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1. Date of next review Page 35 Merthyr Tydfil County Borough Council CONTENTS 1 0 Introd ction EE 3 2 0 AIMS E 3 3 0 PQ STIS Ss Aeon hac Sax rise hea aeacs qancincae tae nace gatos A E ates oe ecteae node uiecr eck en te de 3 4 0 Legal REQUIREMGINS 2 2 2 seve rote EE EE E dE EE ee eden 3 5 0 The Driver sy e ets ic ek hee ee ne ee Eaa aeaaeai aeaea Ea 5 6 0 Ru lte e 6 7 0 Bib dL Bee EE 8 8 0 Advice for the SOUrNCYiisiiccrisesccccce celeesesesuee ENKER denen canegts saat caneeceteseeeemaciee EES 9 9 0 In the Event of an AGCIA SIMs 5 satesdte tore cand sate lave dens cad secede certvavdsevireitserdaed eon eed 14 10 0 Health and Safety of Drivers and Passengers e 14 11 0 Other Considerations for Gchoole ek 15 12 0 Summary Of Responsibilities iccs ersevcetv d se AED EE enews 15 APPENDIX 1 Pre drive safety EE 18 APPENDIX 2 Advice for minibus divers 20 APPENDIX 3 Duties of a passenger assistant ccc ceeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeneeeeeeeeeeeeeees 22 APPENDIX 4 First aid kit and other equipment for minibuses cece ceeeeeeeeeeeeeeeeeeeeeees 23 APPENDIX 5 Minibus Driver Training Providers eect eee eter etter eeeeeeeeeeeeneeeeeeeeees 25 age 36 Minibus Policy 2013 Merthyr Tydfil County Borough Council 1 0 Introduction This policy provides clarity and advice on the Council s position in relation to its operation of minibuses across all its services including schools It is essential that all m
2. See section 5 1 for guidance on work equipment risk assessments 6 Provision amp Use of Work Equipment Policy 2013 Page 66 Merthyr Tydfil County Borough Council 4 2 Suitability of Work Equipment 4 2 1 Suitability of equipment provided for intended use Any equipment that is provided for use by employees must be fit for purpose i e fit for its intended use This is to ensure that a The equipment can be used for its intended purpose without risk of injury or risk to health to employees or to others b Any hazards associated with the use of the equipment must also be taken into account This may include the weight of the equipment the power requirement electrical etc waste generated dust noise vibration risk to the public and so on c Arrangements must be made for the secure storage of the equipment when it is not in use particularly to ensure that unauthorised persons are not able to access the equipment d Equipment designed for a particular purpose must not be used for any other purpose or adapted or modified in any way See section 5 2 for guidance 4 2 2 Suitability of equipment for the persons using it Equipment must be suited to the persons who are intended to use it This means that the following must be assessed to determine if there is any increased risk arising from a The physical strength of the person who will use the equipment b The age or mental capacity of the person who will use the
3. During the journey Do not allow noisy or boisterous behavior Do not allow passengers to trail any article from the vehicle e g flags Do not allow child passengers to operate the doors Approach each stop slowly and with care Use hazard warning lights whenever children are boarding or leaving the vehicle If there is a serious delay during school related journeys then inform the school so that information may be passed to parents Mobile phones must not be used by the driver whilst driving Children must not be left unaccompanied in the minibus If the vehicle breaks down or is involved in an accident give clear instructions to the passengers and see that children remain together and supervised their safety is paramount If there is a risk of fire however small evacuate the vehicle and move the occupants to a safe place If you must stop for an emergency breakdown whilst on a motorway only stop on the hard shoulder and as far away from the carriageway and passing traffic as possible Again ensure that passengers especially children remain together and are supervised Merthyr Tydfil County Borough Council If requested by the police or any other person having reasonable cause give particulars of the driver s name and driving licence At the end of the journey Ensure that children are supervised when leaving the vehicle especially if they are using a rear exit Never allow pas
4. 1 Park as far to the left side of the road as possible in the safest possible position 2 If possible get all the passengers out of the vehicle using near side exits and keep them as far off the road as possible 3 Do not cross the road or allow the passengers to do so Ensure the hazard warning lights are turned on 5 Deploy the warning triangle on the same side of the road 50 metres behind the vehicle 6 Summon assistance ag amp 46 Minibus Policy 2013 Merthyr Tydfil County Borough Council The information contained in Boxes 1 amp 2 is general advice and particular circumstances may justify an alternative course of action For example waiting outside the vehicle in mid winter may be inadvisable some passengers with disabilities may be unable to climb over the crash barrier to reach the embankment and so on Drivers should therefore assess the actual situation taking account of individual circumstances and follow the safest course of action age 47 Minibus Policy 2013 9 0 9 1 9 2 9 3 9 4 10 0 Merthyr Tydfil County Borough Council In the Event of an Accident The driver should inform their Manager or Headteacher as soon as is reasonably practicable Insurance details should be swapped with a third party as soon as is possible However NO LIABILITY should be admitted Where it is safe and necessary to do so passengers should be removed from the vehicle and t
5. The authority has developed an arrangement with school governing bodies whereby the cost of their Service Level Agreement SLA is reduced if they sign up to a training programme with the aim of equipping governors with the knowledge they need to help them undertake their role Strong collaborative links with neighbouring authorities has helped to build capacity in the workforce in areas such as procurement The authority s redeployment scheme was identified as a good example of taking individual needs into account and responding to them accordingly Staff at all levels seem to have a good understanding of local issues though not necessarily all equality issues and are committed to delivering for people in Merthyr The Civic Centre building is regarded as improving in terms of access and front facing staff understand the needs of service users Equalities has been considered as part of the corporate branding and corporate style guide which provides a Page 20 checklist for minimum standards to ensure the needs of people with protected characteristics are considered and there is consistency in communication Areas for Improvement 4 9 4 10 4 11 Some felt that the ongoing requirements of the new duties in relation to employment were not fully recognised and that Job Evaluation was seen as a one off exercise For example Payroll and HR systems are not integrated which means that equality employment information r
6. tickbox exercise in practice While the SEP is the council s key strategic document for equality it wasn t always understood to be integral to organisational business Evidence from some interviews showed that it wasn t always clear where officers saw the SEP in relation to their service areas or individual areas of responsibility Furthermore it wasn t apparent how equality objectives drove and influenced service objectives The next phase of developing the SEP and embedding equality work could focus on strengthening the line of sight between the council s vision for equality and organisational business A stronger strategic direction in relation to equality would also support the Equality Elected Member Champion s role Currently the Champion supports the equality officer in overcoming barriers as and when they arise but a clearer strategic direction would enable the Champion to be more proactive in generating change While there was evident commitment from the political leadership and Elected Member Champions the council could increase the involvement and awareness of other councillors All councillors have a responsibility for equality in their various roles including representing people in their wards and ensuring equality is considered as part of scrutiny Though equality and specifically equality impact assessment EIA has been included in agendas this could be further developed to ensure there is effecti
7. business planning process This will help ensure the council has an effective process for setting equality objectives as per above highlighting how equality work can help serve the community target resources effectively and deliver better outcomes Including Welsh language data within this could help integrate the two areas of work The authority could align and coordinate the collection of equality information and ongoing partnership needs assessment work undertaken for the SEP and SIP Aligning the two could reduce duplication of effort and increase the line of sight between the two strategies Page 8 1 18 The authority could support community and protected characteristic groups within the procurement process While the procurement team work closely with local SMEs they could consider how support could be targeted towards community groups and organisations established by or for protected characteristic groups 2 Leadership and Organisational Commitment Strengths 2 1 2 2 2 3 2 4 2 5 A clear commitment to equality was articulated by both the political and professional leadership The majority of political and professional leaders and operational officers identified the equality officer as the lead person on equality in the organisation noting her energy and drive as key factors in taking the agenda forward Both the Equality and Older Person s Elected Member Champions were recognised as powerful advoc
8. drivers be trained in a non PCV course to an acceptable standard of driving competence e g the MiDAS scheme 4 3 Drivers who gained their car driving licences after January 1 1997 A D1 PCV licence does not need to be held if all of the following conditions are met Di The driver must be aged 21 years or over o The driver must have held a full driving licence for at least two years The driver is trained in a non PCV course to a standard of driving competence expected by the Local Authority e g MIDAS or ROSPA schemes No trailer is to be attached CH Oo Qa No driving outside the UK takes place f The maximum weight of the vehicle must not exceed 3 5 tonnes The driver must be driving in a voluntary capacity i e they receive no payment for driving and driving does not form part of their job description h The minibus is used for education or social purposes by a non commercial body If one or more of the above conditions is not met the driver must hold a full D1 PCV licence plus E if they tow a trailer Please note further to f above many minibuses on the market today weigh more than 3 5 tonnes and it is possible that the majority if not all will be above this weight in the future In the long term then it may become necessary for all drivers to hold full D1 PCV licences age 38 Minibus Policy 2013 Merthyr Tydfil County Borough Council 5 0 The Driver 5 1 All em
9. needed Ensure that children are supervised when boarding the vehicle especially if they are using a rear door Plan which passengers will sit in the front seats and by the doors Do not exceed the carrying capacity of the minibus Make sure everyone is sitting one to a seat and are using seatbelts When school bus signs are used make sure they are in position only when children are being transported and that they do not obstruct your vision Always ensure that ambulant disabled passengers are seated safely and comfortably and that passengers travelling in their wheelchairs are safely restrained Wheelchairs not in use must also be securely stored Make sure there is a complete list of the passengers being carried with a note of any special medical or other needs Keep the list with other relevant documents in a place where it can be readily found in the event of an accident Check that children have any necessary medication with them Take care when using passenger lifts and other specialist equipment Always comply with the manufacturers instruction Check that no bags or clothing are caught in the doors and check all mirrors every time before moving away in case late comers are approaching the vehicle Check that all luggage is secured and that gangways and exits are clear Know the height width length and weight of the minibus and the position of the exterior fuel cap age54 Minibus Policy 2013
