SIMI Submission to the Development of the Apprenticeship Action Plan 2021-2025
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SIMI Submission to the
Development of the
Apprenticeship Action Plan
2021-2025Contents
Executive Summary Background .................................................................................................................3
SIMI Proposals .............................................................................................................................................3
Definition of Apprenticeship........................................................................................................................4
Legislation ....................................................................................................................................................4
Governance Structures ................................................................................................................................4
Development & Delivery of Apprenticeships ..............................................................................................5
Funding of Apprenticeships .........................................................................................................................8
Supports for Employers ...............................................................................................................................9
Increasing Participation ............................................................................................................................ 10
Conclusion................................................................................................................................................. 11
2|PageExecutive Summary
Background
The Society of the Irish Motor Industry (SIMI) welcomes the opportunity to make a Submission
to the Department of Further and Higher Education, Research, Innovation and Science, on the
Consultation Paper “APPRENTICESHIP ACTION PLAN 2021-2025”.
The SIMI is the national trade association and representative body of over 1,200 employers in
the Motor Industry, whose businesses include the distribution, retailing, repair and
maintenance of motor vehicles and their components. SIMI Members are located in every
county in Ireland, and the Motor Industry currently employs in the region of 40,000 people,
underlining its importance to the Irish economy.
Apprenticeship training is essential for our Industry and is a cross sector issue for our
members. As an Industry we rely on the availability of the skill-base provided by the
apprenticeship system and have supported and invested heavily in apprentice development
over many years. The most recent figures from SOLAS indicate that there are currently 2,250
registered Motor trade apprentices. In preparation for setting out our Industry response to
the Consultation Paper, SIMI has consulted with individual representative groups within the
Industry who have a particular interest or direct involvement in apprenticeship training and
have carried out an online survey of members to obtain their views on many of the key issues
outlined in the document.
SIMI Proposals
Phase 2 off-the-job training of 20 weeks is considered too long. It is our view that Phase
2 should be split into two 10-week phases as opposed to one 20-week block release.
In order to maintain and strengthen the relationship between employer and
apprentice, return to the workplace one day a week during off-the-job phases.
It is vital that the current level of funding be maintained.
With the rapid developments in technology, particularly with regard to battery power
and electric/hybrid cars, etc., the need for apprenticeship training to keep pace with
new advances in automotive technology is crucial.
More frequent reviews and updates of the curricula, where necessary, with the
upskilling of trainers and instructors from the Education and Training Boards and
Institutes of Technology, to ensure that the standards of off-the-job training reflected
the best practice within the Industry.
Introduction of online learning modules to support the on-the-job training of
apprentices in phases 1,3,5, and 7 would be of benefit to apprentices.
We believe that a lot more could and should be done to encourage and persuade
young people, their parents and the career guidance professionals that an
apprenticeship is an exciting and rewarding career option.
3|Page A craft-specific aptitude test that potential apprentices could undertake.
Develop the IT administration: A centralised application system, giving employers
access to an online database of eligible apprentice applicants, whose qualifications
have been screened in advance.
Definition of Apprenticeship
At this point in time, the Motor Industry considers that the standards-based dual system which
combines formal education and training with work-based learning works well for the Industry
and should be retained.
Legislation
The Industry does not believe that any fundamental changes should be made to the legislation
currently relevant to apprenticeship in Ireland, in particular in relation to the National Training
Fund Act 2000. It is important that the National Training Fund which is supported by the
employer levy continues to meet some of the costs of apprenticeship.
Governance Structures
In considering the core mandatory features of apprenticeship and notwithstanding the fact
that some of these features place an onerous responsibility on the employer, the Motor
Industry accepts that this is a necessary part of the relationship between SOLAS, the employer
and the apprentice and therefore, the Motor Industry would favour the continuation of the
governance and management structures for apprenticeship for the most part. However, while
the Industry supports that all programmes be structured to deliver at least 50% of training in
the workplace, we are not in favour of the delivery of Phase 2 off-the-job training of 20 weeks
as it is considered too long. It is our view that Phase 2 should be split into two 10-week phases
as opposed to one 20-week block release.
