A note before I start. I’m a lawyer, not a trainer, and most of what I know about RPL I’ve picked up by listening. The work of judging whether someone is competent against a unit of competency belongs to people who have spent years doing it. What I bring is an interest in how evidence works, and the time to write down what I’m noticing. If a trainer reads this and disagrees, they’re probably right.
The thing that has been on my mind lately is how differently the four rules of evidence behave depending on what kind of work you’re trying to recognise. The rules don’t change. The work an assessor has to do to satisfy them changes a lot.
I only intended on writing one blog article about evidence variation across training packages, but it is just too interesting. This one stays with two qualifications: CPC30220 Certificate III in Carpentry and CHC33021 Certificate III in Individual Support.
Both are workplace based qualifications. Both involve substantial hands-on work. Both have candidates who often don’t see themselves as students and aren’t always comfortable producing written evidence. From a regulatory distance you could imagine the evidence patterns would be similar.
They’re not. They might be the most differently shaped portfolios in the entire VET landscape.
Where the four rules stress
Coming from a legal background, the framing that has helped me make sense of this is that the four rules of evidence (valid, sufficient, authentic, and current) apply equally across every qualification, but they stress at different points depending on the work. A portfolio that has no problem with one rule can have a serious problem with another. And the rule that creates trouble varies by qualification.
In carpentry RPL, sufficiency can be plentiful. The candidate has been doing the work for years, often across many sites and many employers. There is no shortage of work to point to. What gets hard is authenticity. The candidate worked on a job. So did three other people. Who actually built the staircase? Who framed that wall? Who was the lead hand on that pergola? Photos of finished work prove that the work exists. They don’t prove who did it.
In Individual Support RPL, authenticity can be straight forward at times. The candidate’s name is on the progress note. Their signature is in the medication record. The third party report is signed by an RN who has supervised them for years. What gets hard is sufficiency, in a particular way. The documents that would prove competence exist, but they live inside the workplace’s clinical management system. The candidate doesn’t own them. Getting them released, anonymised, and into the portfolio is a project of its own.
Same four rules. Completely different friction points.
Visible work and invisible work
A way I’ve come to think about it. Carpentry produces visible work. Things you can stand in front of and photograph. A deck. A roof frame. A staircase. A built-in wardrobe. The evidence often exists already. It’s sitting in a finished kitchen, in a backyard, in a house someone now lives in.
Individual Support produces largely invisible work. The work happens in private rooms, behind drawn curtains, with vulnerable people whose dignity and privacy are protected by law. There is no “finished product” you can photograph. The work leaves traces, but the traces are in clinical records the workplace controls.
That difference seems to drive most of what’s different about the evidence.
What carpentry RPL involves
CPC30220 Certificate III in Carpentry covers the work of a residential and light commercial carpenter. Setting out and constructing wall and roof frames. Installing windows and doors. Building stairs. Constructing decks and pergolas. Installing flooring systems. Working safely at heights. Reading and interpreting plans.
The qualification reflects work that is largely physical, largely outdoors or on site, and largely produces an artefact at the end. A trained carpenter is someone who can be handed a set of plans and turn them into a structure that meets code, looks right, and holds up.
The candidate seeking RPL has typically been doing this work for years. Often across multiple employers. Often as a subcontractor or on family jobs. Often with informal documentation.
A worked example: the carpentry candidate
Picture a candidate who has been doing carpentry for fifteen years. Started as a teenager helping his uncle on weekend jobs. Worked under a licensed builder for eight years. Has been subcontracting on his own for the last five. Builds decks, pergolas, internal renovations, the occasional small extension. He has never held a Cert III because his uncle was a builder and the work just kept coming.
What evidence does he plausibly have?
A phone full of photos. Hundreds of them. Decks in progress. Roof frames going up. Stairs being installed. Some show finished work, some show midway through a job, some show him on site holding a nail gun.
Invoices. Tax records. ABN history. Records of payments received from builders he subcontracted to.
A few signed statements he could probably get from former employers, if he asked.
Some completion certificates from short courses. White Card. Working at heights. Asbestos awareness. EWP licence.
A driver’s licence with a heavy rigid endorsement.
What he probably doesn’t have is anything that maps cleanly to the unit performance criteria. No structured logbook. No third party reports written to the unit requirements. No anonymised plans or work orders linked to specific units.
The evidence is there. The work is real. Connecting it to the qualification requires translation.