10. addition to any routine maintenance and inspection work Whenever such equipment is acquired the appropriate arrangements must be made to ensure that a written scheme is drawn up and implemented The implications of this examination are potentially serious Any identified fault could prevent further use of the equipment until it is rectified and the examiner is required to inform HSE as soon as possible of any fault regarded as critical 9 Work Equipment Policy 2013 Page 69 Merthyr Tydfil County Borough Council 4 5 Information Instruction Training amp Supervision Employees will require information instruction and training in order to use work equipment safely This is particularly important where controls cannot completely eliminate the risk from using the equipment Any instructions given by the manufacturer must be adhered to at all times Manufacturer manuals are typically the most accessible source of information and instruction The extent of the information instruction and training given depends on the complexity of the equipment and the specific risks associated with its use Line managers will need to supervise users in order to ensure control measures and safe systems of work are being correctly followed 4 6 Safe Use of Equipment Employees also have a part to play in reducing the risk from using work equipment Users of work equipment must a Follow instructions and training given b Follow systems of work
11. already undertaking work to extend and strengthen its approach to engagement and consultation but would emphasise the importance of oOo 1 15 1 16 1 17 ensuring a continuing focus across the protected characteristics as part of this For example it will be important to ensure the Citizens Panel is representative and that additional engagement with protected characteristic groups is undertaken where necessary to ensure there is sufficient representation of each The authority could share effective practice and develop consistent standards for engagement and consultation The LSB engagement and consultation work will seek to share effective practice and develop consistent standards both across partners in Merthyr Tydfil and Rhondda Cynon Taf LSBs This could include extending the use of tools that support engagement with protected characteristics groups such as the MIA engagement tool or encouraging other departments and partners to engage with fora such as the Youth Forum It could also involve developing common principles on when to engage and to what level as appropriate to the situation or issue with the aim of supporting professionals in effectively engaging with protected characteristic and seldom heard groups The authority should develop an effective process for the coordination collection and use of equality data from service delivery the census and other sources to shape equality objectives within the SEP and
12. extinguisher and be fitted with a fuel cut off switch The prime concern must always be passenger safety and welfare Should a fire break out passengers must be evacuated from the vehicle immediately and led to a safe place Only then can fire fighting attempts begin and then only if the crew consider it prudent to do so What to do if there is a fire ch Stop immediately and switch off the engine N Leave the gear stick in neutral in case of accidental engine re ignition oo Engage fuel cut off switch if fitted KK A Get the passengers out and away from the vehicle closing the vehicle doors behind them 5 Call the emergency services 6 If you have time remove the ignition key engage battery isolation switch if fitted close all windows and if you think there may be an engine fire release the bonnet catch but do not open the bonnet 7 Tackle the fire ONLY IF IT IS SAFE TO DO SO 8 When the emergency services arrive inform them if there is a hazardous load on board for example gas canisters age 45 Minibus Policy 2013 Merthyr Tydfil County Borough Council 8 3 4 Mechanical Breakdown Should a minibus break down on a highway the occupants are immediately at risk For advice on what to do in the event of a breakdown on a highway other than a motorway see Box 1 below For a breakdown on a motorway see Box 2 BOX 1 What to do if your minibus breaks down on a road other than a motorway
13. hse gov uk pubns books I113 htm Buying new machinery A short guide to the law and your responsibilities when buying new machinery for use at work Leaflet INDG271 rev1 HSE Books 2011 www hse gov uk pubns indg271 htm Safe use of woodworking machinery Provision and Use of Work Equipment Regulations 1998 as applied to woodworking machinery Approved Code of Practice and guidance L114 HSE Books 1998 ISBN 978 0 7176 1630 5 www hse gov uk pubns books I114 htm 20 Page 80 Merthyr Tydfil County Borough Council Lifting equipment at work A brief guide to the law Leaflet INDG290 rev1 HSE Books 2013 www hse gov uk pubns indg290 htm Thorough examination of lifting equipment A simple guide for employers Leaflet INDG422 HSE Books 2008 www hse gov uk pubns indg422 htm Work Equipment Policy 2013
14. local need Equality and Human Rights Commission EHRC guidance on equality objectives emphasises the importance of intelligence To achieve the aims of the duty the objectives need to focus on the most significant equality issues and be sufficiently wide in scope In order to meet the duty the objectives must be based on adequate information and proper engagement 3 17 Equality should be embedded in strategic partnership working and links between the SEP and SIP could be strengthened In practice this could mean joining up the collection of equality data with the needs assessment see point 1 17 impact assessing partnership projects in addition to the high level SIP document and embedding equality in partnership scrutiny as well as articulating how the SIP and SEP relate to one another and how these are mutually reinforcing areas of work 3 18 The EIA process should be reviewed in consultation with staff in key service areas to ensure understanding and buy in to the process Any revised process could be accompanied by guidance on when they should be undertaken and to what level with the aim of developing a proportionate and sustainable approach that is owned by the 1 EHRC Equality Objectives and Strategic Equality Plans A quide for listed public authorities in Wales 2011 Pad 1 3 19 3 20 3 21 3 22 relevant individuals and not reliant on involvement from the equality officer Awareness and expertise
15. must never direct a reversing vehicle ag CH 56 Minibus Policy 2013 Merthyr Tydfil County Borough Council APPENDIX 4 First aid kit and other equipment for minibuses First aid kit e 10 antiseptic wipes foil packed e 1 conforming disposable bandage not less than 7 5cm e 2 triangular bandages e 1 packet of 24 assorted adhesive dressings e 3 large sterile unmedicated ambulance dressings not less than 15 x 20cm e 2sterile eye pads with attachments e 12 assorted safety pins e 1 pair of rust proof blunt ended scissors e Disposable gloves e Mouth mask for resuscitation Fire extinguisher At least one fire extinguisher two are recommended for accessible minibuses which e complies with BS5432 or an equivalent e g BSEN 3 and e has a minimum test rating of 8A or 21B and e contains water or foam please note Halon extinguishers are no longer permitted in vehicles age 5 Minibus Policy 2013 Merthyr Tydfil County Borough Council Other equipment It is recommended that the following should also be carried e pen and paper e any departmental school instructions and contact details e insurance details e motoring breakdown policy details e mobile phone phonecard or change for the phone e webbing cutter e a high visibility coat e An emergency warning triangle or a flashing beacon e A working torch e Sterile gloves and mouth masks ag a 58 Minibus Policy 2013 Merthyr Tydfil County Borough Council APP
16. of staff development is in place to ensure the right staff have the right skills to deliver equality improvement Managerial capability and appraisal There is regular appraisal of the capability of senior management to deliver equality improvement Internal staff feedback A mechanism exists for regular staff feedback to inform the improvement of services and employment provision Workforce culture and environment The necessary provisions to generate a supportive Employee monitoring The organisation has generated a profile of its employe S their workplace requirements and career progressior Workforce planning The organisation has planned how to gener workforce that reflects the make up of the pop lation 4 13 4 18 Appendix 2 List of acronyms CBC County Borough Council CEWG Corporate Equality Working Group EIA Equality Impact Assessment EIF Equality Improvement Framework EHRC Equality and Human Rights Commission Guidance HR Human Resources LSB Local Service Board MAGNET Merthyr Achieving Greater Networking and Engagement Together MIA Multiple Intervention Assistance SLA Service Level Agreement SIP Single Integrated Plan SEP Strategic Equality Plan WLS Welsh Language Scheme WLGA Welsh Local Government Association Pag 134 Agenda ltem 22 DRAFT Minibus Policy Date approved by Council Date of implementation Date of last review
17. risk assessment and manufacturers guidelines However inspections must be done i Prior to first use after equipment is installed purchased ii After a change in operating environment or if a new user takes over the equipment iii After any change in circumstances which could affect health and safety 5 6 Performing Inspections Inspections need to be carried out by a competent person For work equipment this person is normally e The user if it is stated in the user manual that the user can perform inspections If this is the case then instructions will be clearly detailed in the user manual e A person appointed by the equipment manufacturer for more in depth inspections 16 Work Equipment Policy 2013 Page 76 Merthyr Tydfil County Borough Council 5 7 Performing Maintenance It is essential that any maintenance be done competently and safely This can be accomplished as follows a Many minor maintenance tasks are meant to be performed by the user Such tasks will be explicitly stated in the equipment manual as being suitable to be done by the user and will be accompanied by instructions Users must be competent to perform these duties For this purpose users must have understood and be capable of carrying out the instructions given in the manual b All other maintenance must be carried out by nominated competent persons In most cases this would only be those persons appointed by the manufacturer of the eq
18. that the council has been evaluating and is seeking to build upon its existing approach to consultation and engagement Measures to strengthen the approach are currently at various stages of development and implementation such as the Community Voice programme and the LSBs engagement and consultation work which includes the Citizens Panel and consultation and engagement hub Areas for Improvement 1 10 While there are some extremely positive examples of active community engagement this could be strengthened by bringing the range of activity together in a more corporate and strategic manner This would provide a number of benefits including e Improving the sharing of information e Reducing any duplication e Making good use of time and resources e Ensuring there are consistently high standards across engagement and consultation activity It is recognised that the Local Service Board LSB engagement and consultation work will seek to achieve this though it is worth emphasising that equality and engaging with people with protected characteristics should be an overt consideration as part of these developments Engagement is Page 6 1 12 1 13 not only a key means of improving services but also a statutory responsibility in relation to equality as set out under the specific duties for Wales It was also noted that the protected characteristic groups with well established fora such as older people children and young peop
