The following FAQ was last updated September 2018. This material is guidance only to support the implementation and use of the checklists. In the unlikely event, any of the content contradicts with requirements within the specific oil company requirements, WPCG Minimum Control Checklists, or WPCG Work Clearance Form, or legislation then the work instruction, procedure, or legislative requirement shall override this document.
EVERYONE HAS THE OBLIGATION AND AUTHORITY TO STOP UNSAFE WORK
The WPCG accreditation is not an induction, it is the accreditation required for contractors to be able to self issue a WPCG form when conducting low risk work on the oil company sites.
The individual attends a one day training course and then completes an online assessment. The accreditation is valid for two years after which you can maintain your accreditation by completing the online refresher prior to your expiry date.
You need to book online. Simply head to the Login or Register page and create an account. Fill in your details and select the “Issuer” box when choosing an accreditation option. After clicking on submit, you will receive an email with your Unique ID. It may take up to 2 hours to receive your email. Login with your Unique ID and password, and book your chosen class via the My Training menu option in the system.
As a minimum, at least one person on the work crew requires the accreditation. That individual must remain on site at all times. If for any reason they need to leave, they must hand over their responsibilities under the WPCG process to another WPCG accredited individual, or the work must stop.
No, you will need to complete the face-to-face training course again.
WPCG Clearance Training is not required by OHS/WHS law. Some clients require contractors to be accredited when working on their sites (BP, Caltex, Viva).
Only clients can decide whether contractors or subcontractors need to be accredited before taking on work.
You will need to approach your client company regarding their requirements. The WPCG members (BP, Caltex & Viva) do require use of the WPCG clearance form for all decommissioning works.
You can transfer your WPCG accreditation to another company. Fill out the following form from our website. Link to Change Company Details.
The WPCG accreditation is an individual accreditation, it is not a company accreditation. You may use the WPCG logo on your website so long as you do not imply or state that the business is WPCG accredited. It is acceptable for you to state that you have technicians that are WPCG accredited. Contact WPCG administration to obtain a copy of the logo for use.
You can arrange to receive a new card by contacting us. A replacement fee of $AU5.00 applies.
You can find current WPCG accredited contractors on our website. Please note, not all contractors have chosen to list their details.
Current WPCG issuers can commence using the Minimum Controls Checklists once they successfully complete the bridging course. New WPCG Issuers can commence using the Minimum Controls Checklists once they successfully complete the Face To Face training course incorporating the Minimum Controls Checklists.
If you are trained and competent in the WPCG Minimum Controls Checklist/s relevant to your work, and you comply with all the requirements including the scope, equipment, and controls (including gas detection where applicable) then you do not need a WPCG member company Work Permit for WPCG member company facilities within scope of the WPCG process. A WPCG Work Clearance is still utilised to authorise the work and communicate it to the site representative. NOTE: If you are not using the Minimum Control Checklist, or you are not trained in it, or you want to vary some of the scope or controls required, then you need the applicable oil company Work Permit, e.g. for all Hot Work in the Hazardous area.
WPCG member oil companies have now authorised the use of some WPCG Minimum Control Checklists for some work tasks based on industry good practice to manage specific risks for specific routine maintenance and construction tasks that have been assessed as low risk if the controls required within the Minimum Control Checklists are implemented, and the person is trained in the Checklist/s. The WPCG Work Clearance is still utilised to authorise the work and communicate to the operating Site Representative and have them authorise the work at the work site. A specific task may still be escalated to an oil company Work Permit and/or Certificate if it is deemed necessary to safely control the work. EVERYONE HAS THE OBLIGATION AND AUTHORITY TO STOP UNSAFE WORK
Once you are trained in these new WPCG Minimum Control Checklists you will not need to utilise the
previous BP and Caltex equivalents. BP and Caltex may withdraw the use of their previous forms after a
Diesel and electrically powered mobile plant and equipment is within the scope of the WPCG Minor Hot Work Checklist provided the controls required are implemented. It is considered reasonably practicable to utilise diesel or electrically powered equipment rather than petrol or LPG powered/ driven for the overwhelming majority of tasks (e.g. compressors, generators, EWP) or manually operated equipment (e.g. cold work gardening hand tools instead of a hedge trimmer) within Hazardous Areas.
