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Inspection on 23/02/09 for 121a Foxley Lane

Also see our care home review for 121a Foxley Lane for more information

This is the latest available inspection report for this service, carried out on 23rd February 2009.

CSCI found this care home to be providing an Excellent service.

The inspector found no outstanding requirements from the previous inspection report, but made 1 statutory requirements (actions the home must comply with) as a result of this inspection.

What follows are excerpts from this inspection report. For more information read the full report on the next tab.

What the care home does well

The home continues to show diligence with ensuring that the one current service user is supported appropriately in all aspects of their day-to-day living. This includes providing the necessary support that will enable them to be a part of the wider community and to have aspirations, expectations and goals. This is done within a clear risk assessment framework, which properly balances the right to freedom within acceptable risks without imposing unreasonable restrictions. The staff team are also diligent at making sure that protection from abuse is provided as much as can be reasonably expected. (this means that the staff at the home do everything that they can to stop any of the service users from being hurt by someone else). The managing organisation continues to have the necessary safeguards in place to ensure that thorough staff selection and recruitment occurs. The home has excellent systems in place to support staff and to make sure that they have the necessary support to undertake their work.

What has improved since the last inspection?

It is noted that no previous requirements were made at the key inspection that occurred in March 2007.

What the care home could do better:

The registered person must write to the Commission to outline their proposal to appoint a permanent manager who will be required to apply for registration. "Sense" should inform the Commission in writing of the plan to once again ensure that sufficient numbers of staff are qualified and also training and development plans should be present as the result of annual appraisals.

