Think Local, Act National
Case Study: Welsh National Enforcement Priorities
Trading Standards Accreditation to Issue Penalty Notices for Disorder
Wales Heads of Trading Standards
The Issue
Enforcing legislation outlawing sales of alcohol to those under-18 years old has long
been one of the more sensitive areas of Trading Standards enforcement. This is partly
because of the underlying health issues, but also because of the powerful connotations
underage sales have in terms of hoodies, binge-drinking and anti-social behaviour in
general.
At the same time, enforcement can be a time-intensive activity, involving Police,
volunteer, as well as Trading Standards resources. Add to this the fact that the practice of
selling alcohol to underage drinkers is fairly widespread – a Home Office report, albeit
from 2004, found that just under half of 16-17 year olds had successfully bought alcohol
from shops in the past 12 months1 – and it is clear that marrying effective enforcement to
efficient use of limited resources is an ongoing challenge.
The Response
Launched in January 2006, the Government’s Respect Agenda hoped to tackle antisocial behaviour and its underlying causes. Among the headline-grabbing intentions
around parenting, schools and communities though, almost tucked away on p32, was a
pledge to:
‘Make it easier for Trading Standards Officers to issue Penalty Notices for Disorder
(PNDs) to people who sell age restricted products such as alcohol to children.’
In effect it opened the door to Trading Standards Officers to gain greater powers of
enforcement, without the ongoing need to call on Police Officers to be present ‘just in
case’ someone is caught selling alcohol to a minor. The change in legislation enabled
Weights and Measures Inspectors to much more easily and efficiently become an
‘accredited person’ for issuing such PNDs by applying to the local Police Chief
Constable. The potential benefits were clear:
1
Underage drinking: findings from the 2004 Offending, Crime and Justice Survey; Home
Office, 2006
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
Trading Standards Services could operate much more nimbly and independently in
terms of test purchase activities, without needing to have Police presence every
step of the way.

Police resources were consequentially saved to focus on other priorities, without
any loss of enforcement effectiveness.

The licensing trade would also benefit, from a fairer and more transparent system
where they would be treated the same regardless of whether enforcement was by a
Police Officer or Trading Standards Officer.
There would still be a robust degree of due diligence to go through – after all, the Police
wouldn’t want to hand out accreditation to just anyone – but the way was now clear to
secure a step-change in the efficiency of test purchase activities.
Local Authorities in Wales took advantage of this opportunity, and five years later the end
result is that there are now around 70 accredited Trading Standards Officers across 18 of
the 22 Local Authorities in Wales, each able to issue Penalty Notices for Disorder (PNDs)
without the need for an accompanying Police Officer.
Importantly though, an initiative that started locally (five Trading Standards Services and
Gwent Police) has quietly but quickly become a national scheme for Wales – the first of
its kind in the UK.
How It Was Done
Led by Helen Picton, now the Service Manager for Trading Standards at Bridgend
County Borough Council (but also the Wales Heads of Trading Standards (WHoTS) Lead
Officer for Age Restricted Products), the five Local Authorities within the Gwent Police
boundaries approached the force in July 2007, with the proposition of creating a Gwent
Community Safety Accreditation Scheme (CSAS). Mindful of the potential benefits in
terms of its own resources, Gwent Police was supportive of the idea.
Although the intention of the legislation was to ‘fast track’ accreditation for Trading
Standards Officers (Weights and Measures Inspectors), there was still a need for a
formal framework to be set up for the scheme to work effectively. There were four key
elements to this:

Creating the Gwent CSAS – the Chief Executive of each Local Authority signed-up
to the Scheme on behalf of the Authority, giving the agreement a stability and
credibility reinforcing that of individual Trading Standards Officers.

Suitability checks – for the Chief Constable to issue accreditation he or she must be
satisfied the individual meets two criteria. The first is ‘suitability’, that the person is
suitable to exercise the powers given to them. To meet this the people nominated
by their Authorities and friends and families were subject to criminal record and
other checks.

