GENERAL SECONDARY EDUCATION IN UKRAINE IN THE CONTEXT OF EDUCATION IN OTHER EUROPEAN COUNTRIES: DURATION AND STRUCTURE

. The aim of the paper is the comparative analysis of the structure of the general secondary education system in Ukraine and the education systems of thirty eight countries participating in the EU Erasmus+ Programme (27 EU Member States, as well as Albania, Bosnia and Herzegovina, Iceland, Liechtenstein, Norway, Northern Macedonia, Serbia, Turkey, Montenegro, Switzerland, United Kingdom).The authors have analysed the duration of education and the structure of an academic year in Ukraine and in other European countries and made conclusions on the compatibility of the instruction time and holidays length in the Ukrainian general secondary education institutions with those in the foreign ones. Basing on the analysis of the main development trends in the European education area countries the authors have formulated proposals to improve the instruction organisation in the Ukrainian schools in compliance with the transformations currently taking place in general secondary education in Ukraine.


INTRODUCTION. PROBLEM STATEMENT
As a European state, Ukraine shares a common history and common values with the European Union (hereinafter -the EU) Member States. It opens up new opportunities for Ukraine in its European identity. The European choice of Ukraine is confirmed by the Association Agreement between Ukraine and the European Union (2014), as well as by other numerous agreements, statements and political steps that characterize the development vector of our state (Verkhovna Rada of Ukraine, 2015).
The integration of the national education system into the European educational space is an important component of Ukraine's rapprochement with the EU. In this sense, a comparative analysis of the development of the Ukrainian general secondary education national system in the context of transformations undergoing in the education of other European countries, including EU members, is topical. It is important to comprehend the essence of reforms and innovations currently taking place in the European educational community.
The aim of the paper is the comparative analysis of the structure of the general secondary education system in Ukraine and the education systems of thirty eight countries participating in the EU Erasmus+ Programme (27 EU Member States, as well as Albania, Bosnia and Herzegovina, Iceland, Liechtenstein, Norway, Northern Macedonia, Serbia, Turkey, Montenegro, Switzerland, United Kingdom).

METHODOLOGY
In the paper the 2011 UNESCO International Standard Classification of Education (ISCED) has been used as a reference for the analysis of the organization of the secondary education in the countries, i.e. ISCED level 1 -Primary education; ISCED level 2 -Lower secondary education; ISCED level 3 -Upper secondary education. When the need arose, such levels as ISCED level 0 -Early childhood education and ISCED level 4 -Post-secondary nontertiary education were also considered (UNESCO-UIS, 2011).
The analysis covers the national secondary education of Ukraine and the education systems of thirty eight countries participating in the EU Erasmus+ Programme (27 EU Member States as well as Albania, Bosnia and Herzegovina, Iceland, Liechtenstein, Norway, Northern Macedonia, Serbia, Turkey, Montenegro, Switzerland, United Kingdom).

THE EU BENCHMARKS THAT OUTLINE THE DEVELOPMENT OF GENERAL SECONDARY EDUCATION
In the context of building a knowledge society, the EU is implementing the Europe 2020 Strategy (2009), which proclaims the priority of smart, sustainable and inclusive growth in order to increase the competitiveness and productivity of the European countries and support a sustainable social market economy (European Commission, 2010).
The education is seen as an efficient tool for the development of the knowledge economy and social cohesion. The Strategic Framework for European Cooperation in Education and Training "Education and Training 2020" invites the EU Member States to create high-quality national education systems for all segments of the population for lifelong and life-wide learning. The Framework addresses the following four strategic objectives: • Making lifelong learning and mobility a reality; • Improving the quality and efficiency of education and training; • Promoting equity, social cohesion and active citizenship; • Enhancing creativity and innovation, including entrepreneurship, at all levels of education and training.
It also supports achievement of the following benchmarks at the European level by 2020: • at least 95% of children between 4 years old and the age for starting compulsory primary education should be covered with early childhood education • fewer than 15% of 15-year-olds should be under-skilled in reading, mathematics and science • the rate of early leavers from education and training aged 18-24 should be below 10%; • at least 40% of people aged 30-34 should have completed some form of higher education; • at least 15% of adults should be engaged in learning; • at least 20% of higher education graduates and 6% of 18-34 year-olds with an initial vocational qualification should have spent some time studying or training abroad; • the share of employed graduates (aged 20-34 with at least upper secondary education attainment and having left education 1-3 years ago) should be at least 82% (European Commission, 2009).