While the Motor Industry, to a large extent, is in favour of the continuation of the governance
and management structures for apprenticeship, the Industry has highlighted the importance
that the current level of funding be maintained. For Craft Apprenticeships, apprentice wages
are typically set centrally through industrial relations mechanisms and a State-funded
allowance is paid to the apprentice during off-the-job phases. However, for Consortia-led
Apprenticeships, wages are determined by the employer and paid for the full duration of the
programme. The Industry believes that the costs of the Craft apprenticeship should continue
to be shared by the State and the Employer and would not be in favour of any increase in the
employer’s contribution towards the costs of apprenticeship training. However, as with
Consortia-led apprenticeships, increased online or blended learning for craft apprenticeships
would be considered an important change to the structure and delivery of the Motor Industry
Family of Trades Apprenticeship programmes.
In the governance and management of apprenticeships, sectoral bodies can play a vital role if
they are set up to licence or regulate qualified craft persons which in turn might incorporate
apprentices into their structures to allow them to be part of professional membership of a
body throughout their apprenticeship.
4|PageDevelopment & Delivery of Apprenticeships
The opportunity for discussion among stakeholders provided by the NAAC –National
Apprenticeship Advisory Committee, that comprises of two SOLAS Board Members and a
representative from the Department of Education and Skills, the Institutes of Technology,
Education and Training Boards Ireland, the Higher Education Authority, SOLAS, two Employer
Body representatives (one from SIMI), SME representative, Learner representative and two
ICTU representatives, is extremely important for our Industry. SIMI, as an Employer Body
representative, greatly values the work of the NAAC as it provides a platform and opportunity
to bring forward to the SOLAS Board on behalf of employers in the Motor Industry issues and
concerns such as; technological developments that may impact on apprenticeship delivery,
and curricula, best practices within the workplace, the need for continuous improvement in
the delivery of the apprenticeship system and services, and from time-to-time suggestions as
to actions that might encourage more employers to engage in the apprenticeship system.
When considering the impact of new technologies across the Motor Industry Family of Trades,
subject matter experts from the Motor Industry have willingly given their time to collaborate
with SOLAS and the other stakeholders in programme development and programme/curricula
reviews. This type of engagement could be further enhanced if the reviews and updates of the
curricula took place on a more frequent basis and if, in the rolling out of updated curricula, the
industry were in a position to provide support, where necessary, with the upskilling of trainers
and instructors from the Education and Training Boards and Institutes of Technology, to
ensure that the standards of off-the-job training reflected the best practice within the
Industry. Ensuring that the off-the-job training of apprentices encompasses the latest
developments in automotive vehicle technology would go some way to encouraging the
continued and future engagement of employers with the apprenticeship system.
As a consequence of Covid-19, SIMI recently launched a range of online learning events for
employees in our Members companies. These have been well received by employers and
employees, and we believe the provision of online learning modules to support the on-the-job
training of apprentices in phases 1,3,5, and 7 would be of benefit to apprentices.
SIMI were involved with the Consortium Steering Group in the development and delivery of
the new Sales apprenticeship programme and the views of that particular group on the 10-
step process are as follows:
The 10-step process gives an excellent road map on how to develop an apprenticeship
from the initial proposal to the launch of the apprenticeship. However, many of these
steps overlap – would consideration be given to reducing the number of steps
involved?
