The Highland Council
Highland Licensing Committee – 8 February 2010
Agenda
Item
Report
No
6.1
HLC/034/11
Licensed Taxi Operator – Robert J S McPhee
Report by the Area Solicitor
Summary
This Report relates to a licensed taxi operator who has been reported for a breach of
licence conditions.
This application is subject to a formal hearing procedure.
1
Background
1.1
The Highland Council has resolved that in terms of the Civic Government
(Scotland) Act 1982 a licence will be required for the operating of a licensed
taxi. A licence for the same issued by the Highland Council is valid for the
whole Council Area.
1.2
Mr Robert J S McPhee is a licensed taxi operator and licensed taxi driver with
the Highland Council. He currently holds one operator’s licences namely
31114. The licence holder was first granted an operator’s licence in 2005.
1.3
On 17 January 2011 a report was received form the Council’s Trading
Standards Service, who are responsible for the enforcement of the licensing
scheme for taxis/private hire cars and their drivers, in relation to Mr McPhee.
1.4
The report was submitted regarding Mr McPhee’s failure to maintain his
licensed taxi to the standards required by the Council.
1.5
A copy of the report is attached together with relevant documentation and
statements from:
Elizabeth Gardner - Trading Standards Officer
Stewart Hiddleston – Assistant Trading Standards Officer
1.6
A copy of this Report and all attachments have been sent to all parties who, in
the terms of Paragraph 4(2) of the Civic Government (Scotland) Act 1982,
have been invited to attend and will be provided with an opportunity to be
heard by the Committee. A copy of the procedure which will be followed at the
meeting has also been sent to all parties.
1.7
In terms of Section 11 of Schedule 1 of the Civic Government (Scotland) Act
1982 a Licensing Authority may suspend a licence(s) if in their opinion the
holder of the licence is no longer a fit and proper person to hold the licence(s).
2
Policies and Conditions
2.1
The following policies are relevant to this case:
Standard Taxi Driver’s Licence conditions. A copy of these can accessed at
www.highland.gov.uk/businessinformation/licensing/civicgovernmentlicensing
or a hard copy can be supplied where requested.
3
Determining Issues
3.1
Is the licence holder a fit and proper person to continue to hold a licence? If
required the Area Solicitor will offer particular advice on the criteria relating to
this particular case.
4. Recommendation
Members are asked to consider whether or not the licence holder continues to be a
fit and proper person to hold a taxi operator’s licence and upon determining this
whether any action should be taken against the licence holder in the form of a
warning or suspension of licence.
Signature:
Designation:
Area Solicitor
Date:
25 January 2011
Background Papers: Civic Government (Scotland) Act 1982
Highland Council’s taxi operator’s licence conditions
CIVIC GOVERNMENT (SCOTLAND) ACT 1982
Penalty Points System for Licensed Taxi and Private Hire Car
(PHC) Operators and Drivers
Reference No. TS/CG(S)A/PP/4/10
Against:
Robert John Stewart McPhee
Age: 33yrs
DoB: 3.3.77 ¶
Licences Held: Taxi Operator, Licence reference no. 31 114
Taxi Driver , Licence reference no. 31 553
Address:
12 Plover Place
Reiss
By Wick
Caithness
KW1 4RT
Vehicle
Description:
Registration No:
Date of first
registration:
Mileage at Last
Inspection:
Citroen
Xsara
SW02 JXF
25/7/02
160340
Penalty Points Total as of 20/10/2010: 32 points
REPORTING OFFICER:
NAME: Elizabeth Anne Gardner
DESIGNATION: Trading Standards Officer
ADDRESS:
Highland Council,
TEC Services
Trading Standards
38 Harbour Road
Inverness
IV1 1UF
TELEPHONE NO: 01463 228700
SUMMARY
This report relates to the failure by Robert McPhee to maintain his licensed
taxi to the standards required by the Licensing Authority, Highland Council,
contrary to Condition 1 of the Taxi Operator’s Conditions of Licence and to his
continued fitness to hold a taxi operators licence; subject to paragraph 11(2)))
of Schedule 1 to the Civic Government (Scotland) Act 1982.
REPORT
The Penalty Points System was introduced on July 1st 2006. Its main purpose
is to assist Trading Standards in the evaluation of whether licensed operators
are maintaining their vehicles and operating practices to an acceptable
standard and as a visible deterrent to those licensed operators who fail to do
so.
