoting the Donovan Report (1969), the CPRS report had ignored the work undertaken by the ITBs during the 1970s.

Along with the emphasis on 'standards', MSC and government reports and White Papers began to call for an emphasis on 'competence'. Initially, the term was used loosely, placed in opposition from the (supposed) emphasis on 'time serving' in then existing qualifications. Rather than having to undertake specified periods of formal training and vocational education, individuals should be awarded qualifications when they can demonstrate employment based 'competence' (CPRS, 1980; MSC, 1981). In addition, the emphasis on 'competence' as outcome was contrasted with the process and content of vocational education and training programmes, portrayed as 'inflexible' and 'knowledge' based.

The Youth Training Scheme provided an opportunity for the MSC to influence directly the nature of training provision on a large scale. However, it was the 1986 White Paper, 'Working Together Education and Training', which announced the major intervention which is currently being implemented. The National Council for Vocational Qualifications was established, and the MSC was set the task of taking the lead in stimulating industry training organisations to establish standards for occupations in their sectors.

This aspect of public policy has been reinforced over the period of the Conservative governments from 1979, by an emphasis on a declared policy of deregulation, freeing employers from bureaucratic intervention. The first review of training arrangements, undertaken by a joint CBI TUC working party in fact concluded that the then current arrangements, arising from the 1973 Employment and Training Act, were working quite well. If anything, the arrangement should be strengthened. The Government responded by instructing the MSC to review arrangements sector by sector. Even then, the MSC made recommendations that in no sector should the current statutory industry training board be abolished without more detailed proposals being developed by employer associations seeking such abolition. In the event the Secretary of State announced his intention to close 17 of the ITBs, a intention which was carried through. In the 1989 White Paper, 'Employment in the 1990s', the Government announced its intention to remove the statutory powers of six of the seven remaining ITBs.

However, the rhetoric of a policy of deregulation is in many ways not matched by the reality. The MSC's programmes have increased in size and restrictiveness. Whereas the provision of training arrangements for schoolleavers was varied prior to 1983, the introduction of YTS placed severe restrictions on the nature of training programmes available. Tight control was exercised by the MSC so that programmes matched the restrictive criteria set. Similarly, the introduction of Employment Training led to the loss of a variety of training and employment programmes, so that many organisations previously involved in Community Programme and Training Opportunities schemes found great difficulty in continuing successful work in enabling unemployed people to re enter worthwhile employment. The latest structural initiative, setting up the Training and Enterprise Councils, has been severely criticised by employers because of the restrictive nature of the funding and the requirement to take on Training Agency staff.

However, the clearest example of the Government's actual policy is the removal of oppositional voices in policy development and implementation. The ITBs were tri partite bodies, where trade union nominated board members had an equal vote with employer association nominated members until 1982. The 1981 Employment and Training Act increased the powers of employer members, so that a majority among such members could veto a decision on the levy, even though a majority of board members had carried it. Area Manpower Boards had trade union members, but they had only minority membership. The 1988 Employment Act increased the number of MSC commissioners, so that the Secretary of State could appoint six more without consultation with the CBI or TUC. Clearly, this would have resulted in six commissioners who were sympathetic to the Government's policies. In the event, the new commissioners were not appointed, as the Secretary of State effectively abolished the now Training Commission after the 1988 TUC Congress voted to boycott the Employment Training scheme. The TEC boards must consist of at least two thirds employer members, and personnel and training specialists are explicitly forbidden from board membership.

This process of handing over more and more of training policy to employers stands in bleak contrast with the findings of numerous studies of employer commitment to training. The most widely publicised example of this, the report 'Challenge to Complacency' provided a clear statement of this: employer attitude to training was best described as 'complacent'. When challenged why it was handing over control to employers, by abolishing most statutory ITBs and establishing TECs, the Government's response was that it was 'throwing down the gauntlet' to employers. However, the simplistic representation of employer complacency seriously neglects the fact that employer commitment to training varies, not only from company to company, but sector by sector, and occupation by occupation. Yet no serious studies have ever been undertaken to identify what are the factors which lead to employers being committed to training. For example, we might suppose that a relatively closed labour market where mobility is very low, would result in employers being more willing to train, as they cannot buy in trained labour but equally run little risk of losing the investment in trained labour. The clearing banks provide an example of such a dynamic. By neglecting to undertake such labour market research, the Government is neglecting to identify exactly where state intervention might have significant positive effects in improving the operation of the labour market (in terms of skills). In this respect, the Standards Programme represents a distraction from the work which would be necessary to achieve the national improvements espousedly sought.

Of course, such development have been accompanied by massive reduction in funding. YTS and ET have been widely criticised for the low level of resources. As with primary, secondary, further and higher education, vocational education and training has been expected to produce more and more on less and less. This policy permeates most areas of Government policy, and must be taken as a key feature of any policy initiative.

Within this broad policy thrust of economic squeeze and political control, the reform of vocational qualifications may be seen as a key element in obtaining ideological control. By defining 'competence' in terms of assessed performance according to criteria developed through the Standards Programme, alternative provision of educational and training opportunities will be marginalised. The supposed comparability of NVQs will render providers subject to crude market forces, as lower quality providers will offer programmes leading to the lowest common denominator qualifications much more cheaply than providers who are concerned to enhance real competence and accord with ethical practice. By enforcing such an approach on trainer qualifications, and therefore of training provision for trainers, alternatives will be suppressed and excluded. Whilst sceptics of the Standards Programme may regard it as a case of the 'Emperor's New Clothes' we consider that it constitutes a worrying new stage in public policy; perhaps best described as not so much a case of imperial nakedness as naked imperialism!


The Standards Programme and the reform of vocational qualifications has been generally welcomed. We believe that such welcome is misplaced. Although based on a rhetoric of concern for 'standards' and 'competence', the policy is in reality being driven by a specific approach which has little theoretical or empirical justification. When the specific case of the TDLB Standards for Training and Development are critically examined major concerns emerge. Many of these concerns may be generalised to the Standards Programme itself. When placed in the wider frame of the directions taken in Government policy on vocational education and training the Standards Programme may be seen as being a key element in a policy of control, rather than the claimed major step forward in enabling Britain to improve its economic performance and the achievement of social advancement for its people.

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