CARE HOME ADULTS 18-65 Foxley Lane (121a) 121a Foxley Lane Purley Croydon Surrey CR8 3HR Lead Inspector James Pitts Unannounced Inspection 23 February 2009 11:40 rd Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 1 The Commission for Social Care Inspection aims to: • • • • Put the people who use social care first Improve services and stamp out bad practice Be an expert voice on social care Practise what we preach in our own organisation Reader Information Document Purpose Author Audience Further copies from Copyright Inspection Report CSCI General Public 0870 240 7535 (telephone order line) This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI www.csci.org.uk Internet address Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 2 This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for Adults 18-65. They can be found at www.dh.gov.uk or obtained from The Stationery Office (TSO) PO Box 29, St Crispins, Duke Street, Norwich, NR3 1GN. Tel: 0870 600 5522. Online ordering: www.tso.co.uk/bookshop This report is a public document. Extracts may not be used or reproduced without the prior permission of the Commission for Social Care Inspection. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 3 SERVICE INFORMATION Name of service Foxley Lane (121a) Address 121a Foxley Lane Purley Croydon Surrey CR8 3HR 020 8645 0277 020 8645 0605 sara.baldesare@sense.org.uk www.sense.org.uk Sense, The National Deafblind and Rubella Association Manager post vacant Care Home 2 Telephone number Fax number Email address Provider Web address Name of registered provider(s)/company (if applicable) Name of registered manager (if applicable) Type of registration No. of places registered (if applicable) Category(ies) of Learning disability (2), Mental disorder, registration, with number excluding learning disability or dementia (1), of places Sensory impairment (2) Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 4 SERVICE INFORMATION Conditions of registration: Date of last inspection 13th March 2007 Brief Description of the Service: Foxley Lane is owned and managed by SENSE, which is a national charity that caters for people with a variety of sensory impairments and other disabilities. The home can accommodate a maximum of 2 service users with complex needs. The home is a bungalow type property that is set within it’s own grounds and yet is indistinguishable as a care home. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. The Quality rating for this service is 3 star. This means the people who use this service experience excellent quality outcomes. This inspection took place on a Monday morning, through to early afternoon. The one person who currently uses this service was at home and spent a little time communicating with the inspector, with staff support, during this visit. The person who uses this service finds it difficult to verbally communicate with staff or other people to let them know how they are and what they need. This person can let staff know in other ways, through improved and more regularly used signing, that they might want something or to express an opinion. The staff obviously know this person very well and recognise the ways in which this person does this. Observation and communication with this person did not indicate that they were in any way unhappy with living at Foxley Lane. Three comment cards were received from staff earlier last year, and although some views of necessary improvements were made at that time it is evident that subsequently these issues have been attended to. What the service does well: What has improved since the last inspection? It is noted that no previous requirements were made at the key inspection that occurred in March 2007. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 6 What they could do better: Please contact the provider for advice of actions taken in response to this inspection. The report of this inspection is available from enquiries@csci.gsi.gov.uk or by contacting your local CSCI office. The summary of this inspection report can be made available in other formats on request. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 7 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–5) Individual Needs and Choices (Standards 6-10) Lifestyle (Standards 11-17) Personal and Healthcare Support (Standards 18-21) Concerns, Complaints and Protection (Standards 22-23) Environment (Standards 24-30) Staffing (Standards 31-36) Conduct and Management of the Home (Standards 37 – 43) Scoring of Outcomes Statutory Requirements Identified During the Inspection Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 8 Choice of Home The intended outcomes for Standards 1 – 5 are: 1. 2. 3. 4. 5. Prospective service users have the information they need to make an informed choice about where to live. Prospective users’ individual aspirations and needs are assessed. Prospective service users know that the home that they will choose will meet their needs and aspirations. Prospective service users have an opportunity to visit and to “test drive” the home. Each service user has an individual written contract or statement of terms and conditions with the home. The Commission consider Standard 2 the key standard to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): Quality in this outcome area is excellent This judgement has been made using available evidence including a visit to this service. Standard 2 was assessed at this inspection. The service user can remain confident that the home will only care for people that the staff are trained and able to care for. EVIDENCE: The home has not admitted any service users since the previous annual inspection, as this is a specialist service for the one person currently living at the home who has been here for quite some time. Another person who used to be in residence left a few months ago to move to another service. The staff team are very mindful of the fact that should another person move in at a later date that this would need to be managed sensitively whilst remaining aware of the compatibility with the person who lives here at present. This standard will not be assessed again until such time as a new service user is admitted. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 9 Individual Needs and Choices The intended outcomes for Standards 6 – 10 are: 6. 7. 8. 9. 