Points under the scheme accumulate when faults are discovered at the
Council’s programmed inspection of the licensed vehicle, during “on the spot”
inspections of the vehicle by Trading Standards staff or as a result of our
investigation of a complaint. The points remain on a licensee’s record for a
period of two years from the date of issue.
An appeal system is in place which allows an operator to question the
allocation of points. When the points total reaches 20 or more this would
automatically initiate a review of the case by Trading Standards with a view to
considering whether a report to the appropriate Council Licensing Committee,
or some other regulatory action is deemed necessary.
Robert McPhee has been a licensed taxi operator since 7/12/2005 and a
licensed taxi driver since 18/11/2004. As summarised in the attached “time
line”, Robert McPhee’s licensed vehicles have undergone 10 Council
inspections. This has led to 5 “Pass” results, 2 “Conditional Pass” results and
3 “Fail and Dangerous” results.
The Citroen Xsara currently on the licence received its first Fail and
Dangerous result from a Council inspection on 14th October 2009 which led
to the accrual of 13 penalty points and its second on 19th October 2010 which
led to the accrual of 19 penalty points, giving the licence a total of 32 penalty
points. A Report to the Licensing Committee is considered for a total of 20 or
more penalty points within a two year period.
Robert McPhee was interviewed by officers from Trading Standards to allow
him to demonstrate his maintenance regime for his vehicle. Mr McPhee
provided receipts for parts which have been fitted to the licensed vehicle in
recent months and stated that Mr Ivor Campbell carried out any bodywork
repairs for him and Mr Richard Ambler carried out the mechanical repairs
required. He said neither man was prepared to put anything in writing to that
effect but Mr McPhee offered their telephone numbers and said they would be
both willing to confirm they looked after his car. Mr McPhee said that
whenever he thought there was something wrong with his car he took the car
to one or other of these men and had repair work carried out. He did not have
pre-inspection checks carried out on his car.
Trading Standards does not consider that this demonstrates Mr McPhee’s
maintenance regime is sufficient to ensure the licensed vehicle remains at the
standard required by the Council and this report is presented for the
consideration of the Licensing Committee.
CONTENTS
Number
Description
1
Time Line For Taxi Licence 31 114
2
Taxi Test Report Form dated 19/10/10
3
Taxi Test Report Form dated 20/10/10
4
Penalty Points Letter Dated 19/10/09
5
Taxi Test Report Form dated 14/10/09
6
Civic Government (Scotland) Act 1982
Section 11(2) Statutory Notice dated 14/10/09
7
Taxi Test Report Form dated 15/10/09
8
Invoice from Highland Motor Parts Ltd, Units 12-13,
21 Henderson Road, Inverness, IV1 1SN, dated 8/2/10
9
Receipt from Tesco, Wick, dated 10/7/10
10
Invoice from Caithness Tyre Company Ltd, George Street,
Wick, dated 13/7/10
11
Invoice from Highland Motor Parts Ltd, Units 12-13,
21 Henderson Road, Inverness, IV1 1SN, in the name of Dennis
Campbell, Reiss, KW1 4RR, dated 29/7/10
12
Invoice from Highland Motor Parts Ltd, Units 12-13,
21 Henderson Road, Inverness. IV1 1SN, in the name of Dennis
Campbell, Reiss, KW1 4RR, dated 12/8/10
13
Receipt from Autoparts of Thurso 19B Neil Gunn Drive,
Ormlie Industrial Estate, Thurso, KW14 7QU, dated 19/10/10
(for brake cables, bought after the failed taxi test of 19/10/10)
14
Witness statement, Elizabeth Gardner
15
Witness Statement, Stewart Hiddleston
16
Members Briefing Note and Penalty Points Tariff
TIME LINE FOR LICENCE NUMBER 31 114
Application for Licence, November 2005
Vauxhall Astra, reg no P 181 GMP. Date of first registration 07/08/96.
7/12/05 Council Inspection result:- Conditional Pass
Group B Faults
Paint on offside sill rubbed off
24/5/06 Council Inspection result:- Fail and Dangerous
Group A Faults Off-side rear spring broken
Fuel tank leaking
Near-side headlamp bad image
Group B Faults
C.B. radio insecure
26/5/06 Inspection re-test result:- Pass
17/11/06 Citreon Xsara, reg no SW02 JXF, substituted onto licence.
