The Educational Institute of Scotland has estimated that if plans to grade unit assessments go ahead, the average S4 pupil sitting five exams alongside the new literacy and numeracy tests, could face between 30 and 40 assessments in a session, not counting potential re-sits. This, it warns, would be the equivalent of an assessment a week.
Larry Flanagan, education convener for the EIS, said this week he was "disappointed" by the narrow focus of the Government's consultation on the "Next Generation of National Qualifications in Scotland", which closes today.
The Government had largely ignored options suggested by practitioners sitting on the National Qualifications Steering Group - notably, the option to retain Standard grades but update them in line with A Curriculum for Excellence, or to do away with Standard grades and pull Intermediates 1 and 2 into S4.
In the event, the Government had offered only one option - a hybrid of Standard grade and Intermediates, which the EIS felt was the worst of both worlds.
The EIS is also the latest organisation to call for a delay in the implementation of exam reforms, earmarked for 2012-13. Its warning that the lessons of the Higher Still "meltdown" of 2000 appear not to have been learnt as the Curriculum for Excellence management board, which meets today, is expected to advise the Education Secretary to delay the roll-out of CfE.
Mr Flanagan said teachers were "uncomfortable" with proposals for them to grade unit assessments. Not only were there clear dangers to the teacher-pupil relationship in teachers being the administrators and arbiters of assessments that contributed towards final course awards, but the situation could potentially put teachers under considerable pressure from parents.
The EIS's preference is for S4 to be free of external exams, except for those pupils intent on leaving at the age of 16. Instead of a replacement exam for Standard grade and Intermediate exams, it would rather see an assessment system modelled on FE college qualifications, where course units gain accreditation and build towards a final award.
Such a model would be far more in keeping with the principles of flexibility and personalisation envisaged by A Curriculum for Excellence, said Mr Flanagan.
On the issue of early presentation for exams, the EIS response diverges from that of School Leaders Scotland, the body representing secondary heads which wants to retain the freedom to present pupils for exams in S3.
Current Government proposals to introduce literacy and numeracy tests in S3 or S4 originate in pre-election proposals from the previous Labour-LibDem Scottish Executive, claims the EIS. It was not convinced of the rationale for them then and still fails to find any good reason for additional tests being superimposed, particularly given that literacy and numeracy are supposed to be integral parts of CfE.
The inclusion of a statement of ability in literacy and numeracy as part of a pupil's end of S3 statement of achievement would suffice, argues the EIS.