19. training will help ensure minibus drivers can cope with a wide variety of road and traffic conditions If roads are well known consider the risks and hazards at the planning stage Carry out a risk assessment on journeys even where the route is familiar Consider what hazards may be encountered and whether the journey is in fact necessary Is there an alternative form of transport which could just as easily be used Coaches buses and trains are all potentially safer than minibuses The weather can be unpredictable However the hazards of driving in difficult weather conditions are well known and well documented Make sure that the driver and passengers understand the risks and procedures for travelling in fog rain snow ice high winds sun and glare etc 8 3 2 Illness It is possible that any occupant of a minibus may become ill during a journey and require some form of medical treatment The driver or another staff passenger should have received some basic first aid training to deal with minor emergencies In line with this the minibus should always carry a fully replenished first aid kit In the event of a serious medical problem minibus drivers are advised to summon an ambulance by dialling 999 agea44 Minibus Policy 2013 Merthyr Tydfil County Borough Council 8 3 3 Vehicle Fire In the unlikely event of a fire on board a minibus the driver and or the person in charge must know what to do Each minibus should carry a fire
20. turn has had positive benefits for equality improvement Examples include procurement working with consortium and the LSB s engagement and consultation work working with Rhondda Cynon Taf It was noted that regional working has helped the authority achieve further outcomes at greater pace Areas for Improvement 3 8 The SEP does not appear to be the driver for equality work in the organisation The SEP equality objectives could be better positioned and more integral to service planning improvement and partnership working Whilst the equality objectives are situated within service area business plans it is not evident the SEP has generated new work on equality issues 3 9 On balance equality improvement is more associated with compliance with legislation rather than generating outcomes The authority has undertaken work to meet the requirements of the specific duties for Wales but the added value of delivering service improvement mitigating risk and generating meaningful outcomes did not appear to be at the forefront of equality thinking in the organisation The next stage in the development of the council s equality work is making the shift from processes and compliance to using equality work to help the organisation achieve outcomes The council could reframe equality work in terms of serving the community better communicating this to staff and helping them to understand how it can help them in their roles 3 10 Contrar
21. users If a relatively long journey is being planned especially as a day trip serious consideration should be given to hiring a professional coach company to undertake the journey or if convenient to travel by rail When planning the journey expected weather conditions must be taken into account and factors such as start time travelling time etc should be adjusted accordingly 8 2 Driving times Driver tiredness is now well recognised as a significant factor in road traffic accidents No one should drive or be expected to drive if they are tired The maximum number of hours that a driver may drive in any 24 hour period is 9 hours with a weekly maximum of 56 hours The maximum working day is 12 hours which includes the employee s normal work activities as well as time spent driving The maximum continuous period of driving should not exceed 2 hours with a minimum break of 15 minutes out of the vehicle If it is unavoidable to use a minibus on a longer journey the Manager Headteacher or nominated responsible person should appoint a second driver to share the driving duties In inclement weather conditions continuous driving times should be adjusted shortened to reflect the weather conditions The necessary increase in concentration may increase fatigue age 43 Minibus Policy 2013 Merthyr Tydfil County Borough Council 8 3 Potential problems during minibus journeys 8 3 1 Roads traffic and weather Good
22. 4 Merthyr Tydfil County Borough Council j Ensure that work equipment is disposed of properly as described in section 4 10 k Ensure that records relating to this policy are kept as described in section 4 11 3 3 Health and Safety Unit The Council s Health and Safety Unit will a Where necessary provide training to ensure the competence of risk assessors b Review this policy annually 3 4 Employees Equipment Users Users of equipment will a Cooperate with the systems put in place to ensure their health and safety when using work equipment as described in section 4 6 5 Provision amp Use of Work Equipment Policy 2013 Page 65 Merthyr Tydfil County Borough Council 40 ARRANGEMENTS 4 1 Risk Assessments 4 6 Safe use of equipment 4 2 Suitability 4 7 Hiring equipment 4 3 Maintenance 4 8 Wood working equipment 4 4 Inspections 4 9 Mobile equipment 4 5 Information instruction training 4 10 Records supervision 4 1 Equipment Risk Assessments The policy achieves risk reduction by conducting standard risk assessments where appropriate for e Suitability of work equipment for the task e Suitability of work equipment for the persons who must use it e Suitability of work equipment for the environment in which it is to be used Using the results from these assessments risk can be reduced by e Providing suitable work equipment in the first instance e Maintaining work equipment e Inspecting work equipment
23. 998 PUWER The provision of safe plant and equipment also forms part of an employer s common law duty of care toward employees Injuries resulting from work equipment range from minor cuts to fatalities This policy provides a system for prevention which is based on an assessment of risk from different pieces of work equipment The assessment comprises e Suitability of equipment for intended use e Suitability of equipment for persons intended to use it e Suitability of equipment for the environment in which it is used It is the aim of Merthyr Tydfil County Borough Council to endeavour to take all necessary measures to meet with or else exceed the standards set out in the PUWER regulations 2 0 LEGAL REQUIREMENTS 2 1 The Health and Safety at Work etc Act 1974 Employers have a general duty to look after the safety and health of their employees at work as well as to other people who may be affected by their work activities 2 2 Management of Health and Safety at Work Requlations 1999 Employers are required to carry out risk assessments and to tell all workers about the risks to their health and safety and the measures put in place to control them 3 Provision amp Use of Work Equipment Policy 2013 Page 63 2 3 3 0 3 1 3 2 a c d e Merthyr Tydfil County Borough Council Provision and Use of Work Equipment Regulations 1998 Employers have a duty to provide and maintain safe work equipment Desig
24. ENDIX 5 Minibus Driver Training Providers 1 Powys Transport Training Agency PAVO Powys Tel 01597 829 235 Email pttadev pavo org uk Mike Entwisle 2 Graham Evans Driver Training Caerphilly Tel 0777 317 9374 or 029 2083 1614 Email grahamgevans rocketmail com Graham Evans 3 Gwent Outdoor Education Service Hilston Park Outdoor Education Centre Newcastle Nr Monmouth Gwent NP25 5NY Tel 01600 750221 Fax 01600 750613 e mail hilston gwentoutdoorcentres org uk 4 Professional Driver Services UK Ltd 1 St Mary s Avenue Barry Vale of Glamorgan CF63 4LR Tel 0871 200 2217 Internet http www pdsuk co uk age 59 Minibus Policy 2013 This page is intentionally left blank Page 60 Agenda Item 23 MERTHYR TYDFIL COUNTY BOROUGH COUNCIL DRAFT Provision amp Use of Work Equipment Policy Date approved by Council Date of implementation Date of last review Date of next review Page 61 Merthyr Tydfil County Borough Council CONTENTS 1 0 INTRODUCTION eege ENEE GRE SERRE Ree Ree 3 2 0 LEGAL REQUIREMENTS Seeerei ge Gite eee 3 3 0 RESPONSIBILITIES Age 4 4 0 ARRANGEMENTS A 6 5 0 GUIDANCE ees 13 6 0 FURTHER INFORMATION 20 Page 62 Provision amp Use of Work Equipment Policy 2013 Merthyr Tydfil County Borough Council 1 0 INTRODUCTION This policy statement has been produced in order to shape the Council s implementation of the Provision and Use of Work Equipment Regulations 1
25. MERTHYR TYDFIL COUNTY BOROUGH COUNCIL FULL COUNCIL MEETING 5 30 PM WEDNESDAY 6TH NOVEMBER 2013 The attached reports have been added as Background Papers to the previously published Agenda for the above mentioned Committee Anyone requiring information should contact the Democratic Services Department on 01685 725203 or democratic merthyr gov uk 21 Equality Peer Review Report To consider a report of the Chief Executive Pages 1 34 22 Minibus Policy To consider a report of the Chief Executive Pages 35 60 23 Provision and use of Work Equipment Policy To consider a report of the Chief Executive Pages 61 80 This page is intentionally left blank Oo Equality Improvement Peer Review Merthyr Tydfil County Borough Council Report 20 21 June 2013 WLGA CLILC Contact Welsh Local Government Association The WLGA s primary purposes are to promote a better local government its reputation and to support authorities in the development of policies and priorities which will improve public service and democracy It represents the 22 local authorities in Wales with the 3 fire and rescue authorities and 3 national park authorities as associate members Welsh Local Government Association Local Government House Drake Walk Cardiff CF10 4LG Tel 029 2046 8600 Fax 029 2046 8601 www wiga gov uk Page 2 Background This report is a summary of the findings of the equality improv
26. aken to a safe area away from the accident site Children and other vulnerable groups should be fully supervised A visual check of the vehicle should be undertaken before the journey resumes Health and Safety of Drivers and Passengers The driver should explain the following to all passengers Ka Kg KN The importance of wearing seatbelts during the journey This is a legal requirement and it is the drivers responsibility to check this The importance of everyone remaining seated at all times The entry and exit doors which are to be used it is recommended that side doors be used expect in emergencies age48 Minibus Policy 2013 Merthyr Tydfil County Borough Council 11 0 Further Considerations for Schools 11 1 If student passengers are distracting the driver the driver should stop the minibus until all students are settled Drivers should not try to continue Remember that disruptive passenger behaviour may also be a hazard to other road users 11 2 Where possible always park the minibus with the side doors to the kerb Where this is not possible students should remain seated until the driver is able to supervise entering exiting the vehicle 11 3 Drivers must not drive for longer than 2 hours without taking a break for at least 15 minutes 11 4 Itis essential that all journeys in a school minibus be staffed by the driver and at least one escort Under no circumstances should students be taken on a journey o
27. ality issues is low It was also noted that awareness in satellite centres may be lower than in the Civic Centre Rm 4 12 4 13 4 14 4 15 4 16 4 17 As highlighted throughout this report there are a number of examples of good practice in relation to equality The organisation could improve the sharing of these practices and experiences This could be built into internal training shared through developing mechanisms such as the engagement and consultation work senior management business meetings or a Corporate Equality Working Group This would not only help extend the use of best practice across the organisation but would also promote the added value of equality work to staff There is a strong culture of meeting community need and generating outcomes in the organisation Currently equality is not seen as part of that picture and is less favourably associated with process However the team noted a very high level of commitment to making a difference to people in Methyr Tydfil which represents a real opportunity to reposition equality as a means of achieving better outcomes which could generate enthusiasm for the agenda and help officers see how an equality perspective can support their work See section 3 for further details Some felt there was a culture of complacency around equality improvement which could result in resistance and tension when new equality work is being driven forward Equality obje
