APPENDIX 3: THE MANAGEMENT OF SECONDARY
LEGISLATION: GOVERNMENT RESPONSE
Introduction
1. The Government is grateful for the report
from the Merits of Statutory Instruments Committee on the management
of secondary legislation, as part of its work in looking at the
merits of instruments. The report largely concerns matters of
process, which are of course of interest also to the Joint Committee
on Statutory Instruments. This memorandum is in response to the
recommendations and conclusions made in the Committee's Report.
2. The Government fully accepts the thread of
the introductory paragraph in the Report, which notes that delegated
legislation, though often un-newsworthy, is nonetheless highly
significant in the effects it has on the citizen and on businesses.
It is important therefore that such legislation is properly thought
through and is of high quality.
3. Government has, over recent years, sought
to ensure that the quality of secondary legislation is maintained
and that, where appropriate, opportunities are taken to improve
the process. Explanatory Memoranda for affirmative instruments
were introduced in 2001, and extended to negative instruments
in 2004. Common Commencement Dates for most instruments which
affect businesses were introduced from 2005, in a move generally
welcomed by stakeholder groups, and are being extended progressively
through departments. The Government publication Statutory Instrument
Practice is kept under constant review and is re-issued from time
to time. An updated edition will have been issued prior to the
delivery of this response.
4. Prime responsibility for the management of
the quality and of the process of each department's secondary
legislation must of course rest with the department. The circumstances
of individual departments in the context of secondary legislation
will not all be the same and the way they are structured to handle
the process needs to accommodate these differences. The role of
the centre will not therefore be comparable to its role in the
management of the programme for primary legislation. Against this
background, there will nonetheless always be scope for improvement
in the way individual departments manage the process and the Committee's
report will be helpful in promoting such improvement. These points
are developed further in the comments on individual recommendations
which follow.
Recommendations
Recommendation 1: In each department there should
be one member of top management (i.e. at Board level) who is accountable
to the relevant Minister for the efficiency and effectiveness
of the process of preparing SIs as well as for ensuring that the
finished products meet the requirements of good regulation (Paragraphs
51-52)
5. Individual Departments need to be able to
decide on their management structure and Board membership. Departments
have in place chains of responsibility and accountability for
work which is undertaken by the Department. The secondary legislation
process brings together several strands of a Department's work,
each with its own management and accountability structure.
6. It is already the case that, as part of the
better regulation agenda, each Department has a better regulation
champion who works with the Department's Better Regulation Minister.
7. It could be possible to build on this approach
by ensuring that there is also a senior manager in each Department
responsible for monitoring the efficiency and effectiveness of
the process of preparing SIs. Individual Government Departments
will examine this recommendation further to see how it can be
most appropriately applied in each case, but for some Departments
it is clear that it could prove difficult . Given the many elements
of the SI process it would not necessarily be possible for Departments
to have a single accountable person along the precise lines suggested
by the Committee.
Recommendation 2: Departments should prepare annual
management plans for their SIs, including milestones to be met
and machinery for reviewing their achievement; and should produce
and publish annual statements of their projected secondary legislation,
listing the SIs they plan to submit for parliamentary approval,
briefly describing each one and stating when it is planned to
come into effect (Paragraphs 53-58)
Recommendation 6: Departmental lists of planned
secondary legislation should be consolidated into a single list.
A central mechanism should be established for exploring with departments
the scope for adjusting the scheduling of SI programmes if it
should appear from the consolidated list that such action is necessary
in order to avoid congestion at the point of parliamentary scrutiny
(Paragraphs 75-79)
8. The Government acknowledges the important
role of good planning and the use of project management techniques
in the SI process. The Government also acknowledges the importance
of keeping stakeholders informed of forthcoming secondary legislation
which will impact on them.
9. In the December 2004 Pre-Budget Report, the
Chancellor of the Exchequer announced that the common commencement
date (CCD) initiative would be extended progressively to all domestic
regulations with a bearing on business. Under the CCD initiative
Departments are required to prepare an annual statement, which
is issued in January, listing regulations affecting business which
they expect to commence on the following 6 April and 1 October.
CCDs and the accompanying annual statements help business plan
for new regulation; increase awareness of new or amended regulations;
and give Ministers a strategic overview of Departments' regulation
programmes.
