West Dorset District Council Equality Impact Assessment (EIA) Form
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1 The purpose of the EIA: To ensure the service meet the general duty of the equality legislation to: Eliminate discrimination Promote equality of opportunity Make reasonable adjustments and promote positive attitudes for disabled people Promote good relations between people of different groups To ensure that equality is considered in the provision of services and employment, through: Equal opportunity Equal Access Equal treatment Types of discrimination described in the legislation that need to be removed are: Direct discrimination ie not employing or providing a service, because of a person s: age, gender, disability, race, colour, religion/belief, sexual orientation, marital status. Indirect discrimination: ie where someone is treated less favourably through the result of a policy requirement or the way services are delivered eg; housing provision for married couples only, holding public meeting in inaccessible. Victimisation and Harassment. If you are concerned that a particular group may be discriminated against, ie receiving a less favourable service, you can seek further guidance from Alan Muir (Legal) or Sarah Reeves (Equalities) After completing the EIA: Add all actions to the EIA Action Plan Present the EIA to the Customer Focus Group for discussion Send a final copy to Chris Churchill and Sarah Reeves Put the EIA actions into relevant service planning structures Attach the EIA Improvement Plan to relevant committee reports All EIA s will be reviewed at the Corporate Equalities Steering Group and through an external equality scrutiny group that is being set up in 2007/08. NB: Invite key officers to do an impact assessment with you- do not do one on your own. This form is guidance only, to help shape the discussion during the assessment only fill out sections that are relevant to you. The Action Plan must be completed and copies sent to Chris Churchill and Sarah Reeves. Write a summary of each EIA, this will be published on the Dorset for You website. 1
2 Title of service, function or policy being assessed: Name and role of officers completing this assessment: List the name of the provider if the service is tendered out: Don t duplicate if you can link this assessment with an existing review/assessment of your service do so. Date of Assessment: October 2008 Environmental Health Service Sarah Ward (service manager), Graham Duggan (Team ) Sarah Reeves (equalities officer) 1. Is this a new policy/function/service or a review of an existing one? Review of an existing service - Environmental Health Service Food Safety Workplace Health and Safety Pest Control Dog Control Nuisance regulation: Noise etc Air Quality Contaminated Land remediation Private Water Supplies (800 households registered) Policies/procedures in place: Enforcement Policy Food Service Plan Contaminated land Strategy Noise pollution procedures Accident investigation procedures Air Quality Generic areas of work: Regulation: enforcement, inspections, information 2. What are the aims and objectives of the policy/function/review? Aims of the service: Fulfilling statutory duty Objective: To protect human health and the environment. 3. Who are the main beneficiaries? who else will be affected? Beneficiaries: Householders, members of the public, business owners Who else is affected: Older people and/or with mental health problems (infestation and virulence) Housing Associations eg: Magna Housing Association Tenants 2
3 Police (Deal with out of hours noise complaints) Environment agency PCT 4. What needs or priorities is it designed to meet? Mainly statutory services to maintain and improve the public health needs of the community 5. In relation to this policy what do you think are the main issues, positive and/or negative relating to the different equality groups: Consider the 3 steps to Equality: Opportunity, Access and Treatment Race/ethnicity: (this includes Gypsies and Travellers Cultural Differences (Food team) awareness low Communication / lanaguage Share Magna housing results from survey. Gypsy/Travellers: - Dog control / stray dogs, link with gypsy and traveller liaison officer at County Disability: (this includes the wider definition of disability, ie a long-term condition that affect a person for more than 12 months. Physical mobility access? Older people with hearing impairments Complaints of low frequency noise often undiagnosed tinnitus. Mental health and domestic noise Action: GD/SR - look into better referral systems with Age Concern, MIND to help people who suffer or cause domestic noise. Learning Disabled - Issues with amplified noise or comprehension of noise pollution. The service operates as a one size fits all in terms of correspondence eg: letters, warnings, information. Action: GD add a line in a complaint form to ask if the noise perpetrator has letter has any special circumstances? Action. GD& Comms team to Review standard letters and consider producing easy read and Plain English versions. Eg letters for domestic noise Gender: (male, female, transgender) - n/a Sexual orientation Fair treatment links to training and monitoring of service users Religon/Faith or belief Fair treatment links to training and monitoring of service users Age: (currently only applies to employment) Older People 3
4 Less capable of looking after themselves Pest problems Dog control notices service delivered in the day. Low frequency noise and mental health. Single parents poor quality housing - noise insulation. (link to housing service. Young people and music is a common complaint. Do young people know they can complain? - use relevant marketing publicity to inform young people. Rural isolation / deprivation / other issues to consider: Poverty: Pest Control radical overhaul of charges free for people in hardship need to define hardship promote service Consider child protection when officers visit homes ensure officers are trained in child protection training. 800 homes registered with private water suppliers - testing water quality / poor housing quality / knowledge/access to the service promote service 6. How does the current or proposed policy/service meet the needs of the six equality strands? If it doesn t where are the gaps? Please include the findings in the attached improvement plan. 7. Are there any aspects of the policy that result in different quality outcomes for different groups eg: higher/lower update, complaints, poorer/inferior service? Disproportionate number of people with a hearing or mental health disability with an enforcement order for noise pollution Need to review enforcement policy to consider relevant disabilities in assessing noise complaints. Work with key agencies eg: mental health teams, Learning Disabled Partnership Board, Case workers, Dorset Advocacy. Outreach work with schools is well received eg: health warnings on noise pollution for young people leading to tinitus and hearing loss. Dog Warden service a few complaints changing control times eg: evenings and weekends. Action to rewrite the procedures and standard letters in plain English. Consider using Easy Read Symbols, Ensure the strapline This document is available in alternative formats is in large print Take to the CFG. Action: Set up system to monitor enforcement orders and complaints officer self categorise equality monitoring data. 8. What does data from existing sources tell you about the current policy/service in terms of meeting the needs of the different equality group? What does consultation with beneficiaries tell you? Your sources could include: census, ODPM baseline study, CPA, Employee surveys, bi-annual residents survey. Existing Data available: Domestic Noise - No profiling of complaints done via data sources. 4