28. also be required e rear door access must be avoided e the motorway speed limit is 60 mph e itis illegal when towing a trailer to use the outside lane of a motorway of three or more lanes It is important to realise that towing a trailer can significantly affect the performance and handling of the minibus and that reversing in particular requires different skills Any driver who will be towing a trailer must be suitably trained and experienced in such driving 7 0 Driving Abroad 7 1 All drivers of minibuses taken abroad must obtain a Passenger Carrying Vehicle PCV category D or D1 licence In addition EC regulations lay down rules for international journeys in passenger vehicles constructed to carry 9 or more persons including the driver This includes the requirement for the vehicle to be fitted with a tachograph Further information can be found in the Community Transport Association CTA booklet Minibuses and the Law age 42 Minibus Policy 2013 Merthyr Tydfil County Borough Council 8 0 Advice for the Journey 8 1 Journey planning Drivers should plan and prepare for journeys so that routes may be identified which allow ample time to reach the destinations Accidents are more likely to occur when a vehicle is being driven flat out to a time deadline this must never happen It is the driver s responsibility to identify and use safe pick up and drop off areas having regard at all times to the needs of other road
29. ates with strong links to communities and an evident personal commitment to their causes The Champions are therefore viewed as valuable assets to the organisation Steps have been taken by the political and professional leadership to help embed equality in council business such as including equality implications on council and cabinet reports including it as a standing item on scrutiny agendas and inviting the equality officer to attend monthly senior management business meetings Some felt that these measures had helped to bring about a change in culture on equality It was noted that there are close working relationships in the organisation and some feel that senior officers are approachable and accessible This has the potential to support equality work by making it easier to work together change culture and deliver improvement Areas for Improvement 2 6 Though there is evident commitment at the top of the organisation lines of accountability are less clear Often the equality officer is seen as the person who is responsible for enforcing equality work or accountable for its delivery Equality improvement would benefit from senior commitment Page 0 2 7 2 8 2 9 2 10 2 11 translating into clearer direction ownership and accountability While some felt that measures to keep equality on the agenda were beginning to change culture others disputed their value suggesting they might function more as a
30. ational links between the equality officer and other key delivery areas most notably Community Cohesion These two areas have built close productive links The equality officer also has a close working relationship with the Elected Member Equality Champion providing a real opportunity to overcome obstacles to operational changes that can help generate outcomes There is a similar close working relationship between the Older People s Elected Member Champion and the Older People s Coordinator Many services demonstrate a citizen focused coproductive ethos whereby provision is tailored to the needs of citizens or directed by the community This was evident in several interviews and particularly so in MIA Community Cohesion and Communities First Some mainly senior officers interviewed felt that the equality processes that had been introduced were helping to shift mindsets changing conversations from has that been done to what is the impact Schools in the Borough have produced SEPs and annual reports on progress have been prepared The local authority provided information support and guidance and schools used that information to develop their own objectives SEPs were said to have helped to reinforce and formalise existing work on equality and develop consistency across schools Page 14 3 7 The authority has developed productive collaborative links with neighbouring authorities to increase its capacity which in
31. brake pedal is firm when pressed A moving brake test should then be conducted off road if possible Warn any passengers first reach a speed of not more than 15 mph check the mirrors and if it is safe apply the brakes fairly firmly The brakes should work effectively the vehicle should not pull to one side and any luggage should remain securely stored age 53 Minibus Policy 2013 Merthyr Tydfil County Borough Council APPENDIX 2 Advice for minibus drivers On journeys where a passenger assistant is present the points below should be divided between the driver and passenger assistant with the driver concentrating on those tasks which directly relate to driving the vehicle Before setting off Allow sufficient time for the journey If using a SatNav set it before you start Plan breaks to avoid long spells of driving and so that passengers e g children do not get restless Conduct a pre drive safety check before every journey Never allow passengers to board until the vehicle is at a complete standstill and safely parked by an adjacent pavement or other traffic free area If you need to leave the vehicle switch off the engine and remove the keys Passengers should enter the minibus from the pavement adjacent to the bus not from the road itself unless using a ramp or lift at the rear If driving abroad in a country that drives on the right the nearside door may open into the road and extra care will be
32. cessive Mayor makes a pledge and is given direct access to relevant departments to help them deliver on it Merthyr s approach to Communities First is progressive with the council taking on a more facilitational role and the design and delivery being taking forward by the cluster managers and communities This is reflective of a coproductive ethos The detailed work undertaken on the Community Conversation as part of the development of the Community Cohesion Strategy provides a rich source of information on how people feel about their communities and the services they receive The Equality and Older People s Elected Member Champions are valuable assets to the council having strong links to disadvantaged communities Rm 1 6 1 7 1 8 1 9 The Equality Champion Equality Officer and Community Cohesion Officers have also made substantial efforts to engage with new communities in Merthyr Tydfil and there is a Migrant Workers Forum The procurement team engages and works closely with SMEs with the aim of supporting local business A consultation exercise was undertaken for the last budget including four roadshows and an online web survey The learning from this exercise has resulted in the decision to carry out the next exercise earlier engaging with the communications staff and Contact magazine with a view to increasing the response rate The peer review self assessment and interviews highlighted
33. consider how they use corporate processes to improve accountability for it Aspects of equality could be built into the development of the scrutiny forward work programmes more robustly It would be beneficial to develop quality assurance for EIAs The authority should review HR policies and processes to ensure they are up to date and reflect new legislation The authority could consider establishing a staff network s Page828 Phase 3 Long term 6 19 6 20 6 21 6 22 6 23 The SEP should be used to drive equality work within the business planning process Equality should be embedded in strategic partnership working and links between the SEP and SIP could be strengthened More information on embedding equality in integrated planning can be found in WLGA advice note published May 2013 http www wiga gov uk publications equalities equality and inteqrated planning l an advice note for local authorities in wales The authority should develop a more corporate approach to equality training taking a strategic view of the training needs of members and staff across the organisation by for example undertaking a whole authority training needs analysis and aligning training budgets accordingly The authority could strengthen the link between individual action and behaviours and equality work The authority could consider how the equality function has maximum influence across the organisation OC
34. ctives and expectations around equality competencies are not linked to individual performance reviews meaning there is not a golden thread from vision to individual action and behaviour Currently responsibility for carrying out equality work rests with a small number of staff Extending this responsibility and mainstreaming equality should be the long term goal It was acknowledged that there has been little progress on establishing staff networks to engage with protected characteristic groups The reason for this is the time and resource required to set them up but supporting them on an ongoing basis also involves a time commitment Page 22 4 18 Some felt that the overall culture of the organisation was confrontational and there isn t currently a strategy for developing a different organisational culture Proposals for Improvement 4 19 The authority could review HR policies and processes to ensure they are up to date and reflect new legislation including HR policies which may not have been impact assessed training and awareness raising see below and the collection of employment information It is a legal requirement that these policies and processes are compliant with the specific duties in Wales 4 20 The authority could develop a more corporate approach to equality training taking a longer term strategic view of the training needs of members and staff across the organisation by for example undertaking a whole a
35. d In order to determine what equipment needs to be assessed managers must first consider whether the equipment poses any risk in the first place Risk may arise from hazards such as a b c The power supply to the equipment e g electricity petrol air pressure Equipment that lifts or transports goods or persons Moving parts of machinery Noise generated by the equipment Vibration generated by the equipment Dust fume or gas generated by the equipment Radiation generated by the equipment Hazardous substances are needed to operate e g petrol Self propelled work equipment Drivable work equipment Equipment with sharp blades or cutting bits even if non powered including hand tools Equipment with known cases of injury resulting from its use i e ladders 13 Work Equipment Policy 2013 Page 73 5 1 1 Merthyr Tydfil County Borough Council Equipment that does not need to be assessed Equipment that does not pose any significant risk need not be assessed Such equipment may not pose a significant risk because 5 2 When It is non powered or manually powered It is small scale fixed equipment that normally requires little or no human interaction e g wall clocks light fixtures etc It is equipment with no moving parts It is equipment that is used in everyday life away from the workplace e g Cups saucers scissors pens and pencils Assessing the suitability of equipment to purpose ass
36. e6ed Community Engagement 1 Strengths del Streamlined gathering of data and evidence The authority is in a position to identify and understand robust data and evidence on issues of localised inequality 2 Areas for Improvement 1 13 Appendix 1 3 Proposals for Improvement 1 16 1 17 1 2 Consulting and involving the right people on the right things The authority consults and involves relevant groups within th community and individuals on equality objectives equality impact assessments significant policy and service delivery 1 14 1 18 provides opportunities for challenge against commitments and progress 1 14 1 15 1 4 Fostering good relations com sustainability 4 The organisation is assisting in rele improving community cohesion withi communities 4 1 6 3 2 3 13 30 LC ed Leadership and Organisational Commitment 2i Leadership vision and principles The leadership of the organisation have publicly stated what the organisation wants to achieve and the key priorities in relation to equality 2 2 Leadership support commitment and challenge The leadership of the organisation provide ongoing support commitment and challenge to generate the necessary organisational buy in for the agenda Management accountability Corporate vision and principles and equality obj becoming real through clearly evidenced co the management le
