It may be a delayed response – but I felt I had to comment on this …….   Leave a comment

 

It should be noted that I was not at the Nursery World Conference and so I acknowledge that Ms.Truss may have made a slightly different speech, however I shall be adding my comments to the prepared speech , as I am sure there will not have been much deviation, as Ms.Truss has an amazing  ability to quote  repeatedly from written documents.

So that I do not misquote Ms.Truss, I have copied and pasted from the gov.uk site where the prepared speech can be found https://www.gov.uk/government/speeches/elizabeth-truss-speaks-about-2-year-olds-policy-and-practice

Ms. Truss’s prepared speech is in white, and  my  comments are in pink (and final comment in green)

I am really pleased to be here, and to have the chance to outline the government’s policies in relation to 2-year-olds. I also want to speak about early years pedagogy, because it is the basis of everything that follows.

Totally agree – early years pedagogy should be at the heart of everything.

That is why our early learning programme will be open to 2-year-olds who are looked-after or whose background would make them eligible for free school meals. They will be offered 570 hours of early learning a year, which will typically be taken as 15 hours a week, but doesn’t have to be. So I want to start with a thank-you. There are promising signs that we are on track to deliver 130,000 places this September – in no small part due to the efforts of many of you in this room.

A worthwhile aspiration to offer funded places for two year olds – I hope it is extended to all two year olds, but agree it is right to start with those who need it most.

It is right to thank those who provide the places because they often provide far more in the way of services and support than they are paid for.

These children can then continue to benefit from early education at 3 and 4, when all children can get 15 hours of it. But we have more work to do to meet our commitment to ensure all eligible 2-year-olds get a high quality place.

Again worthwhile aspirations, however, does anyone really think that 2 (or even 3) terms of support will be sufficient to overcome the many complex issues that a funded two year may have?‘ I ask because once a child is 3 years old, the early years provider will no longer receive the enhanced funding – but will often still be providing additional support for the child and their family.

This programme will be transformational. We know how important early education is. The Sutton Trust has found a 19-month vocabulary gap at age 5 between children from the poorest and most affluent families.

96% of parents already take up their child’s place for their 3- and 4-year-olds. But only 37% of 2-year-olds from the poorest 40% of families access any formal early education, compared to 78% of their richer peers.

Of course this evidence is very important – but before coming to conclusions, more evidence is needed. There are so many other issues to be considered as a reason for language delay; for example number of home languages used, if English used at home at all or occasionally, if in household where drugs or alcohol have a impact, if domestic violence an issue, if dummies are over used, if a medical issue. Evidence suggests that children from the poorest families often face many of the above situations – all of which can have a profound impact on family life, and in some cases families are only just managing to ‘hold it all together’ mentally themselves – it is unrealistic to expect them to provide an enabling environment or to take up the opportunity of pre school care and education. It is also not just a case of if they attend a childcare setting – there are many excellent parent and baby / toddler groups that parents can attend with their child usually for low cost or even free, has there been any research into if those children with language delay attend these parent groups and what could be done to encourage attendance – after all if the child attends with the parent, the advantages of attending such groups for child and parent should extend far beyond the hours spent at the group.

So there is very much a social mobility imperative here. All of us recognise the unfairness of a young child’s background having a lasting impact on their life.

Would agree BUT as already mentioned, so many other issues need to be considered and with funding for many support services and charities being cut, some of these things are only going to get worse – not better. It is not just a case of providing a funded childcare place. A holistic approach needs to be taken .

Scientific advances have shown us that the way a child’s brain develops in the first years of its life has a profound effect on their life chances. The gap in maths attainment between our country’s teenagers and those in Hong Kong and Singapore is already evident by the age of 5.

I would be interested to see how this gap – at 5 – was measured? – against what criteria? – is it a comparable measure or the countries own stats? In which case what is measured and what is compared? As children in Hong Kong start formal school at 6 – is it not possible that it is what happens after pre school that is the issue – ie children in this country start school too early or the curriculum does not meet their needs?

The MPs Andrea Leadsom, Frank Field and Graham Allen – along with George Hosking of the WAVE Trust – have all published exhaustive reports that showed how high-quality early years education makes a big difference, especially to disadvantaged children, and referred to research that shows the massive effect of a child’s experiences before they turn three – by which age the brain is 80% developed.