What carpentry evidence tends to look like
Photos of the candidate’s work, which is the natural starting point for almost every carpentry RPL portfolio. The challenge is that a photo of a finished deck doesn’t prove the candidate built it. From what I’ve seen and been told, photos work harder when they’re sequenced (before, during, after), when they include the candidate at work in the frame, and when they’re paired with something that authenticates them. A dated invoice for the materials. A signed statement from the homeowner or builder. A geotag.
Third party reports from licensed builders or supervisors who have observed the candidate’s work. These are doing heavy lifting in carpentry RPL because they’re often the only thing that authenticates the connection between the candidate and the visible work.
Plans and work orders the candidate has worked from. With permission, marked up to show what the candidate was responsible for. These are useful because they connect the candidate to specific tasks rather than to general site presence.
Tickets and licences. White Card. Working at heights. EWP. First aid. These don’t prove competence in the units of the qualification, but they prove the candidate has been operating in the regulated environment the units assume.
A clean carpentry portfolio I’d expect to land well: a structured photo log organised by unit, with each set of photos paired with an invoice or work order or third party verification; two or three third party reports from licensed builders or supervisors; a list of jobs completed with addresses (if appropriate) or job descriptions; and the relevant tickets.
A portfolio I’d expect to read as thin: a phone dump of unsorted photos with no authentication, a generic letter from a current employer that doesn’t reference specific tasks, and a resume.
The other thing I keep hearing about in carpentry RPL is recency. The candidate may have built a hundred staircases in his career, but if he hasn’t built one in three years, the currency rule starts to bite. Currency is recent application, not lifetime experience.
What Individual Support RPL involves
CHC33021 Certificate III in Individual Support covers personal care, mobility support, communication, and individualised care planning for people who need assistance with daily living. The qualification has a mandatory 120 hour work placement requirement and is delivered with specialisation streams in ageing, disability, or both.
The work is regulated under the Aged Care Quality Standards or the NDIS framework, depending on the setting. The educator is operating in a workplace with documented care plans, clinical management systems, infection control protocols, and reporting obligations. Everything the candidate does is documented, but mostly in systems the workplace owns.
This qualification is also becoming more central by the year. The Aged Care Royal Commission recommended a mandatory Cert III for aged care workers, around two-thirds of the existing workforce already hold a relevant qualification, and the Fair Work Commission has just delivered a 23 percent pay increase to direct care workers in recognition of the skills involved. The remaining third of the workforce is where RPL volume is going to come from. Whether or not the regulatory reforms land in their fullest form, the direction of travel is clear, and assessors in the CHC training package who understand what robust evidence looks like for this qualification are going to be doing important work for Australia’s care system over the next few years.
A worked example: the Individual Support candidate
Picture a candidate who has been a personal care assistant in a residential aged care facility for six years. Permanent part time, thirty-two hours a week. She works across both the high care wing and the dementia specific wing. Her supervisor is the clinical care manager, an RN who has worked with her since she started.
What evidence does she plausibly have?
Her name in the facility’s clinical management system on hundreds of progress notes, behaviour charts, ADL records, and incident reports.
A signed third party report from her RN supervisor, if the supervisor agrees to write one.
Her performance reviews, which the facility may or may not release.
A workplace training register showing dozens of courses completed. Manual handling. Dementia care. Infection prevention. Elder abuse and mandatory reporting.
A position description from when she started.
Her First Aid and CPR certifications.
A few photos and videos of practical tasks, if she has taken them with appropriate consent and the facility has approved their use.
What she doesn’t have is direct ownership of most of this. The progress notes live in Leecare. The performance reviews live in HR. The training register is the workplace’s record. Even her own clinical documentation is technically the workplace’s intellectual property and protected by privacy law about the residents she has cared for.
The evidence is there. The candidate just doesn’t own it.
What Individual Support evidence tends to look like
Third party reports from a registered nurse or clinical care manager. These do enormous work in Individual Support RPL because the supervisor is positioned to attest to specific clinical practice in a way that the candidate cannot self-evidence.
Anonymised progress notes the candidate has authored, with workplace approval and resident identifiers redacted. These are powerful when available because they show the candidate’s clinical voice, but they require formal release from the workplace.
A structured workplace training register, ideally exported from the facility’s L&D system. Strong because it’s independently authenticated. Weak when it’s a list the candidate has typed up themselves.
Performance reviews, where the workplace will release them.
Care plan contributions, with all resident information redacted, where the candidate has been involved in keyworker activities.