37. ed harness seat or child restraint where appropriate e Check that ambulant disabled passengers are seated safely passengers travelling in wheelchairs are safely secured and wheelchairs not in use are securely stored e Ensure that passengers behave in an acceptable manner during the journey and do not distract the driver in any way Boisterous play must not be allowed Passengers must remain seated and wearing their seatbelts if fitted throughout the journey e Ensure that all luggage is securely stored and that all gangways and exits are kept clear e Ensure that when passengers are dropped off they leave the vehicle safely that no parts of their clothing are caught in the doors with children always ensure there is someone there to meet them e Ensure that children are never left unsupervised in the minibus or if the vehicle breaks down e Only operate the passenger lift and other specialist equipment if trained and qualified to do so e Keep a complete list of the passengers including details of any special needs and ensure that all passengers have returned to the vehicle after each and every rest stop e In the event of a breakdown or accident ensure that children remain supervised are given clear and firm instructions and if necessary are given help to evacuate the minibus e Help to direct the vehicle if the driver needs to reverse but do not stand directly behind the vehicle out of the driver s sight Children
38. ement peer review undertaken for Merthyr Tydfil County Borough Council CBC in June 2013 which was organised by the Welsh Local Government Association WLGA and carried out by its peers A peer review is designed to validate an authority s own self assessment by considering documentary evidence and carrying out a series of interviews and focus groups with Elected Members staff and other stakeholders Importantly a peer review is not an inspection rather it offers an external assessment of an authority s own judgement of its performance Peer assessors are critical friends who have experience of delivering on the particular agenda in their own organisations Their role is to identify areas of strength and areas of improvement A peer review is A peer review is not e An objective external perspective e An audit or inspection provided by critical friends e Aimed at identifying both areas e A detailed check of strength and improvement against compliance e A snapshot based on evidence e An indepth analysis of provided and the interviews all processes and undertaken practices e A process WLGA will continue e An event to work with the authority following the final report if required Methodology The basis for the equality peer review is the Equality Improvement Framework EIF for Wales which can be viewed here http www wiga gov uk english equality improvement framework for wales There are four area
39. enge and improve their quality The authority could consider how its EIA process could be integrated within and complement other corporate processes The authority should consider how it builds the equality dimension into current priority areas of work such as welfare reform RI 6 9 The authority should consider updating the WLS or developing some interim priority actions ahead of the introduction of the new standards Phase 2 Medium term 6 10 6 11 6 12 6 13 6 14 6 15 6 16 6 17 6 18 The authority should develop an effective process for the coordination collection and use of equality data from service delivery the census and other sources to shape equality objectives within the SEP and business planning process The authority could align and coordinate the collection of equality information and ongoing partnership needs assessment work undertaken for the SEP and SIP The authority could further utilise the Equality and Older People s Member Champions The authority could support community and protected characteristic groups within the procurement process More information on embedding equality in the procurement process can be found in WLGA advice note published May 2013 http www wiga gov uk publications equalities building equality considerations into the commissioning and procurement process The professional leadership should increase their ownership of equality work and
40. equipment c Any disabilities that may increase the risk from using the equipment See section 5 4 for guidance 7 Work Equipment Policy 2013 Page 67 Merthyr Tydfil County Borough Council 4 2 3 Suitability of equipment for the environment in which it is used The environment in which equipment is used plays a vital part in its continued safety This is because parts can wear out more quickly in harsh environments To ensure continued safety a If the equipment is to be used in environments where there may be water condensation dust or high or low temperatures then the selected equipment must be designed to be used in those conditions b Adverse environmental conditions such as temperature sunlight water dryness dust or intense light may affect the user s ability to control equipment This risk must be assessed and adequately managed 4 3 Maintenance of Work Equipment By law work equipment must be maintained in order to keep it performing as it was meant to by the manufacturer including the requirement for the equipment to remain safe for use An effective maintenance regime would consist of e Planned Preventative Maintenance This involves the periodic replacement of parts that have a known lifespan By replacing these parts before they breakdown the safety of the equipment can be maintained The components to be replaced in this way as well as the replacement schedule are detailed by the manufacturer
41. equired to be collected under the specific duties can only be compiled by combining a number of data bases meaning the process is labour intensive rather than automatic There was also concern that the data might not cover the full range of protected characteristics meaning the authority would not be able to fully meet its statutory duty to collect and publish the complete range of employment information The corporate approach to equality training could be strengthened Listed bodies in Wales have a duty to promote knowledge and understanding of the general and specific equality duties among their employees and equality training is an important means of achieving equality improvement Equality training could come in the form of awareness raising for staff and members it could be specific to an area of work such as procurement or it could relate to a process such as EIA There are examples of where training has been developed and there are skills and experience within the organisation that could be utilised as part of a corporate approach to equality training Raising awareness of equality among staff is a must do Furthermore the need for equality training was identified several times For example it was not clear how Members equality training requirements were being met In terms of staff it was felt that there might be less understanding of issues relating to certain protected characteristics and that general awareness of equ
42. ermore it was felt that Welsh language is given less credence than equality though conversely some regarded Welsh language issues as having too great an emphasis in terms of resource and in general there are lower levels of awareness of Welsh language issues and the legislative and policy context see point 3 24 for related proposal for improvement Page 26 6 Proposals for Improvement The section below is a compilation of the proposals for improvement identified throughout this report It is not listed in terms of priority rather it is divided into three phases which set out the shorter term changes phase 1 leading to longer term changes phase 3 Phase 1 Shorter term 6 1 6 2 6 3 6 4 6 5 6 6 6 7 6 8 The authority should ensure a continued focus on protected characteristic groups throughout the development of consultation and engagement work The authority could share effective practice and develop consistent standards for consultation and engagement Equality training should be developed further including a specific focus for Members The authority could consider re establishing the Corporate Equality Working Group CEWG More information on establishing effective corporate working groups can be found in heh advice note published April 2010 corporate working groups The EIA process should be reviewed Awareness and expertise should be developed in relation to ETAs to increase chall
43. essing whether the equipment is fit for purpose the following should be considered Is the equipment capable of doing the intended job Can another piece of equipment be used to do the job more safely Is the equipment of suitable power to do the job Equipment that is too powerful or not powerful enough increases the risk of injury Is the durability of the equipment suitable for the amount of use it will be put to Can the hazards introduced by the equipment be adequately controlled Hazards introduced can include but are not limited to electricity vibration noise dust smoke hazardous substances Are the hazards introduced by the equipment itself kept to the minimum practicable 14 Work Equipment Policy 2013 Page 74 5 3 Merthyr Tydfil County Borough Council Assessing the suitability of equipment to environment When assessing the suitability of equipment to the environment the following environmental factors must be considered 5 4 Will the equipment be used outdoors Will the equipment be exposed to moisture or water Will the equipment be exposed to dust Is it likely that the equipment will be dropped or subjected to impacts Is the location adequately ventilated to allow for safe use bearing in mind the wastes produced by the equipment Is the visibility of the equipment a hazard i e can it be easily seen For example will a person be injured by inadvertently bumping into or otherwise coming into contact
44. haracteristics 7raining for Elected Members and close political scrutiny are already included as priorities in the Community Cohesion Action Plan and this report reiterates the value of moving forward with this Aspects of equality could be built into the development of the scrutiny forward work programmes more robustly There are further opportunities for equality to be built into scrutiny s forward work programme and to provide additional support and training to scrutiny committee members This would maximise the value of having equality included as a standing item on scrutiny agendas Page 2 16 The authority could consider re establishing the Corporate Equality Working Group CEWG While the Equality Officer is invited to attend monthly senior management business meetings the CEWG no longer meets Some authorities have found these groups to be useful in overseeing the implementation of overall equality work in the organisation and developing new policy and practice such as an EIA process The organisation may wish to consider reforming this group with appropriate membership and terms of reference 3 Generating Outcomes Strengths 3 1 3 2 3 3 3 4 3 5 3 6 The peer review team noted a common commitment to delivering the best possible outcomes for the people of Merthyr This clear dedication and sense of working together for a common purpose came across in many of the interviews There are strong oper
45. he potential users of the new equipment should be consulted when purchasing work equipment 5 9 Provision for First Aid The risk assessment of the equipment should be used to identify what injuries are likely to result from its use The first aid provision should then make allowance for this 5 10 Delivery of training A risk assessment will determine the training requirements and varies depending on the level of risk Training should cover a Safe and unsafe ways to use the equipment b Foreseeable hazards c Possible injuries and the best way to deal with them d Any other information that will reduce the risk 18 Work Equipment Policy 2013 Page 78 Merthyr Tydfil County Borough Council Training is essential when 1 New employees are recruited 2 New equipment is introduced 3 There are changes to the work system 4 There are changes to the work equipment 5 Periodically as determined by the risk assessment to refresh knowledge and skills 19 Work Equipment Policy 2013 Page 79 6 0 FURTHER INFORMATION Safe use of work equipment Provision and Use of Work Equipment Regulations 1998 Approved Code of Practice and guidance L22 Third edition HSE Books 2008 ISBN 978 0 7176 6295 1 www hse gov uk pubns books I22 htm Safe use of lifting equipment Lifting Operations and Lifting Equipment Regulations 1998 Approved Code of Practice and guidance L113 HSE Books 1998 ISBN 978 0 7176 1628 2 www