10. Alongside this many Departments, whose secondary
legislation is not formally subject to CCDs, have in place alternative
commencement dates for some of their SIs, which have been agreed
in conjunction with their stakeholders.
11. Departments' timetables for projected legislation
can be subject to amendment and revision in response to a wide
range of policy developments, and to outside events. Any management
plans would be subject to substantial and frequent revision. As
a result they are likely to be of limited benefit to either Parliament
or stakeholders. To attempt to produce such plans could accordingly
impose a disproportionate additional burden on Departments.
12. Given this, and the information already published
under the CCD initiative, the Government does not think that Departments
can produce effective detailed management plans for all projected
secondary legislation, with such plans being centrally consolidated.
But the scope for plans of this nature will be kept under review
by Departments.
13. The Government acknowledges the Committee's
concerns regarding congestion at the Parliamentary scrutiny stage.
Every effort is made to give sufficient notice of debates on SIs
to enable the Committee to report before the debates take place.
A good working relationship has been established between the Government
Whips Office in the House of Lords and the Committee, which has
enabled both sides to show flexibility in the past year.
14. The Government acknowledges that there is
scope for improved management of the SI process in some Departments.
The Committee's Inquiry has been helpful in bringing this to the
attention of Departments. However, even with improved management
of the departmental SI process, the Government does not believe
it will be possible to eliminate completely congestion or bunching.
Departments make every effort to introduce their secondary legislation
within the Parliamentary calendar so as to allow for proper Parliamentary
scrutiny and approval. This approach is emphasised in the new
edition of Statutory Instrument Practice.
Recommendation 3: Departments should plan their
scheduling of SIs with common commencement dates in such a way
as to avoid the risk of congestion at the stage of parliamentary
scrutiny (Paragraphs 59-66)
15. The guidance on CCDs, issued by the Small
Business Service in the Department of Trade and Industry, gives
Departments clear guidance on dealing with SIs subject to CCDs.
It advises Departments that they must allow time for proper parliamentary
scrutiny. To achieve this it advises Departments to avoid laying
just ahead of the 21 day minimum period before commencement; to
avoid laying negative instruments in the summer recess; to allow
sufficient time for instruments subject to affirmative resolution
to be considered and reported upon by select committees before
any motion to approve can be moved.
16. The guidance also emphasises that good project
management and planning skills are key elements of the CCD process
and that all key stakeholders, policy divisions, legal teams and
parliamentary clerks should be involved in this process.
17. The Government believes that Departments
should follow the best practice advice and guidance on CCDs to
ensure effective scrutiny of the affected SIs by Parliament.
Recommendation 4: The Government should take action
to ensure that no instrument is laid before Parliament less than
21 days before it is due to come into force unless there are clear
and compelling reasons of operational urgency for such action
which are explained at the time of submission (Paragraphs 67-70)
18. The updated Statutory Instrument Practice
will remind Departments that the 21-day period for laying is a
minimum period and that, whenever possible, instruments should
be laid well in advance of this to allow Parliament to consider
the impact of the instrument. The examples highlighted by the
Committee of failure to comply with this rule of practice include
many instances where it was necessary to take urgent action and
where, had it not been, the Government would have been criticised
for the speed of its response. Such examples included preventive
measures for dealing with Avian Influenza, Food Import Emergency
Control Regulations, Export Control Orders, the application of
United Nations Measures and sanctions against overseas territories;
and instruments implementing Budget announcements where prior
notice could not be given.
19. Where departments are unable to comply with
the 21-day rule then the reasons for operational urgency will
be explained in the Explanatory Memoranda. This will be re-inforced
within the new edition of Statutory Instrument Practice.
Recommendation 5: Departments, when planning their
SI programmes, should, where possible, avoid scheduling instruments
for laying during the peak traffic periods of March, July and
December and, to facilitate effective scrutiny by Parliament,
the Government should stagger the laying of instruments which
must be approved by the ends of these periods (Paragraphs 71-74)
20. The Government shares the views of the Committee
regarding the desirability of minimising the bunching of instruments
during the peak traffic periods of March, July and December. Parliamentary
scrutiny of instruments is a key part of the process and departments
need to allow adequate time within their planning, including contingencies
to allow for slippage, to ensure that this occurs. Improvement
in the planning processes is a key issue for departments to address.
