National Preventative Preventive Mechanism MechanismAnnual Annual Report Report2009–10 2009–10 Challenges As with any other newly designated NPM, the NPM in the UK faces several challenges in fulfilling its functions. Many of the challenges faced by the UK NPM relate to its structure – notably its size and complexity. The UK is not unique in having an NPM made up of several bodies, but it does appear to be unique in having quite so many. With 18 bodies (so far), it is perhaps inevitable that the members may have a different understanding of OPCAT and how best it can be implemented. They may also have different views on the coordination role performed by HMIP and how extensive this should be. The NPM in the UK is made up of a range of organisations: they visit different types of detention; they operate under different legal frameworks; and, importantly, they work in different jurisdictions within the UK, including different political contexts. Furthermore, membership of the NPM is not final and additional bodies may be added as gaps in coverage are identified and addressed. With the views of 18 bodies to consider, coordinated activity of the NPM could prove challenging. There may be different ideas about what collective work should take place and, even where agreement is reached, plans may be tempered by more practical issues such as capacity and resources. This may be a particular issue for the lay bodies within the NPM, so thought is given to how to support them to take part in coordinated activities. On behalf of the NPM, HMIP has requested additional resources for its coordination role, but is aware that the request has been made at a time when the government faces severe financial pressures. 16 When the government assigned the coordination role to HMIP, little guidance was given on what this may involve. During the designation process, concern was expressed that granting the coordination role to one body could place it in a more powerful position than the other members. If the NPM members could not reach agreement about an issue, would the coordinating body be able to dictate a particular course of action? Fortunately, the members have so far been able to operate on a consensus basis, but the issue remains unresolved. For some members, monitoring places of detention is just one part of a much wider regulatory or inspection role. They may find it difficult to sufficiently prioritise visits to places of detention when there are other calls on their resources, particularly in the current financial climate. Designation as a member of the NPM may result in a greater emphasis on monitoring detention but it should be noted that, generally, members have not been given additional resources to do this. Many of the members of the NPM are adept at dealing with their external stakeholders and involving them in their work. Nonetheless, thought needs to be given to those outside the mechanism who are interested in the work of the NPM as a whole. The NPM should form relationships with the SPT and other international bodies, as well as civil society. A particular challenge is that the composition of the NPM in the UK is likely to be confusing to outsiders.