Memorandum submitted by SkillsActive|
This submission focuses primarily on the role of
Ofsted as regards inspection of playwork settings (after-school
and breakfast clubs, holiday playschemes, and adventure playgrounds)
registered on either the Early Years Register or General Childcare
Register. It is based on the views of both employers and practitioners,
highlighting the problems, in particular the lack of understanding
of the ethos of playwork settings they consistently encounter
when dealing with Ofsted inspectors.
1. What the purposes of inspection should
be (relating not only to schools but to all organisations, settings
and services under Ofsted's remit)
(a) For settings on the Early Years Register
and the General Childcare Register, the purpose of inspections
should be to ensure that settings meet the requirements of the
registers upon which they are registered. The potential problem
with this is that requirements can be too rigid and too rigidly
interpreted. SkillsActive has worked with Ofsted to develop some
degree of flexibility so that frameworks such as the Early Years
Foundation Stage can be delivered in different ways depending
on the nature and purpose of the setting. Even though the system
allows for some flexibility, settings often report to us that
Ofsted do not always allow this.
(b) We believe that the purposes of inspecting
educational establishments would be fundamentally to monitor the
learning and development of children as well as ensuring their
safety. For settings in the playwork sector, primarily after-school
and breakfast clubs, holiday playschemes and adventure playgrounds
who operate according to the playwork principles, formal learning
and development is not a priority. We would therefore argue that
the purpose of inspecting a playwork setting is simply to ensure
the safety of children in the setting's care.
2. The impact of the inspection process on
(a) Ofsted should also be looking at how the
school provides for the wellbeing of its pupils as regards attitudes
towards play and break-time. Evidence has shown the importance
of freely-chosen play to children, and recent projects in schools
have demonstrated the practical benefits of freely-chosen play
to the well-being and behaviour of children.
(b) As a specific example, South Gloucestershire
Council has invested a significant amount of time in developing
play opportunities in its primary age schools through the creation
of a "Learning and School Effectiveness Play Adviser"
post. Over the past five years, play development support has
been provided to over half the authority's primary schools. A
programme to support play development called Outdoor Play and
Learning (OPAL) has been developed and delivered to thirty schools.
South Gloucestershire Council have made the following recommendations.
They suggest it would be beneficial if future Ofsted inspectors:
(i) Understood what conditions need to be in
place for play to flourish in schools.
(ii) Understood the value of high quality play
opportunities for children of all ages within the school day.
(iii) Understood the difference in managing risk
thorough risk-avoidance and risk-benefit.
(iv) Understood that the law requires that risk
is managed on a basis of "as low as is reasonably practicable"
and so must weigh up evidence of risk, cost, likelihood, severity
and degree of benefit and negative outcomes.
(v) Made a presumption that the communities where
children live, play and travel are also safe enough for children
to be at school without being secured in unless there is significant
evidence to prove otherwise.
(vi) Please see the Annexe for case studies.
3. The performance of Ofsted in carrying out
(a)The introduction of the Early Year Register has
had an impact on the delivery of play provision by many of the
providers responding to an online survey carried out by SkillsActive
There are some key points to mention here.
(i) One significant point to make from the data
is that some clubs have decided to take themselves out of registration
with Ofsted so that they do not have to abide by the requirements
of the registers. How wide ranging this measure was last year
is unclear. Intuitively, it could be argued that de-registration
means no requirement for qualified staff and thus a reduction
in quality that the Early Year Register was designed to ensure.
(ii) There were concerns raised about the emphasis
of Ofsted's inspections being on the children covered by the Early
Year Register, even when this group of children formed a relatively
small proportion of the children for whom the setting provided
care. (most playwork settings cater to a small proportion of children
in the Early Years age range)
(b) One other respondent, who had encouraged
settings to stick as closely as possible to the playwork principles
whilst delivering the EYFS, suggested that Ofsted inspectors did
not really know what a playwork setting should be and thus by
implication could not inspect it adequately.
(c) Nationally, Ofsted released a very good guidance
document, "Regulating play-based provision"
as well as particular guidance to inspectors which states that
"Where a setting subscribes to a particular approach - for
example, Playwork Principles, Steiner, Montessori or High/Scope;
or settings that adhere to a particular faith - the inspector
carrying out the inspection must be familiar with this method."
There is no evidence from employers that this central guidance
has had any significant impact. Ofsted themselves say that "In
a play setting, playworkers should be planning for play by providing
the best environment possible; they should not be planning the
play itself." This aligns well with the playwork principles,
but again, in practice this seems to have had little influence
4. The consistency and quality of inspection
teams in the Ofsted inspection process
(a) With regard to consistency, the Playwork
sector, which covers after-school and breakfast clubs, holiday
playschemes and adventure playgrounds for children, has had significant
issues with the performance of individual Ofsted inspectors. Some
playwork employers have raised concerns that Ofsted is inconsistent
in its approach to inspections across the out of school sector.