I don’t think anyone disagrees with these reports – we all acknowledge that high quality early years education makes a big difference – it is the definition of what high quality early years education looks like that is being questioned.

This is, of course, an opportunity for providers. It is a great chance for you to expand, to further support child development and improve outcomes.

We (the early years sector) have been doing this for years – and year on year improving outcomes for children. 71% of providers inspected under EYFS 2008 received a good or outstanding grade. The government should let the sector continue this excellent progress and not risk undoing all that has been achieved in the past. Of course there is room for improvement – always will be, but change should be carefully considered and introduced one step at a time – otherwise it will be impossible to know which aspects worked or didn’t work. The government need to listen to those in the sector who understand children, and to support the continuing drive for quality improvement by working with the sector –  not against it.

We are putting funding in but we need to know that it is going to providers who will make a difference.

We are giving local authorities £525 million to fund 2-year-old places. There will be an average hourly rate of £5.09 across England. Every area will receive funding that equates to between £4.85 and £6.07 per hour. Nationally the funding compares favourably to the Daycare Trust Cost Survey 2013 which shows average hourly nursery fees in England are on average £4.26 across England. We have told local authorities to pass all available funding on to providers so that they can provide sustainable, high-quality places.

But they must be good providers. Really? I understand that satisfactory providers can and do offer funded places for 2, 3 and 4 year olds.

The early education for 2-year-olds pilot showed that higher-quality settings have a positive impact on language ability at age three. In addition, across the scheme, parents typically felt that such settings had improved their parenting skills.

Can someone provide the figures that show how many of these setting operated at higher ratios with a graduate in place?, and how many of these settings employed a graduate but did not operate at the higher ratios.

All of which is a reminder of how important it is that local authorities are expected to fund places in settings that are rated good or outstanding by Ofsted.

Sue Gregory – Ofsted’s National Director of Early Years – has highlighted the fact that regional variations in the quality of early years provision are too wide. In some local authorities 80% of early years providers were judged good or outstanding at their last inspection, but in others it was less than 60%. I want standards to rise across the board, and not only be high in certain pockets of the country.

Yes, all very good points – high quality setting have a positive impact on language ability – in fact high quality settings have a positive impact generally on children and their families.  I agree that more should be done to close the regional variation in grades received. However we also need the evidence that says that settings can only achieve the highest grades if they employ a graduate.

All the evidence shows that the No. 1 factor is people, and specifically the quality of engagement with children. The international evidence is clear. Andreas Schleicher of the OECD – who has welcomed our review into childcare practice – has said that “staff qualifications are the best predictor of the quality of early childhood education and care”.

On this point I will have to disagree – the people are the most important factor BUT staff qualifications are only ONE predictor – there are many other equally important predictors.

We know that teacher-led settings with larger groups of children are widely seen as the gold standard in the system. At every age we have studied, there is a benefit to involving graduates in education, and particularly so for pre-school-age children. As last year’s NAO report on early education for 3- and 4-year-olds explained some 96% of maintained nursery schools were judged good or outstanding by Ofsted.

First point – 2 year olds are not 3 year olds – thier needs are totally different – especially as the 3 year olds in maintained nurseries are 3 and a bit due to term starting dates – a huge difference.

Second point – where is the evidence that this is the case for 2 year olds?

Third point – teachers are good at teaching for tests or even end profile results, they are good at documentation (even if they don’t personally agree with doing it – the system says they should) – BUT do the children have the skills needed for later life? Schools and maintained nursery classes are very good at preparing for Ofsted visits – because they have a notice period – anyone can do that – the government need to look further, they need to think why children in other countries do better later on – that they not only catch up, but overtake children in this country. Maybe it is our testing culture or limited curriculum – based on ‘One Size’ fits all?

Fourth point – Has the government not noticed that many children are leaving school without basic skills? Has the government not noticed the number of people who do well in later life – but did not do well at school? Has the government not noticed the number of graduates with good degrees who have not got jobs? Has the government not noticed that actually there are more predictors of success than the qualifications you leave school (or university) with?

Fifth point – children only attend maintained nursery classes for around 3 hrs a day – many then attend a pre school setting or a nursery or a childminder –for the rest of their parents working day –  so why are these children not displaying these wonderful outcomes in those other settings? Rather odd I think.