Petrol powered equipment, e.g., petrol powered concrete cutters, will require a Work Permit from the WPCG Member Company when used within a Hazardous Area. Petrol introduces flammable goods storage (i.e. the petrol within the device) as well as a source of ignition to the Hazardous Area.
It is recommended by the WPCG that the person is trained to a national unit of competency by a registered training organisation in testing atmospheres. Companies may utilise their own in-house training or that offered by equipment suppliers. Companies must keep records of training. These records and the training may be subject of audits by WPCG member companies.
A list of registered training organisations (RTO) approved to deliver national units of competency. These can be found at http://training.gov.au/
At the time of writing, there are two primary options available: MSAPMOHS217A or RIIWHS202D. MSAPMOHS217A is preferred.
Elements and Performance Criteria for each unit as at time of release of this guidance:
2.2 Ensure that the atmosphere is tested and monitored for harmful elements
|1. Prepare for gas testing.|
1.1 Determine type of gas/atmosphere to be tested.
1.2 Select and calibrate equipment in accordance with procedures.
1.3 Determine gas testing regime/sampling pattern required.
1.4 Identify hazards from possible atmosphere contaminants.
1.5 Implement hazard control measures, including use of appropriate personal protective equipment.
|2. Test gas.|
2.1 Use gas testing equipment to test gas as required.
2.2 Interpret and report readings.
2.3 Monitor gas on an ongoing basis as required.
2.4 Take required action(s) if readings are unacceptable.
|3. Maintain equipment.|
3.1 Clean and maintain gas testing equipment in accordance with procedures.
3.2 Inspect and fault find monitoring equipment in accordance with procedures.
3.3 Return gas testing equipment to required location and in required condition.
3.4 Maintain records of tests and results in accordance with procedures.
Any person deemed responsible for monitoring a gas detector during the work shall, as a minimum, have received instruction from a person trained and competent to inform them of the location of the gas detector for monitoring, the alarm settings of the unit, and what to do in the event of an alarm sounding.
No. Just like other competencies for their work, companies must keep records of training. These records and the training may be subject of audits by WPCG member companies.
WPCG does not mandate a particular make or model of gas detector. To be used to conduct the gas testing associated with completion of the Minor Hot Work Checklist it does need to be rated for the hazardous area in which it will be used, within current calibration and “bump tested” prior to use. AS/NZS 60079.29.2:2008 Explosive atmospheres Part 29.2: Gas detectors—Selection, installation, use and maintenance of detectors for flammable gases and oxygen is available to support your selection decision.
If you are considering purchasing (or hiring) your own gas detectors here are some points to consider, other than the obvious things to check like hazardous area rating, alarms (visible and audible), and gas sensors in the unit:
As the gas testing associated with the Minor Hot Work Checklist is with respect to the risk of a flammable atmospheres rather than for a particular atmospheric contaminant that may pose a health risk, the gas detectors will need to test for (as a minimum) LEL, and O2. These fields are required on the Minor Hot Work Checklist. If your company JSA/SWMS identifies other risks requiring testing, e.g. CO from exhaust emissions (if applicable) then this would be required by your own risk assessment associated with the work. Such risks are considered Task Hazards and are outside the scope of the Minor Hot Work Checklist. As such they are not required on the Minor Hot Work Checklist to ensure safe use of the equipment in the hazardous area with respect to site and process hazards. Also note that the Minor Hot Work Checklist cannot be used in Confined Spaces which may require additional gas testing, in accordance with WPCG Member Company requirements.
Yes, if the work inside the inside falls into the scope of a minimum controls checklist the relevant checklist must be used.
There are several key points in this question that need to be understood:
The WPCG Minor Hot Work Checklist contains controls specific to managing the risk of ignition within Hazardous Area. If ignition sources are introduced, these need to be actioned to ensure the safety of the work. A WPCG Member Company Permit will be needed if the work is outside the scope of the WPCG Minor Hot Work Checklist or the controls within the WPCG Minor Hot Work Checklist cannot or will not be applied.
No, DBYD is only required when underground service detection scanning is also required as per the minor ground disturbance checklist.
The common processes for issuing WCF for low risk activities have been operating for many years, previously under AIP and since 2011 under the JV of BP, Caltex and Viva Energy. This was recently expanded to include minimum controls for specific activities with slightly higher risks. The JV is now extending this to higher risk activities under the Permit to Work processes. This provides an integrated system of common processes between the three oil companies.