10. Service users know their assessed and changing needs and personal goals are reflected in their individual Plan. Service users make decisions about their lives with assistance as needed. Service users are consulted on, and participate in, all aspects of life in the home. Service users are supported to take risks as part of an independent lifestyle. Service users know that information about them is handled appropriately, and that their confidences are kept. The Commission considers Standards 6, 7 and 9 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): Quality in this outcome area is excellent This judgement has been made using available evidence including a visit to this service. Standards 6, 7 & 9 were assessed at this inspection. The service user can remain confident that the staff team continue to know what they need. They can also be assured that the staff will make sure that they are allowed and encouraged to live the sort of life that they meaningfully choose. EVIDENCE: The Care plan for the one person in residence is signed and agreed as it is changed and updated. A newly revised format for person centred plans is being introduced which seeks to make the care plan as increasingly accessible to the person as possible. This is highly unique, rather than merely a system, and clearly shows that the individual receiving support is at the forefront of the process. The previous key inspection noted that there was an ever increasing Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 10 success in the way in which support was being provided to the person who still lives at the home. This success continues and means that they have meaningful and beneficial opportunities to participate in their daily life, not only in the home but also in the wider community. The capacity of the service user to make decisions, and express their opinions, about how to manage the practical aspects of their daily lives continues to be effected by their disabilities. The detail of the service user’s care plan continues to demonstrate that diligent efforts are made to include this person as much as possible in making choices. Their more marked communication means that the ability and opportunity to make decisions is much improved. The home’s systems for managing service user’s money continues to be sound, two staff sign for any transaction made on behalf of the service user. It is the policy of the home that the service user must be present when purchases are being made on their behalf. The Registered Provider’s finance department also issues statements documenting how the service user’s money is spent. The continued and effective diligence that the home exhibits is not only of the necessary standard but is commendable in the way that service users rights are safeguarded. The extent of opportunities to make a contribution to the day-to-day running of the home and to the development of policies and procedures are again limited by the complexity of a person’s disabilities. Staff use observation of service user reaction, and improving communication, to anything new in order to establish their likes and dislikes about the things that happen in the home and other aspects of their daily life. During the monthly Regulation 26 visits the Responsible Individual makes sure that contact is made with the family, if possible, to include them in the running of the home. The home continues to employ diligent risk management strategies and risk assessment and minimisation is included into the guidelines that form a part of the care plan. Additionally the home continues to use extensive and very specific risk assessments drawn up in relation to involvement in a range of tasks and activities. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 11 Lifestyle The intended outcomes for Standards 11 - 17 are: 11. 12. 13. 14. 15. 16. 17. Service users have opportunities for personal development. Service users are able to take part in age, peer and culturally appropriate activities. Service users are part of the local community. Service users engage in appropriate leisure activities. Service users have appropriate personal, family and sexual relationships. Service users’ rights are respected and responsibilities recognised in their daily lives. Service users are offered a healthy diet and enjoy their meals and mealtimes. The Commission considers Standards 12, 13, 15, 16 and 17 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): Quality in this outcome area is excellent This judgement has been made using available evidence including a visit to this service. Standards 12, 13, 14, 15, 16 & 17 were assessed at this inspection. The person who currently uses this service can remain confident that the staff of the home will provide opportunities to develop their personal and social skills. This includes active support to participate in the community both in terms of the activities of daily life and leisure interests. EVIDENCE: The person who uses this service has access to a wide range of activities outside of the home such as swimming, weekly visits to a sensory room, weekly aromatherapy sessions (funded by SENSE), country walks and other such outings. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 12 The staff team ensure that this person has access within the local community as much as possible including meals out, trips to shops, pubs, the seaside etc. One to one staffing is always provided, and often two staff are required to ensure safe support, which does not pose a problem for the home to provide. The home continues to provide the necessary resources to expand on the opportunities for this person to engage in activities outside the home and to take the opportunity to try new things. This support continues to have a very marked and beneficial outcome for the person concerned. There are also a range of activities within the home including the use of music facilities, video and television. The garden continues to be very well maintained and provides a very pleasant space for outdoor activities. The service also has a people carrier type vehicle, which assists with activities and holidays being provided further away. However, the person who lives here continues to use public transport more than has ever previously been the case. This person also attends a weekly church service. SENSE provides a generous budget for the provision of activities and annual holidays. The home organise family parties so support the service user to have contact with a wide range of their families and friends. The home has more than sufficient space where the service user can receive their visitors in private. The opportunity for the person who lives here to be involved in daily living and domestic tasks can at times be limited by their disabilities. The staff support this person to engage in those tasks that are appropriate and that do not cause too much anxiety. Clear guidelines are available that inform the staff how best to maximise the opportunity to be involved, and this is another area where continued improvement and opportunity has successfully been achieved. This person also has a system installed in their bedroom where the lights dim to let her know when staff are about to enter her room and the staff are always expected to use this. The meals that the home provides are very much in keeping with the known preferences of the person who lives here. A variety of methods are used to gauge their particular likes and dislikes and to ensure that a healthy, nutritious and balanced diet is offered. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 13 Personal and Healthcare Support The intended outcomes for Standards 18 - 21 are: 18. 19. 20. 