Equality Impact and Needs Analysis (EINA) for the Street
Scene Enforcement Team
Directorate:
Environment
Service Area:
Traffic & Transport
Name of service/ function/ policy
being assessed:
Street Scene Enforcement Team
Officer leading on assessment:
Roland Copley – Street Scene Enforcement Manager
Other staff involved:
Justine Dalton – Performance & Equalities Officer
PREPARATION FOR THE EQUALITY IMPACT AND NEEDS ANALYSIS
1. Briefly describe the service/ function/ policy:
The Street Scene Enforcement Team (SSET) is responsible for ensuring that the London Borough of
Richmond upon Thames (LBRuT) remains as clean, green and safe as possible and to help combat
environmental crime. The SSET responds to complaints made by residents, organisations, Councillors
and visitors to the Borough, as well as carrying out daily inspections.
The SSET have powers that enable them to enforce current legislation – this can mean issuing
warnings, notices, fixed penalty notices and, if required, court proceedings against alleged offenders.
Areas that the SSET can take enforcement action include:
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Abandoned vehicles
Commercial waste
Domestic waste
Dog fouling and control
Fly posting
Fly tipping
Graffiti
Littering
Skips
Untaxed vehicles
2. Why is the equality impact and needs analysis being undertaken?
A service EINA has not been carried out in the last three years.
3. Has this service/ function/ policy undertaken a screening for relevance?
If so, which protected characteristics and parts of the duty were identified as of high
or medium relevance and why? Please attach screening for relevance as an
appendix to this EINA.
If not, make an assessment of which protected characteristics and parts of the duty
are of high or medium relevance and explain why:
Please see attached Screening for Relevance (Appendix 1)
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4. What sources of information have been used in the preparation of this equality
impact and needs analysis? For example, this could include equalities monitoring
information, performance data, consultation feedback or needs assessment. Please
provide the details in the table below:
Information source Description and outline of the information source
The Enforcement
Concordat
The Enforcement Concordat is a Code of Practice between the Government
and local Councils.
It sets out what businesses and others affected by regulation can expect from
the Council’s enforcement services.
Richmond Council has signed up to the Concordat, meaning all Council
services are committed to good enforcement practices and procedures.
Fixed penalty notices
This web page provides details of fixed penalty notice procedures.
Reporting a fault
Online form for reporting faults for all areas of Street Scene Enforcement.
ANALYSING IMPACT, NEEDS AND EFFECTS
It is important that the analysis addresses each part of the duty assessed as relevant to
the area being examined
5. Key questions to consider:
a. What does the data tell you about the groups identified as relevant to the area
being assessed?
b. What does customer feedback, complaints or discussions with stakeholder
groups tell you about the impact of the service/ function/ policy on the protected
characteristic groups, where assessed as relevant to area being examined?
Other questions to consider:
 How well are diverse needs met?
 Have any differences in access to services/functions been identified for any
group?
 Has the area identified any disadvantages experienced by groups, which need to
be addressed?
 Have there been any complaints about a failure to receive an appropriate and fair
service?
 Is there any other evidence of differential impact or different outcomes which
needs to be addressed?
 Is there any evidence that participation in areas of public life is disproportionately
low for any particular relevant protected characteristic group?
 Have the needs of disabled people been identified and addressed where these
are different from the needs of non-disabled people?
 Have you identified any need to tackle prejudice or promote understanding
between different relevant protected characteristic groups?
Remember that equality analysis is not simply about identifying and removing
negative effects of discrimination but it is also an opportunity to identify ways to
advance equality of opportunity and to foster good relations.
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Protected Group
Findings
The screening for relevance identified no impact in the following areas of the SSET:
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Abandoned vehicles
Commercial waste
Littering
Dog fouling and control – dog fouling is a nuisance to both residents and
visitors to the Borough. Dog fouling can also be dangerous, particularly to young
children, as they can contract serious illnesses such as Toxacariasis (round worm
infection) from dog faeces.
Fly posting – a potential impact has been identified, as some fly posts may be
considered unsuitable for children. The SSET will inspect any reports of such
posts and will obliterate the offending posters.
The Service Level Agreement for the removal of offensive posters is within one
day of notification.
Age
Fly tipping and unlicensed skips – Fly tips and unlicensed skips can cause
obstructions to public highways and for this reason they have been identified as
having an impact on ‘age’. Older people who may have mobility issues could be
affected by fly tips and unlicensed skips which block the public highway.
Graffiti – Please refer to fly posting as the SSET apply the same measures to
reports of offensive graffiti.
Domestic waste – Residents that place their domestic waste on public highways
are potentially causing obstruction to the public highway and this has a potential
impact on people with disabilities. Residents who do not manage their waste
properly could face enforcement action from the SSET. If a resident is warned
more than once, they may be issued a fixed penalty notice.
Disability
Fly tipping – Fly tips can cause potential obstructions to public highways and this
could be problematic to people with disabilities.
Unlicensed skips – LBRuT check that all proposed sites for skips are safe and
regulate the number of skips on roads at any one time. Skips are also checked to
ensure that they have reflectors and are lit after dark.
Unlicensed skips cause obstructions to highways and for this reason they have
been identified as having a medium impact on disability.
Gender (Sex)
No impact has been identified at this stage.
Gender
reassignment
No impact has been identified at this stage.
Marriage and civil
partnership1
No impact has been identified at this stage.
