Proctor Conflicts of Interest
What is CCO’s Proctor Conflicts of Interest (COI) Policy?
CCO has adopted the following policy to avoid conflicts of interest in testing:
- An individual may not serve as Proctor or Assistant Proctor for a specific candidate who is a Family Member, defined as a spouse, domestic partner, parent, child, sibling, grandchild, in-laws, stepparent, stepchild, guardian and ward, or member of one’s household.
- An individual may not serve as a Proctor for a specific candidate they have trained for a period of one year from the date of the conclusion of the training activities if there is a sufficient connection between the training and the test.
- An individual may not serve as an Assistant Proctor for a specific candidate they have trained for a period of 28 days from the date of the conclusion of the training activities if there is a sufficient connection between the training and the test.
View the complete Proctor Conflicts of Interest Policy.
Why is CCO now implementing a COI policy?
CCO has always had a COI policy. However, this policy came under review after a number of test security incidents in recent years. The ISO 17024 personnel certification standard and OSHA rules include requirements to separate training from testing. CCO is clarifying its position on this matter and, as of March 31, 2023, a trainer will not be permitted to administer CCO exams to an individual they have trained if the training and testing are too closely related.
When will the COI policy take effect?
The new conflict of interest requirements take effect on March 31, 2023.
Is the COI policy applied on an individual or a company level?
The COI policy applies to individuals, not to companies as a whole.
If I administer a practical exam before I provide classroom training for the written exam, does this satisfy the COI Policy?
As long as you do not provide training to prepare for the CCO practical exam, yes! The conflict of interest is evaluated at the time of testing. Therefore, if you administer a practical exam before any training has occurred, you would be working within the policy.
Can I proctor exams in programs for which I have not provided training?
Yes, the COI policy is program-specific. If a Practical Proctor provided training on the Mobile program, they may, without a waiting period, proctor exams in any or all other programs.
What are considered “programs” under the COI Policy?
The following are considered CCO programs for purposes of the COI Policy:
Will a conflict of interest exist if the candidate is permitted practice time in advance of a practical exam?
No, practice time is not part of the training.
If I trained students on job site safety rather than mobile crane operation, for example, can I still be their Practical Proctor for a mobile crane certification exam?
Yes, this would not create a conflict. The trainer could still proctor the exam because they trained on job site safety, not to prepare the candidate for CCO program certification exams.
If Coworker A helps Coworker B in the field by providing training or help with specific signaling, is it a conflict of interest for Coworker A to later proctor a CCO Signalperson exam for Coworker B?
No, it is not a conflict of interest when on-the-job training is provided on a jobsite. Rather, it is a conflict of interest when training is provided to prepare candidates for CCO program certification exams and the trainer then seeks to proctor a related CCO exam.
If general equipment or operation theory instruction is provided, for instance in an apprenticeship, is this considered training for CCO Certification?
No. General training on equipment or operating theory which is not specifically directed to preparing a candidate to take a CCO exam is not considered training for CCO certification. Therefore, the COI Policy would not apply.
Is there a conflict of interest if I provide training specifically to prepare a candidate for CCO program certification, and I then seek to proctor a CCO exam for that candidate in the very same program?
Yes, in this case, the training is clearly preparatory for examinations in a CCO program and the COI Policy would impose limitations on the trainer’s ability to proctor exams in the very same program within a specified time period.
Does this mean that, for practical exams, the person providing training to a candidate will no longer be able to administer that candidate’s practical examination?
That is correct if the training covered the subject matter of the test and there is a sufficient connection between the training and testing. For example, if a person provides training to a candidate to prepare for a CCO program certification, they may not also administer a practical exam to that candidate, in that same program, for a period of one year. Another Practical Proctor would need to be brought in.
If I am training candidates for the written exam, may I serve as a Practical Exam Proctor for those candidates?
No, not if the training was in the same CCO program as the practical exam and there is a sufficient connection between the training and the test. There is no differentiation between written and practical. If a person provides training to a candidate to prepare for a CCO written examination in a particular program, they many not also administer a practical exam as a proctor to the candidate in that very same program (e.g., Mobile Crane Operator, Rigger, Signalperson) for a period of one year.
Can two related people split the classroom teaching and proctoring the practical exam?
Yes, that is permitted. To be disabling, the conflict of interest must be between a proctor and the individual taking the exam. Family members teaching/training together is not an issue under CCO’s COI Policy.
How can training providers with fewer employees conducting training avoid conflicts of interest for proctoring practical exams?
Smaller companies may want to consider having the trainer conduct the practical exam first, then the classroom training (before the written exam). If the training and testing are closely related, there will still be a need for a proctor who was not involved in training to administer the subsequent written exam.
How can training providers with many employees conducting training avoid conflicts of interest for proctoring practical exams?
Person A can proctor for a group that Person B trains, and Person B can proctor for a group that Person A trains. They will basically swap groups for testing.
Do I need to hire a third-party proctor to resolve a Proctor Conflict of Interest?
No, the COI policy does not require that you hire a third-party proctor. However, if a proctor conflict of interest arises and cannot be resolved otherwise, hiring a third-party proctor may be a convenient solution. If you would like to contract a proctor for hire for an EOT written exam administration, you should consider contacting Proctors, Inc. (917-808-2343). If you would like to contract a practical exam proctor for a practical exam administration, you can find a list practical exam proctors for hire here.
Will trainers be allowed to interact with candidates prior to taking a practical exam?
Yes. Incidental or purely administrative contact during the training process is not deemed to constitute participation in training. Also, merely providing resources (such as testing equipment or training supplies) or selling course materials is not deemed to constitute participation in training. The focus is on whether a person provided training to prepare a candidate for a CCO certification examination in a particular program, and that person later seeks to administer an examination in the very same program.