Education ministers from EU Member States have identified the following priority areas for the secondary education level: • all pupils should develop Key Competences for Lifelong Learning. This can be supported by redesigning curricula and assessment, providing training for school staff, and enhancing the availability and use of good quality learning tools and resources; • each pupil should benefit from high-quality learning experiences and Early Childhood Education and Care should be more widely available; • support for learners with special educational needs, including migrants to the EU, must be improved at the school level, and Early School Leaving should be reduced; • teachers, school leaders and teacher educators need to receive more support, including continued opportunities for professional development and flexible, attractive career options; • quality assurance should be further developed to ensure a more effective, equitable and efficient governance of school education and to facilitate mobility for those undertaking and delivering education and training (European Commission, 2019).
"High-quality education for all will help Europe achieve its economic and social objectives. Good education underpins inclusive and resilient societies. It is the starting point for a successful professional career and the best protection against unemployment and poverty. It fosters personal development and lays the basis for active citizenship. Good education fuels research&development, innovation, and competitiveness" was stated in the Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee of the Regions "School development and excellent teaching for a great start in life" (European Commission, 2017).
The European benchmarks for the secondary education development are synchronized with the global strategy. In 2015, in Incheon, Republic of Korea, the World Education Forum representing 160 states adopted the Incheon Declaration "Education 2030: Towards inclusive and equitable quality education and lifelong learning for all". The Declaration outlines further steps to build the global educational space and develop national education systems in line with Sustainable Development Goal 4 "Ensure inclusive and equitable quality education and promote lifelong learning opportunities for all". The Declaration defines, among other things, the following: "…we will ensure the provision of 12 years of free, publicly funded, equitable quality primary and secondary education, of which at least nine years are compulsory, leading to relevant learning outcomes. We also encourage the provision of at least one year of free and compulsory quality pre-primary education and that all children have access to quality early childhood development, care and education. We also commit to providing meaningful education and training opportunities for the large population of out-of-school children and adolescents, who require immediate, targeted and sustained action ensuring that all children are in school and are learning" (UNESCO-UIS, 2016).

DURATION AND STRUCTURE OF COMPLETE GENERAL SECONDARY EDUCATION IN UKRAINE AND IN OTHER EUROPEAN COUNTRIES
The education is directly related to the economic and social development of the country. Thus, in the Analytical Report for the European Commission "Efficiency and Equity in European Education and Training Systems" (2006) education impact on society in general and individuals in particular is considered from in view of monetary (market) and non-monetary (non-market) effects.
At the individual level, the most obvious effects of education and training are those on wages and earnings. The scholars state that on average across European countries, each additional year of education is associated with more than an 8% increase in wages.
Education affects the well-being of individuals not only via monetary effects. There is also considerable evidence of non-market benefits of education -life-satisfaction and happiness, health, etc.
As for the positive monetary effects for the economy of a country, it has been estimated that each additional year of average educational attainment raises macroeconomic productivity by a direct 6.2 % in the average EU country and by a further 3.1 % in the long run through its contribution to faster technological progress.
There is also increasing evidence of non-market external returns to education -the most important fields of society that are influenced by education are the democratisation, development of civic institutions and human rights, political stability (Woessmann& Schuetz, 2006).
The position of EU on the strategic importance of education in the 21 st century forms a general trend of further extension of schooling in the European countries, both compulsory and complete general secondary education (Lokshyna, 2017).
In Ukraine, according to the Constitution of Ukraine and educational legislation in force, complete general secondary education is compulsory (Konstytutsiia Ukrainy, 1996). Education in primary school (ISCED level 1) starts at the age 6 (7). According to the laws of Ukraine "On Education" (2017) (Zakon Ukrainy «Pro osvitu», 2017) and "On Complete General Secondary Education" (2020) (Zakon Ukrainy «Pro povnu zahalnu seredniu osvitu», 2020), the duration of complete general secondary education is 12 years, the graduation age of students -18 years. However, at present and until 2030, its duration is actually 11 years (graduation age of students -17 years), as the transition to 12-year general secondary education is gradual: • for primary education (four years of study) the transition began on September 1, 2018, • for basic secondary education (five years of study) will start on September 1, 2022, • for upper secondary education (three years of study) will start on September 1, 2027 (Zakon Ukrainy «Pro povnu zahalnu seredniu osvitu», 2020).