As Ofsted inspectors are not trained in play or the playwork
principles (which underlie professional practice and playwork
qualifications) as a matter of course, different inspectors will
have a varying understanding of these and what a setting is trying
to do. With little understanding of what a play setting is trying
to do, it is no surprise that (to give one example) Ofsted inspectors
inspecting a holiday playscheme reported that the setting had
insufficient numeracy activities.
(b) An online survey just completed to feed into
Dame Tickell's call for evidence on the Early Years Foundation
Stage highlighted that the current lack of understanding of playwork
by Ofsted inspectors is also an issue consistently raised by employers.
One of the recommendations of the report based on this survey
is that "Ofsted inspectors should attend mandatory training
in play and playwork"
(c) Anecdotal evidence suggests that that there
are also large differences in interpretation of requirements by
different inspectors. Some are asking for playwork settings to
complete learning journals and display planning on the walls,
whilst others would not.
5. The weight given to different factors within
the inspection process
(a) Some playwork settings have told us that
Ofsted inspectors are much more interested in the Early Years
Foundation Stage aged children (0-5) than they are in children
in the older age ranges. This can sometimes lead to settings
concentrating on what they are doing for this age range at the
expense of the older children.
(b) Settings have also informed us that Ofsted
are much more likely to focus on the learning and development
goals required by the Early Years Foundation Stage than anything
else, such as the welfare requirements.
6. Whether inspection of all organisations,
settings and services to support children's learning and welfare
is best conducted by a single inspectorate
(a) Certainly in terms of playwork settings,
we would like to see Ofsted continue to carry out its role inspecting
against welfare requirements, but not learning and development,
for example as contained in the EYFS. We have indicated to Dame
Tickell as part of her review of the EYFS that playwork settings
should not have to adhere to the learning and development requirements,
and we would like to see a sector-initiated framework addressing
7. The role of Ofsted in providing an accountability
mechanism for schools operating with greater autonomy
(a) SkillsActive is not commenting on this section.
8. The Impact of OFSTED inspections in relation
to risk management, play and outdoor learning in South Gloucestershire
(a). South Gloucestershire has invested more
time and effort than most other local authority in the country
in developing play opportunities in its primary age schools through
the appointment of a "Learning and School Effectiveness Play
Adviser" post. Over the past five years play development
support has been provided to over half the authority's primary
schools and a comprehensive programme to support play development
called Outdoor Play and Learning (OPAL) has been developed and
delivered to thirty schools.
(b) An independent evaluation of the of South
Gloucestershire's OPAL programme is currently being carried out
jointly by The University of Gloucestershire and The University
of the West of England. The interim report was published in August
2010 and has been attached to this submission.
9. Case One
(a) Wellesley Primary
(i). The school had worked closely with the local
authority play adviser over 18 months to develop an outstanding
approach to play. They scored 98% in the OPAL audit which looks
at the prerequisite conditions for play across a suite of 15 criteria.
(ii) The approach to risk management was a well
thought out risk-benefit approach and the levels of supervision
for the grounds were in accordance with the guidelines which the
schools' health and safety adviser, the head of health and safety
for the Council and the play adviser had agreed and ratified.
Approaches to play fighting with the Playpod scrap materials were
governed by a scrap-on-scrap basis; an approach which has been
developed from a research, evidence and experience and which responds
to children's need and wishes for a more robust approach to rough-and-tumble
(iii) The OFSTED inspector glossed over any of
the outstanding achievements of the school and focused on the
fact that some play took place in places that were away from the
direct sight-line of adult supervisors.
(iv) The inspector also expressed a view that
the well managed and successful approach to scrap-on-scrap play
was "over boisterous" and therefore should be curtailed.
These judgements were not based on playtime observations or on
studying of the accident and incident book. If this had been studied,
it would have been clear that there had been an 80% drop in accidents
and incidents in the play ground since the school improved its'
(v) The judgement of the inspector was based
on an interview with a small group of children who expressed a
view they thought that some children might find the play fighting
intimidating, though none of them had actually felt intimidated
(vi) The negative impact of the comments made
by the inspector has been dramatic as the school concerned is
viewed within the authority as the best example of best practice
primary school play and therefore there has been a knock on effect
to other schools. What is cause for concern is that the inspector's
comments and judgements were not based on evidence. It is also
of concern that the inspector did not have sufficient awareness
or training to be able to notice that this was probably one of
the top three schools in the country in its understanding and
provision of play and outdoor learning. It has been visited by
the schools throughout the South West as well as the Assistant
Director of Play England and the University of Gloucestershire
who were immensely impressed by the school's achivements.
