There’s Much For The ECE Profession And Public To Be Worried About – Analysis Of The ECE Regulations Report

Minister Seymour has released the report of the Ministry for Regulation on its regulatory review of the ECE sector.

Chief advisor to the OECE, Dr Sarah Alexander said that the terms of reference for the review meant that the advice provided by the Ministry for Regulation to Minister Seymour would be biased.

“The terms of reference did not allow for a strong focus on children and on the improvement of early childhood service provision for children’s care and education. (See also https://oece.nz/public/news-and-views/stories/ece-regulation-changes-2024-seymour/ )

“The Ministry for Regulation have done good work analysing a wide range of responses about a very complex sector. They have tried to take a wider perspective, as their report for example supports the vision of the Early Learning Action Plan put in place by the previous government that had many good things in it. So why would the Minister want to dump it?”

Dr Alexander said that Recommendation 10 of the report was most worrying.

Recommendation 10 is: “allow greater flexibility in workforce qualifications… Because of the costs and time of gaining qualifications to workers that they may not gain if they were not required and because of the limited role workers can have in the sector if they do not have a bachelors degree.”

Dr Alexander notes that "unqualified workers in primary and secondary education have a limited role because they do not a bachelors' degree, but no-one is suggesting that school teachers should not be appropriately qualified."

The OECE’s Early Childhood Advisory Committee (ECAC) had given the Education Minister and Associate Minister for Education advice on building a sustainably supported and qualified early childhood teacher workforce – but that advice had been ignored. (See: https://www.scoop.co.nz/stories/ED2412/S00040/lack-of-strategy-for-addressing-long-standing-early-childhood-workforce-problems-hurts-childrens-education.htm)

“If you lower qualification requirements and remove ECE qualified and certificated teachers from services, then there will not be people on the ground who know what best practises are and importantly have the understanding and skills to implement best practices appropriately. (See the article NZ Research Shows the Benefit of ECE Qualified Teachers 100% on the OECE website)

“Not having ECE qualified and certificated teachers in services along with removal of a number of really important requirements for child education and safety (see the list below) would multiply risk for children,” she said.

Dr Alexander is also concerned that the Government intends to remove the Health (Immunisation) Regulations 1995 requirement to keep an immunisation register of children attending without adding new requirements to the early childhood regulations to make sure that ECE services will still meet the intentions of the 1995 Health Regulations (to promote the immunisation of children against disease, encourage caregivers to make an informed choice regarding the immunisation of their children, and to facilitate disease control).

The Office of ECE has previously discussed with government officials that ECE staff are falling through a vaccination policy gap and steps must be taken to support awareness and record keeping because many children attending ECE services are too young to be fully protected against vaccine-preventable diseases. (see: https://oece.nz/public/information/resources/vaccination-immunisation-staff/ )

But First There Must Be Consultation

The Ministry for Regulation’s report notes that under regulation 41(1) of the Education (Early Childhood Services) Regulations 2008, sector consultation is required before changes (amendments, additions, or revocations) are made to the licensing criteria.

Dr Alexander would like the Minister for Education, Erica Stanford, to provide the public with an assurance that Minister Seymour will:

1. extend consultation to the public because ECE is a public good,
2. not put through any changes that cannot be shown to be consistent with children’s rights, and
3. that no requirements will be removed or changed that are inconsistent with the best evidence from research and practice on what produces good quality ECE.

“We would like to know that both Erica Stanford and David Seymour have read the submissions made by the OECE, the ECE Parents’ Council, OMEP, the Children’s Rights Alliance, and NZEI.

“We hope after reading the submissions that they decide to make a long-overdue switch in focus from seeing ECE as a business to seeing ECE as a valuable service for children, families, and our society,” Dr Alexander said.

The final report from the Ministry for Regulation notes that ECE is a 'merit good'.

The Office of Early Childhood Education’s submission can be viewed at https://oece.nz

Requirements identified for axing in the Ministry’s report

The requirements identified for removal will increase risk of unsafe and lower quality education and care for children and poorer working environments for staff, unless the requirements can be covered elsewhere.

For example, will the Building Code be amended to included that ECE centres must have a toilet of suitable size and that provides privacy for adults? Will the Building Code be amended so that in ECEs the temperature of water out of taps accessible to children is limited so children cannot be scalded by hot water? (Learn what can happen in a centre: https://oece.nz/public/big-issues/death-injury-prevention/childcare-safety-standards-quality-ministry-education/ ).

Other requirements on the list to be axed are:

• Designated assembly areas for evacuation purposes outside the building keep children safe from further risk. (HS5)
• Adults providing education and care engage in meaningful, positive interactions to enhance children’s learning and nurture reciprocal relationships. (C3)
• The practices of adults providing education and care demonstrate an understanding of children’s learning and development, and knowledge of relevant theories and practice in early childhood education. (C4)
• Acknowledge and reflect the unique place of Māori as tangata whenua. Children are given the opportunity to develop knowledge and an understanding of the cultural heritages of both parties to Te Tiriti o Waitangi. (C5)
• Respect and supports the right of each child to be confident in their own culture and encourages children to understand and respect other cultures. (C6)
• Inclusive, and responsive to children as confident and competent learners. Children’s preferences are respected, and they are involved in decisions about their learning experiences. (C7)
• Provide a language-rich environment that supports children’s learning. (C8)
• Provide children with a range of experiences and opportunities to enhance and extend their learning and development – both indoors and outdoors, individually and in groups. (C9)
• Support children’s developing social competence and understanding of appropriate behaviour. (C10)
• Positive steps are taken to respect and acknowledge the aspirations held by parents and whānau for their children. (C11)
• Regular opportunities (formal and informal) are provided for parents to communicate with adults providing education and care about their child, and share specific evidence of the child's learning and be involved in decision-making concerning their child’s learning. (C12)
• Parents of children attending the service and adults providing education and care are provided with opportunities to contribute to the development and review of the service's operational documents (such as philosophy, policies and procedures and any other documents that set out how day to day operations will be conducted). (GMA4)
• Information and guidance are sought when necessary, from agencies/services to enable adults providing education and care to work effectively with children and their parents. (C13)
• There are hygienic facilities for washing children that are not used for the preparation and cleaning up of paint and other art materials (alternatively there is an art sink) (PF 10).
• A philosophy statement guides the service's operation. (GMA5)
• An annual plan guides the service's operation. (GMA8)
• An annual budget guides financial expenditure. (GMA9)
• There is an ongoing process of self-review and internal evaluation to help the service maintain and improve the quality of its education and care. (GMA6)
• Suitable human resource management practices are implemented and documentation is required. (GMA7)

Eleven requirements are on the list to lose their significance as they will be merged into other existing requirements PF2, PF15, PF20, PF21, PF22, HS6, HS11, HS15, HS20, GMA3, GMA11

Forty requirements are on the list to be loosened so these will be easier for service providers to meet: PF1, PF4, PF9, PF12, PF13, PF14, PF16, PF18, PF19, PF28, PF29, PF30, PF31, PF32, PF33, PF34, PF35, PF36, PF37, PF38, HS1, HS2, HS8, HS9, HS10, HS14, HS16, HS17, HS21, H22, HS24, HS26, HS27, HS28, HS29, HS31, HS34, GMA1, GMA2, GMA10

The only licensing criteria that are proposed to be retained as is are: C1, C2 PF3, PF5, PF6, PF7, PF8, PF11, PF17, PF25, PF26, PF27, HS3, HS4, HS7, HS12, HS13, HS18, HS19, HS23, HS25, HS30, HS32, HS33, GMA7A, GMA12.

© Scoop Media