Post legislative scrutiny of the Freedom of Information Act 2000

House of Commons Justice Committee Post-legislative scrutiny of the Freedom of Information Act 2000 2012.  

Its very revealing that the evidence includes a statement that it is now Government policy to destroy emails after 3 months unless selected for preservation.


This blog makes extensive use of information released by Authorities under the Freedom of Information Act, and the Environmental Information  Regulations.


The video provides a good insight into how Authorities deal with FOI requests  and how the move from the traditional system of files and the demise departmental registries to the modern system of electronic documents records management  has resulted in less effective record keeping.


Witnesses

1. Campaign for FOI, Unlock Democracy, and WhatDoTheyKnow
2. Professor Robert Hazell CBE, Director, Jim Amos, Honorary Senior Research Associate, and Ben Worthy, Research Associate, UCL Constitution Unit

The final report published July 2012


Committee FOI report page on the web

Defence Nuclear Environment Safety Board Annual Report 2010-11

In response to a FOI request the MOD published the Annual DNESB report for 2010-11.  The report yet again highlights the lack of adequate staff and resources to safely deliver the MODs nuclear capability.


The 2010 DNESB and earlier reports clearly demonstrate how the MOD has failed to allocated sufficient resources to nuclear safety in particular the lack of progress on recruiting and retaining suitably experienced and qualified staff.

The 2010 DNESB  report clearly  shows that MOD Ministers continue to ignore MODs internal nuclear Regulator and demonstrates the need for full civil regulation by the Office for Nuclear Regulation

Posts on this blog about  previous DNESB reports have highlighted lack of staff and resources as a significant risk to the safety of MOD's nuclear programmes.


Link to DNESB reports


Link to press report in the Guardian 


Link to a report by Rob Edwards

Dalgety Bay the Music Video

An interesting example of how issues involving radioaactivity enter popular culture and have the potential to go viral.

It should noted that its radium not plutonium at Dalgety Bay. But I sure that this detail will be lost for most people watching the video. What will remain is a lasting albeit wrong association of Dalgety Bay with Plutonium.

MOD provides no evidence that MOD follows best practice for the management of contaminated land

This FOI was submitted to the MOD following concerns raised about poor record keeping by the MOD relating to contaminated land and the MOD saying that it had in place a “robust, proactive programme mirrors industry best practice, ensures the land is suitable for use and will not cause harm to people or the environment”


“I note from a recent BBC news report into radioactive contamination concerns at RAF Kinloss MOD is quoted as saying "The MoD is committed to assessing land quality across the entire defence estate. This robust, proactive programme mirrors industry best practice, ensures the land is suitable for use and will not cause harm to people or the environment.”

"I note that MOD is a member of “Safegrounds” which has produced best practice guidance for the management of radioactive contaminated land.

Could you please provide me with the audit and compliance reports that demonstrate that the MOD meets this “ industry best practice”

Also you could please provide me with me with the audit and compliance reports that demonstrate that the MOD meets “SAFEGROUNDS Good practice guidance for land quality records management for nuclear-licensed and defence sites””

The MOD replied

“I can confirm that the MOD holds no information that falls within the scope of your request. I am advised that there are no requirements for the MOD to have audit and compliance reports in relation to the management of radioactive contaminated land.”  

“There is no requirement for the MOD to follow the Safegrounds guidance for land quality records management, therefore no audit and compliance reports exist”

Full reply.

The reply clearly shows that the MOD can provide no evidence to support it's statement saying that the MOD meets “best practice” and this by implication means there are no audit or compliance systems to demonstrate that it is meeting its own policy and standards for managing radioactive contaminated land let alone discharge its legal duty of care to protect man and the environment.

It is also interesting to note the MOD in JSP375 Volume 4 the MOD Safety Health and Environment Audit manual lays down the requirement for audits to provide assurance that health safety and environmental standards are being met. The reply to the FOI suggests that this requirement in so far as the management of contaminated land and “best practice” is concerned that the MOD is ignoring its own requirements for audit and assurance.

Refrences

Safegrounds Good Practice  Guidance  for the Management of Contaminated land on Nuclear-licensed and Defence Sites; version 2

Safegounds Good Practcie Guidance for Land Quality Records Management for Nuclear-licensed and Defence Sites