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Proposed Changes to Requirements for Registration of Painters in WA

The Department of Mines, Industry Regulation and Safety has been consulting with the National Painting and Decorating Institute in regards to proposed changes to the requirements for registration for painters in Western Australia.

Changes to the requirements do not happen often, and so it is important that when changes are proposed that thought is given to the impact they will have on the industry. The National Painting and Decorating Institute is a national not-for-profit organisation that has established itself as a peak professional body for the advancement of education and professionalism for the industry.

Western Australia has one of the best systems for regulation of the industry, and it has resulted in a high standard of professionalism compared to other states. However, there are major flaws in the current system that need to be addressed and these flaws are not being fixed by certain proposals which have been put forward.

Proposals include:

  • adding red tape to force apprentices to study estimating twice in order to become registered
  • adding red tape to force fully qualified painters to pay extra to get reassessed by 'approved TSA providers' just to prove they are qualified.
  • continuing to allow painters to get registered without being trained and qualified in Working at Heights, Lead Paint removal or asbestos encapsulation.
  • continuing to prevent experienced painters to access the training they need to become fully qualified.

These proposals will have a profound effect on the industry, and will not result in better outcomes. With so much misinformation around it is important to understand the facts and identify ways that the registration process can be improved.

Current Pathways for Registration

There are currently two pathways for registration in Western Australia. These are:

Set 1:

Required qualification:
Certificate III in Painting and Decorating and two units offered as part of the Course in Painter's Registration in small business management and estimating and specification; or an equivalent qualification as determined by the Board.
Required experience
Completed an apprenticeship in painting; or
at least the equivalent of four years of full-time experience in carrying out painting work.

Set 2:

Required qualification:
Completed the course in Painters' Registration, or an equivalent qualification.
Confirmation of a completed practical trades test.
Required experience
Five years of experience in carrying out painting work.

Time in Industry

It is worth noting from the above that it is impossible for anyone to get registered without having a minimum of 4 years full-time experience in the trade. It always has been and is one thing that should never be changed.

Certificate III Painting and Decorating

Notice that the qualification in Set 1 is Certificate III in Painting and Decorating. This is the industry recognised and nationally recognised qualification for painters and decorators in Australia. It is the only qualification recognised by employers, TAFEs, RTOs, the immigration department, and all government agencies across Australia. It is the qualification issued to apprentices once they complete training, and it is the same qualification issued to persons who are assessed and trained under Recognition of Prior Learning and gap training programs. It is the technical qualification required for licencing for painting contracting in New South Wales and Queensland, and for Registration in Victoria.

Certificate III Painting and Decorating is the only nationally endorsed qualification which details the competency standards, assessment requirements and Australian Qualifications Framework (AQF) that industry agrees is the benchmark for technical competence and skill. The qualification is reviewed by the industry every few years, with the last update being in 2020. After being endorsed by industry, it is endorsed by what used to be called Industry Skills Councils, under the direction of the federal government's Department of Employment and Workplace Relations. In 2020 the industry Technical Advisory Committee, including representatives from TAFE in Western Australia, signed off and endorsed the latest version of this qualification.

The latest version of this qualification, endorsed in 2020 and actively used since 2021, includes an updated unit. This updated unit, which was not part of the old qualification is called CPCCCM3005 Calculate costs of construction work. This updated unit was included and updated because the industry agreed that all painters who get qualified, via an apprenticeship pathway or RPL/gap training pathway, must be trained in professional estimating, costing and quoting. The painting trade is the only trade where training in estimating is a compulsory core subject in their qualification.

Therefore, since 2021 all painters across Australia who get qualified have been trained and assessed in estimating. There is no need for them to be trained again in estimating, as we shall see.

Course in Painter's Registration in small business management and estimating and specification

The Course in Painter's Registration in small business management and estimating and specification, as required by the Set 1 Pathway for registration, has included two nationally recognised unit of competency:

BSBSMB401 Establish legal and risk management requirements of small business
CPCCBC4004A Identify and produce estimated costs for building and construction projects

The unit BSBSMB401 Establish legal and risk management requirements of small business has been superseded by the unit BSBESB402 Establish legal and risk management requirements of small business. This unit of competency covers all the business acumen and business principles required by any business in order to meet its obligations under the Building Services (Registration) Regulations 2011, and all legislation and regulations that affect a painting contracting business.