46. ing outcomes As part of this the authority may wish to consider where the equality function could have the most impact and influence depending on its priorities for equality improvement Page 24 5 Key findings The following points were recurrent themes that cut across many areas already identified in this report These represent the team s key strategic findings 5 1 5 2 5 3 5 4 Evidence throughout this report suggests the approach to equality is largely shaped by external legal drivers and this was acknowledged within the organisation The authority has undertaken work to ensure it is meeting the requirements of the specific duties for Wales but equality work is less often seen as a means of making a difference and improving outcomes for people in Merthyr Reframing equality in the context of serving the community better would improve the reputation of the equality agenda and help staff understand how it fits with and supports their work While there are inevitable financial constraints and competing priorities it is important to emphasise that equality work is a statutory must do Given this it is necessary to maximise its potential by using equality processes as a means of adding value to priority areas of work The political and professional leadership articulated their commitment to equality Furthermore a commitment to delivering the best possible outcomes for the people of Merthyr was a common the
47. inibus drivers and operators are aware of the legal and procedural responsibilities pertaining to their use 2 0 Aims 2 1 To provide clear procedures relating to the use of minibuses 2 2 To ensure that all staff who may have cause to drive a minibus on Council or school business are aware of their legal responsibilities 2 3 To provide general guidance on the safe operation of minibuses 3 0 Definitions For legal purposes a minibus is a vehicle constructed or adapted to carry between nine and sixteen passengers not including the driver 4 0 Legal Requirements 4 1 The law requires that a minibus must a be correctly licensed b display a valid tax certificate c be adequately insured d be well maintained e have a valid MOT certificate if more than one year old Anyone who drives or operates a minibus to carry passengers has a legal duty to take all reasonable precautions to ensure that it is operated safely It is an offence to cause or permit a minibus to be driven on the road when its condition or the way in which it is driven could cause danger to anyone in the minibus or to other road users age 3 Minibus Policy 2013 Merthyr Tydfil County Borough Council 4 2 Drivers who gained their car driving licences before January 15t 1997 Staff who hold a licence issued before 17 January 1997 may drive a minibus without a D1 Passenger Carrying Vehicle PCV licence However it is strongly recommended that these
48. ipment may be required This can include e hydraulic hoists e wheelchair clamps and tracking e harnesses and seat belts for seated passengers e inertia reel harnesses and headrests for wheelchair passengers e ramps for wheelchair access and egress It is the responsibility of the Director Headteacher or a nominated responsible person to ensure that e any such access equipment is fully operational and properly maintained e all drivers of vehicles fitted with such equipment are trained in its use e full written instructions are displayed in the vehicle age 41 Minibus Policy 2013 Merthyr Tydfil County Borough Council 6 5 Trailers Towing trailers behind minibuses is subject to several legal requirements e drivers who passed their test before January 1 1997 will be able to drive minibuses with trailers of any weight Those who passed after this date will need to pass the PCV D1 test for trailers up to 750kg gross vehicle weight GVW maximum permitted weight for trailers over 750kg they need to do yet another test to obtain D1 E e the weight of vehicle plus trailer must not exceed the maximum Train Weight set for the vehicle e the GVW of the trailer itself must not be exceeded e the GVW of the towing vehicle must not be less than that for the trailer e the trailer will be required to have additional braking indicator and tail lights and a second registration plate e separate braking for the trailer may
49. le and disabled people play a strong part in planning and have good access into the organisation However this level of engagement could be replicated with other protected characteristic groups to ensure they have the same opportunities to influence decision making Merthyr s portfolio of Community Voice projects MAGNET Merthyr Achieving Greater Networking and Engagement Together will be an important means of achieving this The role of the Elected Member Champions could be developed further recognising they are a point of contact for communities officers and Members alike They have a valuable role to play in engaging stakeholders and supporting equality improvement in general Please see point 2 3 Some staff noted good operational sharing of data but room for improvement in terms of coordinating and using data and specifically equality data more strategically The collection of equality data for the Strategic Equality Plan SEP and needs assessment data for the Single Integrated Plan SIP could also be joined up in future recognising that both require data gathering and there is an overlap in the data required for each Furthermore joining up the intelligence would support the alignment of the two documents Proposals for Improvement 1 14 The authority should ensure a continued focus on protected characteristic groups throughout the development of engagement and consultation work This report recognises the council is
50. me across all of the interviews However the overall direction of equality work and the lines of accountability are less clear Equality improvement would benefit from demonstrable senior commitment translating into clearer direction and accountability The team identified many examples of good equality practice and these are highlighted throughout the report However there are opportunities to develop more corporate approaches which would help share and extend the use of good practice Examples include training engagement and consultation Whilst this report has warned against an over reliance on process it is also important to remember that the processes outlined in the specific duties for Wales are statutory and 5 5 they also have the potential to embed sustainable equality practices Over the longer term the authority should aim to use the statutory processes to mainstream the agenda and extend responsibility beyond the small number of staff currently identified as taking equality work forward Taking a proportional approach that fits with the authority s culture structure and corporate processes will support this While the Equality Officer is responsible for both equality and Welsh language issues the impression gained during the review was that though these are seen as related they are in practice regarded as distinct agendas and the benefits of greater integration between the two are not fully appreciated Furth
51. n the minibus accompanied by only one adult 12 0 Summary of Responsibilities 12 1 The Council School will 12 1 1 Ensure that the minibus is maintained in a roadworthy condition and is regularly serviced 12 1 2 Ensure that the minibus will not be used until defects which have safety implications are rectified 12 1 3 Ensure that the proper insurance licences and permits are held and kept up to date 12 1 4 Ensure that all new minibuses are equipped with seatbelts and conform to the relevant legislation 12 1 5 Maintain a list of authorised drivers age 49 Minibus Policy 2013 Merthyr Tydfil County Borough Council 12 1 6 Ensure that a sign indicating maximum permissible passenger capacity is displayed in each vehicle 12 2 The Council School will not 12 2 1 pay fines for parking speeding or other motoring offences 12 2 2 provide legal support for staff charged with the above 12 3 Drivers will 12 3 1 not drive minibuses unless they are on the list of authorised drivers produced by the school 12 3 2 when organising the use of minibuses ensure that only authorised drivers are selected 12 3 3 inform the school of any change in their health which affects their ability to drive 12 3 4 refrain from consuming alcohol for the twelve hours preceding and throughout the period of time they are in charge of the vehicle 12 3 5 refrain from driving if taking medication which could affect their driving abilitie
52. ners manufacturers and suppliers of work equipment have a duty to produce goods that are safe by design construction and installation RESPONSIBILITIES Directors Directors will ensure that the Heads of Service and Managers in their Directorates who are responsible for work equipment are adequately performing their duties under this policy Managers Heads of Service Managers will Ensure where work equipment presents a specific risk that a suitable risk assessment is undertaken as described in section 4 1 Ensure that work equipment is suitable for its intended use and suitable for persons using the equipment as described in section 4 2 Ensure that work equipment is maintained according to manufacturer s instructions and any risk assessments are to be completed as described in section 4 3 Ensure that a suitable system of scheduled inspections is implemented based on the guidelines given in section 4 4 Ensure that the level of information instruction and training required is assessed and provided for persons using work equipment as described in section 4 5 Follow the policy for hiring work equipment as described in section 4 7 Not allow employees to bring their own work equipment to work Ensure that the policy for woodworking machinery is followed as described by section 4 8 Ensure that the policy for mobile work equipment is followed as described by section 4 9 4 Provision amp Use of Work Equipment Policy 2013 Page 6
53. of the equipment e Condition Based Maintenance This occurs as a result of an equipment inspection identifying a component that has been damaged or is about to wear out Replacement of parts so identified can quickly return equipment to a safe state before an incident occurs 8 Work Equipment Policy 2013 Page 68 Merthyr Tydfil County Borough Council e Breakdown based maintenance The only time this type of maintenance is required is when a part has failed unexpectedly Breakdown based maintenance almost always results in lost time loss of productivity costly repairs and possibly an injury if a safety critical component has failed 4 4 Equipment Inspections The type of inspection required will depend on the type of equipment and the environment in which it is used It can be as simple as a visual inspection or may require the equipment to be dismantled The equipment manual and manufacturers guidelines are good sources of information when determining the type of inspection required 4 4 1 Written Scheme of Examination The Council has a statutory duty to carry out a thorough examination of certain types of work equipment namely lifting equipment and pressure systems Examples include lifts hoists boilers and air compressors The examination must be carried out by a suitably competent person in accordance with a written scheme of examination which complies with the relevant regulations This requirement is in
