Select Committee on Environment, Transport and Regional Affairs Sixth Report


THE ENVIRONMENT AGENCY

MANAGEMENT AND STAFF

  36.  It has been clear to us throughout the course of this inquiry, both through the written and oral evidence which we have received and through our experiences during our visit to the South West, that the Agency's existing staff are all personally fully committed to the improvement of the environment and to their jobs.[84] However, we are concerned that their commitment is being undermined by senior management decisions and actions in a number of areas, resulting in high staff turnover, low morale, and a consequent decrease in the Agency's effectiveness.[85] We examine these areas below.

Waste and IPPC inspectors

  37.  As demonstrated clearly to us during our visit to the Avonmouth industrial estate, it is vital that Agency inspectors have both sufficient expertise in their field and sufficient experience of industry both to regulate effectively and to be seen to regulate effectively.[86] The Agency's problems in the waste regulation sector in this regard are well-documented, not least in our own Report of July 1998 on Sustainable Waste Management.[87] We are concerned not only that these problems appear not yet to have been fully resolved, but that similar problems may arise in the Agency's IPPC function unless there is a significant change in attitude towards its inspectors on the part of Agency senior management. Such problems would be a very serious risk to the effectiveness and credibility of this important new regime.

Waste

  38.  In our Report on Sustainable Waste Management, we were very critical of the complacent manner in which the Agency appeared to be treating the problems it was experiencing in ensuring that its waste regulation function was undertaken by a full complement of properly trained staff. We recommended that "audits of training ... continue as a high priority for the Environment Agency", and that "these should be backed by implementation of appropriate training at all levels, from new entrants to senior management."[88] The Agency responded during this inquiry by noting that it had "recruited 220 new staff and implemented operational training programmes, including industrial secondments".[89]

39.  However, evidence from the waste management industry suggests that Agency is still not doing enough to train its staff in the waste management function. Biffa Waste Services, for example, said, "The competence of Environment Agency resources, particularly in waste management regulation, is a growing concern ... inexperienced officers are becoming more commonplace and internal reorganisations lead to a worrying trend of transfers across technical disciplines: increasingly, waste regulation is being performed by former National Rivers Authority staff who have little waste management experience."[90] Dr Marion Carter of the Environmental Services Association told us, "We see little evidence of substantial progress in this matter ... it is the absence of training and general lack of skills in waste management which is an underlying problem which the industry thinks leads to many of the difficulties we experience. The Agency recently has been making efforts to improve the situation, but this is three and a half years on from when they were formed and 18 months on from your report."[91] She went on to say, "The Agency have asked us to be patient about the training, but we feel that that patience is perhaps coming to an end and we feel that the Agency should be doing something very quickly."[92] Asked whether the Agency had sufficient understanding of the waste industry to be an effective and fair regulator, she replied, "I think it would be fair to say that currently we do not have that confidence."[93]

40.  We are surprised and disappointed that, even after the considerable length of time that has elapsed since our Sustainable Waste Management inquiry, and despite the 'improved dialogue' with the industry of which the Agency boasts,[94] it has still not done enough by way of training its staff to gain the confidence of the waste management industry. We recommend that the Agency urgently take further steps to improve the competency of its staff in the waste management function.

Integrated Pollution Prevention and Control

  41.  Shortly before the Agency's Chairman, Chief Executive and Director of Operations appeared before us, the Agency announced the results of a job evaluation exercise relating to its field inspectors in the Process Industry Regulation/Radioactive Substances Regulation function. Whilst the job specification appears to leave unchanged the job undertaken by field inspectors, the exercise has resulted in a score on the Hay job evaluation system, which the Agency uses to assess such posts, some 30 per cent. lower than it was when the Agency evaluated it in 1997. The starting salary which corresponds to this evaluation, we were told, is £19,646 to £22,325.[95]

42.  Following this announcement, the Institution of Professionals, Managers and Specialists, the trade union representing over 90% of the Agency's Process Industry and Radioactive Substances Regulation (PIR/RSR) inspectors, expressed to us in a supplementary memorandum considerable concern about the consequent downgrading of their members' posts.[96] They suggested that the recruitment salary for jobs of the proposed score was insufficient to attract candidates of the right calibre, who would have neither the relevant industrial experience nor the stature required to regulate major industry effectively. The fact that some 80 per cent. of the present inspectors in the PIR/RSR function will require salary protection under the new evaluation, as their current salaries lie above the grade maximum, demonstrates clearly the reduction in experience and expertise amongst field inspectors which this regrading exercise will entail.

