The National Quality Framework Consultation Regulation Impact Statement (CRIS) is currently under consultation. In this survey we ask questions about key issues related to safety, health and wellbeing which are being addressed in the CRIS. The key areas covered are transition between services, sleep, transport and multi storey buildings.


Safety of children during transitions between services 

Many children go missing each year transitioning between services, particularly in school and out of school hours care. Options for change that have been examined include legislative requirements to require either schools or services to supervise, national regulations and/or guidance.

There are a small number of gaps between the National Principles for Child Safe Organisations and the NQF. Key areas requiring strengthening regard volunteers, online environments including video surveillance and the role of organisational culture in reducing children’s exposure to the risk of abuse. Options proposed range from aligning assessment, requiring policies and procedures to meet the principles and amending the regulations to address the gaps.

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* 1. What measures do you currently use to mitigate the risk of children going missing?

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* 2. Are missing children a significant risk in your service?

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* 3. How would you respond if the duty of care for children transitioning between services was made a legislative responsibility of ECEC/Out of school hours care?

Sleep and rest requirements

Although Approved Providers must ensure that the service has in place policies and procedures in relation to health and safety, there have been 7 sleep related deaths in early childhood education and care since 2011 and a recent study shows most services breach sleep guidelines at times. This may place children at a higher risk of SIDS. Options for change range from training, guidance, policies and procedures and risk assessments to legislative change to require that sleeping and resting children in education and care services are within sight and hearing distance of an educator at all times.

We are seeking feedback to understand whether all options have been explored, and to ensure measures implemented best reduce the risk of harm.

In Centre based care at least 50% of educators are required to have or be working towards a diploma level qualification with other staff counted in ratios required to be at least working towards a Certificate III. There is currently no time limit on actively working towards nor requirements on what satisfactory progress through a course is. Options proposed include setting a proportion of staff that must be qualified, setting time limits on how long educators can work towards and setting guidance or introducing thresholds around satisfactory progress.

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* 4. What practical measures would support you to ensure the safety of children during sleep and rest?

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* 5. Would it be feasible for you to have an educator supervising sleeping children at all times?

Improving children’s safety during regular transportation 

There is a heightened risk of harm to children during transportation. This risk is both during transportation and the period of embarkation/disembarkation. New regulations have been implemented requiring a risk assessment for services transporting children and written authorisations. It is currently unclear how centre based educator ratios should apply during transportation. Options for change include introducing ratios requirements for travel (and potentially excluding school aged children from these requirements), introducing a ratio for embarkation and disembarkation, legislative requirements for drivers to undertake training such as first and or guidance and risk assessments regarding transport.

We welcome feedback from members who transport children regularly.

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* 6. What additional training should the driver of a vehicle have (such as first aid, anaphylaxis, asthma management etc)?

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* 7. Should ratios be applied to transport?

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* 8. If ratios are applied, should the driver be included in ratio calculations?

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* 9. If adults are supervising transport, should they hold qualifications?

Improving children’s safety during emergency evacuations from multi storey buildings

Although a minority of services are in a multi storey building, they pose a significant evacuation risk. Around 13% of all confirmed breaches of the National Regulations relate to emergency and evacuation procedures so the likelihood of harm arising is significant. There are added complexities in Victoria and the ACT, whereby buildings can meet planning approval but not service approval due to evacuation procedures, natural light and outdoor spaces. Options relate to amending emergency and evacuation requirements to expert oversight of evacuation drills, pre-approval of services, and strengthened building approvals.

We welcome feedback from services in a multi storey building.

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* 10. Do you believe further guidance in the NQF on the nature and content of emergency and evacuation procedures would assist you to better meet the national regulations?

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* 11. What other suggestions do you have regarding evacuations and emergency procedures?

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* 12. Your details

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* 13. State

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* 14. Where is your service located? 

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* 15. Service type

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