So do you see the same complications with CPD under the 2006 Act?  Do you consider the Board has also acted ultra vires in this circumstance i.e. given themselves more power than the legislation intended?  This point has been made by other bodies, more learned than us - i.e. the Regulations Review Committee and the Office of the Auditor General - in their reports.  You would think the Minister overseeing the Board would consider this a worrying trend - that a relatively small administrative Board would assume power bigger than Parliament.  However, it appears not as he backs them at every opportunity.  I guess the current consultation on CPD gives us yet another opportunity to state this fact.  25% self directed learning is not enough in my opinion.  It's simple, if it is a matter necessary to promote the health and safety of the public then make it a formal unit standard, make everyone do it and then drop it down into the apprentice programme so that it is embedded there and make competency assured going forward.  The only other way is to do random audits of people's work on a regular cycle.  It looks also like the Board will be looking over courses a little more closely before they accredit them if this all goes through - so hopefully there goes the manufacturer's sales pitches cleverly disguised as credit earning courses.  When it all boils down - the proposed scheme for 75% is still buying points rather than knowledge and cannot be tailored to your specific business but will become an exercise where we go to get the biggest bang for our buck and time - i.e. the course that is the shortest, cheapest and returning the most points.