According to the official web-site:

This unit describes the skills and knowledge required to identify and comply with legal and risk management requirements of the business or new business venture, including negotiating, creating and planning for legal contracts used within the business, where required. The unit applies to those establishing a business providing self-employment, as well as those establishing a new venture as part of a larger organisation.

This unit has been and will continue to be part of the requirements for painters registration in Western Australia. It is clear to anyone reading the the Performance Evidence and Knowledge Evidence in this unit that anyone completing this unit will have sufficient business acumen to meet all the regulatory requirements of a painting contracting business. Statements by certain stakeholders that this will change or be watered down are clearly false and misleading. It is disappointing to see organisations that claim to represent the industry deliberately misrepresent the truth in the interests of their own commercial gain and desire for control over the industry.

The other unit in this course has been CPCCBC4004A Identify and produce estimated costs for building and construction projects. This unit was superseded in 2020 by an updated unit CPCCBC4004 Identify and produce estimated costs for building and construction projects. In 2022 the National Painting and Decorating Institute advised the Department of Mines, Industry Regulation and Safety that this updated unit was no longer suitable for painting contractors, as it had been changed to be specific to building contractors. Eventually all stakeholders agreed to the fact that this unit should no longer be used for training estimating to painters and a replacement would need to be found.

CPCCCM3005 Calculate costs of construction work - the estimating unit for the painting industry

This unit has been a core compulsory part of the Certificate III Painting and Decorating since 2020 and ensures that all painters who get qualified, anywhere in Australia, including apprentices, have been trained and are qualified in trade contracting estimating.

The web-site training.gov.au, a joint initiative of federal and state governments, including Western Australia, states that:

This unit of competency specifies the outcomes required to estimate materials, overheads, labour and time requirements and establish costs for the provision of products and services for construction work.

The unit supports tradespersons and those in independent construction job roles to cost a construction project or part of a construction project. It applies to construction work on residential and commercial sites.

A person demonstrating competency in this unit must satisfy all of the elements, performance criteria and foundation skills of this unit. The person must also cost three different construction jobs, where the costing includes:

  • estimating quantities of material required
  • determining the types and amount of labour required to complete the work
  • estimating time required to complete the work
  • estimating overheads associated with the work
  • totalling all costs and applying profit margin to establish a client quote.

In doing the above work, the person must:

locate, interpret and apply information, standards and specifications relevant to estimating and costing work
calculate final cost for the work and prepare a written quotation for each of the work requirements.

Knowledge Evidence
A person demonstrating competency in this unit must demonstrate knowledge of:

  • accuracy and detail required in costing estimates for construction work
  • construction terminology used in plans and specifications for construction work
  • contents and impact of job safety analyses (JSA) and safe work method statements (SWMS) on costing construction work
  • environmental and sustainability requirements relevant to the costing being determined
  • procedures for applying the Goods and Services Tax (GST) to costings
  • procedures for determining wages and overhead costs relevant to a quotation for construction work [such as awards]
  • international system of units (SI) of measurements relevant to the construction industry
  • process of estimating and costing construction work
  • quality requirements of construction projects and their impact on time required for completion
  • relevant statutory and authority requirements related to estimating and costing construction work
  • sources of information on material requirements and processes for calculating them
  • standards applicable to the work being costed, such as Australian standards and those in the National Construction Code
  • terms and content of relevant contract documentation to inform estimate.

Therefore, it is clear that this unit is not just for first year apprentices, as has been stated and asserted by some training providers and organisations.

It is mandatory that all training organisations, including TAFE, train all apprentices to the above standards and competencies. If anyone is aware of apprentices who are not being taught how to perform the above skills and are not being taught the above required knowledge, we ask them to report the training provider to the National Painting and Decorating Institute for referral to the Training Accreditation Council, Western Australia's Vocational Education and Training (VET) Regulator for investigation and possible breach of the Vocational Education and Training Act 1996.