(Step 1) An appropriate occupational skills profile is fundamental to the development
of an apprenticeship programme and thus the importance of the Initial Consortium
Steering Group (ICSG) members cannot be underestimated. Their input is valuable in
relation to skill requirements and job opportunities available. What might be useful to
consider is the establishment of structured communications to employers about the
role of the ICSG, the CSG and requirements relating to the programme development in
general (overview of how a programme is developed, the resources required, the
number of meetings, financial remuneration/expenses covered for attending meetings
etc
(Steps 1 – 4) Rather than the apprenticeship programme be industry led, could
5|Pageconsideration be allowed for an employer/education provider partnership? Education
providers have the experience and expertise on developing programmes and welcome
the employers’ input across all phases of development. However, resources such as
time can be very challenging to employers as currently the expectations are that they
lead the development of the programme and thus need to attend all meetings as well
as continuing to work on a full-time basis.
(Step 3) Consider the frontloading of funding of resources to take into consideration
the appointment of a programme team and in particular a programme development
lead who would be the key liaison point between the CSG and the education provider.
(Step 3) Consider the inclusion of the Female Bursary incentive in new apprenticeships
as well as craft apprenticeships
(Step 6) SOLAS documentation suggests that a new programme takes approximately 12
– 15 months to complete however realistically this is often not the case. Many
education providers and employers wish to design a programme based on current
industry requirements however the length of time required often impacts negatively
on this. Research initially collated could often be obsolete by the time the validation
panel is established and the programme approved for validation.
(Step 9) Consideration in relation to the appointment of regional SOLAS Authorised
Officers (AOs) dedicated to new apprenticeships. Currently, confusion arises between
the structure of traditional craft apprenticeships and new apprenticeships. Many of the
AOs are not subject matter experts in areas such as Financial Services, Accounting,
Sales, Logistics, Retail for example. Would it be useful to consider appointing AOs
based on their subject matter expertise and thus developing regional AOs to deal with
clusters of apprenticeships – IFS/Accounting, Sales/Retail etc.?
(Step 9) Consider a promotional campaign targeting parents, guidance counsellors and
potential apprentices. The current one size fits all does not work and if we are to
promote apprenticeships as an education model, more focus is needed to reposition
them in the minds of the above target audiences. The UK Government Fire it Up
campaign developed key messages and marketing assets targeting a number of
audiences. Toolkits were designed and disseminated to key audiences. Results
suggested that the proportion of interested young people considering an
apprenticeship almost doubled (14% to 24% in 9 months)
(Step 9) The UK, USA, Australia and New Zealand have annual dedicated
Apprenticeship Weeks – an excellent means of promoting apprenticeships to relevant
audiences. Could this be considered by The Apprenticeship Council?
The recently launched SOLAS initiative regarding online registration is excellent, but to date
the level of engagement by employers appears to have been poor. Further promotion of the
service to employers would be welcomed. When recruiting an apprentice, Motor Industry
employers have frequently commented that aside from considering the individuals CV,
education and interview performance, they still find it difficult to find a good, quality
apprentice and therefore, if there was a craft-specific aptitude test that potential apprentices
could undertake, it would be of benefit to both the employer and the individual in determining
whether they might be suited to the particular craft. If in the future, the online registration
system could incorporate such tests, it might encourage more employers to engage with it
when recruiting.
6|PageRegarding the development and review of craft apprenticeship curricula, with the rapid
developments in technology, particularly with regard to battery power and electric/hybrid
cars, etc., the need for apprenticeship training to keep pace with new advances in automotive
technology is crucial as it is anticipated that there will be significant growth in EVs in the next
few years, with an interim target in 2025 of 181,500.
A significant number of Motor Industry employers of apprentices are small to medium sized
Independent Sales and Service garages, many of which are family owned and run businesses.
Unlike their main competitors, larger Franchise Dealers, they do not have direct access to the
training and upskilling for their apprentices through a dealer network. This places the
employer at a distinct disadvantage in terms of their profitability and competitiveness and the
apprentice at a disadvantage in terms of the range of their knowledge, skills, competencies,
career progression and future employability. To guarantee that all apprentices on completion
of their apprenticeship may compete for employment on a level-playing field, we should
endeavour as far as possible to ensure that during their apprenticeship they are trained on the
most up-to-date equipment by trainers who are experts in current vehicle technology.