At the same time, the educational legislation in force defines preschool education for five-year-old children as compulsory (Zakon Ukrainy «Pro osvitu», 2017; Zakon Ukrainy «Pro doshkilnu osvitu», 2001). However this provision is not supported by the relevant wording in the Constitution of Ukraine, which defines as a compulsory only a complete general secondary education.
The structures of the above mentioned European countries' general secondary education are quite diverse and depend on traditions and educational policies, in particular, on the issue of its compulsory acquisition.
In the majority of the European countries, primary education lasts 4 or 6 years (10 and 17 countries, respectively); in 7 countries it lasts 5 years, in 6 countries -7 or 8 years. Basic secondary education generally lasts 3 or 4 years (23 and 12 countries, respectively), in 4 countries -5 or 6 years. Upper secondary education lasts 3 years in 17 countries, 4 years -in 19 countries, in Lithuania it lasts two years (with the duration of basic secondary education 6 years), in 3 countries -five years.
In Ukraine the structure of general secondary education of 11-year school is as follows: primary education (grades 1-4) lasts 4 years, basic secondary education (grades 5-9) lasts 5 years, specialized secondary education (10-11 classes) is for 2 years. Starting from 2027, the specialized secondary education will be extended by 1 year and become the three-year long with the introduction of academic and professional orientation. General secondary education in the countries that were components of the USSR in its European part, after gaining independence, developed according to different scenarios depending on the political situation, cultural traditions and trends of educational policies.
Estonia, Latvia, Lithuania, which joined the EU, have transformed their national general secondary education systems in accordance with the requirements of the European Education Area, changing the structure and extending the duration of general secondary education to 12 years.
Currently in Estonia the secondary education consists of two levels -basic education (1-9 grades) comprising primary (ISCED level 1) and lower secondary education (ISCED level 2) in a single structure and upper secondary education. The standard period of study in the upper secondary school is 3 years (10-12 grades)

. It is of academic (level ISCED 3) and professional orientation study courses (ISCED levels 3 and 4) that can be mastered in VET non-tertiary education institutions.
In Latvia complete general secondary education has a "classic" structure for the EU: primary education (grades 1-6), basic secondary education (grades 7-9), upper secondary education (grades 10-12).
In Lithuania complete general secondary education also lasts 12 years but has a unique structure: primary education (grades 1-4), basic secondary education (grades 5-10), upper secondary education (grades 11-12). In all three of these countries, students complete their general secondary education at the age of 19.
After gaining independence Armenia, Georgia and Moldova also introduced a 12-year general secondary education. In Armenia and Moldova the structure of general secondary education has not changed, only upper secondary education has been extended by one year, i.e. primary education is for 4 years, basic secondary education -5 years, upper secondary education -3 years.
In Georgia the national system of general secondary education is somewhat different: primary education lasts 6 years, basic secondary education -3 years, upper secondary education -3 years.
In the European part of the post-Soviet educational space there are only 3 states left, except for Ukraine, where general secondary education lasts 11 years. These are Azerbaijan, Belarus and Russia. None of them declares their intention to integrate into the European educational space, limiting themselves to the educational space of the CIS countries.
The duration of general secondary education of the European countries we consider in the paper is at least 12 years. It gives the right to enter universities. In particular in 19 countries the duration is 12 years; in 17 countries -13 years; in 2 countries -14 years. In all the countries, the age of completion is 18 years or more ( It should be noted that in the majority of European countries, unlike Ukraine, the general secondary education is not compulsory. Compulsory education covers at least primary and basic secondary education (ISCED levels 1 and 2) and in most countries continues for another 1-2 years in upper secondary school. In 4 countries (and their number is expanding every year), the compulsory secondary education (ISCED level 3) also covers upper secondary school in its various forms. Thus, full general secondary education is compulsory in these countries. However, in Europe more than 95% of compulsory basic secondary education graduates continue their academic/vocational education in upper secondary schools despite its noncompulsory character.
In 16 European countries pre-school education (ISCED level 0) is also compulsory, its duration differs.