54. ployees wishing to drive a minibus must Di be over 21 years old by law and preferably over 25 for insurance purposes oO hold a clean current full driving licence with full D1 entitlement or CH have successfully completed the Minibus Driver Awareness Scheme MiDAS via an accredited organisation within the previous three years 5 2 Although it is not law it is strongly recommended that ALL minibus drivers complete an approved MiDAS course before being allowed to drive a minibus on school or Council business 5 3 Driver responsibilities Minibus drivers must a refrain from consuming alcohol for the twelve hours preceding and throughout the period of time they are in charge of the vehicle b not be taking any medication which could affect their fitness to drive c carry out the list of checks given in Appendix 1 for the roadworthiness and safety equipment of the vehicle age 39 Minibus Policy 2013 Merthyr Tydfil County Borough Council 6 0 The Minibus 6 1 The law requires that a minibus must a be roadworthy and well maintained b display a valid tax disc c have a valid MoT certificate if more than one year old d be adequately insured 6 2 Roadworthiness It is the responsibility of Directors and Headteachers to ensure that all minibuses under their control are maintained in a roadworthy condition Drivers must use the checklist in Appendix 1 before any journey whether the vehicle is o
55. put in place for their health and safety c Take reasonable care for their own health and safety and that of others d Inform their managers of dangerous situations or shortcomings in health and safety arrangements e Inform their managers of any change which is likely to affect the health and safety of themselves or others 10 Work Equipment Policy 2013 Page 70 Merthyr Tydfil County Borough Council Users must NOT f Abuse or bypass systems put in place for their health and safety g Use procedures other than those stipulated during training h Use the equipment for anything other than its intended purpose i Use the equipment anywhere other than the intended environment 4 7 Hiring Equipment When deciding on work equipment that is going to be hired all of the requirements laid out in this policy must be met in the same way as if the equipment was being purchased See section 5 8 for more guidance 4 8 Woodworking Machinery Risk assessments must be made for all equipment used in connection with woodworking Risk assessments should include non standard use of the equipment for example cleaning and maintenance They must also determine whether braking devices are required for the machinery Where there is a risk of contact with moving parts braking devices should be fitted to ensure a rundown time of 10 seconds or less 4 9 Mobile Work Equipment As for woodworking machines each piece of mobile work equipment
56. s including Community Cohesion and Communities First As previously outlined in relation to community engagement many officers felt there was a stronger emphasis on certain protected characteristic groups and therefore the equality agenda in the authority primarily centres on disability older people and Gypsies and Travellers The council does not currently have an up to date approved Welsh Language Scheme WLS in place The reasons for this are understood however without identified actions it is difficult to take the agenda forward Proposals for Improvement 3 16 The SEP should be used to drive equality work within the business planning process Equality objectives should be set with services areas on the basis of engagement with stakeholders and analysis of equality information This will Page 16 ensure the organisation is effectively responding to the needs of protected characteristic groups with the SEP as the main driver and the objectives embedded in organisational business This is a medium term goal which is reliant on supporting processes such as the collection and analysis of equality data and engagement and consultation across the protected characteristics working well The formulation and review of objectives must be responsive and dynamic and it is good practice for equality objectives to be reviewed regularly over the course of the plan in light of new information to ensure they are genuinely representative of
57. s of the Framework e Community Engagement e Leadership and Organisational Commitment e Generating Outcomes e Equipped Workforce This peer review was therefore based on an examination of processes policies performance and outcomes associated with each of these areas which are the building blocks of equality improvement The review consisted of two parts Firstly the peers conducted a desktop analysis of the completed WLGA self assessment framework attached as Appendix A a narrative report and supporting documents provided by Merthyr Tydfil CBC Secondly the peers undertook a two day site visit which involved a series of interviews and group meetings with Members staff and stakeholders to gain more detailed insight Based on the peer team s analysis initial findings including observations and recommendations were presented to Merthyr Tydfil CBC at the end of the site visit This report provides further analysis against the areas of the EIF Peers for this review were Anna Morgan Equalities Training Advisor Welsh Local Government Association Bernadette Elias Head of Policy Performance amp Development Blaenau Gwent County Borough Council Catryn Holzinger Policy and Improvement Advisor Welsh Local Government Association David Thomas Senior Policy Officer Equalities and Welsh Language Caerphilly County Borough Council Rob Beardall Equalities Officer Powys County Council The WLGA would like to take
58. s or which carries a warning to this effect 12 3 6 refrain from smoking whilst in the vehicle 12 3 7 ensure that the minibus is cleared of litter at the end of each use and that any damage to interior fittings is reported in writing ag 66 50 Minibus Policy 2013 Merthyr Tydfil County Borough Council Appendices age 51 Minibus Policy 2013 Merthyr Tydfil County Borough Council APPENDIX 1 Pre drive safety check Do this before every journey Walk around the vehicle including the trailer if applicable to check for visible defects and then check the items listed below K Not Not Exterior check OK OK Interior check OK OK o Mirrors are correctly adjusted clean and Oil level once only at start of day unobstructed Position and function purpose of all the Coolant level once only at start of day dachbosrd controls Windscreen washer fluid level once only at Position of driving seat so that all controls start of day can be operated comfortably Brake fluid level once only at start of day Check for pressure on brake pedal Perform moving brake check no more than Check for pressure on brake pedal and 15mph Also check handbrake operation correct operation of handbrake Windscreen and windows are clean and Wipers and washers are working properly undamaged Wiper blades are clean and undamaged Fuel level and type of fuel diesel petrol Lights including brake lights and indicators Seat belts
59. sengers to leave until the vehicle is at a complete standstill and safely parked by an adjacent pavement or other traffic free area and the handbrake is engaged Always park so that passengers step onto the pavement and not the road Take particular care when reversing the vehicle if children are nearby Avoid unnecessary reversing but if there is no alternative seek the help of an adult to act as a reversing assistant making sure they do not stand directly behind the vehicle Children alighting from the vehicle should be closely supervised Do not leave children alone if no one has arrived to collect them Ensure you know what to do if a child is not collected Report any problems or incidents that occurred during the trip age 55 Minibus Policy 2013 Merthyr Tydfil County Borough Council APPENDIX 3 Duties of a passenger assistant e Supervise the passengers when boarding or leaving the vehicle taking particular care if they are leaving by the rear exit If driving abroad in a country that drives on the right be aware that some doors may open onto the roadside e Check that no passenger boards or leaves the vehicle until it is at a complete standstill and safely parked by a pavement or other traffic free area e Ensure the driver does not move off until everyone is safely seated facing the front and wearing a properly positioned and adjusted seatbelt if fitted or using a securely fixed and properly adjust
60. should be developed in relation to EIAs to increase challenge and improve their quality This could be achieved through training of Members staff and union representatives There is a duty to publish all EIAs that have a substantial impact but the authority could choose to publish all EIAs or make them available internally so there is transparency and staff can see how they are done As part of this awareness raising the benefits of EIA should be promoted with the aim of increasing buy in which should in turn increase the use and quality of EIAs The authority could consider how its EIA process could be integrated within and complement other corporate processes including self evaluation and business planning risk management project management and also how the various impact assessments could be brought into a more streamlined process It would be beneficial to develop quality assurance for EIAs particularly for those where there may be a substantial impact This could be provided internally by other service areas by third sector partners or a Corporate Equality Working Group if one were to be re established This would help drive sustained quality by providing officers with useful feedback The authority should consider how it builds the equality dimension into current priority areas of work such as welfare reform For example work is already underway in relation to welfare reform with further developments such as
61. should undergo its own risk assessment This should take into account a The different environments where the equipment is likely to be used The use of the equipment must then be limited to these environments b If mobile equipment is meant to carry persons it must be fit for purpose c The possibility of injury caused by roll over of equipment 11 Work Equipment Policy 2013 Page 71 Merthyr Tydfil County Borough Council 4 10 Records Records of the following must be kept a Any risk assessment carried out b Details of any interventions made as a result of a risk assessment c Any information instruction or training that was provided to users d Attendance of any training provided e Any incidents or near misses involving work equipment f Written schemes of examination g Maintenance and service records h Inspection reports i Daily weekly check sheets 12 Work Equipment Policy 2013 Page 72 5 0 5 1 5 2 5 3 5 4 5 5 5 1 5 1 1 Merthyr Tydfil County Borough Council GUIDANCE Assessing the risk 5 6 Performing inspections Suitability of equipment to purpose 5 7 Performing maintenance Suitability of equipment to environment 5 8 Purchasing Suitability of equipment to the person 5 9 First aid Schedule of inspection amp maintenance 5 10 Delivery of training Assessing the risk from equipment Equipment that needs to be assessed Not every piece of work equipment needs to be risk assesse
62. the Communities First and Citizens Advice Bureau Financial Inclusion Forum planned Evidence shows that there is a specific equality dimension to welfare reform and the authority s approach should analyse the impact on protected characteristic groups to help understand need and develop appropriate responses Page 18 3 23 The authority should consider updating the WLS or developing some interim priority actions ahead of the introduction of the new standards This is in recognition of statutory requirements as well as an opportunity to progress the agenda Furthermore the authority may wish to consider these alongside the actions in the SEP to avoid duplication and achieve quick results given there are many overlapping requirements between the SEP and the WLS 4 Equipped Workforce Strengths 4 1 4 2 4 3 4 4 4 5 4 6 4 7 4 8 Human Resources HR policies are regularly reviewed and updated Consequently many older policies have been brought together and simplified and have equality considerations built into them However there may be some policies that were last updated prior to the duty to impact assess coming into force There are examples of where equality training needs have been identified and met For example Community Cohesion officers have provided equality training to frontline staff and social care explore training needs then work with the equality officer to deliver an appropriate programme