Settings that have a graduate leader have significantly improved outcomes, especially with language and literacy. And once again, these benefits are particularly acute for disadvantaged children.

I must be the exception to the rule then. I am not a graduate leader, all the children currently in my care (included 2 bilingual children, and one who was a funded 2 yr old) have exceptional language and literacy skills. Those that have left my care have all done extremely well in later life.

But I am not the exception am I? Many of my colleagues across all sectors do as well – dare I suggest that dedication, professionalism, passion for working with children are all just as important as a degree?

I will repeat myself – higher qualifications are not the only thing needed – it is a much bigger picture. Yes, everyone should undertake continuous professional development – and many early years practitioners do, they don’t need to be told what to do – it should be an individual plan to meet the needs of the setting, the practitioner and the children

Crucially, not only are trained teachers the most effective in their interactions with children, but their supervision of less well-qualified staff made those staff better as well.

So just teachers? Not others with degrees? Not EYPS? Not those who have years of experience and lots of ‘people’ skills? I am sure lots of teachers do have these abilities – but not all – and a huge number of people who have these skills are not teachers and don’t have a degree. Sweeping statements such as the above cause a lot of harm through misinformation and devaluing those who are doing an excellent job

Sue Gregory has said:

Entry requirements for teaching, particularly in English and mathematics, are being strengthened. If this level of qualification is essential for teachers, why not for the early years?

So why can academies employed unqualified people?

If we are serious about investing in the future, I believe that many more of those working with young children should be highly skilled and qualified to degree level. There are other countries where the majority of the early years workforce holds a degree-level qualification, unlike England where numbers are much lower. This just can’t be good enough.

She is right.

She is right – but support should be provided to enable practitioners paid time off and funding for the actual course. If made an entry requirement many of the most suitable people will not enter the profession.

As you will be well aware, early years professionals are paid significantly less than primary school teachers, who earn £33,250 on average – a figure which compares favourably with France, where they earn £25,400, and Sweden, where they earn £23,250.

The figures are not comparable –  as around a third more in this country – and the main reason that teachers can be paid a reasonable salary is because the state pays for statutory education – but not for pre school education.

Yet childcare workers in formal settings earn £13,300, in contrast to £22,450 in Sweden and £22,100 in the Netherlands. Supervisors and managers earn only £16,850, whilst in France and the Netherlands the averages are £23,950 and £34,400 respectively.

This distance between the early years and primary schools is a mistake. It would be quite wrong to think that under-5s should have one sort of pedagogy and over-5s a completely different one. And it is wrong that early years staff are paid so much less than primary school teachers.

I totally agree – however the big difference (as mentioned above) is in this country the state pay teacher’s salaries – the parents pay for early years staff salaries. In other countries parents have more direct or indirect help.

 

Increasing qualifications will meet with some resistance. This country went through the same trajectory with teaching a few decades ago. The mushrooming of teacher numbers in the 1950s and 1960s had seen a lot of inexperienced and under-qualified people enter the profession.

In the mid-80s Keith Joseph sought to improve training and development for teachers, insisting on higher standards in maths and English. His stance was not universally popular; but it was right.

So in the mid 80’s things changed in teaching – evidence suggests that although some are achieving higher qualifications on leaving school – many are not – so is this really good evidence to support this? Surely after 30 years – if it worked that having higher standards in maths and English for teaching staff – then all children would be leaving school able to read and write?

 

Please note this is not meant to undermine teaching colleagues as they are highly skilled  and valued – however they know the reason that some children are leaving school without basic skills. (because ‘One size’ does not fit all and the national curriculum is not flexible enough)

Play and structured learning are not opposites and nor does one stop at age five and the other one start. Rather, they are complementary. And there are real-world examples of this.

Agree

At Woodberry Down School 9-year-olds learn fractions in a fun way in a programme known as ‘Go Fish’. I spent a good half-an-hour watching them, and they were engrossed and immensely engaged.

Elsewhere, a teacher prepared 3 water trays at differing levels, with only the top tray full. Having made guttering, hosepipes and various other objects available, the teacher challenged the children to move the water in the top tray down to the bottom tray – thus providing an excellent lesson in the theory and practice of gravity.

The best nurseries do similar, age-appropriate work for 3- and 4-year-olds. Alexandra Nursery School has a structured maths teaching programme that encourages counting at every opportunity – for example through songs and counting blocks when building a wall or ingredients when making a gingerbread man. Having got such a good head start, children are known to make significant progress when they leave the nursery.