43.  The concerns of the IPMS were shared by industry. It was put to John Seeley, the site manager of the Rhodia Organique Fine chemical production plant which we toured during our visit to the South-west, that the use by the Agency of less experienced inspectors might be beneficial to industries such as his, because it could make it easier for them to "pull the wool over the eyes" of inspectors. However, he pointed out that it could also mean that inspectors would be more prone to irrational, erroneous and potentially costly decisions which would not be made by more experienced inspectors.[97] Such decisions could also lead to expensive and inefficient statutory appeals or legal proceedings. This point was also made to us by other witnesses in written evidence.[98]

44.  The relatively low levels of pay attaching to these regraded posts[99] may also cause another problem. The Agency cannot expect to regulate effectively if it pays its staff significantly less than they might expect to receive were they to work for the industry they are regulating. There is a risk that Agency inspectors will be demoralised, and regard themselves as subordinate to their industry counterparts.

45.  When questioned on the matter, the Agency's Director of Operations, Archie Robertson, claimed that he had evidence of the Agency's ability to recruit new staff at the level of pay corresponding to the new grading. He argued, "In looking to the future, we see that in pursuit of integration and the risk-based approach, we cannot possibly sustain an organisation where we expect individuals to know everything. They must be supported by teams where there are specific requirements and by networking. By networking the experienced people we have in to the properly trained recruits, we will be able, we believe, to cover the ground, to have more consistency through the way we operate and through the standards we have, and to give people satisfying careers and development within the job, which is what the motivation is about."[100]

46.  We agree that it is not possible to sustain an organisation which expects individuals to know everything. However, Mr Robertson was unable to convince us that these new recruits will have the experience and expertise necessary to carry out the effective regulation of major industry with which these posts are concerned. Nor can such expertise credibly be achieved by internal "networking" within the Agency, particularly as the staff with the necessary expertise and field experience are lost and are not replaced. If the Agency follows through with this decision, it is storing up serious trouble for itself in the future. As its existing experienced staff retire, they will be replaced, for the most part, by new graduates who cannot possibly be expected to carry out the same quality of work. The Agency should have learnt from its experience in the waste sector what happens when there is not sufficient staff expertise on the ground. We do not wish this also to happen in the IPPC sector.

47.  We are therefore seriously concerned about the consequences of this decision for the effective environmental regulation of major industry. Our visit to the Rhodia Organique Fine chemicals production site in Avonmouth during our visit to the South-west showed clearly the level of detailed process-specific expertise that is necessary for this work.[101] We also have doubts as to whether the use of the Hay evaluation to assess such posts is wholly appropriate. We recommend that the Agency reconsider its decision to downgrade its Process Industry Regulation/Radioactive Substances Regulation Inspector posts.


84  See, for example, ev p.16 (EA08); p.25 (EA15); p.80 (EA37); p.103 (EA49); p.128 (EA58); Annex . See also ENDS Report, April 1999, "Environment Agency management comes under fire from staff", which reported the results of a survey carried out for the Agency to explore employees' perceptions of communications within the Agency and other aspects of its culture: this survey showed that 55% of staff "agreed strongly" that they were committed to giving their best, compared with a 'benchmark figure', used for comparison with other organisations, of 27%. Back

85  Ev pp.16, 19 (EA08); p.65 (EA29); pp.97, 98 (EA47); p.101 (EA49); p.112 (EA54); p.125 (EA58); Q105; Q112; QQ115-118; Q635 Back

86  See Annex Back

87  op cit Back

88  ibid, paras 234-236 Back

89  Ev p.140 (EA62) Back

90  Ev p.29 (EA16) Back

91  Q99 Back

92  Q100 Back

93  Q106 Back

94  Ev p.140 (EA62) Back

95  Ev vol. II p.102 (EA58(a)). See also ENDS Report, December 1999, "Row over downgrading of Agency's industry inspectors" Back

96  ibid Back

97  Annex Back

98  Ev p.29 (EA16); p.80 (EA37); p.112 (EA54) Back

99  See QQ327-329. Back

100  Q635 Back

101  See Annex Back


 
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