Opinion of the Economic and Social Committee on the 'Proposal for a Council Decision on the promotion of European pathways for work-linked training, including apprenticeship'
10. 7. 98 EN Official Journal of the European Communities C 214/63 Opinion of the Economic and Social Committee on the ‘Proposal for a Council Decision on the promotion of European pathways for work-linked training, including apprenticeship’ (98/C 214/16) On 3 February 1998 the Council, acting in accordance with Article 127 of the Treaty, asked the Economic and Social Committee for an opinion on the above-mentioned proposal. The Section for Social, Family, Educational and Cultural Affairs, which was instructed to prepare the Committee’s work on this matter, adopted its opinion on 16 April 1998 (rapporteur: Mr Dantin). At its 354th plenary session (meeting of 29 April 1998) the Committee adopted the opinion set out below by 115 votes to one, with five abstentions. 1. Introduction 1. 1. The recent Commission communication on the promotion of apprenticeship training in Europe (1) drawn up at the request of the European Council held in Florence (June 1996) highlighted the importance of apprenticeship and work-linked training in general. 1. 2. The Committee’s opinion on the above- mentioned communication (2) welcomed its innovative provisions whilst expressing a number of reservations and putting forward some proposals, particularly with regard to the mobility of apprentices. 1. 3. The draft Council decision, which seeks to promote European pathways for work-linked training, including apprenticeship, is thus an opportune develop- ment. 1. 4. As is pointed out in the explanatory memoran- dum, in the context of the completion of the single market and, more generally, that of the building of a Europe without frontiers, trainee mobility is becoming an increasingly important dimension of European citi- zenship, as well as an instrument of multi-cultural and social integration. 1. 5. Whilst respecting Member States’ prerogatives in respect of the content and organization of their vocational training systems and structures, the draft Council decision sets out measures which apply to vocational training systems and structures providing for work-linked training including one or more elements of mobility. The proposal has a twofold objective: — to define the content and common underlying prin- ciples in respect of training periods spent in another Member State, as part of work-linked training, (1) COM(97) 300 final. (2) OJ C 95, 30. 3. 1998. where such training forms part of the course taken by the trainee in his home Member State; — to enhance the profile of such training periods by issuing a certificate (the Europass-training certifi- cate); the content and lay-out of this certificate, which validates the training or work experience acquired in another Member State, are defined at EU level. 1. 6. The Commission takes the view that the estab- lishment of ‘European pathways’ and the introduction of the ‘Europass-training’ certificate should, in turn, promote the development of work-linked training and apprenticeship in the Member States in the broader context of the policies designed to bolster growth, competitiveness and employment. 2. General comments 2. 1. The Economic and Social Committee broadly endorses the draft Council decision; it does, however, believe that the scope and some operational aspects of the proposal should be amended (see point 3 below). In line with its Opinion on the Commission’s 2. 2. Communication entitled Promoting apprenticeship training in Europe, the Committee endorses the view that work-linked training — and in particular appren- ticeships — makes it easier for people to find jobs, promotes employment and boosts recognition of EU citizenship and fosters freedom of movement. In the abovementioned opinion the Committee 2. 3. pointed out that it ‘awaits with interest the draft instrument intended to lead to the drawing-up of a common legal framework with a view to promoting apprenticeship training in Europe. A common legal framework of this kind should lay down guarantees with regard to working and training time, material C 214/64 EN Official Journal of the European Communities 10. 7. 98 conditions (lodging, meals, tuition, quality criteria) and social and legal cover. More generally, the legal framework should mitigate or even eliminate altogether the various difficulties in relation to intra-Community training pinpointed by the ESC in its Opinion on the Commission Green Paper on Education, training and research — the obstacles to transnational mobility’ (1). With this aim in view, particular attention should be paid to the recognition of intra-Community diplomas awarded in connection with apprenticeship training and work-linked training in general, particularly in relation to new sectors. 2. 4. The Committee’s appraisal of the draft decision must therefore be seen in the context of the comments made in its previous opinions. 3. Specific comments 3. 