I have been trying so hard not to post a reply on this subject - but I guess I'm just weak ;-) Ok, In the UK the legal requirement is Health and Safety law. Section 2 of HASWA states that the employer has to be able to prove that the employee has received adequate basic training. On completion of training we the instructors issue a basic operator certificate as proof of adequate training - we dont issue a "licence"
If the certificate holder has been trained by a commercial trainer the trainer has to hold accreditation from the awarding body - if its an in-house certificate the instructor does not have to hold accreditation but the certificate is limited to that company only. A non accredited instructor can not issue certificates or imply in any way accreditation from the awarding body.
Now - UK instructors should follow training guidlines from the ACOP (L117). If the instructor does not follow the L117 that in itself is not an offence but it may be used as evidence that an offence has been committed.
So, the legal requirement in the UK is that the employer has to be able to prove that the employee has received adequate basic training in accordance with Health and Safety law (section 2 HASWA 1974, & PUWER '98 regulation 9)