An article from Worksafe QLD.
The Work Health and Safety Regulation 2011 (the WHS Regulation) sets out specific control measures for construction workers when there is a risk of fall from height.

These control measures will be required for work below three metres in housing construction, and below two metres for all other construction work, if a risk assessment identifies they are needed. Inspectors will take enforcement action if there is an uncontrolled risk a worker could fall. This could include issuing an improvement or prohibition notice.

In some cases, the risk can be eliminated by completing the work on the ground or on a solid structure. If this isn’t possible, the risk can be minimised using:

• fall prevention devices (such as fences and edge protection)
• work positioning systems (such as an elevating work platform)
• fall arrest systems (such as safety nets and harnesses).

The WHS Regulation outline duties that apply to working at heights. This includes specific requirements and ways to manage the risks of falls. For further information, refer to the Managing the risk of falls at workplaces code of practice 2021 (PDF, 3.9 MB).

Construction work that involves the risk of people falling more than two metres is considered high risk construction work and the person conducting a business or undertaking must prepare a safe work method statement (s.291 and s.299). This applies to all construction work, including housing construction work.

Further information

Formworkers play a crucial role in the construction industry, involved in shaping the foundation and structures of various projects. However, compliance with the safety training requirements outlined in the Work Health and Safety (WHS) Act can be a challenging aspect for these skilled workers. In this article, we will explore the difficulties faced by formworkers in meeting the training mandates set forth by the WHS Act and propose potential solutions to bridge the gap.

Challenges Faced by Formworkers

1. Lack of Accessible Training Programs
   One of the primary hurdles faced by formworkers is the limited availability of accessible training programs that cater specifically to their needs. As their responsibilities and tasks may differ from other construction roles, formworkers often require specialised training, which is not always readily available.
2. Cost Barriers
   Completing training courses can be expensive, and this financial burden is a significant challenge for many formworkers, especially those working in smaller construction firms or as independent contractors. The cost of training, along with potential time off work, can create barriers to compliance.
3. Time Constraints
   Formworkers often work in demanding environments with tight project schedules. Finding time to attend training sessions can be problematic, and employers may face difficulties releasing workers for training without affecting project timelines.
4. Language and Literacy Barriers
   For some formworkers, English may not be their first language, and they may encounter difficulties in understanding complex training materials, assessments, and instructions. This language barrier can hinder effective learning and comprehension.
5. Limited Recognition of Prior Experience
   Experienced formworkers who have been in the industry for years may find it frustrating that their practical knowledge and skills are not adequately recognized for training compliance. Some training programs may not offer suitable avenues to assess and credit their existing expertise.

Proposed Solutions

The recently released 'Australian Work Health and Safety Strategy 2023-2033' states that companies need to make sure that, on their projects, there is 'meaningful and relevant training for workers delivered in a way they can understand'.

It supports the continuation and strong focus on compliance and enforcement by regulators, with a particular focus on systematic work health and safety (WHS) management. If you don’t have meaningful and relevant training and cannot demonstrate robust WHS management, the risk is that the safety regulators will investigate the quality of your systems, including training and competency, to hold companies and individuals accountable.

WHS laws are risk based and don’t need an incident to occur for a business and its individuals to be liable. It is every employer’s responsibility to make sure their workers get the training, instruction and support they need to keep them safe at work.

The Formwork Industry Association (FIA) in conjunction with their members have developed a new education and skills pathway to overcome the challenges faced by Formworkers. Addressing the compliance issues the initial ‘Safe Formworker Program’ has been designed to provide the following features to ensure construction, civil and formwork companies can comply with their obligations.