The results of our Members’ survey indicated that 60% of the respondents felt that the current
curriculum was not up to date and almost 70% believed that the investment in equipment and
the upskilling of staff in training centres was not keeping pace with technological advances in
the Motor Industry. For those reasons we would like to see, as mentioned previously, more
frequent curriculum reviews, training centres better-equipped with the latest automotive
vehicle technology, so that what is taught in the off-the-job training phases stays relevant to
what is happening in the workplace.
There are a number of changes that the Motor Industry consider necessary to the structure
and delivery of the craft apprenticeship programmes and are detailed as follows:
Balance between On and Off-the-Job
The majority of Motor Industry employers consider that the off-the-job training phases are too
long, in particular Phase 2, when apprentices spend 20 weeks in a training centre during the
first year of their apprenticeship. It is our view that Phase 2 should be split into two 10-week
phases as opposed to one 20-week block release. From an Industry perspective, when
employing an apprentice, the employer accepts the responsibility of developing and nurturing
young adults/school leavers and when living away from home for 20 weeks for the first time,
in shared accommodation, it can affect their well-being both in the short and long term.
Furthermore, while most of our Members would favour a return to day-release, we appreciate
that this may not be practicable from the point of view of the best use of training centre and
college resources. However, there is a clear view in our industry that employers and
apprentices would benefit significantly if the apprentices were in a position to return to the
workplace one day a week during off-the-job phases. This would help to maintain and
strengthen the relationship between employer and apprentice and keep the apprentice in
touch with the reality of the day-to-day activity in the workplace. Additionally, the employer
can monitor their apprentices weekly and know immediately if they are struggling with
anything and can assist them. Another change that would improve the balance between on-
the-job and off-the-job training is the location of where apprentices are called to undertake
their off-the-job phases in training centres. In our Members’ Survey, ensuring that the off-the-
job training centre be located as close to the apprentice’s employment/residence insofar as
7|Pagepossible was ranked the most important change to the structure and delivery of the Motor
Industry Family of Trades apprenticeship programmes.
Timing of the Off-the-Job Training
The business cycle of the Motor Industry is traditionally subject to seasonal fluctuations, with
almost 60% of their business being done within the first quarter of the year when the majority
of new car sales are transacted and trade-in vehicles are taken into stock. It is important that
consideration is given to ensure that apprentices are not called for off-the-job training during
these periods. As this is such a crucial time for the Industry, it is really is not appropriate that
Motor Industry apprentices be scheduled for off-the-job training during these periods.
Consideration should also be given to calling multiple apprentices from the one company at
the same time as this can place unnecessary strains on the business.
Online Assessment On-the-Job
The Motor Industry would welcome the addition of continuous online assessment by SOLAS
throughout the on-the-job training. This would facilitate a uniform approach to assessing that
key learning points have been completed on-the-job and would indicate the apprentice’s
readiness to continue with off-the-job training and examinations.
Funding of Apprenticeships
The Industry has highlighted the importance that the current level of funding be maintained.
Currently, the costs of the apprenticeship are shared by the State and the employer with the
employer paying apprentice wages typically set centrally through industrial relations
mechanisms and the State paying an allowance to the apprentice during off-the-job phases.
Employers believe that their investment in apprenticeship training represents value but more
importantly, it is an investment in the future. With the supply of apprentices already greatly
reduced over the years and further again this year due to the disruption caused by COVID-19,
it is vital that no additional costs are placed on employers taking on new apprentices. Again,
the Industry would stress the importance they place on the State to continue paying the
allowance for the apprentices during the off-the-job training phases.
The recent announcement of the Apprenticeship Incentivisation Scheme, as a responsive
measure to the COVID-19 crisis, is very welcome and will make a very positive impact on
employers. In some cases, it may have kept some apprentices in their apprenticeship who
might otherwise have been made redundant.