63. this opportunity to thank Merthyr Tydfil CBC for inviting the WLGA to undertake the equality improvement peer review particularly at a time when local authorities are facing significant challenges in the form of reduced budgets increasing demand for services and multiple competing priorities The peer team appreciated the welcome and hospitality provided by the authority and would like to thank everybody they met during the process for their time and contributions Page 4 Detailed Findings 1 Community Engagement Strengths 1 1 1 2 1 3 1 4 1 5 There are a number of examples of notable practice in community engagement These include permanent mechanisms such as the established Older People s Forum and the Youth Forum which have strong ties to the council and are able to inform and influence decision making They also include engagement and consultation on specific issues such as the development of the contact centre and residential care Furthermore tailored techniques have been developed such as the Multiple Intervention Assistance MIA Children and Young people engagement tool Crucially these examples have provided or continue to provide a genuine means for the community to influence council policy and delivery For example extensive consultation was undertaken in relation to the contact centre the result of which was a service designed to meet citizen need Another example is the Youth Mayor whereby each suc
64. uipment These persons would be aware of the risk involved in maintenance work and would have completed risk assessments Some requirements such as isolation may be required before maintenance is performed 5 8 Purchasing New Equipment The PUWER regulations require the Council to select equipment that has been designed and constructed to comply with any EC Essential Safety Requirements relating to that equipment All equipment purchased or acquired second hand must be safe to use and to maintain and must be suitable in terms of its initial integrity the place where it will be used and the purpose for which it will be used When selecting work equipment managers must take account of ergonomic factors and should select the least hazardous type of equipment that can adequately perform the task For example preference should be given to equipment that reduces health and safety risks to users to as low as is reasonably practicable 17 Work Equipment Policy 2013 Page 77 Merthyr Tydfil County Borough Council Safety features such as the following should be selected whenever possible e low noise levels e low vibration levels e low voltage electrical equipment e lightweight helps reduce manual handling risks e adjustable dimensions to improve ergonomic fit When purchasing new equipment prospective equipment must undergo the risk assessment processes as described in 5 1 to 5 6 before any purchase is made Finally t
65. uthority training needs analysis and allocating training budgets accordingly This could build on the existing courses as well as the knowledge skills and experience of Elected Member Champions staff partners and the WLGA to develop both traditional and less formal forms of training such as sharing practice and e learning It could use case studies to highlight the consequences of non compliance but should also have a significant focus on highlighting the additional benefits equality can bring to services so that staff can see how it can help them in their role Training represents a valuable opportunity to reposition equality in terms of serving the community better as outlined in point 3 9 4 21 The authority could strengthen the link between individual action and behaviours and equality work This could be achieved through the performance review process and could be built into a competency framework 4 22 The authority could consider establishing a staff network s as a means of engaging protected characteristic 4 23 groups of employees The configurations of the network should be realistic reflecting available resources The authority could consider how the equality function has maximum influence across the organisation Equality work has stronger links with some areas than others and there is a need to further embed it in service delivery across the organisation as part of the shift from compliance to generat
66. ve challenge For example it was noted that there has only been one occasion where a challenge was made at a budget meeting on the basis of an EIA Increasing Members knowledge of equality issues and the EIA process would enable them to provide challenge as and when necessary Proposals for Improvement 2 12 2 13 2 14 2 15 The professional leadership should increase their ownership of equality work and consider how they use corporate processes to improve accountability for it In practice this could mean ensuring equality is effectively embedded in business planning self evaluation and risk management processes and that the SEP is and is seen to be the driver of equality work This is described in more detail in section 3 The authority could further utilise the Equality and Older People s Elected Member Champions While they have strong links to the community and are a force for driving change forward there is greater scope to align their efforts to the equality objectives and priorities for improvement Planning how they can use their unique position to further these objectives would enable them to have maximum impact Equality training should be developed further including a specific focus for Members This could draw on a variety of methods including less traditional training such as visiting other areas or particular projects This could also focus on some of the less well established issues and protected c
67. vel 2 4 Collaborative partnership working The authority has agreed with pa 1 Strengths 2 Areas for Improvement 3 Proposals for Improvement 2 12 2 13 2 14 2 15 2 6 2 12 3 13 1 17 3 17 1 2 1 11 1 14 ze abed Generating Outcomes 3 1 Setting equality objectives Corporate equality objectives and an associated strategic equality plan have been agreed by the organisation Managing and reporting progress l There is an equality management mechanism in place that will enal corporate vision and principles and equality objectives to happen Assessing and monitoring impact L The organisation has an effective corporate process establ enable the ongoing assessment of impact across services Business planning process Procurement practice NG The organisation has procedur hat will enable the procured services to meet i C expectations on equality 3 6 Connecting cross cutting agendas Links have been made with other cross cutting agendas to enable a joined up approach to generating improved outcomes for the local community 1 Strengths 2 Areas for Improvement 3 Proposals for Improvement 2 15 2 16 3 16 3 10 3 11 3 12 3 18 3 19 3 20 3 21 2 8 3 8 3 16 1 7 3 7 4 4 1 18 3 2 3 13 3 17 32 CC obed Staff development A rolling programme
68. where fitted are undamaged and are clean and working working properly Tyre pressures including the spare and inner tyres and tyres on a trailer if applicable Location of wheel brace and jack Tyre tread including the spare and inner tyres and tyres on the trailer if applicable At Location and contents of first aid kit and fire least 3 0mm across centre is extinguisher s recommended Location of relevant paperwork permit disc All tyres free from any cuts and bulges insurance tax disc MoT emergency numbers and driving licence Change for parking or for the telephone or Doors open and close properly mobile phone or phonecard Trailer brake lights and indicators work if Luggage is securely stowed and aisles and applicable exits are clear Lift if fitted works safely Damage or sharp edges Ramp if fitted fits and works safely Roof rack or trailer is properly fitted and all luggage is securely held Damage or sharp edges ag 638 52 Minibus Policy 2013 Merthyr Tydfil County Borough Council Ensure that emergency equipment is available in the event of an accident or breakdown For example a high visibility jacket and torch Other equipment such as a warning triangle and a webbing cutter could also be included Brake checks Before the passengers are loaded the brakes should be checked With the engine running check the handbrake is working properly and that the
69. with it Does the presence or use of the equipment require an access controlled area For example a circular saw in a school workshop Assessing the suitability of equipment to persons using it When assessing the suitability of equipment to the persons using it the following factors should be considered a b Are there persons with disabilities who may need to use the equipment and are they able to do so safely What is the age or mental capacity of the persons using the equipment For example school pupils work placement staff or trainees are likely to be more vulnerable to risk What is the physical strength of the person using the equipment What is the skill level of the user More powerful equipment generally but not always requires a more skilled user What is the effect of the equipment on young persons or new and expectant mothers 15 Work Equipment Policy 2013 Page 75 Merthyr Tydfil County Borough Council 5 5 Scheduling of Inspections and Maintenance Frequency of inspections and maintenance depend on the following factors a Manufacturer s recommendations b How much the equipment is used c The results of risk assessments For the purpose of scheduling inspections and maintenance time spent in storage is considered time in use This is because some components deteriorate with time regardless of the time in actual use For equipment that is in use scheduling is determined almost entirely by a
70. wned leased or hired Checklists should be kept for a period of 15 months from the date they are completed This is in accordance with the document entitled Guide to maintaining roadworthiness published by the Vehicle amp Operator Serviecs Agency VOSA Electronic copies of this document are available from the Councils Health and Safety Unit and posted on the Council s Intranet site 6 3 Seats and seat belts All vehicles should have forward facing preferably high back seats Minibuses with rear seats along each side of the vehicle and facing inward crewbus type must not be used All vehicles must be fitted with seat belts for the driver and all passengers and these must be used By law passengers in the front seats and any exposed seats in any minibus must wear the seat belts provided Those in the rear of a minibus of unladen weight of 2540 kg or less must wear the seat belts provided Although the law does not require that passengers in the rear seats of a minibus of unladen weight of more than 2540 kg wear seat belts this is strongly recommended by all road safety organisations and is a requirement of this policy age 40 Minibus Policy 2013 Merthyr Tydfil County Borough Council In summary this policy requires that seatbelts be worn on all journeys by all passengers irrespective of the unladen weight of the vehicle 6 4 Special access equipment Where disabled passengers are carried appropriate access equ
71. y to the view held by some that EIAs were helping to change culture and reframe conversations many officers felt they were still seen as a tickbox exercise being completed to meet legal requirements rather than because they can add real value to service planning and decision making This reflects the general emphasis on compliance rather than added value Lack of knowledge in terms of their value 3 11 3 12 3 13 3 14 3 15 purpose and how to undertake them were identified as reasons EIAs had not developed into a useful tool Some officers alluded to death by impact assessment as there are multiple impact assessments including the Single Integrated Plan and Sustainability Impact Assessment While EIAs were regarded as useful in supporting budget setting the responsibility for undertaking them rests with service areas Given the points above an improved corporate EIA process with increased buy in across the organisation would be beneficial to the budget setting process Links between the SEP and SIP could be strengthened The SIP includes a reference to equality as a cross cutting theme but it is not clear how equality has been embedded in the strategy and wider partnership activity The SIP and SEP could articulate how one relates to the other and how these are mutually reinforcing areas of work Some suggested there is also the opportunity to strengthen links between strategic partnership working and key area

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