This creates one integrated program covering training for low to high risk activities, managed by one organisation. This reduces confusion, has one point of contact for clarification, standardises processes across the three oil companies, simplifies the understanding of contractors and Permit Officers and creates a more efficient process by reducing time understanding the three oil companies systems.
Information sessions have been held across Australia, as well as a webinar. More information is available on wpcg.com.au. Bridging programs are being implemented to cover the changes to the new system for those that are WPCG accredited in the Work Clearance process, and Permit Officers accredited with BP, Caltex and Viva Energy. Those that are not Permit Officers or WPCG Clearance Issuers will need to undergo the new WPCG training courses.
All questions on the WPCG process should be directed to the WPCG rather than the individual WPCG Member Companies. The first point of call will be the WPCG website www.wpcg.com.au.
To test the market on delivery of the new program, the WPCG went to an expression of interest and then tender process to select an Administrator to deliver training and administration of the total program. Julsen Pty Ltd, who was the current Administrator, has won the tender program based on overall capability to deliver the program and costs to contractors and Permit Officers to complete the training, assessment and administration of the program. Many of the familiar faces from WPCG will remain and new resources have been added.
The initial training to enable contractors to issue Work Clearances will now be split between an online component and a face to face training. Additional components have been added to the face to face program, covering the expanded program, Permit receivers and Permit endorsers. So that the face to face program remains at approximately 5 hours, some theory components have moved to a new online module which must be completed prior to attending the face to face training. This keeps the cost down and time to attend the face to face sessions as low as possible. The Work Clearance Form has also been updated
Yes, the same coverage offered by the previous program will be maintained.
Yes wpcg.com.au will provide the same information as in the past and will be expanded to include the Permit to Work process.
Yes, the forms will be available in pads, but your cost to attend the training will also include access to online eforms. These are online versions of the Workplace Clearance Form as well as Minimum Controls Checklist and Work Permits (for Permit Officers), accessed through your WPCG profile on the website. Each time you sit the refresher course, access to these forms will continue and is provided as part of the refresher cost.
The system initially applies to WPCG member facilities where the Work Clearance Form currently applies. i.e. service stations, commercial facilities, and depots. The expansion to other WPCG member facilities is being reviewed by member companies.
The WPCG system, both the Work Clearance Form and Work Permit must be used as a minimum on WPCG member facilities where WPCG applies. If your company has other requirements, you must consult your organization on whether these must be applied in addition to the WPCG system but note that they cannot be used instead of the WPCG system at WPCG member facilities where WPCG applies.
Whoever engages you as a contractor or Permit Officer is responsible and liable for your activities on their sites and they need to ensure you have been adequately trained and safe systems of work (amongst other duties of care and regulatory requirements). You and whoever engages you need to be aware our trainer, the WPCG and JulSen Consulting are not an RTO and this is not a nationally recognised course. The WPCG JV partners have no liability for implementation on non-JV partner sites.
As part of project to develop and implement the change, communication has occurred with organisations such as ACAPMA.
The WPCG is focused on implementing the changes for sites controlled by the program owners; BP, Caltex and Viva Energy (Shell). Once the program is embedded and operating as planned, the WPCG may look to expand the program to other organisations, if they would like to be part of it.
A communication will be sent by the oil companies to the relevant site representatives.
The WPCG training courses are not National Units of Competency (NUC), the WPCG and JulSen Consulting are not Registered Training Organisation (RTO). If you wish to acquire a nationally recognised qualification, you will need to undertake training in the relevant NUC by an RTO.
For any questions there will be an Activity Matrix outlining the minimum level of work authorisation is required for some general activities.
Training will only be tracked for new Permit Officers as part of demonstrating completion of pre-requisites prior to attending the new Permit Officer training course. Others will be able to enter their training into their WPCG online profile. Cards issued by WPCG will only identify a Permit Officer or Work Clearance Issuer at this point.
Currently on the WPCG website, if the individual has allowed their information to be displayed you can see their Work Clearance Issuer & Minimum Controls training. We will be adding Permit Officers into the WPCG database and making this information available on the website. The Permit To Work Bridging course for both Work Clearance Issuers and Permit Officers will also be added to the profiles of all current personnel in the WPCG database. All other information can only be accessed by the individual themselves.