It is for the above reasons that the National Painting and Decorating Institute has recommended to the Department of Mines, Industry Regulation and Safety and to the Minister Sue Ellery MLC that this unit be used to replace CPCCBC4004A Identify and produce estimated costs for building and construction projects as a requirement for painters registration. No valid arguments have been provided either to the Department or the Minister as to why apprentices need to be forced to study estimating again in order to become registered. In no other state are painters required to study estimating twice in order to be licenced or registered. It is an absurd waste of tax payer funds, and time.

52921WA Course in Painters Registration - A risk to the industry and the public

This course has been submitted as a suitable qualification for registration under Pathway 2. It is not recognised as a qualification by the broader painting industry anywhere outside a small area in Western Australia, because it is not a suitable course and does not meet the needs of the industry in 2024. This course does not include any training or assessment in working at heights, scaffolding, EWPs, lead paint removal, or the identification and encapsulation of deadly asbestos. It does not even include an assessment of basic painting skills. It is wholly unsuitable as a technical trade test, and poses an unacceptable risk to employees, employers, and the general public.

Persons getting registered under Set 2 Pathway have not had any training in high risk activities such as the erection of scaffolding, working at heights, or the identification and treatment of hazardous materials such as lead and asbestos.

In a recent survey undertaken by the National Painting and Decorating, 88% of painters surveyed in Western Australia stated that only fully qualified painters should be allowed to get registered.

Therefore the National Painting and Decorating Institute recommends the deletion of Set 2 as an acceptable pathway to registration.

Mandatory Trade Certificates - an unviable option

Some within the painting industry are calling for and advocating that only persons who have a Trade Certificate should be able to become registered or qualified. To be clear, Trade Certificates are NOT a qualification.

The reason why some TAFEs and RTOs want to do this is so that they can then lobby the government to only allow them to issue qualifications recognised for a Trade Certificate.

A trade certificate may be issued by the Western Australian Department of Training and Workforce Development (the Department) to an individual who has achieved an apprenticeship qualification if the individual has:

 completed the qualification via a training contract registered in Western Australia (apprenticeship);

 met the Department’s trade skills recognition (TSR) requirements; or

 completed a qualification that is recognised within the Australian Qualifications Framework (AQF) in an Australian state or territory other than WA. The qualification must be equivalent to a qualification on the Classification of prescribed vocational education and training qualifications in WA with the title of apprentice, and must have been achieved through an employment-based training arrangement.

Certain organisations that claim to represent the industry want to limit which RTOs are approved to conduct RPL for the purposes of registration, perhaps because they would then lobby the government to only allow their RTO to issue painting qualifications.

That is really what this is all about; restricting who can conduct assessment. It has nothing to do with the quality of assessment; its about them controlling the training purely for commercial interests.

Many painters in Australia have received their qualification from an RTO that cannot issue WA Trade Certificates. Maybe they got qualified interstate, or completed gap training and Recognition of Prior Learning. Even though the qualifications are nationally recognised and identical, they would then be forced to pay extra to these 'approved TSR providers' to get their qualification recognised as legitimate. It is extra regulation for no benefit to the industry.

Most painters who got qualified interstate would need to pay extra to be reassessed in exactly the same qualification they already have.

This is completely unnecessary because the requirements for obtaining the Certificate III Painting and Decorating qualification are identical for all RTOs.

In addition, RTOs registered in WA cannot train anyone in Certificate III Painting and Decorating unless they do an apprenticeship, so even if the person failed the RPL assessment they would not be able to get the gap training they need to get qualified. In WA all Class A apprenticeship qualifications can only be conferred through completion of a training contract in WA, or via RPL. It is an offence for RTOs registered in WA to provide training for Class A qualifications outside of a training contract, for the purpose of conferring the qualification.

Therefore, this would not improve the standard of training in the industry; it would ensure that people who need training will never get it and never be able to get a Trade Certificate and registered.

Making Trade Certificates mandatory would effectively limit registration or qualifications to persons who had been trained by a very limited number of RTOs, or had paid to be reassessed.