Date of first regisration 25/07/2002
7/11/07 Council Inspection result:- Conditional Pass
Group B Faults
Off side door dented
MOT result:- Pass. No advisory notice issued.
30/4/08 Council Inspection result:- Pass
30/10/08 Council Inspection and MOT result:- Pass
MOT no advisory notice issued
29/4/09 Council Inspection result:- Pass
14/10/09 Council Inspection result:- Fail and Dangerous
Group A Faults
Nearside track rod end excessively worn
Offside track rod end excessively worn
Offside headlight image not to
requirement
Exhaust mounting in front of silencer
broken
Nearside rear brake binding
MOT also lists:- Parking brake efficiency is below
Requirements. **DANGEROUS**
13 Penalty Points accrued
15/10/09 Inspection and MOT Re-test result:- Pass
19/10/09 Letter re Penalty Points posted to Mr MacPhee
22/4/10 Council Inspection result:- Pass
19/10/10 Council Inspection and MOT result:- Fail and Dangerous
Group A Faults
Offside headlamp aim low**
Offside headlight insecure**
Nearside number plate lamp not
working**
Nearside number plate lamp insecure
Brake pipe going to offside rear
excessively corroded**
Nearside brake indicates brake bind**
Offside hand brake cable broken**
Offside parking brake showing little or
no effort**
(** denotes **DANGEROUS**)
Group B Faults
No First Aid Box
19 Penalty Points Accrued
32 Penalty Points in Total on Licence
20/10/10 Inspection Re-test Result:- Pass
The Highland Council
Trading Standards
Statement of Witness
Surname:
GARDNER
Forename(s):
ELIZABETH ANNE
Title:
MRS
Maiden Name:
Address (H):
Tel No (H):
Trading Standards,
38 Harbour Road,
Inverness
IV1 1UF
Place and Date of Birth:
Tel No (B):
Address (B):
Occupation:
WILSON
01463 228700
Trading Standards Officer
‘Care of’ Address (e.g. students, etc.):
Known as or Alias:
Taken by:
On(Day, Date):
At (Time):
At (Location):
States:Accompanied by Stewart Hiddleston, Assistant Trading Standards Officer, I interviewed Mr Robert
John Stewart McPhee on 9th November 2010 with regard to the 32 penalty points accrued by his
licensed taxi.
I asked Mr McPhee if he had any way of showing that the licensed vehicle had been regularly
maintained, any paperwork for example. He replied that he had invoices for the parts he had bought for
his taxi. He said that Ivor Campbell, Coachbuilder, telephone number 0781 802271 and Richard
Ambler, telephone number 0754 7066782 had both checked over his car through the year. Mr McPhee
said that the guys wouldn’t give him anything in writing but I could ring them both to check what he
said was correct. He said that he didn’t have a pre-inspection check done on his car because it was too
expensive. When he thought something was wrong he had the car fixed. The car is his family car too
and he wouldn’t put his son at risk.
Date:Page 1 of 2
statement.doc
Signed:Committee Report 31 114 EAG
The Highland Council
Trading Standards
Statement of Witness
I advised Mr McPhee that I would contact the men who looked after his car and the decision would then
be made as to whether he would be the subject of a report to the Licensing Committee. Mr McPhee
asked what the Licensing Committee would do. I advised him that if a report was submitted then the
Licensing Committee had three options, they could choose to do nothing, they could choose to issue a
warning or they could suspend the operator’s licence for any period up to the duration of the licence. Mr
McPhee said if he was reported to the Committee he would have to think about his driver’s licence since
it was up for renewal soon. I advised Mr McPhee that having his driver’s licence meant that if he was
reported and if the Committee chose to suspend his operator’s licence for whatever period, he could still
drive someone else’s taxi or lease one. Mr McPhee said he wouldn’t do that.
I rang both men the next day. Ivor Campbell confirmed he carried out bodywork repairs for Mr
McPhee’s car and a little bit of mechanical work. When a bus hit the car in April he’d done the repairs
for that, a door and a wing. In October he’d put a new wing mirror on the car.
Richard Ambler confirmed he works on Mr McPhee’s car. The last time he saw it he’d changed both
brake cables, the driver’s side brake pipe and two indicator bulbs. Mr McPhee comes to his house for
the repair work to be carried out. Mr Ambler has access to ramps at his father’s house. Mr Ambler said
he had been brought up in a breaker’s yard but had no formal training as a mechanic.
