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I kind of disagree with your comment on ACS.
What in your opinion would be a reliable test of competence?
No problems with your well-made points Graham. But I can offer a better, more valid way of assessing competence, and its been used since we were hunter gatherers.
Its called clinical observation. If I wished to have an adequate understanding of your competence, I would not invite you to a training centre.
I would want to observe your performance in different work contexts. I could assess your 'know how', knowledge and performance without saying a word to you. It would take a couple of days at the most.
If I wished to accertain your understandings of abstract (written) knowledge, I could verbally question you, while you are working - but this knowledge often has limited use in work situations for most technicians.
I could offer more technical faults with competency and competence, with regard to what they mean and how they are defined, but I know one thing for sure - the current system does not test understanding, or knowledge or performance because they are tested in simulated environments - so they immediately contradict any sort of claim to 'competence' because this can only be tested in real situations - would we be happy with surgeon working on our families, that have only practised on dummies - I doubt it. Would we be happy flying with pilots that had only learned on simulators...probably not.
It has become a belief that we can be trained in these situations, but really we only start learning on the job...we all know this for sure. So apprenticeship is the most reliable system - all other routes are a short-cut to this, and hence questionable as to their reliability and validity.
This is a well documented area of discussion, and the Germans don't buy it - that is almost good enough for me!