Today in Europe about 50 % of students complete general/academic programmes, the rest -vocational programs at the upper secondary level. The proportion of students enrolled in general education / academic programmes in most countries is 30-70%; the lowest rates are in the Czech Republic, Finland and Slovenia (25-30%), the highest -in Hungary (77%) and Ireland (89%). In Ukraine, after getting basic secondary education (grades 1-9) the majority of students (64.8%) continue their education in upper secondary school (grades 10-11), vocational education institutions (14.7%) or vocational colleges and technical schools (19.6%). In 2019 only 1% of the 9 th grade graduates did not continue their studies. At the same time, the steady trend of an annual decline in the number of 9 th grade graduates is of concern: the share of students entering vocational programmes track has fallen from 38.7 to 34.3% over the past four years, i.e. by 4.4% (Derzhavna sluzhba statystyky Ukrainy, 2019).
Thus, a comparative analysis of the above mentioned data shows that the duration of the general secondary education in Ukraine is currently the shortest in Europe. Only introduction of the 12-year general secondary education will allow reaching the lowest duration indicators among the European countries. The preservation of the current 11-year school will not allow the Ukrainian schools graduates to compete with their peers from the European countries and correspondingly the Ukrainian education to enter organically into the European and world educational area.
In this respect, the case of Turkey is illustrative. After announcing its intention to join the EU the country changed its educational legislation towards increasing the duration of general secondary education to 12 years.
At the same time, it should be noted that according to the Constitution of Ukraine, general secondary education is compulsory. This norm corresponds to the best European standards but creates certain difficulties for the state in both financial and social dimensions.
In our opinion, it would be expedient to interpret this constitutional norm as such that the state creates opportunities for obtaining a full general secondary education through citizen's life but does not require it to be compulsory before the age of 18. After all, part of the 9 th grade graduates intends to get a profession and enter the labour market and not to continue general secondary education. This approach will relieve the upper secondary school from students who at this stage are not able or do not plan to master the relevant educational programme and reduce the budget costs for upper secondary education.
At the same time, these 9 th grade graduates can obtain a profession in VET institutions mastering vocational programmes without completing general secondary education and join the ranks of workers in various sectors of the economy.
Besides, in our opinion, the imbalance between those who receive higher education and those who receive a profession at the appropriate (ISCED 4 and 5 levels) levels of education and go to work should be eliminated. To this end, it is necessary to promote the growth of the share of the 9 th grade graduates who will receive VET and post-secondary non-tertiary education in vocational lyceums, colleges, technical schools and other educational institutions after 9 th grade graduation.

STRUCTURE OF THE ACADEMIC YEAR IN UKRAINE AND IN OTHER EUROPEAN COUNTRIES
Despite some differences in the organization of the educational process, European countries show many common features regarding the structure of the academic year. In most European countries, the academic year begins in early September; in 18 European countries (regions) the academic year begins, as in Ukraine, on September 1. In 10 countries, usually in northern Europe, it begins in August: first of all -in Denmark and Finland. In Germany, schools in different lands actually start teaching between August 5 and September 11, although the official start date of the academic year is August 1. In some countries, usually in southern Europe, the start date of study is usually mid-September (Albania, Greece, Italy, Portugal, Spain); in Malta, children go to school in late September. In Austria, Germany, Spain, Italy, the Netherlands and Switzerland, the beginning and end of the academic year depend to a large extent on the regions.
In primary schools in Europe, the range of recommended annual minimum instructional hours for a conditional academic year ranges from 469 standard (astronomical) hours per year in Bulgaria to 1,051 hours in Denmark. In four countries (Denmark, Ireland, Luxembourg, the Netherlands) the recommended minimum instruction time for a conditional academic year exceeds 900 standard (astronomical) hours, in seven countries (Bulgaria, Bosnia and Herzegovina, Latvia, Lithuania, Romania, Croatia, Montenegro) it is less 600 hours. In primary education in European countries, the recommended minimum instruction time (i.e. the lower limit) for a conditional academic year is on average 740 standard (astronomical) hours.
In Ukraine, the maximum allowable annual workload per primary school student (i.e. the upper limit) is only 499 standard (astronomical) hours per year (Figure 1). That is, during the school year, Ukrainian students attend primary school one and a half times less than their peers from Europe, although they master no less, sometimes even more, material. This raises the problem of overloading primary school students, which has recently increasingly worried the teaching community and parents, because the intensity of educational activities of children who are just beginning to adapt to school conditions is too high.