Following these discussions I rang Mr McPhee to inform him that he would be the subject of a report to
the Licensing Committee. Mr McPhee said he would fight it.
Date:Page 2 of 2
statement.doc
Signed:Committee Report 31 114 EAG
The Highland Council
Trading Standards
Statement of Witness
Surname:
HIDDLESTON
Maiden Name: N/A
Forename(s):
CHARLES STEWART
Title:
MR
Address (H):
Tel No (H):
Address (B):
TRADING STANDARDS
HIGHLAND COUNCIL
38 HARBOUR ROAD
INVERNESS
Place and Date of Birth:
Tel No (B):
Occupation:
ASSISTANT TRADING STANDARDS OFFICER
01463 228700
‘Care of’ Address (e.g. students, etc.):
Known as or Alias:
Taken by:
On(Day, Date):
At (Time):
At (Location):
States:I was present when Mrs Liz Gardner, Trading Standards Officer, interviewed Mr Robert John
Stewart McPhee on 9th November 2010 because the penalty points total for his licensed taxi had
reached 32 points. When asked if he had any paperwork to show that the licensed vehicle had
been regularly maintained Mr McPhee produced invoices and receipts. He said that Ivor
Campbell, telephone number 0781 8022871, and Richard Ambler, telephone number 0754
7066782, looked after the car but they wouldn’t put anything in writing for him. He gave Mrs
Date:Page 1 of 2
Statement.doc
Signed:Committee Report 31 114 CSH
The Highland Council
Trading Standards
Statement of Witness
Gardner their mobile phone numbers so that she could contact them to confirm they carried out
work on his car. He did not put his car into a garage for a pre-inspection check because it was too
expensive. When something was wrong he had it fixed. His taxi was also the family car and he
wouldn’t put his son at risk.
Mrs Gardner said she would contact Ivor Campbell and Richard Ambler and then let Mr McPhee
know if he was to be the subject of a report to the Licensing Committee. Mr McPhee asked what
would happen if he was and Mrs Gardner explained to him that the Licensing Committee had
three options, they could choose to do nothing, issue a warning or suspend his operator’s licence
for what ever period they chose, up to the duration of the licence. Mr McPhee said he would
have to think about his driver’s licence then, it was up for renewal and there was no point if he
was to lose his operator’s licence. Mrs Gardner pointed out that if he was reported to Committee
and if they suspended his operator’s licence for any period then his taxi driver’s licence allowed
him to drive for another operator or lease a taxi. Mr McPhee said he wouldn’t do that.
Date:Page 2 of 2
Statement.doc
Signed:Committee Report 31 114 CSH
Transport Environmental & Community Services
Trading Standards Unit
Regulation of Licensed Taxi & Private Hire Cars {PHC}
The Penalty Points System and Associated Issues
Members Briefing
Author:
Gordon S Robb, Principal Trading Standards Officer
Trading Standards Unit, 38 Harbour Road, Inverness, IV1 1UF
Committee Briefing Note.doc 25/01/2011
1. The System: What is it?
1.1. This system commonly referred to as the “Taxi & PHC Penalty Points System” is in effect a
method used by Trading Standards staff, as part of their enforcement policy, to determine
whether the behaviour of a licensed Taxi or PHC operator or driver, when examined over a
period of time, has reached the point when the matter justifies referral to the Area Licensing
Committee for their consideration.
2. Why was it introduced?
2.1. After approval by the Council, the system was introduced by Trading Standards in July
2006, in an attempt to improve the general standard of Taxis and PHCs operating within
Highland and to address the concerns expressed by Members of the Civic Government
Licensing Working Group about the level of safety related failures recorded during the
routine vehicle examinations undertaken on Taxis & PHCs by the Council’s appointed
contractor.
2.2. In addition to the real public safety concerns that existed, the time spent by Trading
Standards staff suspending unsafe vehicles from use and chasing up licensees to remedy
other defects found, was seen at a time of ever deceasing resources as wasteful and
inefficient.
3. What is the principle of the system?
3.1. The principle being applied is clear, i.e. by openly communicating to licensees that their
persistent or blatant failure to maintain and otherwise operate the licensed vehicles, or by
their unacceptable actions or omissions as a licensed driver; will result via the Penalty
Points System in their behaviour being routinely scrutinised and them being subject to
sanctions imposed by the Council; will hopefully cause them to regulate their own
behaviour.
