It seems that Labour’s commitment to rethinking Ofsted’s role in safeguarding inspections has been broadly welcomed by the sector. 

Certainly, plenty of leaders have offered cautious support, though not all.

Labour’s proposal is to “introduce a new annual review of safeguarding, health and safety, attendance and off-rolling”.

The most common reason for supporting this approach seems to be that it’s seen as a way of taking heat out of inspection, and it’s easy to follow that logic. 

Ofsted inspection process

Given a school could be doing lots of things well and would otherwise be judged good or better, the fear of an unexpected downgrade on the basis of a relatively minor or procedural safeguarding issue - especially when it would be easily resolved - is understandable. 

From the school’s perspective, separating safeguarding from the rest of the routine inspection framework is a way of offsetting this risk. The school could still be seen as “good” in the normal inspection carried out at four-year intervals, while being given some pointers for improvement in the annual safeguarding review. 

But if we probe a bit deeper, there might be some unintended consequences lurking beneath the surface. The following are things that a Labour government - and the profession - would need to think carefully about if this policy is taken forward.

Logistics  

Perhaps the most pressing considerations are who would do it, and how much it would cost. 

Assuming the plan is that each of England’s approximately 20,000 schools would be visited each year, and that schools would continue to receive routine full or ungraded inspections every four years, this means that in an annual period, the number of inspection activities might multiply by as much as five-fold. 

While some of this might be offset by the fact that other inspection activities could be streamlined, it is hard to see a scenario where this does not lead to a significant increase in inspection activity, which would mean many more inspectors. This would require a much larger budget. 

Opting for this, then, would be an interesting prioritisation in the face of frontline funding challenges in schools, and would need a compelling narrative. 

You’ll note I haven’t yet said it would be done by Ofsted, but that seems like a certainty. 

Others have suggested an alternative agency could be set up, but to do this would risk losing the benefit of the expertise that Ofsted already holds in these areas. It would also likely be a more expensive way forward. 

Some have suggested that local authorities could do it. This is a non-starter for two reasons. 

Firstly, many local authorities just don’t have the resources to deliver it. 

Secondly, and more importantly, it is a fundamental tenet of good regulation and public inspection that you don’t inspect yourself, otherwise we create the conditions for conflicts of interest to arise. 

Given local authorities are still the responsible body for many schools, it is no more sound to have local authorities inspecting their own schools than it would be for trusts to do likewise. 

This is not a point about structures, it is a point about effective regulation. 

In any case, whichever body has responsibility, it would require a large number of people. The greatest risk amid the current workforce crisis is that this sucks people out of schools and other frontline services. 

This must be avoided and would require careful thought from a Labour government. 

Regulation

The supposition that separating safeguarding and inspecting it annually would dial down the pressure on inspection seems to assume that hard regulatory consequences, such as a change of governance, wouldn’t follow a poor safeguarding inspection. 

Otherwise, one might argue that facing the possibility of regulatory intervention every year rather than every four years could add to, rather than reduce, leaders’ anxiety. 

So far, the regulatory details of the policy are yet to be announced. This is right and proper: these need to be designed carefully and situated coherently within the wider reforms of accountability Labour has proposed and is presumably working through in more detail. 

However, for now, it is simply worth noting that until the regulatory levers are set out, it pays to be cautious about assuming exactly how this policy might affect the burden of inspection and regulation in the system. 

Rationale

Beyond the argument about dialling down pressure on schools, it has also been suggested the policy could have a beneficial impact on levels of assurance and safeguarding practice.

Going through the processes on an annual basis, it could be argued, means there will be more regular oversight - potentially helping schools to spot issues and strengthen approaches. 

However, any potential benefit would depend on the nature of the inspection activity undertaken. 

While some assurance can be gleaned from a brief compliance check, perhaps including the single central record and a review of how incidents are handled, these activities provide limited access to insights about what Ofsted currently calls the “culture of safeguarding”. 

Conversations with teachers and pupils are likely to give a deeper insight into issues like bullying or the sort of societal challenges we saw in the Everyone’s Invited situation. 

And parents might wonder, if these deeper inspection activities are not carried out, how much assurance the annual visit actually provides. If they were carried out, one might wonder what the extra burden on schools would be. 

All of this would be more straightforward if we were amid a national crisis in safeguarding. Inspection outcomes, with 89 per cent of schools being judged “good” or better, don’t suggest this is the case. 

And how many leaders advocating an annual safeguarding visit would argue there is a “burning platform” crisis in safeguarding in their school?

This suggests the main attraction from leaders’ perspective is where we began - an understandable desire to dial down pressure on inspection, assuming this is what is delivered. 

It may be that inspecting safeguarding annually resolves some of the pressures in the inspection system, improving the burden on schools and leaders while also maintaining, or even improving, assurance for pupils and parents. 

But it is also possible that neither of these things are delivered and the real change that’s felt is the increased resources required to deliver the system. 

In order to steer this policy in the right direction and unlock the mooted benefits, there is work to be done. 

A government implementing this policy would need to make sure they are clear on the rationale and the resource implications, and build the right regulatory approach, achieving assurance while not adding to burden. 

And the profession needs to be watchful that what is a well-intentioned proposal on paper is delivered in reality. 

As the old proverb reminds us, many policies “slip twixt the cup and the lip”. The details of this policy really matter.

Steve Rollett is deputy chief executive of the Confederation of School Trusts