Today’s correspondent is “… a third year paramedicine student at … [a named university]”. They ask:

 Do you know if one can legally work on a site under their student registration and work up to the skill level of that year in the degree if competent? I’ve heard a lot of mixed answers.

I was thinking of doing a cert 4 in health care before I graduate just to cover my bases but as a third-year paramedical student do I need to do this in order to be a medic on a mine site?

A person conducting a business or undertaking (a PCBU) needs to ensure that there are in place adequate provisions for first aid (see for example Work Health and Safety Regulations 2011 (NSW) rr 42 and 42; Work Health and Safety (Mines and Petroleum Sites) Regulation 2014 (NSW) Sch 7)).

The Model Code of Practice for First Aid in the Workplace (2019) stresses that it is up to the PCBU, in consultation with workers, to determine what the first aid requirements for their particular workplace are.  The Code of Practice says (at [3.5]):

As a PCBU you must ensure an adequate number of workers are trained to administer first aid at the workplace or workers have access to an adequate number of other people who have been trained to administer first aid. First aid in the workplace can be provided in two ways:

1.         training one or more of your own workers to administer first aid, or

2.         arranging for a person who does not work for you to administer first aid to your workers provided they have been trained to do so…

As a minimum first aiders should hold nationally recognised Statement/s of Attainment issued by a Registered Training Organisation (RTO) for the nationally endorsed first aid unit of competency Provide First Aid or a course providing equivalent skills. A higher level or additional training may be required to ensure your first aiders have appropriate skills for the risks you have identified in your workplace.

(And when it comes to being a first aider, remember that terms like ‘medic’, ‘first responder’, ‘advanced responder’ etc are not legally defined – what the mine needs is someone to do first aid, regardless of what they are called).

What training the first aider requires is not mandated (even the requirement of a first aid certificate is a recommendation – they ‘should’, not ‘must’ hold that qualification). If a mine site wants to employ a third year paramedic then the PCBU would need to consider what skill set that involves.  Does the student paramedic have the equivalent or higher skills than Provide First Aid?

So the answer to the question “can you legally work on a site as a first aider as a third year paramedic student?” has to “yes; it’s not illegal to do that”.  It may not be ‘illegal’ but it may not be wise.

If we assume the relevant decision makers in the PCBU are the mine managers, they need an assessment of the first aid needs and then either employ someone to provide first aid or engage someone. If they are going to employ someone, they will want someone with a qualification or train them to that qualification.  A third-year paramedic may or may not have equivalent skills but how would the PCBU know?  If you have the qualification, then you have it.  What is the skill level or scope of practice of a third-year student? There really is no scope of practice; student paramedics necessarily practice under supervision. And what you have done in your three years may be different to another student so there is no indication of what it is you may or may not know.  The PCBU cannot say ‘we assessed your qualification’ because you don’t have a qualification.

A much better bet would be to do a qualification – whether a First Aid Certificate, a Certificate IV or something else. If the learning in the degree equates to learning for that qualification, then apply for recognition of prior learning. The Registered Training Organisation that issues the qualification is in a position to assess, and certify, equivalence, whereas a PCBU operating a mine is not.

To put that another way, student registration does not carry any right to practice so you cannot practice anywhere ‘under student registration’ (and a word of warning, if you do, it may cause the Paramedicine Board to query whether you are a fit and proper person to be a paramedic if you don’t understand your own limitations).

Calling yourself a student paramedic may not be the same as calling yourself a paramedic but as with so many things, context is important (see The use of protected titles by students and others (January 30, 2018) and NSW students and retired officers referred to as ‘paramedic’ (August 14, 2019)).  A student paramedic on clinical placement, working with a paramedic whilst wearing a uniform that says ‘student paramedic’ is probably making it clear to anyone they interact with ‘I’m not a paramedic, I’m a student’. But a student paramedic who applies for a job on the basis of their progression, so far, through the degree may mislead any potential employer as to their capacity – given they are indeed applying for a job and claiming to be able to ‘work on a site under their student registration’.


If you want to get a job as a first aider at a mines site then I suggest you would want, and a PCBU would require, a qualification.  A third-year student may be competent in somethings but is not qualified to do anything.

Whilst a PCBU could employ a third-year paramedic to provide first aid if satisfied that the student had the necessary skill set, a student paramedic my put their future registration at risk if they held themselves out as being qualified or even competent to practice given that no university, nor the Paramedicine Board, nor any jurisdictional ambulance service would give them an authority for independent practice.

This blog is made possible with generous financial support from the Australasian College of Paramedicine, the Australian Paramedics Association (NSW), Natural Hazards Research Australia, NSW Rural Fire Service Association  and the NSW SES Volunteers Association. I am responsible for the content in this post including any errors or omissions. Any opinions expressed are mine, and do not necessarily reflect the opinion or understanding of the donors.