The WPCG Member companies are accountable for communicating any additional requirements that may remain within their organisations and updating you on any changes to individual company requirements. It should be noted WPCG is a common Authority to Work process and is not a common Health, Safety, Security, and Environmental Management System.
Some key requirements of direct relevance to Permit to Work that will remain include:
BP will continue to require its’ Task Risk Assessment Process, known as HITRA, for all Work Permits that require the minimum level of authority to be a Senior Permit Officer. Senior Permit Officers must be BP HITRA trained, IN ADDITION to being a WPCG Senior Permit Officer. Contact BP for more information.
Viva Energy considers high risk work at height to be 1.8m, whereas BP considers it to be 2m, and Caltex does not specify. Notwithstanding this, the risk of falling from one level to another must be considered and as such the Minimum Controls Checklists must be used for heights lower than these. These heights are merely the triggers related to potential to fall when working within 2m of an exposed edge that would trigger a Work Permit.
Viva Energy and BP require that all Confined Space Entry entrants, standby personnel, and Permit Officers are trained in Confined Space Entry to a National Unit of Competence by a Registered Training Organisation and current within the past 3 years. Caltex requires such personnel to be trained and competent in accordance with contractual arrangements and Contractor Safety Management processes.
Contact your WPCG Member Company representative. If in doubt, don’t commence work until you understand the requirements to ensure safe and compliant execution of the work.
The Hazard Maps are available on wpcg.com.au to view, download and/or print. The Work Clearance Form pads will still have the hazard maps and instructions for completing.
WPCG went to tender to select the preferred trainer and administrator for the Work Clearance program who is capable of providing an efficient and effective service using the latest technology and training methodology, at a reasonable cost to contractors. The new costing does include some minor increases (e.g. Work Clearance refresher), but there has also been some decreased costs (e.g. Work Clearance pads).
They must not use the WPCG Minimum Controls Checklists until they have completed that course. They will need to complete both the WPCG Minimum Controls Bridging course and the Permit To Work Bridging course before they can be nominated as Permit Receiver or Permit Endorser.
The WPCG training is provided in many regional centers. The schedule is available on wpcg.com.au. If there is not a course that suits your timing or location, please contact WPCG on (03) 9399 8002. Refresher training is available online.
WPCG is not looking to make the WPCG Card a form of photo ID. The contractor is required to comply with any WPCG Member Company requirements for proof of ID.
Your Permit Officer status including renewal dates and Permit Officer vs Senior Permit Officer competence has been provided by the WPCG member companies and will be transferred to the WPCG Work Authorisation system upon successful completion of the Bridging Course.
You will need to complete the WPCG Work Permit online bridging course and your accreditation will transfer across from the WPCG member company to the WPCG system. Your expiry date will remain the same. If you are accredited with multiple WPCG Member companies, the most future date will be selected so as to not disadvantage those with multiple authorities.
Applicants require a minimum of two years oil industry experience or another industry with equivalent Work Permit requirements
The WPCG Work Authorisation process apples to WPCG member facilities sites when there is fuel within bulk site fuel assets. A WPCG member company may consider equivalent Principal Contractor Permit to Work systems as alternative. A WPCG member company will approve use of such systems under the contract. Otherwise it is up to the Principal Contractor to apply the appropriate control of work processes.
Each WPCG Member Company has its own contractor monitoring processes to ensure compliance on their sites. These will continue. It will not be part of the role of JulSen Consulting to conduct this.
All Permit Officers migrating from BP, Caltex and Viva Energy will be given Recognised Prior Learning for Working at Height with respect to issuing Work Permits. You should only issue a Work Permit for which you are competent to issue. For Confined Space Entry, Viva Energy and BP require that all Confined Space Entry entrants, standby personnel, and Permit Officers are trained in Confined Space Entry to a National Unit of Competence by a Registered Training Organisation and current within the past 3 years. Caltex requires such personnel to be trained and competent in accordance with contractual arrangements and Contractor Safety Management processes. All new Work Permit Officers will need the pre-requisite external certificates of competence, so that you understand the work and the hazards associated with the work as you will be authorised to issue a Work Permit with those Certificates as a Permit Officer. You also need to have an understanding of Confined Spaces, in particularly, so that you do not issue a Work Permit for work in a Confined Space if you have not maintained currency of training. The pre-requisites also serve to minimize the material that WPCG need to present during the Permit Officer training and avoids duplication for those that require the National Unit of Competence for other work purposes.