Competency checks – the second criteria is around competency, that the
individuals have received adequate training. To meet this Gwent Police and the
Trading Standards teams developed a day-long training course explaining the
powers and their limits.
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
Creating the administrative framework to support the Scheme – to ensure that
accredited Trading Standards staff would be ‘recognised’ by the Police system; that
copies of issued PNDs are returned promptly to the central ticket office and that the
necessary information relating to each offence dealt with by way of a PND is
entered onto the Police National Computer within 24hours.
Once the framework was set-up the policy could start being put into practice, and in
November 2007 a total of 23 Trading Standards Officers from the five Local Authorities
were accredited to issue PNDs for underage sales of alcohol.
There is of course still a very close relationship between Trading Standards services test
purchase activities and Gwent Police, in terms of communication and sharing
intelligence; the big difference is now that Gwent Police do not have to devote Officer
hours to accompany every test purchase exercise.
However, while Gwent Police had been very receptive to the idea of an accreditation
scheme, other forces in Wales were a little more reticent when their Local Authorities
independently suggested similar plans to them, unsure of what this would entail in
practice. This changed once the Greater Gwent scheme was up and running, and
through the determination of the WHoTS Lead Officer the other three Police Forces in
Wales were brought on board. What was a local scheme was now going to be a national
one.
The idea was simple – Gwent Police would run the Wales accreditation scheme on behalf
of the other three forces (Dyfed Powys, South Wales and North Wales). This would build
on the expertise of the Gwent participants in developing the scheme, at the same time
avoiding the duplication of effort involved in four different forces operating four different
schemes. It also meant the other Forces could sign up to the scheme without needing to
worry about allocating scarce resources to it.
Over the course of the next year or so another 13 Local Authorities signed up to the all
Wales Community Safety Accreditation Scheme (CSAS), and Gwent Police toured their
training package around Wales on a force-by-force basis. A total of over 70 Trading
Standards Officers are now accredited across Wales.
Alcohol sales at retail premises (all Wales)
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Measures of Success
In principle the benefits would seem clear – particularly in terms of saving of Police
Officer time. WHoTS’s One Year Evaluation of the scheme produced evidence confirming
that this was indeed the case.
In 2009-10 Trading Standards staff were in a position to issue a PND if an underage sale
had occurred on 331 occasions, many of which instances would previously have involved
a Police Officer being present. With average annual costs of a Police Officer estimated to
be £54,5002, the savings are clear.
On top of this is the less tangible benefit of the greater flexibility Trading Standards teams
now have when arranging test purchase exercises.
The introduction of accreditation to offer PNDs is just one of the many initiatives
aimed at deterring under-age sales, but the evidence does suggest that the overall
effort (which includes for instance publicity campaigns, proof of age cards and
training for licensees) is having an effect. Underage sales of alcohol at retail
premises in Wales are trending downwards, as the chart above shows 3 (although
sales at on-licensed premises stubbornly remain a problem).
What Now?
The current accreditations last for two years, and then individuals have to be reaccredited. As a result the process is ongoing, although with all of the Local Authorities
involved speaking positively of the benefits or potential benefits it brings, the hope is that
it will become a long-term feature of the Trading Standards landscape in Wales.
Overall the accreditation scheme would seem to be a success, and an innovative one at
that. Perhaps most impressive though is the degree to which the determination of a small
team, fuelled by a belief in the powers of collaboration, helped a local scheme be
efficiently and successfully rolled-out to a National one.
Our thanks go to Helen Picton, Service Manager for Trading Standards at Bridgend
County Borough Council, for help with compiling this case study.
2
3
Sustaining Value for Money in the Police Service; Wales Audit Office, HMIC, and Audit
Commission; July 2010
Report on Underage Sales of Alcohol in Wales 2009-10; Wales Heads of Trading Standards;
October 2010
Local Better Regulation Office
[email protected]
www.lbro.org.uk
0121 226 4000
CS13 / May 2011
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