21. Even with improved planning it is unlikely
that periods of bunching will be avoided completely. There is
a need for much legislation to come into force at the start of
the financial year or at the start of a calendar year. Although
individual departments will, as far as possible, spread their
instruments, the tradition of holding the Budget near the end
of the financial year will mean that many instruments cannot be
laid other than during March. Additionally, part of the July peak
will be attributable to departments attempting to bring forward
into the period when Parliament is sitting the laying of instruments
which would otherwise be laid during the recess.
Recommendation 7: Departments should be given
guidance on best practice regarding the planning and management
of secondary legislation programmes and should be held to account
for their performance in this area (Paragraphs 80-81)
22. The Government acknowledges that Departments
should follow best practice in planning and managing their secondary
legislation.
23. Extensive guidance is currently available
to officials on the SI process. The documents listed below cover
the wide range of work undertaken by officials in the preparation
of a statutory instrument.
Statutory Instrument Practice
Code of Practice on Consultation
Regulatory Impact Assessment Guidance
Transposition Guide: How to implement European Directives
effectively
Common Commencement Dates Guidance
24. All of this guidance will be linked via the
new Statutory Instrument Practice section of the OPSI website
which is being developed by Her Majesty's Stationery Office (HMSO).
25. In addition to this, Departmental Lawyers
can access guidance materials and advice on drafting secondary
legislation through the Government Legal Service's intranet.
26. The Government does not feel that it is necessary
to further add to the available guidance. It is the Government's
view that prime responsibility for the management of the quality
and of the process of each Department's secondary legislation
should rest with the Department. In line with this, each Department
is best placed to promote and take forward best practice initiatives
in the planning and management of their secondary legislation.
Recommendation 8: The Government should develop
more robust mechanisms to ensure that the guidance which is issued
on SI planning and good regulation in general is more closely
followed (Paragraphs 82-83)
27. The Government does not believe that it would
be practical to have one Minister responsible for co-ordinating
secondary legislation across Government. Individual Secretaries
of State are responsible and best able to manage their Department's
secondary legislation.
28. The Government makes good use of several,
effective tools for ensuring good planning and good regulation
from Government departments: the Government insists on high-quality
Regulatory Impact Assessments (RIAs) from departments, the Government
scrutinises proposals by Ministerial committee, the NAO carries
out audits of RIAs and the independent Better Regulation Commission
(BRC) makes recommendations to Government on issues of better
regulation. Moreover, the Better Regulation Executive (BRE) works
closely with departments' Better Regulation Units and Board-level
Champions to ensure that guidance is followed.
29. The most robust mechanism is the need for
cross-government Ministerial clearance through the Panel for Regulatory
Accountability (PRA), chaired by the Prime Minister or the Minister
for Cabinet Office. All regulatory proposals likely to impose
a major new burden on business require clearance from the Panel,
the two exemptions being emergency legislation and tax matters
considered by the Chancellor in the course of normal budgetary
processes. The Panel's consideration is based on a thorough RIA
which has to have been agreed with the Cabinet Office BRE before
the proposal can be put to wider ministerial approval. The PRA
considers all such proposals in the context of the department's
previous regulatory performance and the burden of regulation across
key business sectors.
30. In terms of compliance with Statutory Instrument
Practice, HMSO will from 1 October report to departments on their
performance (e.g. in terms of compliance with the 21-day rule)
and will continue to monitor the Explanatory Memoranda which departments
prepare, drawing to their attention areas which in their view
do not comply with the Statutory Instrument Practice guidance.
However final responsibility for the standard and quality of Explanatory
Memoranda must remain in departments.
31. The Heads of the Government legal teams take
a keen interest in the SI process. Departments also seek to avoid
having any instrument reported on adversely by either the Committee
or the JCSI. Reports of both Committees are subjected to close
scrutiny and any lessons to be learned are promulgated either
via SI Practice Circulars or via the secondary legislation section
of the Government Legal Service's intranet.
Recommendation 9: The Government should take action,
via the BRE, to ensure that the 12-week consultation requirement
is met other than in exceptional cases and that, where there are
compelling reasons for breaching this rule, a clear explanation
is given (Paragraphs 85-86)
32. The Government agrees with the need to ensure
that the consultation requirements are met. The BRE already takes
action to achieve this. In addition to working on a day-to-day
basis with Departments on all aspects of Better Regulation, including
consultation, the BRE reports annually on compliance of these
consultations against the Code of Practice on Consultation.