Your accreditation will expire as you will not be able to adequately demonstrate currency of your competence. You will have to commence the process again.
We will allow you to submit Permits from member company systems. The number is being determined and may be on a case by case process.
All new Work Permit Officers will need the pre-requisite external certificates of competence. All Permit Officers migrating from BP, Caltex and Viva Energy will be given Recognised Prior Learning for gas detector competence with respect to issuing Work Permits. Note that with Viva Energy and BP you will need to be trained in Confined Space Entry to a National Unit of Competence by a Registered Training Organisation and current within the past 3 years. Any other Authorised Gas Testers who are not Permit Officers must be able to demonstrate they have completed the required NUC by a RTO; or the Authorised Gas Testers organisation will be required to demonstrate equivalent competency and have this authorised in writing and accepted by WPCG. One way to achieve this might be to have your existing training mapped to the national unit of competence, as defined in WPCG-PRO-01.
The Authorised Gas Tester will need to be competent in a national unit of competence in gas testing, conducted by a registered training organization; or the Authorised Gas Testers organisation will be required to demonstrate equivalent competency and have this authorised in writing and accepted by WPCG. One way to achieve this might be to have your existing training mapped to the national unit of competence and submit this to WPCG for authorisation.
WPCG does not provide professional indemnity or insurance. Permit Officers and Permit Receivers should seek their own advice on financial protection or insurances and comply with any WPCG Member company minimum requirements for any such insurances carried by their organization in accordance with relevant contractual requirements, as applicable.
Only the Permit Officer who issued the permit can amend the Work Permit. Otherwise a new Work Permit must be issued. Any changes must be initialized by the Permit Officer, and the Work Permit must be endorsed by a Permit Endorser at the work site prior to the change being implemented. The Permit Officer does not have to be on site to amend a Permit. However, it is important to note that the Permit Endorser must receive a verbal handover (as a minimum) from the Permit Officer of the change (if they are not the same person) and must endorse the revised Work Permit at the work site.
A hard copy does not have to be on site. However, there must be a copy available to everyone at the work site. This may be an electronic version.
All work authorised by the Work Permit must stop. A new Work Permit would need to be issued.
The WPCG Process will not cover off all aspects of Work Health and Safety. It will not be providing a system to document all the training and competencies of your workforce. It will only be providing information on the training, and currency thereof, in the WPCG Work Clearance, Minimum Controls, and Work Permit processes.
The Permit Officer in such case may be deemed authorized to be the Site Representative and sign this section of the Work Permit if the WPCG member company has authorized them to Permit the work on an unstaffed site or site after-hours. If in doubt, contact the relevant WPCG member company representative.
Yes, so long as they are not the Permit Officer for the Work Permit.
One copy must remain at the work site with the Permit Receiver. A second copy may be obtained by the Permit Officer, e.g. by photocopying, scanning, printing and signing duplicate, or photographing with their phone (in compliance with requirements with regards to use of phones on site). It is anticipated that most Work Permits will be issued electronically, once available. As such there will be a copy available in the cloud for records, and review by the Permit Officer at a later date or off site, in addition to one available on the work site.
Electronic copies can always be retrieved from the WPCG system. There are other technologies available to make copies as required including copiers/scanners at sites, devices/cameras etc.
The Work Permit is authorized by a person with greater authority and will take precedence over the Work Clearance including any standard requirements that may be deemed by the Permit Officer as not required (or not sufficient) for a particular task due to the level of risk. For example, the opposing example to that given may be that the Work Permit requires hot work not to commence for 30mins after tanker delivery and also a repeat of gas testing has been conducted prior to work recommencing.
This system applies to WPCG Member facilities, the WPCG Member Companies will recognise the WPCG Permit Officer accreditation on their sites within scope of WPCG provided the Permit Officer has been engaged by the WPCG Member Companies or an accredited contractor of the WPCG Member Companies. However, please note that some types of facilities may require additional authorization from the member company to be engaged to issue a WPCG Work Permit on certain types of facilities due to the focus of the WPCG training on the Retail environment. Examples include Air BP Facilities and BP Depots. Consult the WPCG member company for information on any such requirements.