1. The Committee approves, in principle, the estab- lishment of the ‘European pathways’ and the introduc- tion of the ‘EUROPASS-training’ certificates, but urges that this proposal should not be regarded as an end in itself; the aim should be to maintain and increase the momentum created by the proposal. Despite its appeal, the proposal cannot be regarded, in itself, as an adequate response to the need to promote work-linked training, including apprenticeship, in the EU, and the requisite international mobility. In the Committee’s view, the draft decision does not go far enough. Such a decision could not under any circumstances define the status of ‘apprentice’ or set out how mobility is to be implemented. The political scope of the decision is limited; in reality it is a purely technical instrument, merely extending the Leonardo programme to include work-linked training, including apprenticeship, whilst at the same time re- solving some of the problems arising between host countries and the countries in which students are following work-linked training courses. In addition to the draft decision, it is therefore necessary to continue the appraisal (see Opinion No CES 110/98) and to draft proposals which will take us further along the road towards realising and implementing this concept. Steps should however be taken to ensure that the measures taken do not reduce the number of work-linked training places available; they should, on the contrary, create additional training places, over and above the existing ones. earlier that whereas the The Committee regrets the fact Commission’s communication focused on apprenticeship, the draft decision under review covers the broad swathe of work-linked training, including apprenticeship. This will create a distortion between the appraisal carried out and the implementation of the (1) OJ C 129, 27. 4. 1998. appraisal because of the difference in the scope of the two measures. This situation blurs the case for a comparative assessment, especially since — by virtue of its principles and functioning — apprenticeship must be distinguished from other types of work-linked training in a number of states. 3. 2. The Committee takes the view that the draft decision represents only a small step towards the establishment of the legal framework which it has advocated. This assessment applies (a) to the definition of the training and (b) to the allocation of the various areas of responsibility. In its proposal the Commission should have spelt out individual tasks and responsibili- ties. Despite these limitations, the document does how- ever represent a first step in the development of work-related training, including apprenticeship, at EU level, whilst scrupulously respecting the responsibility of the Member States for the content and organization of vocational training (Article 127 of the EC Treaty). 3. 3. Whilst the proposed introduction of ‘Europass Training’ is a legal instrument which will remove a number of obstacles to mobility, it will achieve this goal only in a piecemeal and haphazard way. 3. 4. This is illustrated by Article 3(1) which stipulates that ‘Where Member States provide in their vocational training system for work-linked training, including an element of mobility in another Member State, they shall adopt the necessary measures so that those persons concerned in training can benefit from “European pathways”. ’ (bold type added by rapporteur). The Committee takes the view the ‘Europass Training’ should be available in all the EU Member States without exception. To this end, the Committee calls upon the Council to urge the Member States to incorporate in their work-linked training and apprenticeship schemes the possibility of a period of training in other EU Member States, where this is not already the case. The Committee also makes the following proposals to the Commission: — that it extend the legal basis of its proposal beyond the provisions of Article 127 of the Treaty. Consider- ation of Articles 48 and 51 of the Treaty could prove beneficial in this respect; — that it consider making EU rules on free movement of workers and students, applicable to the proposal; this applies in particular to the right of abode, right to work, safety and social protection; — that persons participating in the Europass Training scheme be regarded as students, within the meaning of Directive No 93/96/EEC on students’ right of abode, thereby enabling them to benefit from the provisions of that Directive. 10. 7. 98 EN Official Journal of the European Communities C 214/65 3. 5. At all events, the Committee expresses both its surprise and disapproval at the proposal to confine the Europass-training system to persons whose home Member State gives de facto recognition to work-linked training, including apprenticeship, which includes a period of training in another Member State. 3. 6. The Committee reiterates its calls for a legal framework to be established which ensures de jure equality between persons undergoing training, irrespec- tive of which Member State they come from and makes a significant contribution to removing obstacles to the pursuit of training in another Member State, in particular, by recognizing intra-Community certificates over and above the Europass-training certificates. 3. 7. It is deplorable that the draft decision fails to list — and define — a number of quality criteria and reference criteria which would make intra-Community certificates awarded for work-linked training, including apprenticeship, more transparent and facilitate their recognition, without jeopardizing the responsibility of the Member States, as defined in Article 127 of the EC Treaty. In addition to validating qualifications, such a joint identification system should spell out: — the objectives of the EU training pathways (the abilities and skills to be acquired, etc. ); — the broad thrust of the European pathways (what aspects should be particularly highlighted, what should be the goal of European training, etc. ); — validation procedures; the aim should be to endorse a component or a module of the overall training pathway. This identification, like the validation, must be differen- tiated according to whether it relates to apprenticeship or work-linked training, and involve the participation of public or private bodies which manage work-linked training or apprenticeship in a number of Member States. A certificate should be issued testifying that the holder has acquired specific skills; the certificate should be recognized throughout the EU. to take on any persons following a course of work-linked training, including apprenticeship. Such a scheme would lend credibility to the development of mobility, whilst making it easier to regulate the flow of exchange trainees. 