1. Tailored Training Programs
   The Safe formworker program is a specialised WHS training program exclusively for formworkers that address their specific needs and challenges. The program covers essential safety protocols, techniques, and technologies relevant to their roles. By addressing the unique needs of formworkers, this specialised training is more relevant and effective in enhancing competency and safety.
2. Government Subsidies and Support
   To alleviate the financial burden, the FIA has secured funding from the NSW Government to provide 1000 free places for formworkers' training and access to the program and App.
3. Flexible Training Delivery
   Offering flexible training options, the program is delivered via a modern mobile learning experience. It enables formworkers to complete their training without significant disruptions to their work schedules, by providing bite-sized mobile courses that can be completed in the shed during toolbox talks. The program also enables employers to support a learning culture that allows workers to upskill during quieter periods.
4. Multilingual Training Materials
   The Safe Formworker Program has been translated into Arabic and has capability to be translated into other languages. This provides training materials in multiple languages to improve accessibility and understanding for non-native English-speaking formworkers. This approach will enhance the learning experience and overall training compliance.
5. Recognition of Prior Learning (RPL)
   Creating formal Recognition of Prior Learning (RPL) processes will allow experienced formworkers to demonstrate their skills and knowledge, gaining credit for their existing expertise toward training compliance. Our new education and skills pathway for formwork will enable these RPL programs to be successful and the App has certain features that allow workers to provide on the job video of their skills.
6. Industry Endorsement
   The Safe Formworker Program is endorsed by a growing number of construction companies that have specifically named the program as an essential compliance requirement in their tender process.

Conclusion

Complying with the training requirements identified in the WHS Act is essential for the safety and well-being of formworkers and those working alongside them. By implementing the Safe Formworker Program, we can bridge the training compliance gap, ensuring that formworkers receive the necessary knowledge and skills to perform their duties safely and efficiently. Collaboration between governments, industry stakeholders, and training providers will be key to fostering a safer and more compliant construction industry.

Published by Inside Construction Magazine.

A recent article by Comcare stated a review of studies found that online work health and safety training is adaptable, affordable and effective for the prevention of injuries. It can improve workers' knowledge and skills, leading to fewer workplace injuries and accidents.

The review identified 25 studies of interventions carried out on a mobile platform, the web or both. The findings indicate that online training offers advantages to workers and assists employers to effectively monitor employee progress and to ensure that training requirements and needs are met. The educational programs covered work health and safety related topics such as office ergonomics, neck and shoulder pain, obesity, heart disease, physical activity and more.

Have you signed your workers up for the Safe Formworker Program to improve your workers knowledge, skills and prevent accidents?

If the competency of a worker is improved, improvements in safety, productivity, and quality will follow.

By implementing the Safe Formworker Program, the Formwork Industry could significantly contribute to improving training compliance among formworkers. Through a targeted and comprehensive approach, the program could empower formworkers with the knowledge and skills they need to work safely, ultimately enhancing overall safety standards in the formwork industry, leading to improved quality and productivity.

Furthermore, the program provides a vehicle to re-engage the formworker in learning and provides the first step to the newly proposed Formwork Education and Skills pathway to improve Australian formwork safety, via certified and non-certified training.

READ MORE ABOUT THE PROGRAM

REQUEST FREE ACCESS HERE

The Minister for Employment and Workplace Relations Tony Burke has announced the 12 members of the new National Construction Industry Forum.
 
The body will examine issues facing the building and construction sector, with a focus on safety, productivity, skills and training, workplace relations, industry culture, diversity and gender equity.
 
Members are: 

• Ms Melissa Adler – Housing Industry Association
• Ms Irma Beganovic – National Electrical and Communications Association
• Ms Deborah Coakley – Dexus Funds Management and the Property Council of Australia
• Mr Brent Crockford – Australian Owned Contractors
• Mr Jon Davies – Australian Constructors Association
• Mrs Alison Mirams – Roberts Co.
• Ms Naomi Brooks – Construction, Forestry, Maritime, Mining and Energy Union (CFMEU)
• Mr Tony Callinan – Australian Workers’ Union (AWU)
• Mr Steve Murphy – Australian Manufacturing Workers’ Union
• Ms Stacey Schinnerl – Australian Workers’ Union (AWU)
• Mr Michael Wright – Electrical Trades Union
• Mr Zach Smith – Construction, Forestry, Maritime, Mining and Energy Union (CFMEU) 

Mr Burke said a priority for the forum would be to look at issues around gender equity, particularly the recruitment and retention of women in the industry.
 
“I welcome the appointees to their new roles and know that their experience and insights will be invaluable as we work together to address key issues within the industry,” he said.

The makeup of new Jobs and Skills Council (JSC) for the building, construction and property sectors is expected to be announced within weeks, marking the formal establishment of all ten JSCs.

The Minister for Skills and Training Brendan O’Connor announced  five new JSCs in mid-July – Powering Skills Organisation (energy, gas and renewables); HumanAbility (early educators, health and human services); SkillsEQuipped (arts, personal services, retail, tourism and hospitality); Public Skills Australia (public safety and government); and Future Skills Organisation (finance, technology and business).