The evaluation of the impact and cost effectiveness of apprenticeship depends on the
employer’s view of an apprentice and the reasoning behind their employment. If an employer
is viewing their apprenticeship recruitment policy as low-cost employment or cheap labour,
the impact and cost effectiveness becomes a simple calculation evaluated by how quickly the
apprentice can become productive and start being an additional revenue stream for the
business. For the apprentice in this scenario, it tends to lead to delays in initial registration,
delays or failure to send the apprentice to off-the-job phases, poor quality on-the-job training,
which reflects in the apprentice’s inability to pass off-the-job examinations and finally poor
employment retention figures upon completing the apprenticeship programme. However, if an
employer has a long-term view with regards to its apprenticeship recruitment policy, the true
measure of both impact and cost effectiveness is what is gained at the end of the 4-year cycle.
8|PageDoes the employer have their next systems technician, diagnostic or master technician, a
future workshop controller, service advisor or service manager? This is a test of the
apprenticeship programme and the commitment of the employer to the development of its
apprentices. It may lead to lower apprenticeship registrations but higher retention post-
qualification, greater internal promotion opportunities and longer service employment.
Supports for Employers
The results of our SIMI Members’ survey indicated that the In-Company trainer/supervisor
costs impacts the most on employers when taking on an apprentice, followed closely by
Apprentice wages/social insurance costs and therefore it is vital that no additional costs are
placed on employers taking on new apprentices.
From an Industry perspective, the cost/benefit balance of participation could be improved by
increasing funding/support, if required, for rural colleges. Whilst there is an urban/rural
disparity with apprenticeship numbers and a need therefore to send an apprentice for
example, from Dublin to Athlone to increase numbers attending for funding and course
viability, this needs to be changed along with a review of the length of Phase 2 off-the-job
training. It is also difficult for the employee to return to work at the culmination of each phase
as the business has moved on each time in their absence. While the Industry is advocating for
a split in the 20-week block release, there is also a clear view that employers and apprentices
would benefit significantly if the apprentices were in a position to return to the workplace one
day a week during off-the-job phases. This way the employer can monitor their apprentices
weekly and know immediately if they are struggling with anything and can assist them.
The barrier to small enterprises participation in apprenticeships can be directly attributed to
the length of time it can take for a return on their investment in the initial training. The Motor
Industry would welcome an incentive scheme based on turnover that extended the
Apprenticeship Incentivisation Scheme for small enterprises. Furthermore, the addition of
continuous online assessment by SOLAS throughout the on-the-job training would facilitate a
uniform approach to assessing that key learning points have been completed on the job. It
could also lower the administrative burden in monitoring learnings completed/outstanding for
each phase. Calling multiple apprentices from the one company at the same time also acts as a
barrier to small enterprises participation in apprenticeships as this can place unnecessary
strains on small businesses.
A centralised application system, giving employers access to an online database of eligible
apprentice applicants, whose qualifications had been screened in advance, would greatly
improve efficiencies when it comes to finding a suitable apprentice in the locality.
Furthermore, if there was a craft-specific aptitude test that potential apprentices could
undertake, it would also be of benefit to both the employer and the individual in determining
whether they might be suited to the particular craft. If, in the future, the online registration
system could incorporate such tests, it might encourage more employers to engage with it
when recruiting and increase small enterprises participation in apprenticeships. This would
also aid apprentice applicants in finding a willing, local employer.
9|PageIncreasing Participation
It must be acknowledged that through the work of SOLAS and the Department of Further and
Higher Education, Research, Innovation and Science, the profile of apprenticeships in general
has improved in recent times with initiatives such as the Generation Apprenticeship and the
Ireland Skills Live exhibition at the RDS in 2019 promoting a very positive image of
apprenticeship training and highlighting the wide range of skills levels and professionalism of
apprentices and something that we, as an Industry, will continue to support and encourage
Members and their apprentices to get involved in. However, as employers tell us, it is still a
huge challenge to recruit suitable candidates for apprenticeships from second level education
as it appears that the emphasis within many schools, and for many of the career guidance
professionals is primarily to have students focus on third level college education. We believe
that a lot more could and should be done to encourage and persuade young people, their
parents and the career guidance professionals that an apprenticeship is an exciting and
rewarding career option.