Surveys taken of registered painters in Western Australia by the National Painting and Decorating Institute have shown that approximately 50% of registered painters have never completed an apprenticeship. Nationally, less than 50% of qualified painting trades workers complete an apprenticeship.

Mandating Trades Certificates would:

  • severely limit the numbers of painters who would be able to get registered as supervisors. Most highly experienced and qualified painters who migrate to Western Australia to fill the skills needs would not be eligible to ever work as a supervisor or start their own business, because they got qualified at a college that is not a 'approved TSR provider'. It would exacerbate the skills shortage that already exists in the industry.
  • Encourage painters to get licenced in other states and then apply for Automatic Mutual Recognition in order to be able to work in WA. Painters who apply for Automatic Mutual Recognition would not need to complete the business units and therefore be unaware of WA Building Services (Registration) Regulations 2011. This would lead to an increase in non-compliance with the regulations.


A painter with 25 years experience and 15 years as a supervisor obtains his qualification via a gap training and assessment program for Certificate III in Painting and Decorating. He gets a job offer in Western Australia as a supervisor and moves to WA. After 3 months his employer asks him to apply for registration so that he can be a registered supervisor for the painting contractor. He discovers that since he doesn't have a 'WA Trade Certificate' he is not eligible to apply for registration. He is told that the only way he can get a 'Trade Certificate' is to be reassessed by a 'approved TSA approver'. This means he needs to take time off work and travel to a college to be assessed by an 'approved TSA approver' to prove that he is competent in a qualification he already has.


A qualified painter from the U.K. arrives in Australia on a skills needs visa. After working in Australia for 10 years he has permanent residency and wants to get registered. He discovers that he needs a 'WA Trade Certificate' to get registered. To get the 'WA Trade Certificate' he needs to be assessed for RPL by a 'approved TSA provider'. He does the RPL assessment and is told he doesn't pass because he has not been trained in asbestos encapsulation and lead paint removal. He is then told that the RTO who did the assessment is not allowed to provide him with gap training so that he can complete the qualification.

In a recent survey undertaken by the National Painting and Decorating, 67% of painters surveyed in Western Australia stated that painters who got qualified, ie. obtained Certificate III Painting and Decorating, through alternate pathways to an apprenticeship should be allowed to get registered.

All of this is completely unnecessary because:

  • All Certificate III Painting and Decorating qualifications issued by RTOs are nationally recognised and MUST be recognised.
  • The Painters Registration requirements already have a built in mechanism to ensure that only painters with industry experience can get registered. The minimum 4 year experience requirement ensures that only painters that have obtained industry experience over a 4 year period can apply for registration.

How do we improve the WA Painting industry?

In summary there are five things which should be adopted by the government if we are to improve the industry in Western Australia. These are:

  • Ensure all apprentices and painting students are fully trained in estimating and quoting as per the required skills and knowledge in CPCCCM3005 Calculate costs of construction work. Short cuts, and ignoring the requirements of this unit are not acceptable. RTOs who deliver training to apprentices in WA must be held accountable if they are not adequately training apprentices in estimating.
  • Remove the Set 2 pathway to registration, which has led to unqualified and under-trained painters gaining registration, risking their safety and the safety of the general public. This will raise the technical skill requirements.
  • Remove the restrictions on RTOs in WA being able to conduct gap training for experienced workers who want to get trained and qualified without having to go back to being an apprentice, just as is possible in every other state and territory.
  • Replace the estimating unit in the Course in Painter's Registration with the nationally recognised unit CPCCCM3005 Calculate costs of construction work, which will ensure that painters who got qualified prior to 2021 are trained in estimating, and that fully qualified apprentices that got qualified after 2021 do not need to spend extra time and money redoing subjects they have already completed.
  • Ensure that tax payer money is not spent on duplicating training that has already been provided, or on red tape, but is instead spent on actual improved training.

Focusing on actual outcomes instead of narrow commercial interests and protectionism will help the Western Australian painting industry thrive in the 21st century.

For more information on training, apprenticeships, and business development for painting contractors contact the National Painting and Decorating Institute.


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