It follows the creation of four JSCs earlier in June. These were the Manufacturing Industry Skills Alliance (manufacturing); Industry Skills Australia (transport and logistics); Mining and Automotive Skills Alliance (mining and automotive); and Skills Insight (agribusiness).

“The tenth JSC will be Building Construction and Property, operated by BuildSkills Australia, and will be fully operational in coming months,” Mr O’Connor said.

“It will work closely with employers and unions to address workforce issues in the building, construction and property sectors,” he said.

“Over the initial months, the JSCs will focus on recruiting staff and establishing their operations to ensure they are best positioned to provide the highest-quality engagement with industry and stakeholders, and on developing future focused workforce plans for their industries.”

In May 2023, SafeWork NSW responded to an incident where a young worker was fatally injured after falling through a penetration that was not adequately covered on a construction site.

Construction workers risk serious injury or even death when working at heights, and these risks are greatest when there are open penetrations and voids workers can fall through.

Businesses are reminded to consider reasonably practicable control measures to manage the risk of working near penetrations and voids.

What can you do to stay safe? Ensure that:

To read more on SafeWork NSW Construction Incident Releases, see the SafeWork NSW website here.

VISIT THE FIA SAFETY PAGE ON VOIDS & PENETRATIONS

TRAIN YOUR WORKERS

Our finance and business strategy partner, HLB Mann Judd's Year-End Strategies newsletter addresses a number of topics relating to 2022/23 tax savings and end of year business planning. Some of the topics covered are working from home deductions, increases to the super guarantee, family trust resolutions & electronic signatures and your EOFY checklist.

Download

In this issue:

Your EOFY checklist

With a new financial year comes key opportunities for your business to re-strategise and plan for the year ahead. Ensuring that your business is prepared at the end of the financial year for the next year is critical to ensuring its viability.

No more shortcuts for WFH deductions

There are no more shortcuts when it comes to claiming your work-related expenses this financial year. The popular ‘shortcut’ method is no longer available for 2022-23 tax returns.

Increase to super guarantee from 1 July 2023

Over the last few years, the superannuation guarantee (SG) has been steadily increasing by a set percentage. It’s likely the super guarantee will be continuously increased to 12% gradually over the next few years (predicted to occur by 2025).

Why should you start your pension on 1 July 2023

If you’ve turned 60 during the year or are already over the age of 60, you could be in a position to save yourself a lot of tax by starting a pension from your superannuation at the start of the new financial year (1 July 2023).

Clock’s ticking on some much-used tax deductions

Tax deductions introduced by the Australian Taxation Office to lessen the impact of COVID-19 are approaching the end of their eligible timeframe. As your tax return for 2022-23 is likely to be different from the previous year due to expiring offsets, revised methods of deduction and more, make sure you take advantage of them before they’re gone (if you’re eligible for them, of course).

Don’t forget to do these critical things for super

In order to qualify for a tax deduction for the 2022-23 financial year, Super Guarantee contributions must be paid by 30th June 2023.

Family trust resolutions & electronic signatures

As we approach the end of the financial year, it is very important to consider the tax impacts of certain decisions that are made by your family trust - namely, the signing off on the family trust resolutions.

SafeWork inspectors will be targeting work at heights safety on construction sites over the next 12 months.

Falls from heights are the number one cause of traumatic fatalities on NSW construction sites – with most serious falls being from roofs, ladders and scaffolds, and from a height of less than 4 metres.

Did you know that when working on a roof, you must have temporary edge protection such as roof guard rails or scaffold in place?

Harnesses must only be used if roof guard rails or scaffold can’t be fitted.

SafeWork NSW small business safety rebate can provide eligible small businesses up to $1,000 towards the cost of safety solutions, including purchasing roof guard rails.

For more information:

Inspectors take a zero-tolerance approach to workers lives being placed at risk, and can issue on-the-spot fines of up to $3,600 for each falls risk.

See SafeWork NSW construction work at heights safety web page for more information.

As the number of complex building and infrastructure projects around the world continues to rise, Working at Height Association Chief Executive Officer Scott Barber delves into the complexities associated with height safety management in the construction industry.

Increased complexity is a challenge facing many organisations. Understanding key risks and how to apply suitable solutions is critical, but how do we distil the problem to find the best remedy?