Fig. 1. Maximum permissible instruction load per year for general secondary education students in Ukraine and the recommended maximum instruction time per year on other European countries
In European countries, the range of recommended annual minimum instruction hours for a conditional school year for basic secondary education (ISCED 2) ranges from 637 standard (astronomical) hours per year in Croatia to 1,200 standard (astronomical) hours per year in Denmark; in Spain, the Netherlands, and the United Kingdom (Northern Ireland's education system), it also exceeds 1,000 standard (astronomical) hours per year. In general, in European countries, the recommended minimum instruction time for a conditional academic year at the level of basic secondary education exceeds the level of primary education by an average of 133 standard (astronomical) hours and is 873 hours.
In Ukrainian schools at the level of basic secondary education (grades 5-9) in accordance with the current State Standard, the maximum allowable instruction load for students is 824 standard (astronomical) hours per conditional academic year, i.e. 49 hours less than the average value (873 hours) of the recommended minimum instruction time for an average academic year in EU Member States.
In the profile high school of European countries for academic (general) programmes that provide access to the next level of higher education, the average value of the recommended minimum instruction time for an average academic year reaches 903 standard (astronomical) hours, which is 30 hours more than the basic secondary education. In Spain, France, and the United Kingdom (Northern Ireland's education system), the recommended minimum instruction time is about 1,000 standard (astronomical) hours or more; in Northern Macedonia it is the lowest -774 hours. In some countries, such as the United Kingdom (the education systems of England and Scotland), there are no centralized standards for the recommended minimum time at this level.
In Ukraine, this indicator for high school is equal to 866 standard (astronomical) hours per academic year, i.e. less than the average of European countries by 37 hours and is much lower than the education systems of leading European countries.
In European countries, the most common range of school days in an academic year is between 170 and 190 days. In about half of the educational systems, the length of the academic year is within 180 days; in 17 countries / regions the number of school days varies from 181 to 190 days. The shortest academic year in a primary school is in Belgium (Flemish community) -157.5 days, the longest timespan that children attend schools is in Denmark and Italy (up to 200 days). In most countries, the number of school days per academic year in primary and basic secondary education is the same. On average in European countries, the academic year in primary school lasts 182 school days, in basic school -179 school days. In high school, the range of school days in the academic year is wider, as it depends on the type of educational programme mastered by students, the examination period and other factors that affect its duration. This figure is even higher in OECD countries ( Figure 2).

Fig. 2. Duration of an academic year in Ukraine, EU Member States and OECD countries
In Ukraine, the school year lasts 175 school days, i.e. closer to the lower limit of the school year in the EU. In fact, given the holidays, quarantine activities (even before the COVID-19 pandemic) and other circumstances that arise during the school year, its duration is really even shorter; the actual school year usually lasts less than 170 school (working) days, as it traditionally ends by June 1, regardless of the number of days worked, although by law the school year can end by July 1. It is worth noting that in terms of the number of school days during the completion of general secondary education; today's Ukrainian students are inferior even to secondary school students who studied in a 10-year school during the Soviet period, as there was a six-day working week. After all, each school year, the current 11-year school has 35 school days less in a school year compared to the 10-year Soviet school; for 10 years of study there are 350 days, which is equivalent to two academic years of 175 days. That is, the introduction of a 12-year period of complete general secondary education by the current Law of Ukraine "On Education" practically renews the number of school days of the Soviet "decade schooling".
In Europe, the school year usually ends in mid-June; at this time, summer vacations begin in most countries. In European countries, the time and duration of vacations during the school year are different. In addition to summer vacations in secondary schools in Europe, there are four more vacation periods: autumn holidays, Christmas and New Year, winter carnival holidays, as well as spring at Easter. The start of summer vacations depends on the structure of the school year of a particular country and lasts from 6 weeks in the Netherlands, some lands of Germany, Great Britain to 13 weeks in Albania, Italy and Portugal.
In Ukraine, summer vacations in primary school last 13 weeks, in primary school 11-13 weeks, depending on the year of study, which is closer to the maximum duration of summer vacations in European countries.