Lovely examples – but a structured maths teaching programmeis not needed to do this type of learning through play. The activities  described occurred day in day out in thousands of early years settings. So by providing these examples  not only is a lack of understanding of what happens in early years settings shown, but also a demonstration that do not understand that practitioners can provide these enabling environments without having a degree and without a structured programme.

It would also be wrong for people in schools to take the view that life doesn’t begin before the age of 5. In fact, what we have learned about the brain shows that this is very far from the truth. I think we have a lot to gain from seeing early education and primary school as a continuum rather than as 2 completely separate things.

Yes – primary schools need to be more like early years settings – not the other way round.

This is the motivation behind our reforms on professional qualifications. We want to increase the number of trained teachers entering the early years. It is not a rebuke to those of you who have dedicated your lives to this profession and do not have these formal qualifications. And you are absolutely right to make the point that qualifications alone are inadequate – anyone working with children needs a whole range of other skills.

Early years teachers, who will specialise in early childhood development, will face the same entry requirements and need to pass the same skills tests as trainee school teachers.

Oh dear –  this is not intended as a rebuke to those already in the professional but it is suggested that early years teachers are needed for a understanding of child development. I can not speak for my colleagues but I am personally insulted by this statement, my understanding of child development is outstanding – as is that of many of my colleagues

By the way my daughter who has a 2.1 as an early years teacher (age range 3 -7) gained through 4 years study at a university with a good reputation for their teacher training – asked me for advice and ideas during her first months of employment – not because she is not good at her job within a Children’s Centre – she is – but because she lacked experience of working with children (at that time).

Please do not underestimate experience.

That is not to say that I am against child development training – I am not – I am very much in favour and I think everyone working with or making decisions about children’s lives should have a secure knowledge of child development.

I also want those working with children to have a good understanding of proven theories. Attachment theory would be one of these. It is well-established that secure bonds between children and adults provide safety, security and protection and also help children learn to socialise and form new relationships with their peers.

Again I am personally insulted –  this statement seems to have been written without the full understanding of attachments – if it  had – it would not be suggested that one nursery practitioner can care for 6 two years olds (maybe ask Mr.Walton father of the sextuplets for his views) nor would it be suggested a childminder could care for four children who may not only be under two but only just over 12 months, nor would it  be suggested that 2 year old would have better outcomes in large structured groups.

As part of raising standards among professionals below graduate level here, people will train at level 3 to become early years educators. The National College for Teaching and Leadership will set out which rigorous qualifications are needed to earn that title. Being an early years educator will require at least a C in maths and English GCSE and the qualification will be the contemporary equivalent of the highly respected Nursery Nurse Diploma (which was discontinued in the mid-1990s).

I hope that aspirations are met and we don’t end up with the mess called ‘NVQ’s. By the way if the Nursery Nurse diploma was so highly regarded why was it discontinued?  I hope that we will not be saying the same about our current early years success at some point in the future and asking why it was discontinued / changed.

Just as there is no contradiction between structured, teacher-led learning and play, there is no contradiction between education and enjoyment! One of the great joys of young children is their sense of wonder and curiosity about the world.

That last sentence is so true – only problem is children have much more of a sense of wonder and curiosity if not led by a teacher – children learn best through their own discoveries.

It is still concerning that there are so few teachers employed in early years and that 70% of settings do not take advantage of the higher ratios and graduate leadership. Our analysis suggests that it is affordable for nurseries but sometimes there is a resistance to the idea of larger groups.

Has anyone asked why there is resistance?

That is why I am pleased that Ofsted has confirmed today that qualifications will be a critical in how they judge a setting – with a view to getting many more qualified graduates into the sector. Ofsted has already adjusted the focus to be more heavily upon outcomes. Today Ofsted is announcing a greater focus in their inspection regime on qualifications, because it considers this a key to making it happen.

Settings will be judged against a new framework from September, including a ‘requires improvement’ category. Ofsted proposes to re-inspect them within 24 months if they are judged to fall into that category.

So no matter how good they are, how well the children are doing, no matter what the outcomes –  settings might not be able to receive the highest grades unless they have staff with higher qualifications – and that having a graduate will be deemed an indicator of high quality?