33. The first criterion of the Code of Practice
on Consultation is that departments should consult widely throughout
the process, allowing a minimum of 12 weeks for written consultation
at least once during the development of the policy. The Code goes
on to say that departments should consider the specific circumstances
of their stakeholders and consider longer consultation periods
at certain times, e.g. during the summer holiday period. The Code
also states that where, due to exceptional circumstances, a consultation
period lasts less than 12 weeks this must be highlighted in the
consultation document, giving the Minister's reasons for this
and explaining the extra efforts taken to ensure the consultation
is as effective as possible. The BRE challenges departments when
any consultation exercise is considered to be below the expected
requirement. In 2005, 80% of the Government's consultations lasted
at least 12 weeks, representing an increase of four percentage
points on 2004.
34. Each government department has its own Consultation
Coordinator who is fully aware of the Code's requirements regarding
the minimum length of formal consultations and consultation exercises
which go beyond the minimum requirements are encouraged through
this network.
Recommendation 10: Consultation should be mandatory
for all instruments which seek to transpose EU obligations into
UK law, even where this is not required by the European Communities
Act 1972 (Paragraph 87)
35. Departments are already required to consult
fully on instruments implementing EU legislation, as stated in
the Code of Practice on Consultation.
36. Moreover, government departments are required
to carry out full impact assessments (except for when the legislation
imposes no costs or no savings or increases statutory fees by
a predetermined formula) when preparing to transpose EU law into
national law and the consultation of stakeholders is a significant
part of the RIA process.
37. The Cabinet Office has provided departments
with a Transposition Guide to encourage clear thinking about the
practicalities of implementing legislation right from the start
of the policy-development process in order to ensure that policies
are delivered in the most proportionate and effective way. This
guidance covers the need to consult on the various implementation
options.
Recommendation 11: - The Government should include
in its guidance to departments on the consultation process the
need, in appropriate cases, to ensure that there is adequate opportunity
for ordinary citizens, as well as representative groups, to make
their views known and should offer advice to departments on the
various means by which such grass-roots consultation might be
achieved (Paragraphs 91-93)
38. The Government is fully committed to ensuring
that consultation exercises are accessible to all relevant stakeholders,
whether citizens, businesses or charities and voluntary groups.
The importance of making special efforts to reach certain stakeholders
such as small businesses, children, consumers and those from minority
groups is emphasised in the Code of Practice on Consultation.
Suggestions in the Code of how to reach such groups include public
surveys, focus groups, regional events, targeted leaflet campaigns
and stakeholder meetings.
Recommendation 12: The Government should put more
impetus behind the process of consolidation and should aim, as
a general rule, to publish consolidated electronic versions of
each instrument following amendment (Paragraphs 94-99)
39. There is a distinction to be drawn between
formal consolidation—that is making new legislation—and
the publication 'informally' (that is without making a new instrument)
of an unofficial text of an instrument taking account of textual
amendments that have been made to it in subsequent instruments.
The key consideration as to whether an instrument should be consolidated
- whether formally or informally - is the convenience and ease
of comprehension for users. Consolidation can also make a major
contribution to better regulation.
40. The Government agrees that consideration
should be given to formal legislative consolidation, both in cases
where there are large numbers of instruments and amending instruments,
and cases where minor changes are made in the principal instrument.
The Government will therefore continue to dedicate resources to
the task of formally consolidating instruments where departmental
Ministers can identify appropriate cases.
41. In the past departments have sought to maintain
a balance between amending and consolidating instruments because
of concerns about the costs to the end-user who would be required
to purchase copies of larger documents on a regular basis. With
the increasing use of the internet, most users of statutory instruments
access legislation via the HMSO website. The former concern about
cost is thus much less significant now and this can be taken into
account in considering consolidations.
42. However the task of consolidation can be
a complex and resource intensive operation, involving not only
the mechanical task of applying amendments but also involves a
review of the policy objectives, a complete review of the drafting—including
ensuring the drafting language is up to date and the overall structure
of the instrument remains appropriate—and ensuring that
cross-references to other legislation remain correct.
43. The work on consolidating the Veterinary
Medicines Regulations by DEFRA, which resulted in the revocation
of 45 instruments and disapplied another 22 and resulted in everything
that needs to be known about the subject being contained in a
single set of regulations, is an excellent example of consolidation.