Once you have completed the online bridging course for Permit Officers you are able to issue permits for any of BP, Caltex or Viva Energy (Shell branded), if commercially engaged to do so by that oil company or their contractors per normal procurement process.
No, you will be engaged by one of the WPCG Member Companies or their accredited contractors. The WPCG only administer the program. There is no contractual relationship established between WPCG and Permit Officers, Permit Receivers, Permit Endorsers, and Work Clearance Issuers with regards to authorization or delivery of work.
WPCG and oil company representatives will be undertaking spot audits in accordance with audit and assurance processes. A Permit Officer risks losing his or her accreditation if it is found they are not following the correct process. There will be a fair and transparent process for any such action which, if it were to occur, is likely to be a loss of WPCG accreditation and therefore across all WPCG facilities and not just those at which a particular incident (or series of incidents) occurred.
The WPCG will be conducting the assessments associated with certification and refresher training for both new and existing Permit Officers that move across to the WPCG system. Each WPCG member company has their own contractor monitoring processes to manage a contractor’s performance.
No, it is not mandatory to be a WPCG Work Clearance Issuer to issue a WPCG Work Permit. Some organizations (such as integrated maintenance service providers) for their own purposes may require the Permit Officer issue a WPCG Work Clearance Form for their own work deemed to be the issuing of a Work Permit. However, this is not a WPCG requirement.
Yes, if they can demonstrate the required level of competence, and amongst the Work Permits submitted from the buddy process have at least 2 high risk certificates that require authorization by a Senior Permit Officer for that task.
With regards to WPCG member company facilities within scope, up until now you were trained by the oil company X to provide a Permit Officer service to company X. If you wanted to provide Permit Officer service to company Y, you had to complete the training of company Y. Recently BP, Caltex and Viva Energy agreed to harmonise their Permit to Work systems so that all 3 oil company processes, procedures, and training are now the same. You can attend one training session and issue Work Permits for all three companies mindful of any individual additional company requirements such as currency of Confined Space Entry training by an RTO in a NUC at BP and Viva Energy; and BP HITRA training for Senior Permit Officers on BP sites. The training and administration of this training has been outsourced to JulSen Pty Ltd, who will charge a fee for the training and assessment. The changes to the program for existing Permit Officers will be covered through an online bridging course and the information town hall meetings held in the capital cities. These are provided for free.
In most cases there will be one set of rules to follow, one set of forms and one administrator. Permit Officers will be able to issue Work Permits on all three oil company sites within scope and where engaged to do so.
The costs associated with the training was historically by absorbed by each of the three oil companies. The move to a common WPCG system applicable across BP, Caltex and Viva Energy will move to a user-pays system in order to be equitable to all parties utilizing the services of WPCG accredited Permit Officers. WPCG went to tender to select the preferred trainer and administrator for the Permit to Work program who is capable of providing an efficient and effective service using the latest technology and training methodology, at a reasonable cost to Permit Officers.
The Company Trainer program has been in operation for many years and up to 800 trainers were registered at one stage under the program. It was designed to provide a more efficient way for larger organisations to provide Work Clearance training and also to provide additional training sessions in more remote locations to meet demand. Expansion of the Company Trainer program ceased mid 2017 to allow a review of the program. Based on audits of trainers, it became clear that the quality of training and competence of contractors trained under this program was inconsistent and, in some cases, did not meet the required standard.
WPCG recognised there is a need to provide an efficient program for larger organisations with many workers and to provide courses based on demand in remote or regional areas. The new program is under the banner of Licensed Training Provider (LTP). Organisations will be licensed to provide Work Clearance Issuer training, by their own trainers, to their own staff. The trainers must meet minimum training qualifications and experience, and the Training Provider organisation will need to agree to implement the training on specific Terms and Conditions as outlined in a License Agreement. The LTP model focuses on a Company License relationship, not individual Trainer, with WPCG.
Under the Licensed Training Provider (LTP) model, the trainers and contractors will be audited to review the quality of training and competence of trainees. They will be provided with all the training material, assessment tools and by the small trainee cost, access to the online versions of the Work Clearance Form and Minimum Controls Checklists. The cost is reflective of the time required to manage the program, and materials provided.
No, you can only train Work Clearance Issuers. Under the new Licensed Training Provider (LTP) model, similarly, the License Trainers will not be able to train Permit Officers. All Permit Officer training will be conducted by WPCG directly.