Surely the focus should just be on outcomes – and then when inspections results are analysed – evidence will be there to say if having  a graduate or higher qualified staff does improve outcomes. If Ofsted use higher qualifications / graduates as a focus – the evidence will be lost as by default those without those higher qualifications will have been pre judged.

 

I do hope I have read this wrong because this is back to ticking boxes

HMIs will be looking for highly qualified staff and Ofsted will clarify what it expects to see. It is also recruiting inspectors who can work across both primary and EY settings. Standards and requirements for HMIs will be as tough as for the settings themselves.

I hope this means that inspectors will understand and acknowledge the differences between early years and primary age children and how they learn. I really hope it won’t mean that early years settings will be excepted to implement formal teaching as seen in primary settings.

Since September Ofsted has started keeping records of qualifications held by staff, which will be updated at every inspection.

Good practice – but not if inspectors are to pre judge those without graduates/ higher qualified staff.

I welcome this new emphasis.

The independent charity Teach First has done great work in encouraging top graduates to become teachers and so I am very pleased that from September recruits will begin working with children as young as 3, with more trainees beginning in September 2014.

Over 2 years trainees will learn about teaching and leadership and undertake coursework and on-the-job training.

I am absolutely clear that – although we should have strong accountability – we should give high quality providers more autonomy. Just as we are doing in schools where academies and free schools have greater freedom, so I want to see the same for the best practitioners in the early years sector. After all, there are lots of good ways to do early education – and although poor settings quite often look the same, 2 outstanding settings rarely do.

Double standards here – more accountability – but not if you don’t have a higher qualification?

Actually Outstanding settings do often look similar not in their environment or even their policies – but in their ethos because they understand how children learn, how to support staff and parents and are dedicated professionals. Knowledge and understanding will be apparent – with or without a bit of paper called a qualification.

In his report for the Department for Education on evidence-based learning, Dr Ben Goldacre wrote:

I think there is a huge prize waiting to be claimed by teachers. By collecting better evidence about what works best, and establishing a culture where this new evidence is used as a matter of routine, we can improve outcomes for children, and increase professional independence.

Too often moves by government or local authorities are interpreted as directions. I am clear that whereas government should set the ‘what’ and hold providers to account, it is for teachers and professionals to determine the ‘how’.

I want to see confident practitioners, availing themselves of the best available evidence to deliver the early years foundation stage (EYFS) in the way they see fit, so long as outcomes for children are good. I also want to see practitioners well-versed in the evidence.

Dr. Goldacre is very knowledgeable and should be listened to – the words used are ‘evidence’, ‘outcomes for children’ – ‘professionals allowed to determine the how’.  All this could be achieved – no, was being achieved without More Great Childcare. 

This is very compatible with best practice that Sue Gregory outlined this week. We are seeking out good interaction between adults and children as well as encouragement for children to work with each other.

For example, Toad Hall Nursery Group has family rooms in their nurseries, similar to a model which is popular in Scandinavia. Children aged between 2 and 5 learn and play together. Not only is the development of younger children boosted, but the older children behave better.

I went to France this week to look again at how they do things there. There is a strong focus on structured learning, led by a qualified professional. I saw a teacher lead 8 2-year-olds in putting together a series of plastic discs for a good 20 minutes. I was captivated – and so were they. In fact, the 1 boy who had left to go and play with Lego came back because he felt he was missing out.

I also saw 26 3-year-olds all following the steps of a dance teacher.

There is a real culture in French nurseries of socialisation and interaction, rather than excessive tailoring to each child, which can mean that they miss out on the chance to take part in a purposeful activity together.

There is also a premium on manners.

In the best French nurseries that I saw, the children are recognisably happy and confident, and eager to learn. I saw teachers working very effectively on the kids’ vocabulary. They are even taught logic!

And there is a comparatively seamless experience between early education and formal schooling.

For their part, the French have also found much to like about nurseries in this country and also our regulatory structures through Ofsted. This exchange of ideas and best practice on an international level is thoroughly welcome.

I have commented before about this ‘cherry picking’ of ideas from abroad, yes of course we can learn from other countries – but we can not pick and choose, nor must we think we are the same as the French or the Dutch or any other nationality.

There are various myths about practice which sometimes can prevent the development of different ways of doing things and inhibit professionals developing their knowledge. It can also prevent new providers entering the sector with new ideas.

