1. The “fitness to practise” criteria is very vague and it is not clear to us what objective standards the SSSC would be measuring against. At present they look at conduct within the context of whether the Codes of Practice have been breached. Whilst there is still a level of interpretation involved, at least practitioners can see what standards they are being measured against and can mount a defence on this basis.
2. Secondly it is the employer’s responsibility at present, through their clearly laid down and negotiated employment policies and procedures, to deal with concerns about a social service worker’s practice and to address any health concerns affecting a worker’s practice. We do not see how these new powers for the SSSC would fit with that. We do not think it acceptable for the SSSC to say that the public may be exposed to risk if they can take no action. This is to assume that the employer is not competent to deal appropriately with matters relating to an employee’s health or competence short of a breach of the codes of practice.
3. The proposed new model could cause confusion between the responsibilities of an employer and the SSSC.