Sexual orientation
It has been identified that there is a high impact in the areas of Fly Posting and
Graffiti. Posters that are offensive to a sexual orientation will be obliterated from
property or land within one day of notification.
Formal enforcement action will be taken against identified offenders, whilst
persistent identified offenders will be prosecuted.
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Only in relation to the first part of the duty: eliminate discrimination and harassment
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Domestic waste – Residents that place their domestic waste on public highways
are potentially causing obstruction to the public highway and this has a potential
impact on people trying to navigate the environment with young children in prams
or pushchairs. Residents who do not manage their waste properly could face
enforcement action from the SSET. If a resident is warned more than once, they
may be issued a fixed penalty notice.
Pregnancy and
maternity
Fly tipping – Fly tips can cause potential obstructions to public highways and this
could be problematic to people with young children in prams or pushchairs.
Unlicensed skips – LBRuT check that all proposed sites for skips are safe and
regulate the number of skips on roads at any one time. Skips are also checked to
ensure that they have reflectors and are lit after dark.
Unlicensed skips cause obstructions to highways and for this reason they have
been identified as having a medium impact on this characteristic.
Race/Ethnicity
It has been identified that there is a high impact in the areas of Fly Posting and
Graffiti. Posters that are offensive to any race or ethnicity will be obliterated from
property or land within one day of notification.
Formal enforcement action will be taken against identified offenders, whilst
persistent identified offenders will be prosecuted.
Religion and
belief (including
non-belief)
It has been identified that there is a high impact in the areas of Fly Posting and
Graffiti. Posters that are offensive to any religion or belief will be obliterated from
property or land within one day of notification.
Formal enforcement action will be taken against identified offenders, whilst
persistent identified offenders will be prosecuted.
6. Have you identified any data gaps in relation to the relevant protected
characteristics and relevant parts of the duty? If so, how will these data gaps be
addressed?
Gaps in data
Action to deal with this
No gaps in data have been identified in this analysis.
SUMMARY OF THE KEY FINDINGS
7. Set out the key findings from the equality impact needs analysis of the service/
function/ policy. Key questions to consider when completing this section:
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Are there findings of unlawful discrimination?
Can you address any identified adverse impact?
Can you mitigate any negative impact?
Please provide rationale if you are unable to address any adverse impact.
Have you identified any ways of advancing equality in this area? For example,
meeting diverse needs?
 Is there a need for actions to promote understanding between different protected
groups?
No unlawful discrimination has been identified.
Due to the nature of the work undertaken by the SSET, it is not appropriate to collect customer
monitoring data. The team react to customer complaints and the findings of customer surveys (such as
the ‘All in One’ survey).
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CONSULTATION ON THE KEY FINDINGS
8. What consultation have you undertaken with stakeholders or critical friends about
the key findings? What feedback did you receive as part of the consultation?
Not applicable.
ACTION PLANNING
9. What issues have you identified that require actions? What are these actions, who
will be responsible for them and when will they be completed?
Issue
identified
Planned action
Lead officer
Completion
Date
No issues or actions have been identified as a result of this EINA.
MONITORING AND REVIEW
10. How will the actions in the action plan be monitored and reviewed? For example,
any equality actions identified should be added to business, service or team plans
and performance managed.
Not applicable.
PUBLISHING THE COMPLETED ANALYSIS
11. When completed, the equality impact and needs analysis should be approved by a
member of DMT and published on the Council’s website.
Approved by
Andrew Darvill, Assistant Director of Environment (Traffic & Transport)
Date of approval
25th June 2014
Date of publication
2nd July 2014
DECISION-MAKING PROCESS
12. Has a copy of this EINA or summary of key findings been provided to key decisionmakers to help inform decision making, for example as an appendix to a Cabinet or
Committee report?
 If so please provide the details including the name of the report, the audience
i.e. Cabinet/ Committee, the date it went, and the report author.
 Please also outline the outcome from the report and details of any follow up
action or monitoring of actions or decision taken:
N/A
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Appendix 1
Public Sector Equality Duty 2011: Screening for Relevance
Environment – Street Scene Enforcement
Telephone
Roland Copely – Street Environment
Email
Manager (Enforcement)
Name of Directorate
Contact
020 8891 7096
[email protected]
Service/ Function Are the areas listed below relevant to your service/ function?
1. Abandoned Vehicles
2. Commercial waste
3. Domestic waste
4. Dog fouling and
control
5. Fly posting
6. Fly tipping
7. Graffiti
8. Littering
9. Unlicensed skips
SO
GeR
P&M
M&CP
Eliminating discrimination,
harassment or victimisation
L
L
L
L
L
L
~
~
~
L
L
M
L
L
L
L
L
L
Advancing equality of
opportunity between different
groups
L
L
L
L
L
L
~
L
L
L
L
H
L
H
L
L
M
H
L
H
L
L
H
L
H
L
L
~
~
~
~
~
L
M
L
L
M
L
L
L
L
L
H
L
H
L
L
L
L
L
L
L
H
M
H
L
M
Disab’ Re&B
Age
Sex
Race
L
L
L
L
L
L
L
L
L
L
L
M
H
L
L
H
H
H
L
M
L
L
L
L
L
H
L
H
L
L
Fostering
good relations
L
L
M
Legend
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Age
Age
Sex
Sex
Race
Race
Disab’ Disability
Re&B
Religion and Belief
SO
Sexual orientation
GeR
Gender re-assignment
P&M
Pregnancy and maternity
M&CP
Marriage and civil
partnership