Photos and videos of practical tasks. The consent regime is strict. Resident faces excluded. Workplace approval required. Even with all that, the photos prove technique rather than care relationships, which means they’re useful for some units and not others.
A clean Individual Support portfolio I’d expect to land well: a strong third party report from a clinical supervisor, anonymised samples of the candidate’s own clinical documentation, a workplace-verified training register, a position description that maps to the unit requirements, and selected photos with proper consent.
A portfolio I’d expect to read as thin: a self-typed list of duties, a generic supervisor reference, training certificates with no sense of what the candidate did with the training, and no clinical documentation at all.
The friction point is almost always getting the workplace to release the documentation that would make the portfolio strong. A candidate without an engaged employer often has weaker evidence than her actual practice deserves.
The authentication problem and the provenance problem
Coming back to the framing, I think the cleanest way to describe what’s different is that the carpenter has an authentication problem and the care worker has a provenance problem.
The carpenter’s evidence exists in the world but doesn’t have the candidate’s name on it. The deck is real but the photo doesn’t prove who built it. Authentication is the work of connecting the candidate to evidence that already exists.
The care worker’s evidence has the candidate’s name on it but lives somewhere she can’t get to without help. The progress note is real, the candidate wrote it, but it sits inside a workplace system. Provenance is the work of getting the evidence into the candidate’s hands in a form that satisfies the rules.
That distinction has implications for the assessor. It also has implications for what an RPL platform can usefully do.
What if the document doesn’t exist
Both of these worked examples assume the candidate is reasonably organised. The carpenter who has fifteen years of photos on his phone. The care worker whose RN supervisor is willing to write a third party report. In practice, plenty of candidates are not that organised, and plenty of workplaces are not that supportive.
A candidate might have done the work for years and have almost nothing in writing to show for it. The phone died and the photos are gone. The former employer has retired. The workplace won’t release documentation. The candidate didn’t keep records because nobody told them to.
The point I keep hearing from experienced trainers is that this does not mean the competence isn’t there. It means the assessor’s job is different. The starting question shifts from “what evidence has the candidate brought” to “what evidence can we surface for this candidate, given what’s actually available.” Workplace observation. Practical demonstration. Structured competency conversation. Verbal accounts triangulated against a supervisor’s confirmation. Photos taken now, against current work, rather than dug up from years past.
A candidate-centred approach to RPL involves an assessor starting with the candidate, not with the kit. If the standard pathway doesn’t fit, the question becomes what alternative pathway would surface the same competence in a way the four rules can hold. That mindset is qualification specific too. The alternative pathways available for a carpenter (a practical demonstration on a job site) are different from the alternative pathways available for a care worker (a structured workplace observation with the supervisor present).
The candidate’s organisational skills are not the qualification. The competence is the qualification. A good assessor knows the difference.
Many ways to skin a cat
Worth saying clearly. None of this is prescription. Different candidates bring different evidence. A carpenter with twenty years on a single large building site has a different portfolio shape from a carpenter who has been a sole trader for a decade. A care worker with an engaged employer who supports RPL has a different portfolio shape from one whose employer has changed three times in five years and isn’t responsive.
The patterns I’m describing are tendencies, not rules. What an experienced trainer brings to RPL is the judgement to see what matters for this candidate, in this context, against these units. That judgement is qualification specific, sector specific, and candidate specific. It’s not something I have. It’s something the trainers I’ve spoken to spend years developing.
The thing I keep coming back to, watching from the outside, is that not all evidence is equal, and that the specific friction points in each qualification are predictable enough that they can be supported.
So what
If you’re running RPL across both trades and human services, the assessor’s job is genuinely different on each side. The trades assessor spends most of their time working on authentication. The human services assessor spends most of their time working on provenance and release. Same four rules. Different work to satisfy them.
That has implications for everything downstream. The questions you ask in a competency conversation. The conversations you have with employers and supervisors. The structure of the portfolio itself. A platform built on the assumption that all qualifications behave the same way will help on neither side.
Work together with us
VelvetPath is the platform we’re building at Red Velvet AI to take this seriously. Different evidence shapes for different training packages, different friction points within the four rules, and an audit trail that holds up when the regulator looks. If you’re a trainer or an RTO leader who has run into the limits of generic RPL kits, we’d like to hear from you. We’re running small working groups by training package because the people who actually do this work are the ones who know what the platform needs to do.
partners@theredvelvet.ai. We read every email.
A good RPL decision is a bit like a good red velvet cake. The surface looks simple. The layers are what hold it up.
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