Similarly, in the case of the Criminal Procedure Rules, the DCA
consolidated 45 SIs into one instrument in 2005. The work currently
being undertaken by the Insolvency Service and DTI to consolidate
the various Insolvency Rules, Orders and Regulations, will similarly
reduce the number of instruments which cover this subject.
44. As regards informal consolidation, there
are some examples of "informal" consolidations being
prepared by Departments or their agencies. For example DWP publishes
on the internet and makes available for sale a very comprehensive
textual restatement of all social security and pensions legislation,
primary and secondary, known as "the Blue Books". Similarly
the Environment Agency publishes its "NetRegs" on the
internet. Departments have to be careful in publishing informal
consolidations, to prevent any possibility of accidental errors
occurring on which users might rely and to avoid generating any
confusion as to what is the authoritative text, but we are not
aware that significant problems of this kind have arisen hitherto.
Departments will therefore continue to identify opportunities
for informal consolidations, assisted by new technology, where
it is feasible to do so and where the additional resources required
are manageable.
45. The recommendation is consistent in its intention
with the Government's Simplification Programme. As the report
of the Committee notes, all departments are producing simplification
plans which explain how they will reduce the regulatory burdens
which fall on business, the voluntary sector and front-line public
servants. As part of the exercise, departments are considering
whether they can reduce that burden by providing greater clarity
on the content or interpretation of legislation. In some cases,
a change to the presentation of regulations (such as consolidation)
or a change to other supporting material (such as shortening or
redrafting guidance), may reduce the time it takes for a business
to understand and implement a statutory requirement. Where that
is the case (i.e. where there is a practical benefit from doing
so) departments should already include such measures in their
simplification plans.
Recommendation 13: Once a public database of statute
law is available, it should be extended as quickly as possible
to cover secondary as well as primary legislation (Paragraph 100)
46. The Government accepts the value of making
available a fully revised and updated version of all secondary
legislation via the Official Legislation website. This could best
be provided by extension of the existing Statute Law Database
project being taken forward by the Department for Constitutional
Affairs. The immediate priority is to ensure that a fully revised
and up to date version of the official statute book is delivered
for use by the public and that work on this is maintained. After
this has been achieved consideration will then be given as to
how work can be extended to updating secondary legislation.
Recommendation 14: To the extent that it is not
already departmental practice, SIs as a whole, and their Explanatory
Memoranda (EMs) in particular, should be subjected to review in
the course of preparation by a senior official who is sufficiently
detached from the subject in question to be able to assess its
intelligibility to the layman reader (Paragraphs 101-102)
47. The Government accepts that it is good practice
for Departments to assess whether the SIs and Explanatory Memoranda
which they produce are intelligible to the layman reader. The
method suggested by the Committee is one way in which this can
be done and will be drawn to Departments' attention.
Recommendation 15: Departments preparing SIs which
implement EU obligations should give particular attention to including
in their EMs a clear statement of the obligations which the instrument
in question imposes, of the penalties for non-compliance and of
the guidance which is available to those who will be affected
by its enactment (Paragraph 103);
48. SIs implementing EU obligations which will
increase costs have to be accompanied by a Regulatory Impact Assessment
(RIA) when submitted to Parliament and the RIA must detail the
communication strategy for informing those affected by the changes
the SI will bring about. The RIA, according to the Cabinet Office
guidance, should also set out clearly all issues relating to compliance,
enforcement and sanctions.
49. Cabinet Office guidance on writing RIAs states
that RIAs should be carried out when negotiating any EU legislation
or agreement that will have to be implemented in the UK: this
includes European directives, regulations, decisions, technical
adaptations to EU provisions, and joint positions and conventions
under second and third pillar cooperation.
50. The EM should also set out what guidance
the department is providing to users and stakeholders.
Recommendation 16: The guidance to departments
on consultation should reinforce the need for EMs to report the
outcome of consultation and to explain why legislation rather
than other forms of regulation is the chosen course for achieving
the required objective (Paragraphs 104-105);
51. Revised guidance on preparation of Explanatory
Memoranda makes it clear that departments "should set out
who was consulted, over what period and with what responses".
There should also be "some analysis of the outcome and the
Department's policy response to the opinions expressed".
Where appropriate departments should also refer to more detailed
analysis available on its website.