21. Service users receive personal support in the way they prefer and require. Service users’ physical and emotional health needs are met. Service users retain, administer and control their own medication where appropriate, and are protected by the home’s policies and procedures for dealing with medicines. The ageing, illness and death of a service user are handled with respect and as the individual would wish. The Commission considers Standards 18, 19, and 20 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): Quality in this outcome area is excellent This judgement has been made using available evidence including a visit to this service. Standards 18, 19 & 20 were assessed at this inspection. Service users can feel confident that they will get the right support to take care of their personal and healthcare needs. Anyone who needs to take medicine regularly to help them stay well will get the proper support from staff to make sure that this happens EVIDENCE: The staff are continually able to demonstrate that they are very aware of what the current service user needs and they are sensitive about how they should meet those needs. This person uses some technical aids and equipment to help them to be as independent as possible. The continually well written care plan tells the staff in great detail the way that this person wants to be cared for, supported and about what they do and do not like. Male staff do not provide intimate physical care to the female service user. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 14 The person who currently lives here is also encouraged to maintain some routine and is able to set their own bedtimes and getting up times. Staff at the home are continuing to have a marked degree of success with discouraging this person from remaining in bed all day, and this has expanded their opportunity to be involved in their day to day life. The person who lives at the home usually goes to see a local GP if they are not feeling well. The staff are very good at writing down anything that happens if this person becomes unwell. If this person were to develop signs of illness then the staff do know what this is and how to help them to get the treatment that they need. Body maps are used to document incidents of self-harming behaviour. These are monitored daily. The staff team are still very good at mapping any changes in mood to try to establish patterns of mood change and triggers for mood change. This demonstrates a continued understanding of this service user’s complex needs and a commitment to meeting those needs. The home has a policy and procedure for handling medication. All staff receive medication training as part of their induction training. The person who uses this service does need to take medicine every day and the staff are very good at making sure that this happens so that they can stay well. The staff are also good at making sure that no one can get hold of any medicine that they should not have and so they keep medicines locked away. The staff also make sure that medicines are handled properly to help to keep everyone safe and two staff are always involved in giving medication. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 15 Concerns, Complaints and Protection The intended outcomes for Standards 22 – 23 are: 22. 23. Service users feel their views are listened to and acted on. Service users are protected from abuse, neglect and self-harm. The Commission considers Standards 22, and 23 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): Quality in this outcome area is good This judgement has been made using available evidence including a visit to this service. Standards 22 & 23 were assessed at this inspection. The person who currently uses this service can feel confident that the staff team at the home continue to know what to do if there are complaints or concerns about abuse. The home has clear guidance for staff about the procedures to be followed in either of these circumstances. EVIDENCE: All person’s who have previously or currently made use of this service were / are given clear information about how to complain and what happens when they make a complaint. However, due to their complex needs and communication impairments the person who currently uses the service would find it difficult to make a complaint without the assistance of either an advocate or family member. It is noted that the one care manager and two family members who have made contact with the Commission are all very aware of how to make complaints if the need arose. No complaints about the standard of care have been made to either the home or to the Commission since the previous inspection. The staff team are good at making sure that they protect people who use the service from abuse (this means that the staff at the home do everything that they can to stop any of the service users from being hurt by someone else). There is also clear written information for staff about what to do if they think Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 16 that a service user is being hurt or abused by another person. The staff know what they then have to do to keep people safe. The home has a copy of the geographical authority’s local protecting vulnerable adults from abuse procedures, and staff are trained in how to apply these procedures. The home also reports any significant incidents to the Commission, as it is required to do. The home has made 1 protection referral since the previous inspection. The service responded to this in the most appropriate and effective way. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 17 Environment The intended outcomes for Standards 24 – 30 are: 24. 25. 26. 27. 28. 29. 30. Service users live in a homely, comfortable and safe environment. Service users’ bedrooms suit their needs and lifestyles. Service users’ bedrooms promote their independence. Service users’ toilets and bathrooms provide sufficient privacy and meet their individual needs. Shared spaces complement and supplement service users’ individual rooms. Service users have the specialist equipment they require to maximise their independence. The home is clean and hygienic. The Commission considers Standards 24, and 30 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): Quality in this outcome area is good This judgement has been made using available evidence including a visit to this service. Standards 24, 29 & 30 were assessed at this inspection. The person who currently uses this service can continue to feel confident that they are living in a usually well maintained and clean home. EVIDENCE: The home had an entirely new kitchen fitted in 2005. The bedroom of the person who currently lives here is laid out in a way that not only takes account of their particular needs but also very importantly, their own unique personality. The home is well maintained, well decorated and comfortably furnished, although it is acknowledged that some decoration will soon be needed and this has been planned to occur. In 2005 the home had new carpets fitted and softer furnishing that helps with the acoustics around the communal areas. The loop system in the lounge was again tested during this visit and was found to now not be operating properly. The day after this inspection visit the Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 18 home’s acting manager confirmed that approval had quickly been received in order to have this loop system replaced. The home was once again found to be clean and free from any offensive odours. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 19 Staffing The intended outcomes for Standards 31 – 36 are: 31. 32. 33. 34. 35. 