Most efforts to improve safety are still based on the assumption that our safety management systems are effective, and that it is the behaviours of individuals, who either take shortcuts or fail to follow procedures that create unsafe workplaces. It’s an easy line to follow if there is a disconnect between safety management and the actual application of policy and procedures.

When we put our faith in these systems, we must understand that while an individual safety management system may be coherent and logical, it is always surrounded and impacted by other factors. It’s not only considerations like environment, weather and changes in the workspace dynamics (particularly in construction – different trades and structural changes), but it’s the appropriateness and versatility of the systems and more importantly, the working at height competency of those working in the space that will determine the best outcomes.

All implemented systems need to align with the WHS Act and Regulations, taking into consideration the PCBU requirements for providing a safe workplace. Then there is the importance of aligning with the appropriate standards. But these are base level compliance KPIs, proper safe design and training are the critical pieces of the puzzle.

The important point here is that each of these systems and processes has an end purpose or goal, so it follows that each of these goals influences how work is completed and where attention is focused. Unfortunately, these systems and goals, while each important and valid in its own right, interact in such a way that they create layers and complexities that are rarely intended or well understood.

These layered and sometimes complicated procedures can introduce inefficiencies, and if not understood clearly and aligned with an understanding of the core competencies required to perform tasks safely, can make it difficult for workers to apply. This can result in a significant gap between work as envisioned, based on idealistic compliance with our safety systems and procedures, and work as executed where our workforce does their best to balance these competing priorities.

In managing safety effectively, leaders need to develop a greater understanding of the complexities that the work location creates in the execution of those tasks that need to be undertaken. The skills required to work safely at height sit parallel to trade and engineering skillsets, so the actual execution of those safe work methods needs to align with the work being carried out. This type of understanding would include recognising the difficulty frontline managers, supervisors and the workforce face in understanding, rationalising and applying the intent of those safety protocols in practice. In other words, while our safety systems look great in the comfort of our offices, we really need to look at them from the perspective of our teams in the field.

Understanding and managing complexity

One of the most significant consequences in not understanding the complexity in height safety is oversimplification. Not understanding or adopting the working at height hierarchy of controls leads to the assumption that applying the lower tiers of control measures (PPE and Administrative) provide effective enough protection for those at risk. This oversimplification is a common phenomenon, as the implementation of PPE measures is a highly visible indicator, but often the issues with this approach are only recognised after an incident has occurred.

All too often, the incident focuses on the behaviours or actions of the individual, and this almost always arises from hindsight bias and failing to take into account the realities of the situation from the perspective of those involved in the event.

Assuming the systems put in place effectively address the risk profile, how much consideration is made for the core competencies required to operate at height safely, and the maintenance of these skills, in delivering the safety outcomes desired?

It is very easy to apply hindsight in the investigation of fall events, highlighting ‘flawed decisions’ and ‘missed opportunities’ when looking back at the approaches to safety that were taken. But this view only looks at how the task should have been done. What we need to account for is that the situation and actions taken by the individual may have seemed completely rational at the time. The question is, was the worker trained well enough and genuinely competent to assess the risk appropriately and have the experience to be situationally aware when applying the safest methods of achieving the set tasks.

The challenge for safety managers is to be able to assess why the worker thought the work methods they were using at the time of the incident were rational.

But by providing practical and relevant education and training, we empower individuals to make better and safer decisions, and with it, the ability to apply the systems put in place by management. By encouraging genuine skills and expertise, there can be collaboration with safety leadership in the development of better work practices. When we can achieve that level of understanding, we will have the greatest opportunity to identify the competing goals, complexities and systemic influences that, if addressed, have a much greater chance of preventing fall events.

Addressing the challenges

We need to challenge the way we currently manage fall risk, and this extends to how we manage the associated and linked hazards of dropped objects and confined space. Questioning and challenging our current safety paradigms are the inherent responsibility of safety managers, but are we informed and expert enough to look at this holistically?

It is very easy to adopt pre-packaged solutions to address the risk, but without understanding the complex nature of the discipline and the variety of measures available to manage the high-risk nature of the work, this path leads to heightened exposure to all affected. Adopting a more ‘critical thinking’ approach to PPE/PFAS and systems selection, which is informed by a better understanding of the nature of work being carried out at height, will lead to much better outcomes. Ultimately, this comes down to education, information availability and engagement.