52. Further information on the consultation process
is also available in the Regulatory Impact Assessment.
53. The fourth criterion in the Code of Practice
on Consultation states that feedback should be given by Government
regarding both the responses received over the course of the consultation
period and how these responses influenced the policy. Departments
should provide a summary of the responses given and an explanation
of how the proposal will change in the light of the responses
received for each question asked. This information should then
be included in the RIA which is attached to the EM accompanying
all SIs laid before Parliament. Departments and departments' Consultation
Coordinators, and the BRE where appropriate, work together on
the development of RIAs including how the results of the consultation
exercise have affected the SI.
54. Under the heading "Rationale for Government
Intervention" Cabinet Office guidance says that RIAs should
detail alternatives to the proposed legislation to reach the same
policy outcome such as non-regulatory approaches. The RIA should
state why the draft legislation is deemed the most suitable approach
and how the findings of the consultation have impacted on this
decision.
Recommendation 17: The guidance which departments
are given on the preparation of SIs should emphasise the need
for officials to consider, in appropriate cases, how adequate
and timely publicity can be given to the implications for members
of the public of imminent secondary legislation (Paragraphs 106-107)
55. As a result of the revised Statutory Instrument
Practice and guidance on the preparation of Explanatory Memoranda,
Departments will be required to provide details of proposals to
disseminate information on secondary legislation and any accompanying
publicity plans.
Rec. 18 - The Government should review its guidance
on the avoidance of excessive implementation of EU Directives
to ensure that it is reaching and being understood by officials
who are engaged in the transposition of EU Directives into UK
law. More specifically, departments involved in preparing secondary
legislation for this purpose should consider carefully whether
parallel action is appropriate—for example, making compensating
adjustments to existing UK legislation or invoking any exemptions
from Directives which may be allowed—to reduce the risk
of over-implementation and whether less complex and burdensome
procedures, perhaps reflecting what is being done in other Member
States, might suffice (Paragraphs 109-111)
56. It is Government policy not to go beyond
the minimum requirements of EU legislation, unless there are exceptional
circumstances, justified by a cost-benefit analysis and extensive
consultation with stakeholders.
57. The Cabinet Office's Transposition Guide
includes recommendations on taking advantage of derogations
which keep requirements to a minimum, streamlining between new
and existing domestic regimes, and making comparisons with the
approaches to transposition taken by other Member States. Instances
of where departments go beyond the minimum requirements - "gold
plating" - have to be approved by the Panel for Regulatory
Accountability.
58. The Government recognises that the stock
of existing EU-derived legislation may include some legislation
which has not been implemented in the least burdensome
way possible. The Davidson Review is therefore working with
departments to identify and consider ways to simplify any
unnecessary burdens created by over-implementation of existing
EU-derived legislation. The review is due to report with recommendations
to the Government by the end of 2006.
Recommendation 19: The Government should ensure
that there is timely consultation with the business community
and others likely to be affected at the stage when proposed EU
Directives are being examined and that Ministers are fully sighted
at that stage of the likely shape and impact of the secondary
legislation which will be required to implement such Directives
once they have been approved (Paragraphs 112-113)
59. Consulting with the business community and
other stakeholders as early as possible is recognised good practice,
and as such is promoted across Government as a way of assisting
Ministers to determine UK positions on EU proposals. The Transposition
Guide states that before a proposal is published, departments
should carry out appropriate informal consultation with other
government departments and with external stakeholders. The Guide
holds up the DTI's VIPER Group (Vehicle Industry Policy and European
Regulation Group) as an example of best practice - this stakeholder
group, convened by the DTI, is made up of representatives of the
automotive industry and meets regularly to discuss emerging EU
regulatory proposals.
Recommendation 20: Departments, when they draw
up their plans for secondary legislation, should include against
each instrument a target date for post-implementation review and
the outcomes of such reviews should be reported when completed
(Paragraphs 114-115)
60. Post-implementation review is an important
part of the RIA process. According to the Cabinet Office's RIA
Guidance, the RIA should state how and when the review will take
place, which elements of the policy will be reviewed, the basis
of the review and the criteria for modifying or replacing the
policy. The RIA Guidance also says that stakeholders will need
to be consulted during the review and that, where possible, a
specific person should be named as responsible for conducting
the review.
Cabinet Office
10 October 2006
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