(vii) The head at the school did not want to
"rock the boat" by challenging the inspector but has
since told me he would be happy to show OFSTED around his school
to demonstrate the value of what the is doing.
10. Case Two
(a) Hawkesbury Primary
(i) Hawksbury Primary School is a small village
primary set on the edge of fields a few miles North of Chipping
Sodbury. The head reported that the OFSTED inspector had advised
her that the stone field wall which runs around the boundary of
the school was not sufficient for child protection purposes, as
strangers could gain access to the school grounds from the fields.
(ii) OFSTED must be challenged on comments like
this for the following reasons:
(iii) Current Health and Safety law requires
that risks are mitigated "As Low as is Reasonably Practicable"
(ALARP). It does not require all risk to be eliminated. This means
that decisions on risk must weigh up the evidence
and look at what the benefit will be in relation to the cost and
what the negative impact may be. In the case of the evidence of
risk posed from outside the schools, there should be a presumption
that the environment is safe enough unless the statistics on abductions
from rural village schools show that there is an unacceptable
level of risk. Advice given should consider what will be likely
the reduction of risk in relation to the cost and also what will
the negative impacts be.
(iv) The negative impacts of surrounding primary
schools in high security fencing may outweigh the positive gains.
In the Case One the OFSTED inspector based a recommendation to
the school to take action because of a perception that children
thought others might feel a threat. In relation to the enclosure
of many primary schools with very high fencing, consideration
must be given to how this makes children feel. Research by CABE
in relation to what they call "target hardening" has
demonstrated; the more physical evidence in an environment that
an area is dangerous, with feature like high security fencing
and CCTV cameras; the less safe people perceive an area to be.
My own research with children backs this up. The message children
get from high fences around that schools is; their own communities
in which they live their daily lives, and where they should be
learning to travel and play independently, are dangerous and a
threat to them. It raises the question of how we will ever build
sustainable communities if children are made to feel these communities
pose such a threat that they must be secularly separated from
them. In an interesting contrast Sweden's schools are forbidden
from fencing themselves away from society as this gives the wrong
message about the relationship between the school, society and
11. Case Three
(a) Little Stoke Primary
(i) The head at this school called in the Play
Adviser immediately after an OFSTED inspection. The inspector
had been looking a the early years outdoor area and said that
a gentle tarmac slope, running from the classroom to the outdoor
area was a health and safety risk, and the area should not be
used until the school had taken steps to mitigate the risk, or
supervise the children when they were using the slope. I inspected
the area and despite having had ten years experience in both risk
management and out door play in schools could not perceive any
unacceptable risk. This may seem like a small issue but it is
not. Schools are very risk averse institutions and have needed
a lot of encouragement from Early Years Advisers and the Play
Sector to move way from a risk aversion model of risk management
to a risk benefit model. If inspectors are not aware of the difference
and issue advice based on a principle of elimination of risk of
all risk, either in the name of health and safety or child protection,
then immense damage will be done to the ability of schools to
meet children's basic needs and to deliver the EYFS.
12. Case Four
(a) Bromley Heath Junior School
(i) This school was the second in the country
to reach Platinum level in the Outdoor Play and Learning Awards.
This means that it scored 96% against the 15 criteria for creating
the best possible conditions for outdoor play and learning. Along
with Wellesley it is probably one of the most outstanding schools
in the country for the way it has embedded outdoor play and learning
into the culture of the school and enabled the children to experience
a very rich and diverse range of outdoor play and learning opportunities.
This has had a huge impact on the pupils' enjoyment of school
and on a range of social and development skills which enable them
to be more imaginative, creative and co-operative learners.
(ii) Although the OFSTED inspection did not criticise
the school for its approach neither did it recognise the achievements
the school had made or how this contributed to standards, learning
(a) The case studies and the independent evaluation
report suggest that head teachers, parents, pupils, play experts,
academics and researchers, school improvement partners and above
all children acknowledge the benefits of high quality play opportunities
(b) Play in schools can only take place if the
conditions are right. The most important conditions without which
play cannot take place are:
(c) freedom to take appropriate levels of risk
(d) freedom for children to playfully and independently
explore the relationship between themselves and the physical
and social environments around them.
(e) OFSTED inspections of schools which excel
in providing outdoor play and learning opportunities in South
Gloucestershire have, at best, failed to notice the contribution
of play to the happiness and learning of the children and at worst
confounded and eroded good practice.
23 The Early Years Register, General Childcare Register
and Early Years Foundation Stage - Holiday Playschemes Impact
Assessment, SkillsActive, 2009 Back
Regulating play-based provision, Ofsted, 2010 Back
Conducting early years inspections, Ofsted, 2009 (revised 2010) Back
Playwork settings and the Early Years Foundation Stage, A response
to the call for evidence by SkillsActive, SkillsActive, 2010 Back
Not published on the Committee's website. Back