Embracing the complexity of working at height does not necessarily complicate the situation but provides a more robust framework of assessment and application of best practice work methods. There is not one solution to fix all situations, but that does not mean there are not comparable approaches and cross-overs in skills and equipment. Understanding the potential hazards informs our decisions as professionals, and opening conversations within the safety community around how we have successfully managed these challenges benefits every single stakeholder, including the families of those we expect to operate in these environments.

We need to encourage leaders to engage in these discussions and learn from our peers. We do not operate in silos, so supporting safe working at height means collaboration with our community, industry associations and subject matter experts. There are relationships between safe design principles and system design, integration and execution, and to acknowledge the complexities of this interaction potentially inspires advancements in our approach. We have not seen any real changes in the statistics for many years, so broadening our view to include these external factors and the different layers and interactions that make up best practice can only lead to positive change.

We can try to segregate education/training from our safety management systems from these other influences, but this is just another form of oversimplification. They are indelibly linked and this forms part of the structure of more holistic approaches.

My advice to organisational leaders and safety professionals wanting to embrace a new and fresh approach to height safety is to acknowledge the complexities, both systemic and personal, that exist in modern workplaces. We must broaden our view to include not only what makes up our safety management system, but all the external factors that potentially interact and affect the safe execution of those systems.

Adopting this approach will encourage leaders to avoid deconstructing individual elements of a system when trying to find why something went wrong and will encourage them to look at the system as a whole.

While we will struggle to address every risk factor on dynamic and changing worksites, if we engage and listen more carefully to our workforce and embrace complexity by looking at systems holistically, we will have the chance to see these layers and interactions. This will provide the opportunity to proactively identify and mitigate some of these risks and to change the way that we and our workforce perceive safety at height.

By Scott Barber, Chief Executive Officer, Working at Height Association.

Article published in Inside Construction magazine June/July 2023.

Following the recent launch of the new Safe Formworker Program, Michael Sugg delves into the Formwork Industry Association’s plans to develop a new education and skills pathway.

With the launch of the new Safe Formworker Program, featured the June 2023 edition of Inside Construction, and with enrolments increasing by the day, the Formwork Industry Association (FIA) is working with its members to develop a new education and skills pathway. This will take the re-engaged formworker from the Safe Formworker Program to certified training and the new Certificate III in Formwork, currently being discussed by the FIA with Federal Government training bodies. The goal is to develop a ‘fit for purpose’ formwork qualification in preparation for the large number of government infrastructure projects in the pipeline.

History

As you may be aware, the previous Federal Government made the decision to subsume the Formwork & Falsework Certificate III qualification into the Carpentry Certificate III qualification in 2021/22. This took away the only formwork-specific qualification and access to any funding for apprenticeships or funding for recognition of prior learning (RPL) programs, as well as formwork specific education and skills pathways. Whilst the Carpentry Certificate III qualification is ‘fit for purpose’ for those building residential houses, it is not ‘fit for purpose’ for large scale building and infrastructure projects, putting further pressure on the skills shortage and safety in our industry.

Following extensive campaigning at both federal and state levels by the FIA, the Australian Skills Quality Authority (ASQA) agreed to extend the transition period of CPC31511 - Certificate III in Formwork/Falsework until 31 December 2023.

This enabled the formwork industry to continue to employ formwork apprentices and access relevant funding to assist with their wages. It also enabled the industry to access training and demonstrate education and learning targets now required for most government projects to secure future projects and work.

Back in 2022, the Federal Government instructed the FIA to work with consultancy ARTIBUS on a new formwork certification, and together with industry, we drafted a proposed new infrastructure-focused formwork Certificate III qualification. This was going through the necessary approval process until the recent Federal election and now it is ‘stuck’ in government bureaucracy as the new Jobs and Skills Council (JSC) is formed. Registered training organisations (RTOs) and industry have called for an extension to the transition period in view of the delayed formation of the JSC and we are still waiting to hear the outcome.

With high incident levels on sites, a skills shortage and other industry pressures, there is still a need, and demand, for the right level of training and expertise to minimise the level of risk and improve safety on site. Without any formwork specific education and skills pathway, and no need for formworkers to be specifically skilled or licensed to work on site, the formwork industry decided to take control and take the lead to improve safety on construction sites.

