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Routine Re-Inspections
These are maintained at a steady pace on a systematic basis aiming at a reasonable
maximum coverage. During 1969 the proportion of premises on the register at the end
of 1968 which were re-inspected during the year was almost exactly 80%. It is anticipated
that with the present staff it will be possible to maintain a future re-inspection
coverage of 65 — 70% ensuring that every registered premises will be visited at least
once in each two year period.
Where contraventions are found to exist an informal notice is served, followed,
at reasonable intervals, by a reminder and finally, after Committee approval, a 14 day
warning issued by the Town Clerk and prosecution where necessary. Verbal warnings
in cases of comparatively minor infringements are, in our experience, not generally of
value. Personal interviews and persuasion are readily adopted to clear up misconceptions
and to provide technical advice but precise documentation of each step avoids
misapprehensions and disputes.
New Businesses
In the case of new or renovated premises or change of occupants, the aim is to
encourage consultation by the prospective occupiers with our staff before extensive, and
often expensive, work is carried out. Business executives or their consultants are aware
of the need to obtain approval of their proposals for Planning and Building Regulations
purposes but they are often surprisingly ignorant of the possible impact of the Offices,
Shops and Railway Premises Act (and in some cases the Food Hygiene Regulations)
upon their plans.
It is exceptional to receive an OSR 1 form prior to the opening of the establishment
and in this matter Section 49 has proved to be rather naively optimistic in its
phrasing viz: "Before a person first begins to employ persons" etc., he must supply
details on OSR 1. In consequence by far the greatest number of premises changing
hands are re-registered as a result of observation by the officer on his district or by a
follow-up to information of plans submitted for Planning approval.
Registration of Concessionaires
It is a not unusual practice for large departmental stores to grant concessionary
use, upon suitable terms, of parts of their sales floors to commercial firms as exclusive
retail outlets for their own goods or services. The concessionaires employ their own
staff directly at these sites but they are able to avail themselves of all the facilities,
amenities and privileges provided by the store for its own staff.
Some measure of protest was received from a few concessionaires when asked to
complete an OSR 1 as separate employers. It was considered that as separate employers,
occupying separate retail areas, albeit sharing premises, registration was necessary. A
number of concessionaires in a store could together employ a significant number of
employees who could not accurately be included in the total of store employees but
their numbers might have an effect on the required number of toilet facilties, the employment
of trained first aid persons, etc. In any event the provision of washing
facilities, toilets, etc., by the store may relieve the concessionaire of these obligations
but there are a number of requirements of the Act for which the concessionaires must
themselves accept responsibility within the area of their concession, e.g. Section 13 —
seating, Section 16 — safety, etc.
Part II — Operation of the Act
Temperature
The problem of maintaining a reasonable temperature arises each winter, more
especially in those shops where managerial policy firmly insists on the ever-open-door
as an invitation to customers. During periods of strong cold winds this practice often
makes it impossible to maintain a tolerable internal temperature and there is no doubt
that managers should be allowed greater flexibility in this matter.
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