In Ukraine, obtaining a complete general secondary education at all its levels (primary, basic secondary, specialized secondary education) is inferior to European countries in terms of the number of study hours. The length of the school year in Ukraine is closer to the lowest number of school days among European countries. One can observe a clear trend at all the levels of general secondary education: in our education system, it is normatively assigned less time to obtain the appropriate level of education than in European countries, due to which students are unreasonably overloaded. At the same time, Ukrainian schoolchildren have one of the longest vacation times without proper organization of their leisure and development. All-in-all, this leads to the situation that Ukrainian students are given less time to master the content of educational programmes of the appropriate level of general secondary education than their peers from European countries, although Ukrainian programmes in terms of the requirements and scope of acquired knowledge and acquired competencies are equivalent to European ones, and in some cases (for example, for primary school) even exceed them. Ultimately, this affects the physical and mental health of children, especially younger students, due to unjustifiably excessive intensification of their learning activities, leading to fatigue and exhaustion.

CONCLUSIONS
Basing on the results of the comparative analysis of complete general secondary education duration in Ukraine and European countries the following conclusions can be drawn.
1.-The introduction of a 12-year period of complete general secondary education by the Law of Ukraine "On Education" (2017) is a justified step, as it meets the basic principles of educational policies of the world community, including the provisions of the Incheon Declaration "Education 2030", and reflects an objective regularity of a continuous increase in learning time, which is clearly traced in the history of mankind, especially at the present stage.
2.-The EU recognizes the strategic importance of education in general and general secondary education in particular for building an open democratic society and declares the general trend of European countries to further extend schooling both in the formats of compulsory and comprehensive secondary education. Today, there is no European country with a term of complete general secondary education less than 12 years. Ukraine's aspiration to the EU inevitably presupposes the integration of the domestic education system into the European educational space, which requires bringing Ukrainian legislation into line with European educational policies, in particular in terms of the duration of education. After all, the 12-year term for completing general secondary education corresponds to the lower limit of its duration in European countries.
3.-The comparison of the annual workload of Ukrainian schoolchildren with the recommended minimum instruction time per year in European countries shows that in the home system of general secondary education at all levels, Ukrainian schools have less instruction time for education than in other European countries. At the same time, the vacation period in Ukrainian schools is approaching the highest rates among European countries. Due to various factors, the length of a real academic year is often less than the statutory 175 school days. This causes students to become overloaded, which affects their health. Therefore, it is worthwhile to consider the possibility of a real prolongation of the academic year at least until mid-June.
4.-According to the Constitution of Ukraine (Article 53), full general secondary education is compulsory. We believe that this constitutional norm should be interpreted as an obligation of the state to create opportunities for obtaining a full general secondary education during life, which does not then require its mandatory acquisition before the age of 18. Such an interpretation of this norm would alleviate the financial and social tensions that exist in the society today, improve the moral climate in Ukrainian schools, relieve specialized lyceums of some students who are not going to get a full secondary education at this stage of life, but want to get a profession and start working. Over time, when they need such education, they will be able to obtain it free of charge in the forms envisaged by law.
5.-We believe that for more efficient use of resources it is advisable to eliminate the imbalance between those who receive higher (university) education and those who intend to acquire a professional specialty at the appropriate levels of education and go to work. Today in Ukraine, the majority of high school graduates (about 80%) are focused on entering higher education institutions, which in principle could be considered positive if they were all ready to continue their studies at universities. In this regard, it is more appropriate to achieve European indicators, because in Europe there is an approximate parity between those who choose to study at universities and those who choose the path of acquiring a specialty. Therefore, in our opinion, it is necessary to take the necessary measures to reorient some applicants for secondary education to vocational training and professional higher education with further employment in various fields of economic activity.
Thus, the comparative analysis of the structure and indicators of the duration of general secondary education in Ukraine and in other European countries has showed that in Europe there is a steady trend to increase the duration of students instruction in school, extend the duration of secondary education in academic or vocational programmes, education of all children under the age of 18. This objective pattern of human development is proclaimed in the Declaration "Education 2030", adopted by the international community at the World Education Forum in 2015 in Incheon (Republic of Korea). Ukraine is to be building its educational policies in accordance with the world trends in the development of education and society as a whole to successfully integrate Ukrainian education into the European and world educational space.