5 The detail comes from officers experience of complaints. (set up monitoring system) The profile is often older people with hearing impairment or an increase of noise by living next to a family, or complaints by people with mental illness or living next to someone with a mental illness. Officers work with mediation centre, eg with domestic Noise Links wddc community safety team could lead to the ASB route Dog Warden Profiling was done but analysis not finished due to SNAP problems. (Set up Monitoring system) Enforcement tends to be on older people between 8-5pm, the time that officers work and the way the service is designed (refer to the contractual work). Scrutiny Committee Review of Environmental Protection 2007 identified areas for improvement, rolling sampling and increased resources for this service, Customer Satisfaction form sent to every Domestic noise complaint Customer Satisfaction Dog Warden Questionnaire Pest Control Customer Satisfaction last year, The programme SNAP software breakdown failed to provide the analysis of equality data for customers for this customer satisfaction surveys. The Dorset Health and Safety Group are doing a lot of work around Migrant Workers Action: use the new International Workers web portal to link environmental protection services, esp Housing services. Audit of private water supplies ask every household if they have a private water supply (could equality data be collected here?) Database systems of complaints details of complainees Follow up monitoring form: o for noise o 2006 pest control (good satisfaction / no difference) o Dogs Dog control orders Input database Benchmarking? Yes A benchmarking exercise was done in 2005 with the other Dorset Councils responsible for environmental health Scrutiny report identified issues in the service structure with recommendations. 9. What gaps have you identified, from questions 7&8, and what further data/consultation do you need to carry out if any?. Please include the actions in the attached improvement plan. Access to pest control linked to income disadvantage market service to wider community: Set up monitoring system for warnings, enforcements, complaints. Programme in analysis of data from SNAP or other programmes. 5
6 10. In what way(s) might this service or policy have an adverse impact on the grounds of race/ethnicity, disability, gender, age, religion/belief, sexual orientation. adverse impact means that the policy/service is disadvantageous to one or more groups of people. Disproportionate number of disabled people with noise pollution enforcement orders Disproportionate number of older people with offences with the dog warden service Disproportionate numbers of low income families and younger people using the services eg: pest control and water testing. Action: Changes are already in place to make changes to these services - see improvement plan 11. If you have identified that the service/function is having, or might be having, an adverse impact, is it justifiable or legitimate? Please give your reasons for this. 12If you have concluded that the adverse impact or the discrimination is justifiable or legitimate, you will need to explain your actions and reasons to people. This is because we have a statutory duty to promote equality of access, opportunity and treatment of other people. You will need to think what action could be taken to mitigate the adverse impact on people. Please include the actions in the attached improvement plan. 13. If you have concluded that there is an adverse impact and discrimination which could be illegal, speak to Alan Muir in legal and Sarah Reeves in Community support. You must take action to remedy this immediately. Please outline the action you will be taking and include it in your improvement plan. 14. Please outline any unmet needs you have identified as a result of carrying out this assessment and how you intend to address them. Please ensure this is included in your improvement plan. 6
7 Improvement Plan Issue Identified Action required Budget allocation Access to service: Develop a marketing Strategy for pest control linked promoting Environmental Health services to income to those on low income, disabled, low disadvantage literacy levels, young people. young people less aware Disabled residents disproportionate number of complaints/ enforcement orders Market service, use posters and leaflets that cross reference services eg: through benefits service, HRSA, ASBO, community safety, housing service. Look into better referral systems with support agencies eg: Age Concern, Learning Disabled Partnership Board, MIND Officer responsible - EH Team - EH Team By when July 09 April 09 Add a line in the complaint forms to ask if the perpetrator has any special circumstances. Review enforcement policy to consider relevant disabilities in assessing enforcement approach Customer profiling Disproportionate number of people from Set up monitoring system for all services for enforcement orders and complaints based on equality data where possible Review standard letters, orders in plain English and/or Easy Read Symbols - EH Team - EH Team April 09 February 09 7
8 equality strands and income disadvantage using the service. Update training needs Improving the service Timetable officers to undertake child protection training, mental health training and equality awareness training. Cross reference the service with other services eg: housing advice, home improvements grants, - Community Protection Manager EH Team January 09 April 09 Work with support agencies around case work support and advocacy service. Link with Community safety Advocacy project. Any consultation exercise should follow the guidance provided by Chris Churchill, Corporate Performance Manager. Next Steps: These actions need to be built into the service planning framework, with SMART targets. A copy sent to the Chris Churchill (performance) and Sarah Reeves (Equalities) 8
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