New education and skills pathway

Over the past year the FIA, formwork and construction industries have got together to formulate a new Formwork Education and Skills Pathway to improve safety in the Australian formwork industry. Industry feedback requested the FIA create industry wide and recognised minimum levels of safety to get workers safely on site. Feedback also stated that there was a need to re-engage workers in learning and prepare them for future learning/training to address the skills shortage.

As the Building Confidence report by industry experts Peter Shergold and Bronwyn Weir stated, industry collaboration is a key driver in ensuring future success within the industry and a catalyst for change to occur. The recently released Australian Work Health and Safety Strategy 2023-2033 states that companies need to make sure that, on their projects, there is meaningful and relevant training for workers delivered in a way they can understand. It supports the continuation and strong focus on compliance and enforcement by regulators, with a particular focus on systematic work health and safety (WHS) management. If you don’t have meaningful and relevant training and cannot demonstrate robust WHS management, the risk is that the safety regulators will investigate the quality of your systems, including training and competency, to hold companies and individuals accountable. WHS laws are risk based and don’t need an incident to occur for a business and its individuals to be liable. It is every employer’s responsibility to make sure their workers get the training, instruction and support they need to keep them safe at work.

In an industry that does not require any more than a White Card to work as a formworker, and with no clear training and skills pathway, it is easy for companies not to be compliant. This is a great opportunity for change to occur and for industry to take the lead – and that’s what it’s doing.

The proposed pathway has been received well in NSW, with support of both the formwork and construction industries, and particularly the NSW Department of Education, which has funded the progress of 1,000 formworkers through the Safe Formworker Program, as the first ‘run’ of the new pathway towards certified training. As we reported last edition, there is a need to re-engage workers in meaningful learning and assist them to develop confidence and an appetite for further training to develop their skills and ultimately their careers.

There has been no dispute from anyone in the industry when we say, “if you improve the skills of a formworker you improve their safety, quality and productivity on site”. It’s a situation that benefits everyone.

In the new pathway, a worker can progress their learning from the Safe Formworker Program into a series of relevant formwork-specific micro-credential courses and formwork skills to build learning confidence, and assess workers’ knowledge and competencies. The FIA’s app-based learning tool also allows a worker to build a body of video-based evidence of their competencies on site following these micro-credential courses. This not only improves their knowledge but gives them control and ownership of their training and learning records and allows them to present these to future employers. This makes them more employable and provides a mechanism not currently available for both workers and employers to understand and rate a worker’s skills. It makes recruitment of skilled labour easier and reduces some of the pressures on formwork companies at present. It also allows for companies to be more compliant with record keeping of their workers meaningful and relevant training.

From these micro-credential courses and skills, the FIA and industry have been working with industry training advisory bodies (ITABs) to develop a series of skill sets which include entry-level accredited training on specific units of competency relating to formwork. These skill sets will be delivered by RTOs and funded by the smart and skilled program. The FIA is working closely with RTOs and ITABs to ensure that these skill sets can be delivered in line with industry demand and, where feasible, onsite, to reduce the time a worker spends offsite. While there is still a lot of work to do here, we are confident that these skills sets will meet industry demand and ensure there is a pathway for workers to follow and address the skills shortage.

In an industry that does not require any more than a white card to work, and no need for tickets, you cannot expect a worker to jump straight into a Certificate III training course, or for their employer to encourage this when the cost to them is so high. A pathway is essential. Not only does this assist the worker and allow them to manage their learning and skills progression for a better career, but it also enables the employer to access relevant and meaningful learning for their workers and be compliant under the WHS Act.

The pathway enables a formworker to then choose whether they engage in the Certificate III in Carpentry or, when it is available, the new Certificate III in Formwork for Infrastructure. For the first time we will have a formwork specific education and skills pathway that everyone can recognise.

Safety is an issue on all sites. Skills shortages are an issue in our industry. With an ageing workforce and financial pressures, we are looking at a very bleak future for the Australian formwork industry. The time to act is now.

Details of the Safe Formworker Program and Skills Pathway can be found on the FIA website and industry participants are encouraged to contact Michael Sugg to discuss support on how to achieve the target of 1,000 workers through the program to improve site safety. Please note that given the significant uptake in the program, there are limited places and those will be offered on a first-in basis.

COPY OF ARTICLE