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 
