• The IMBs responded to the European Ombudsman’s wide-ranging consultation on the operation of Frontex, making special reference to human rights infringements and the lack of a credible complaints procedure. • The CQC laid before Parliament its third annual report on monitoring of the Mental Health Act, in January 2013. The report was widely referenced by the Health Select Committee in its post-legislative scrutiny of the Mental Health Act 200713. • The Regulation and Quality Improvement Authority (RQIA) has have been working with the Department of Health, Social Services and Public Safety, which is preparing a draft Mental Capacity Bill for Northern Ireland, which will be put out for consultation next year. • HMIPS provided evidence and comments to the Scottish Parliament Justice Committee on its annual report 2011–12, following up with further information on legalised police cells, as well as on the Prisons (Interference with Wireless Telegraphy) Bill (UK Parliament legislation), and the Scottish Government’s draft budget scrutiny 2013–14 regarding the financing of the findings of the Commission on Women Offenders. It also took part in an evidence session on prison health care, and a Scottish Court Service consultation on Proposals for a court structure for the future. • The SHRC made recommendations on Chapter 16 of the Police and Fire Reform (Scotland) Act, 2012, to ensure OPCAT compliance and give due consideration to the Subcommittee on Prevention of Torture (SPT) guidelines on NPMs when placing the independent custody visiting on a statutory footing (Section 91)14. • The OCC gave evidence to the House of Commons Justice Committee inquiry into the youth justice system of England and Wales and the House of Commons Home Affairs Committee’s consultation on the draft Antisocial Behaviour Bill. It also responded to a consultation on the Mayor’s Office for Policing and Crime, Police and Crime Plan 2013–17, a Department for Education consultation on local authority responsibilities towards children looked after following remand, and made a submission to the UN Committee Against Torture for its periodic review of the UK. • HMIP gave evidence to Justice Select Committee inquiries into youth justice; female offenders; and older prisoners, as well as to the Independent Police Complaints Commission consultation into the way that deaths following police contact are investigated. Priority areas Sanctions (OPCAT Article 21) At the first business meeting of 2013, it was decided that the issue of sanctions should be on the agenda of the UK NPM. ‘Sanctions’ refer to any punishment that may arise from a detainee having contact with an independent monitor. It is a broader term encompassing what is often referred to as ‘reprisals’, when punishment practices are inflicted by guards or detaining authorities against detainees who have reported to independent monitors15. 13 http://www.publications.parliament.uk/pa/cm201314/cmselect/cmhealth/584/58402.htm 14 http://www.scottishhumanrights.com/publications/consultationresponses/article/policereformsubmission2012 15 Association for the Prevention of Torture (2012) ‘Mitigating the risks of Sanctions related to Detention Monitoring’ Briefing No4. At: http://www.apt.ch/content/files_res/Briefing4_en.pdf 23