Based upon the previous steps (describing the context, setting priorities and defining objectives and strategies), the inspecting authority should then develop its inspection plan and inspection programme. The inspection plan can be seen as a strategic plan and does not contain operational information (e.g. does not include the planned and type/dates of inspections). The review and revision of the inspection plan is also part of this step. When we continue the process, after step “Performance monitoring”, we return to this step. Based upon the monitoring and evaluation of the inspection plan (including the inspection programme), it will be reviewed and possibly be revised.
An inspection plan describes:
- The objectives that the Inspecting authority, given its mission and tasks, wants to achieve;
- The policy, environmental, legal, organizational, financial and other relevant conditions under which the inspecting authority has to perform its inspection activities;
- The strategies which the inspecting authority has adopted for performing its inspection activities;
- How priorities with regard to inspection activities are set, taking into account these objectives, conditions and strategies;
- The priorities themselves;
- And the additional items described in Article 23 of the IED.
The general public has the right to know what the inspecting authority has planned for the defined period (it should be transparent) and the plan should therefore be available to the public. However the inspecting authority may choose to withhold part of the plan (e.g. the Inspection Schedule). This could be typically due to the inclusion of unannounced Inspections or other unannounced enforcement actions which must be without warning in order to be effective.
The inspection plan will be used to compile the inspection programme. This programme should include information such as names of installations, dates, type of inspections, inspectors assigned, etc.
When developing the inspection plan and inspection programme it is necessary to consider the organisational, human and financial circumstances. Most importantly the inspection plan and the inspection programme should be in balance with the available resources and budgets and should be in line with the organizational structure.
See factsheet 3.07 to find the required element for an inspection plan.
Review and revision
The inspection plan should be reviewed and if necessary revised periodically. In evaluating the success of the inspection plan the inspecting authority should determine the extent to which it achieved the objectives and targets set out in the plan. Where they have not been met the inspecting authority should determine the factors that have impacted on the completion of the tasks. As the inspection plan is a more strategic document it is envisaged that revision may only be required in response to significant changes to policies, significant changing activity in given industrial/work sectors, or other changing situations. However, changes to the plan may also be made as a result of performance monitoring.
Where performance targets set are met (or not met), or where efforts expended through the inspection plan have not resulted in the expected improvements to the state of the environment, the authority may also wish to change the inspection plan (e.g. to change the strategy to be employed, the resources to be assigned, or the objectives/targets set).
For the revision of the inspection plan the authority should go through the steps in the strategic cycle. When only the inspection programme has to be revised, revision of the entire plan may not be necessary (e.g. where the only change is to the number of planned inspections to be carried out – i.e. changes in desired output). The inspection programme however will normally change on an annual basis.
The requirement to revise and evaluate the implementation of previous plans in order to develop the plan for the coming period is the application of a management systems approach. In defining the priorities and targets within the inspection plan, the inspecting authority should put in place the means to track and evaluate their performance with respect to the plan. The inspection plan should contain the targets to be achieved during the year to allow for ongoing evaluation of activities during the execution of the plan. In addition to the numerical targets inspecting authorities should also consider how they are going to evaluate performance in relation to the priorities that they set in their plans so that the environmental outcome of their activities is checked in addition to the activities themselves.
Output: inspection plan and inspection programme