3. 9. There is also a need to remove the ambiguity by spelling out the legal means for ensuring that the Europass-training scheme would be applicable to all EU Member States, without exception. This requirement would not clash with the voluntary nature of this scheme. that 3. 10. the The Committee would point out proposed budgetary proposals make no provision for funding the actual operation of the Europass-training scheme. The Committee is thus unable to give its views on the financial feasibility of the proposal. It is essential to make budgetary provision for the operation of the scheme, either through the direct allocation of funds, or by providing funding under the Leonardo or Erasmus programmes — though not at the expense of those programmes; such measures would lend credibility to Europass and would give it a good chance of being implemented. This is particularly important in view of the ‘significant duration’ requirement for European pathways (Article 3) which, the Committee construes as a minimum duration of three weeks; the duration should vary in line with the specific nature of the occupation involved and of training content. 3. 11. The Committee also has its doubts about the scope of the Erasmus programme, which covers the right of abode and right of study of university students. The Committee calls for an appraisal to be carried out and proposals to be put forward for the purpose of extending the Erasmus programme to secondary students, and, perhaps, to all persons with employment contracts for work-linked training. The Committee would be very interested in the establishment of an Erasmus programme for apprentices. The Committee is surprised that no specific 3. 12. provisions have been made in respect of SMEs and the craft sector, despite the fact that they have a central role to play in the system of work-linked training, including apprenticeship, and are crucial for the development of this system. The Committee takes the view that simplifying and abbreviating the application procedure for EU aid would represent an important step towards involving SMEs. It is vital that the social partners be involved throughout this process. Such participation is a prerequisite, in each of the Member States, for the success of planning including Europass measures in respect of training, Training. 3. 13. In order to ensure more effective utilization of Europass Training, the certificate should be drawn up in three EU languages: — the language of the trainee’s home Member State; The Committee would also reiterate its proposal 3. 8. that grants be given to enterprises which are prepared — a third EU language. — the language of the host Member State; C 214/66 EN Official Journal of the European Communities 10. 7. 98 3. 14. The Committee calls upon the Commission to draw up an appraisal report after the Europass-training scheme has been in operation for two years. The Committee would like the report to be referred to it for its opinion. 4. Conclusions 4. 1. The Committee has issued a number of opinions on the general subject of vocational training. The Committee’s appraisal of the draft Council decision takes account of these earlier opinions. 4. 2. The Committee takes the view that, although a significant number of questions have yet to be answered, the draft Council decision is a step in the right direction; it does, however, fall far short of constituting an acceptable vehicle for implementing the views expressed earlier by both the Commission and the ESC. 4. 3. The Committee urges that this proposal should not be regarded as an end in itself; it does in fact represent only a small step towards the establishment of the legal framework, in particular the specific legal framework for apprenticeship, advocated by the Committee. 4. 4. Moreover the proposal must not exclude EU citi- zens solely on the grounds that the domestic legislation in their country makes no provision for intra-EU training. 4. 5. The Committee would ask the Commission to pursue its appraisal with a view to drawing up a legal framework, in line with the terms of its communication Brussels, 29 April 1998. on the promotion of apprenticeship training in Euro- pe (1). The objective should be to promote the mobility of apprentices and the recognition of diplomas (CES 110/98). The Committee awaits with interest the out- come of this overall appraisal. The Committee considers it necessary to avoid dispersion of resources and proposes adoption of an effective overall strategy for apprentice- ship, in the form of an internally consistent package of measures for promoting and developing apprenticeship. This system should be introduced in the Member States where it does not yet exist. The Committee urges the Commission to lose no time in extending the legal basis of its proposal to embrace Articles 48 and 51 of the Treaty and Directive No 93/96/EEC on the right of abode of students. in 4. 6. On the subject of Europass Training, particular, the Committee takes the view that the ‘significant duration’ should be a minimum of three weeks; it calls for appropriate budgetary provision in order to guarantee the scheme a minimum of credibility. 4. 7. The Committee recalls that the development of mobility and the success of the Europass scheme hinge on participation in the development and monitoring of the scheme by all the relevant public and private operators involved in work-linked and apprenticeship training. The Committee also considers that the mobility must concern not only persons in training but also those providing that training. (1) COM(97) 300 final. The President of the Economic and Social Committee Tom JENKINS