36. Service users benefit from clarity of staff roles and responsibilities. Service users are supported by competent and qualified staff. Service users are supported by an effective staff team. Service users are supported and protected by the home’s recruitment policy and practices. Service users’ individual and joint needs are met by appropriately trained staff. Service users benefit from well supported and supervised staff. The Commission considers Standards 32, 34 and 35 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): Quality in this outcome area is good This judgement has been made using available evidence including a visit to this service. Standards 32, 34 & 35 were assessed at this inspection. The person who currently uses this service can remain confident that they are living in a home that gives proper consideration to recruiting only suitable people to work here. EVIDENCE: Recruitment is processed by SENSE with the Manager short listing and interviewing candidates with another SENSE manager. The file of two new members of staff were seen during this visit and all of the relevant documents were found to be in place. The home has just less than one part time staff vacancy at the moment. Bank staff and a small group of familiar agency staff cover for any vacancies, although this is more rare. The service is careful to only use bank staff that are known to the service user. Bank staff receive the same training and support as permanent members of staff. All new staff continue to be subject to a detailed induction programme that includes core training such as basic first aid, food handling, adult protection, Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 20 communication and SENSE core values. All staff completing the induction automatically progress to NVQ, although due to changes in the staff team the home now falls below the 50 minimum level of qualified staff that are required. For this reason “Sense” should inform the Commission in writing of the plan to once again ensure that sufficient numbers of staff are qualified. Staff training profiles are maintained in the home, although no training and development plans are present which they should be as the result of annual appraisals. Additional to the induction core training there is evidence of extensive focus on communication training with staff having access to training on working with deaf/blind people, Makaton, British Sign Language and Deaf awareness. All staff have training is Crisis Prevention and Intervention. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 21 Conduct and Management of the Home The intended outcomes for Standards 37 – 43 are: 37. 38. 39. 40. 41. 42. 43. Service users benefit from a well run home. Service users benefit from the ethos, leadership and management approach of the home. Service users are confident their views underpin all self-monitoring, review and development by the home. Service users’ rights and best interests are safeguarded by the home’s policies and procedures. Service users’ rights and best interests are safeguarded by the home’s record keeping policies and procedures. The health, safety and welfare of service users are promoted and protected. Service users benefit from competent and accountable management of the service. The Commission considers Standards 37, 39, and 42 the key standards to be inspected. JUDGEMENT – we looked at outcomes for the following standard(s): Quality in this outcome area is good This judgement has been made using available evidence including a visit to this service. Standards 37, 39 & 42 were assessed at this inspection. The person who currently uses this service can continue to feel confident that they are living in a home that is well managed both internally and by SENSE and that the necessary health and safety checks are properly carried out. EVIDENCE: The previous manager of the home took up a position as an area manager with SENSE and their registration as manger ceased in October 2008. Since then the deputy manager has been promoted as the acting manager. As this situation has been ongoing now for 4 months it is necessary for “Sense” to write to the Commission to outline their proposal to appoint a permanent manager who will be required to apply for registration. This acting manager Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 22 already has the NVQ level 3 qualification and stated that she will soon be commencing the NVQ level 4. The home continues to be subject to Sense’s quality audit system; this system is service user centred and fully meets the requirements of this standard. This audit is subject to regular reviews. The acting manager undertakes regular audits of all aspects of the running of the home. Each member of staff has designated responsibilities, their achievement of which is monitored through the supervision system. The Responsible Individual visits the home on a monthly basis. As part of these visits the Responsible Individual contacts representatives of service users to establish their feed-back on the service. The following health and safety checks have been carried out within the last year: Fire Alarm System: 23/09/08 Fire Extinguishers: 27/05/08 Gas Safety Check: 08/05/08 Electrical Installation: 19/09/02 Legionellosis: 08/05/08 Portable appliances: 24/04/08 The home is good at making sure that the people who live and work here are kept safe from fire and other hazards. Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 23 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Adults 18-65 have been met and uses the following scale. The scale ranges from: 4 Standard Exceeded 2 Standard Almost Met (Commendable) (Minor Shortfalls) 3 Standard Met 1 Standard Not Met (No Shortfalls) (Major Shortfalls) “X” in the standard met box denotes standard not assessed on this occasion “N/A” in the standard met box denotes standard not applicable CHOICE OF HOME Standard No Score 1 X 2 4 3 X 4 x 5 X INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 Score CONCERNS AND COMPLAINTS Standard No Score 22 3 23 3 ENVIRONMENT Standard No Score 24 3 25 X 26 X 27 X 28 X 29 X 30 3 STAFFING Standard No Score 31 X 32 3 33 X 34 4 35 3 36 3 CONDUCT AND MANAGEMENT OF THE HOME Standard No 37 38 39 40 41 42 43 Score 4 4 X 4 x LIFESTYLES Standard No Score 11 X 12 4 13 4 14 X 15 4 16 4 17 3 PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 Score 4 4 4 x 3 X 4 X X 3 x Foxley Lane (121a) DS0000028136.V373616.R01.S.doc Version 5.2 Page 24 No Are there any outstanding requirements from the last inspection? STATUTORY REQUIREMENTS This section sets out the actions, which must be taken so that the registered person/s meets the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The Registered Provider(s) must comply with the given timescales. No. 1. Standard YA37 Regulation 8 (1) (a) Timescale for action The registered person must write 31/03/09 to the Commission to outline their proposal to appoint a permanent manager who will be required to apply for registration. Requirement RECOMMENDATIONS These recommendations relate to National Minimum Standards and are seen as good practice for the Registered Provider/s to consider carrying out. No. 1. 2. Refer to Standard YA35 YA35 Good Practice Recommendations “Sense” should inform the Commission in writing of the plan to once again ensure that sufficient numbers of staff are qualified. Training and development plans should be present as the result of annual appraisals. 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