employment”. Accordingly, the CESCR took the view that technical and vocational education forms an integral element of all levels of education. The CESCR has recently stated that the obligation to fulfil (facilitate) the right to work requires States parties, among other things, to take positive measures to implement technical and vocational education plans to facilitate access to employment.226 Finally, the European Social Charter contains detailed references to technical and vocational education. The Charter affirms that everyone has the right to vocational training. Under article 10, State parties make various undertakings, including: • to provide or promote the technical and vocational training of all persons, including the handicapped; • to provide or promote a system of apprenticeship and other systematic arrangements for training young people; • to provide or promote adequate or readily available training facilities for adult workers; and • to encourage the full utilisation of the facilities provided by appropriate measures, such as reducing or abolishing any fees or charges and granting financial assistance in appropriate cases. The standards contained in the European Social Charter may be useful in the development of national plans of action. Higher or tertiary education must be made equally accessible to all, on the basis of capacity, by every appropriate means According to human rights instruments, higher or tertiary education must be made equally accessible to all, on the basis of capacity, by every appropriate means and, in particular, by the progressive introduction of free education.227 As noted by the CESCR, there are three differences between the provisions relating to secondary education and those relating to higher education.228 First, the higher education provisions do not include a reference to education “in its different forms”. Secondly, the provisions do not refer specifically to 226 CESCR General Comment No. 18: The Right to Work E/C.12/GC/18 6 February 2006 at para 27. Article 13(2)(c) of the ICESCR and article 28(1)(c) of the CRC. See also article 26(1) of the UDHR (which refers to access to higher education on the basis of “merit”) and article 13(3)(c) of the Protocol of San Salvador. 228 CESCR General Comment No. 13: The right to education E/C.12/1999/10 8 December 1999 at paras 18 – 19. 227 90