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The Forensic Science Regulator’s Consultation: Specific Issues
To help you get to grips with the specific issues raised by the Forensic Science Regulator in his Consultation Paper, this section lists the issues in which he
is particularly interested, together with some background information
and key considerations for each issue. We have tried to avoid biasing the
information in this section towards our own views (which you can
read in the
section if you wish), and crave your indulgence if you feel we have not
achieved complete neutrality!
After reading this, you can:
Paragraph 3.30
“In the meantime, all providers with any laboratory function will be expected to be accredited to ISO 17025. Any law-enforcement body with an in-house laboratory function will be expected to work to the same standard and to apply for ISO 17025 and/or ISO 17020 accreditation. This, along with the full adoption of the National Occupational Standards means that each organisation will have to maintain a high level of practitioner competence.”
The Regulator proposes that, pending the outcome of his work to create a single set of ISO-based standards bespoke to the use of forensic science in the UK, all providers (as distinct from practitioners) should be accredited to the existing ISO 17025 standard.
- Is the ISO route the best one to take?
- Is it correct to think that most of the organisations that would be covered by this provision have already achieved, or could readily achieve, the relevant ISO accreditation?
- Is the claim in para 3.31 – that forensic laboratories already spend up to 15% of operating costs on quality systems – true across the board?
- Is there any need to have some ability to transfer ISO 17025/17020 accreditation into whatever standard the Regulator develops, or should the two be kept separate?
Paragraph 3.36
“National Occupational Standards (NOS) - Are viewed by managers as an indispensable tool for managing a highly skilled workforce. They are used widely to support individual and organisational development and quality assurance at all levels. They provide benchmarks of good practice across the UK.”
- Have you heard of National Occupational Standards before now?
- Are they the useful tool the Regulator claims, or are they just more pointless bureaucracy?
- Have you any personal experience of NOS in action in your workplace? Do they work?
- If you are a small, independent provider of forensic science services, how are NOS relevant to you?
- Do you agree that NOS have “ensured that the identification of the skills, knowledge and understanding needed by forensic practitioners is far easier than has previoulsy been the case”?
Paragraph 3.40
“Skills for Justice recommend that NOS are used as a ‘common language’ and that they are the key test of practitioner competence.”
This is closely related to the previous issue.
- While it is natural for Skills for Justice to promote this view given their role in developing NOS, how true is it in practice?
- Have you found that NOS help you to communicate your skills and knowledge to colleagues, lawyers or the courts?
- Do those outside your immediate specialism understand your NOS, or do you use some other system for communicating your competence?
Paragraph 4.13
“The Regulator would welcome views on the current assessment and registration processes conducted by Council for the Registration of Forensic Practitioners (CRFP) to be sure that all views and experiences are heard and considered.”
- Have you any experience of the CRFP assessment procedures?
- Did you make a positive choice to get involved with the CRFP or to stay away? If so, what were the reasons you had for making that choice?
- Have you any evidence for the CRFP system working or failing?
- In your view, could the CRFP system ever prevent experts giving ‘poor’ evidence in court?
- Can you perceive of any system of accreditation that would prevent experts giving ‘poor’ evidence in court?
- If the Regulator's proposals are implemented, can you foresee a role for the CRFP in the new regulatory landscape?
Paragraph 8.3
“The Regulator takes the view that it is unnecessary and disproportionate to demand further levels of practitioner assessment through the CRFP process, and questions what additional benefits, if any, registration with CRFP can add.”
The Better Regulation Executive’s five principles of good regulation dictate that regulation should be proportionate and targeted.
- If the vast majority of forensic practitioners work within providers who are accredited to ISO 17025, a process that involves far broader assessment of competence within the context of the workplace, and with clear responsibility placed on in-line (senior) management, can the CRFP assessment of individuals add anything?
- What additional benefits, if any, does CRFP membership offer?
Paragraph 8.7
“It is important to recognise that individual competence is a product of the culture and quality management approach of the organisation in which someone works, as much as it is a reflection of individual ability. It seems logical, whenever possible, to assess individual competence within the overall assessment of an organisation. This is the standard adopted internationally for forensic science practitioners.”
- The notion that an individual’s performance is closely related to the workplace ethos feels right, but is this assertion correct?
- Is the competence of the individual best tested within the context of the organisation in which he/she works and its approach to quality management?
- Is there any objective evidence to support this view?
What next?
You can now:
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