So I want to clarify the position of the government. The EYFS is a framework that sets out the standards expected for children’s learning and development, and for their safety and wellbeing. It is not a straitjacket that requires professionals to operate in one particular way. And beyond the EYFS, there is no central guidance, because we expect professionals to take the lead – just as we do throughout the education system.

If only that was the case – the government provides central guidance all the time and if practitioners take the lead – in the best interests of the children – Ofsted then ‘down grade them – as seen time and time again.

For example, Development Matters is not statutory – it just outlines one possible approach and helps underpin inspections, rather than dictating. And we are reforming the role of local authorities so that their focus is on the champions of children and parents, not on setting out methodologies that nurseries should follow. And local authorities will no longer be able to withhold funding for not following their way of doing things – it really is up to you.

Please tell the inspectors this.

From September Ofsted will have a revised framework for the early years. This framework will be more focused on child outcomes than any specific methodology. This will give early years professionals more freedom to tailor teaching to the specific needs of the children in their care.

Oh – but only provided we have graduate leaders, structured programmes of formal learning – where is the freedom? – when it has already been  said what Ofsted will be looking for – that is not freedom!

Let me dispel a few other common myths. These are things I have heard visiting nurseries that they tell me they are expected to do. I want to point out that they are required by neither government nor Ofsted:

Free-flow play between outdoors and indoors is not a requirement and not something Ofsted is looking for.

Inspection reports say otherwise

There is not a requirement to have a certain amount of child-led activity. There is no reason why children should not be part of structured groups and be encouraged to interact with each other.

 It has been stated we have freedom to tailor ‘teaching’ to the needs of the children? Children of this age need lots of child led activity – What will Ofsted say if we offer lots of child led activity?

There is no requirement to fill in learning journeys. For each individual child there are just 2 pieces of writing: the 2-and-a-half year check and the EYFSP.

That will be news to inspectors – I personally agree about learning journeys – but just two pieces of writing for a child’s entire time in an early years setting?

And Clare Tickell in her report on the EYFS made very clear her view that adult direction was not inconsistent with the requirement of the EYFS for planned, purposeful play. She said that:

Adults should be modelling, demonstrating and questioning. To exclude elements of teaching from the early years would increase the risk of children not being ready for the move to key stage 1.

Agree with Dame Tickell – model, demonstrate, question – but these are not the same as structured learning programmes.

Of course that also means exercising professional judgement according to the children’s stage of development, or about the time of day things happen, or about what group structures are appropriate, or where a child may need something else.

Please leave early years practitioners to do this then – and stop giving contradictory information / guidance.

 

 

To this end, we’re working with Ofsted to make sure that all documents reflect this approach.

With an increase in quality will come increased freedom for professionals – backed up by an improved and clearer inspection regime in which Ofsted will take the lead and ensure better accountability.

The whole of government must be concerned about child development, and work together towards better outcomes. The Department for Education and the Department of Health are working together to implement an integrated review at age 2-and-a-half. The Healthy Child Programme already requires a health review at age 2, 2-and-a-half, and since September 2012 in the newEYFS there has been a requirement for parents to be provided with a written summary at age 2 of their children’s progress in the EYFS prime areas of learning. By 2015, we want to integrate these 2 processes.

Our drive for higher standards is a recognition of the fact that the area in which you work is of immense importance. The stakes could scarcely be higher when we are talking about 2-year-olds, all of whom are infinitely precious and all of whom – no matter where they come – deserve the very best start in life.

I do agree with most of the above points – but disagree that the government is allowing practitioners to exercise professional judgement – I feel the government is wasting a lot of practitioners time and devaluing a lot of very professional practitioners by the whole More Great Childcare debate.

There is no need for this – EYFS 2012  should have been allowed to be fully implemented, inspection evidence analysed – and the next steps then looked at – the old plan (the EYFS 12) observe (the inspection results) review ( changes for EYFS 2016?)

All in the format that we know, understand and respect – you see the early years sector are not against change – the sector has undergone many changes and in some cases come full circle – but what the early years sector will not do is stand by and watch changes that are rushed through without full consultation and the necessary time – and which they believe to not be in the best interests of the children.

 

Please listen to the early years sector – and at the very least allow the EYFS 2012 to run for the 4 years that it was intended to do and base any changes on evidence and research and inspections outcomes from this country.

 

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