The Health & Safety Executive (HSE) requires organisations to examine their businesses and decide upon the appropriate first aid training required, both in terms of the number of first aiders and the level to which they need to be trained. Many businesses will opt for a mix of training – a few key personnel who hold the full 3-day First Aid at Work qualification and others who hold the one-day Emergency First Aid at Work qualification to supplement the provision, for example. But regardless of which course you choose, how do you know that it meets the HSE requirements?

The name of the course, unfortunately, does not necessarily tell you that it meets the criteria. Anyone can write and deliver (or create digitally) a course called Emergency First Aid, for example, but it could be 10 minutes long or 6 hours long, it might have the required practical (in person) components to meet HSE requirements, or it might be completely online which doesn’t. It may have assessment built in – or it might not. So, how do you know if the course offered for a ridiculously low price on LinkedIn or Facebook actually meets the HSE criteria?

As an employer, it’s your responsibility to do due diligence to ensure your selected training provider is competent and has the relevant quality assurance systems in place. HSE set the contents of each course and the standard to which these must be taught, the qualifications and experience the trainer must hold to be competent, the quality assurance requirements, the maximum class size, the minimum length of the course, the training resources which must be provided and the information that must be on certificates.

There are 4 different approved options when choosing a training provider:

1. They offer nationally regulated qualifications (regulated by Ofqual) through an Awarding Organisation (AO). These courses have a ‘Level’ assigned to them and crucially have the letters RQF at the end of the title. RQF stands for Regulated Qualifications Framework – and these letters are your peace of mind. It means that the training course is accredited and regulated and therefore is also quality assured by the Awarding Organisation to ensure the training provider is competent, is completing regular CPD and is also regularly observed by internal and external quality assurors to ensure quality teaching, practical assessments to the appropriate levels and compliance with written assessments. In short, if you choose a training provider who offers you an RQF qualification, your due diligence is already complete.
2. Choose a Voluntary Aided Society (VAS) – e.g. St John’s Ambulance, Red Cross, St Andrew’s First Aid. These organisations self-accredit and their courses, whilst recognised nationally, are not qualifications and do not have RQF in their title. Whilst it’s usually quite easy to find these courses near you, with so many trainers it can be hit and miss as to the quality of your trainer and they are usually one of the most expensive options for completing training. By using a VAS you have completed your due diligence.
3. Operate under voluntary accreditation schemes, including trade/industry bodies. Depending upon which industry body they are working with, there may or may not be a quality assurance programme in place, and due diligence checks will be required in full.
4. Operate independently of any such accreditation scheme – i.e. they have no organisation checking they are complying with the HSE requirements, often no quality assurance system in place and no external due diligence at all. You will need to do full due diligence checks on these organisations.

So – options 1 and 2 complete your due diligence for you; options 3 and 4 require you to do your own due diligence checks which extend over 5 pages of checks in this HSE document. Most employers believe it is far quicker, easier and provides peace of mind to select a training provider offering RQF qualifications or using a VAS provider rather than doing your own checks and recording them!

The employer is responsible for ensuring the training meets HSE requirements. Selecting a training course using options 3 or 4 requires in-depth checking and if this isn’t completed and something should go wrong resulting in an HSE investigation, not carrying out this due diligence or pleading ignorance will be no defence to any charge of negligence or fine issued for non-compliance. The consequences could close a business down.

I recently freelanced for a business operating under option 4, although I didn’t know this when I offered my services. The course was blended (partly online learning using an e-learning programme, partly in person) and I realised – too late because I hadn’t done my own due diligence checks – that the course was not compliant and did not meet the criteria. When I asked the lady who booked the course whether she had completed any due diligence, she said she had asked whether the course was compliant and was told it was. Unfortunately, that doesn’t meet the 5 pages of due diligence required by the HSE!

So, how was the course non-compliant?

• The number of learning hours was not met. The course required 18 hours of training, 12 of which needed to be in person. The hours totalled 10, including breaks which have to be excluded.
• The required course content did not completely meet the HSE criteria.
• No identity checks were required – it could have been anyone on my course! No registration forms were completed nor was ID shown.
• The ‘e-learning’ should take at least 6 hours using an online programme. What was actually provided was a course textbook per person sent in advance, plus an open book multiple choice worksheet which was supposed to demonstrate they had completed 6 hours worth of reading a short course book. Nothing was completed online.
• There were no checks that the person in front of me was the person who had completed the multiple choice questions.  
• They marked their own work. 
• There was no pass mark.  
• It would take a maximum of an hour to read the book so not meeting the 6 hour requirement – had they read it – but they all admitted that (having completed the course several times before) that they went straight to the multiple choice questions and hoped for the best, looking up anything they weren’t sure of. HSE would not deem this ‘an appropriate means of assessing the e-learning component of the training’ (para 26 p.6).

So what did I do?  

I cannot have poorly trained learners on my conscience – someone could die because of it. I provided access to my e-learning programme (at a significant cost to me). I increased the course hours to ensure the 12 hours were met. I built in verbal assessment as we went through the course, and added in the missing components. I checked their ID – and I slept OK that night! I won’t be working for that training company again – but there’s no one I can report them to as the industry has no regulation – it’s down to the clients to do the due diligence!

Who gains? The training provider. They do not have the costs of quality assurance. They don’t have certification costs from an Awarding Organisation – they just print their own. They have no costs for the blended learning part of the course – so they can attract clients by offering courses at a lower cost than their competitors who are doing things properly.

And the losers? The organisations who use them. They don’t actually have qualified first aiders…

• They don’t meet HSE requirements and are open to prosecution or heavy fines in the event of an incident.
• Their ‘first aiders’ lack the confidence to act when needed.
• Lack of a quick, effective response can result in more severe medical consequences – bad for the casualty, and the business in terms of liability and decreased productivity, increased sickness absence costs and lowering of staff morale.

The moral of the story? Use a training provider who can provide RQF qualifications, a VAS, or make sure you have completed your due diligence!