This could be done through advertising campaigns – TV, social media, etc. to show craft
apprenticeships as high-level skilled careers and by increasing the knowledge of
apprenticeships in the schools. Currently, there is an Access to Apprenticeship programme
delivered by TU Dublin which aims to support the transition of young people from
disadvantaged backgrounds into an apprenticeship scheme and provides an opportunity to
sample a range of apprenticeships in a variety of trades. Offering a similar programme,
perhaps as part of the Transition Year programme in secondary level education would help not
only in the promotion of apprenticeships but also to change any negative perceptions people
may have about apprenticeships or skills as a future career pathway. Many employers in the
Motor Industry are already playing a part by participating in Careers events in their local
schools and facilitating work experience for transition year students. This is an initiative that
hopefully will be expanded in the coming years, within Covid-19 guidelines.
A key feature of improving the attractiveness of apprenticeship to not just young people but
also adults would be demonstrating that there are clear progression pathways from
apprenticeships including the craft apprenticeships, into further and higher education. While
some technicians, once qualified, will continue to work in the retail garage sector and perhaps
specialise or become experts in a particular brand or area, some may advance to Workshop
Management/Service Manager level. However, it is vital that those craftspeople, who might
wish to take the academic route in order to further their career, are given the opportunity to
do so and therefore, craft apprenticeships should have clear and defined pathways for
progression from a National Craft Certificate Level 6 qualification to degree programmes in 3 rd
level education, that gives recognition/credit for prior learning/qualification.
Colleges offering PLC and Pre-Apprenticeship courses also play a role in increasing
participation in apprenticeships by giving students an opportunity to find out if, for example a
career in the Motor Industry, would suit them. However, according to the National Further
Education and Training Strategy 2020-2024, the absence of Further Education and Training
programmes from the CAO application system “devalues it as an equally valid option” 1and this
needs to change.
1
Future FET: Transforming Learning p 52
10 | P a g eThe Motor Industry has been very open to the in-take of females in what has been a very male
dominated Industry, but numbers have remained extremely low despite previous programmes
and financial incentives to redress the balance. In our survey to SIMI Members, when asked
why they have not availed of any incentives in the past, the majority responded that they were
not aware of the incentives in place. Therefore, improvements on the provision of specific
financial and non-financial incentives to increase participation by under-represented groups
would be welcome by the Motor Industry and should be considered.
Something that could be considered in the development of the new Action Plan, possibly in
connection with Ireland Skills would be to organise an annual “National Apprenticeship Week”.
For 13 years, the UK has organised a week-long celebration of apprenticeships across England
to recognise and applaud apprenticeship success stories across the country. Apprenticeship
employers use the opportunity to promote the success of their apprentices and highlight the
huge benefits to other employers who are thinking of taking on an apprentice. Apprentices
from across the country also get involved and are celebrated throughout the week with
engagement and events in schools and colleges to attract the next generation of apprentices
and to get them excited about their future career. The Industry would be very supportive of a
similar arrangement in the promotion of apprenticeship and would welcome this development
in the new Action Plan.
Conclusion
The Motor Industry has always supported the Apprenticeship system and will continue to do
so. We also commend the work SOLAS and the Department of Further and Higher Education,
Research, Innovation and Science are doing to pave the way forward for apprenticeships.
However, the current system needs to evolve and keep pace with the rapidly changing future
world of work. Any initiatives that may arise from the new Action Plan that improves and takes
into account the new way we now work will be most welcomed. Planning for the future is
now.
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