Submission - PAC Review of the Annual Report and Accounts 2023 - JHA Chief Officer response - 6 June 2024

19-21 Broad Street | St Helier Jersey | JE2 3RR

Deputy Raluca Kovacs

Lead Member

States Annual Reports and Accounts 2023 Review

By email only June 2024

Dear Deputy Kovacs

PAC Review - States Annual Report and Accounts 2023 Thank you for your letter of 3 June 2024.

Please see response to your questions as below:

Health and Safety Inspectorate (HSI)

1. What were the staffing conditions like for the Health and Safety Inspectorate (HSI) in the first half of 2023, and how did this impact their operations?

HSI is a small department with a full complement of 7 Full Time Equivalents (FTE) comprising a Director, 4 Inspectors, a Regulatory Officer and a Health & Safety Adviser. At the start of 2023 HSI had 3.4 FTE and a 75% vacancy rate.

With such limited resource the focus was primarily on reactive work (complaints and investigations) and particularly the complex joint investigation with States of Jerey Police into the tragic explosion at Pier Road in December 2022. HSI still continued with proactive work with telephone advice, reviewing asbestos plans of work, event safety (with the Bailiff s Panel), as well as advisory site visits.

2. How did the retirement of the Director at the end of April contribute to the challenges faced by the HSI in the first half of the year?

With the retirement of the existing Director at the end of April 2023, HSI resources dropped to 2.4 FTE, and a 75% Inspector vacancy rate. The focus remained on the complex major incident investigation as well as reactive work (complaints and incident investigations). The second quarter saw HSI meetings its complaint response targets but there were reduced proactive on-site inspections due to resource availability. Telephone advice, reviewing asbestos plans of work, dealing with defect reports, and the provision of advice to the Bailiff s Panel all continued.

3. What was the approach taken by the HSI to address the difficulties in recruiting experienced Inspectors?

As all HSI Inspectors are required to hold a post graduate diploma in health & safety regulation, a recruitment agency was used to identify potential candidates from the GB Health & Safety Executive (HSE). This resulted in the recruitment of a new Director and Inspector who started in June & July 2023 respectively. This bought HSI up to 4.4FTE and 50% Inspector resource.

The agency was unable to source the additional two Inspectors, largely due to there being increased recruitment within HSE which opened job opportunities for Inspectors without the need for a change of location, combined with the challenges of the cost-of-living in Jersey.

With the difficulty in recruiting to the full complement of experienced Inspectors from HSE the new Director, with my support, decided to recruit two trainee inspectors locally and train them through the Regulatory Training Programme (RTP) with HSE. The RTP is a three-year programme that combines both legal and health & safety training as well ongoing formal competency assessment. This is the pre-requisite training for the experience Inspectors HSI were trying to recruit.

The RTP training is paid via a salary increment progression that sees the trainees progress from G9.03 to G12 (the qualified Inspector grade) over the three-year training period.

4. How many trainee Inspectors were decided to be recruited and when is it expected for them to be in post?

A recruitment exercise commenced in July 2023 and two trainee Inspectors were appointed in October 2023 to bring the resource complement of Inspectors to 100%. The two trainees immediately commenced the RTP.

5. How do you anticipate the recruitment of trainee Inspectors will impact the operations and capabilities of the HSI in the coming years?

There was a recognisable short-term pain for long-term gain as HSI were operating at maximum training capacity with the experienced Inspectors joint visiting with trainees until they are assessed as competent to undertake solo visits to carefully selected work activities as part of their structured training programme. Both trainees have passed the six-month mark and are starting to solo visit, and their training continues with joint visits in accordance with the RTP.

The three-year training programme combined with on-going competency development should increase the amount of time an Inspector remains in post and operationally effective within HSI before seeking further career opportunities. The aim is to better manage Inspector turnover with a range of experience and time in post as far as possible to ensure continued effective operations.

The additional benefits of having trainee Inspectors undergoing regulatory training is that it ensures that the knowledge within the Inspectorate is current, it reaffirms legal good practice and assists with the ongoing competency development of the rest of the Inspectorate.

Jersey Customs and Immigration (JCIS) GST

1. What preparations were made for the reduction in the GST de minimis' from £135 to £60?

Prior to introduction, JCIS extrapolated qualitative data and analysed this to forecast the impact of the de minimis drop from £135 to £60. As a result of this work, funding was secured in the Government Plan to develop CAESAR (online goods clearance system) and to recruit additional staff resources to deal with the anticipated increased workload.

JCIS worked with a local marketing research company to map the process and use this research to identify areas for improvement to CAESAR. This resulted in significant enhancements to ensure CAESAR was more user friendly, with a particular emphasis on the removal of jargon and ensuring ease of use on mobile devices.

In addition to this, a large piece of development work was undertaken to ensure that consignments arriving on island from an online marketplace/ retailer who had collected GST at source would be automatically released on CAESAR, resulting in a seamless process for the importation of correctly manifested goods and removing the need for individuals to log on' and make a declaration.

Additional staff were recruited in both JCIS and Customer and Local Services to ensure public enquiries could be dealt with expeditiously.

Operationally, JCIS set up a working group for local shippers and other relevant stakeholders in the 18 months prior to the changes. Monthly meetings were held which ensured good communication on CAESAR development work, updates and timescales.

JCIS and Revenue Jersey also held separate monthly meetings with the large online marketplace/ retailers to ensure robust understanding of legislation and requirements. This group also worked together to ensure systems were developed in tandem which resulted in a seamless transition on Day One of the change for those offshore businesses who collect GST at source.

2. What challenges, if any, were faced during the implementation of the changes to the GST 'de minimis'?

Owing to the amount of preparatory work undertaken as above, challenges both prior to and on implementation were thankfully limited. One challenge was, and still is, the poor data entered at manifest level which results in difficulties with identifying consignments which have already had GST collected at source. This challenge is ongoing and one JCIS is working on to ensure that CAESAR can automate the process with a limited dataset whilst we also work with suppliers and shippers to ensure that manifest data is of a good quality.

3. How were stakeholders, such as businesses and consumers, informed about the reduction in the GST 'de minimis'?

The creation of the working group which included shippers and representatives of Jersey Business and Chamber of Commerce ensured there was a regular and frequent forum for communication. This was achieved with monthly Teams meetings.

Revenue Jersey also ran a media campaign in the months leading up to the change which used various media channels to inform consumers about the change.

Whilst the impact of the drop in de minimis was significant for JCIS operationally, it should be noted that the policy development and resulting change project was led by Revenue Jersey.

I trust that this provides you with the additional information requested. Should you require any further clarification please let me know.

Yours sincerely

Kate Briden

Chief Officer, Justice and Home Affairs