3.2. In addition, should they fail to regulate their own behaviour, then the decision making
process by Trading Standards staff to report the matter to the Licensing Committee can be
seen as being fair and transparent. Members can also be confident that a consistent
approach is being taken and that the behaviour of one licensee can be easily compared
against other licensees as well as in relation his/her performance against the standard set
by the Council.
4. How does it work in practice?
4.1. The current Penalty Points Tariff is reproduced on page 3 of this briefing note. The tariff
was drawn up by reference, where relevant, to existing VOSA guidelines on the
categorisation of vehicle safety defects. Other non-safety elements of the tariff were agreed
by the Civic Government Licensing Working Group members.
4.1.1. The tariff was last reviewed by the Civic Government Licensing Working Group
during 2009.
4.2. Different categories of licensee i.e. Operators v. Drivers will be liable to have Penalty
Points allocated for different event/ defects. This is due to the very specific responsibilities
that are applicable to these licensee categories; examples of this are as follows: 4.2.1. A licensed Operator has overall responsibility for the vehicle and will therefore be
liable for safety defects discovered which should have been detected by appropriate
routine maintenance. A licensed driver also has some responsibility for the safety of the
vehicle, but whilst it is seen as reasonable that he/she should carry out an examination
of the vehicle prior to being used and detect tyres that are below the legal tread depth.
He/she should not be liable for defects that would take a mechanic to identify.
1
4.2.2. On the other hand a licensed operator can not be reasonably liable for the failure of a
licensed driver to display his identity badge. The penalty points being allocated only to
the driver in such circumstances.
4.2.3. In some cases e.g. the “bald tyres” scenario, both driver and operator would be
allocated penalty points as both have equal liability.
4.3. Any vehicle defects discovered either during routine periodic examinations; inspections
carried out on taxi ranks and elsewhere while vehicles are in use; complaint investigation
outcomes; and any necessary follow-up action e.g. warnings issued where remedial work
has not been carried out as required etc. are recorded on the Trading Standards activity
database.
This record entry is automatically translated into the relevant number of Penalty Points
according to the agreed tariff.
4.4. Licensees have been provided with guidance on the system and will therefore know that
penalty points will have been accumulated if their vehicle has been found during routine
periodic examination to have defects within a particular category.
Any licensee can however appeal to the Trading Standards operational staff against the
allocation of penalty points and in some cases an adjustment to the allocated points will be
agreed, where there are circumstances that justify this.
A further route of appeal to the Principal Trading Standards Officer is also available, should
this be necessary.
4.5. In other cases where it is intended to allocate Penalty Points e.g. As a result of an
investigation into a complaint; Failure to display a driver’s ID card; The issue of a warning
letter due to non compliance with enforcement notice etc. the allocation of penalty points
will be identified to the licensee at the time of the incident or subsequently in a letter to the
licensee.
5. What is the Formal Action Trigger Point?
5.1. The “Formal Action Trigger Point” has been set at a total of 20 Penalty Points during
any 2 year period.
5.2. If any licensee accumulates a total number of penalty points greater than 50% of this
“Formal Action Trigger Point” they will be formally notified in writing of this fact and given
the opportunity to discuss the matter with a member of Trading Standards staff.
5.3. Should the “Formal Action Trigger Point” be reached or exceeded, the preparation of a
report to the Area Solicitor for relevant Area Licensing Committee would be triggered.
5.4. Licensees are then notified in full of the occurrences that have resulted in the penalty
points that have been accumulated and given the opportunity, before the report is
submitted, to make representations to the Head of Environmental Health & Trading
Standards in relation to the matter.
5.5. A report would only go ahead if the Head of Environmental Health & Trading Standards
was content that such a report was justified.
6. What information will any report to the Licensing Committee contain?
6.1. Any report will identify the licensee against which the case relates. This could be a licensed
operator, licensed driver or both.
6.2. Where a report is made against a licensed operator who is also a driver, the report may
only be in relation to his behaviour in relation to one of the licence categories he currently
possesses.
6.3. The Penalty Points accumulated by the licensee will be identified, but the full facts including
vehicle inspection reports; complaint outcomes; warnings issued and any other evidence
relevant to the case will also be included. It is on the basis of the total evidence and not
simply on the Penalty Points total that any case has been submitted.
2
Penalty Points Tariff
Applicability
Operator
Driver
Taxi
PHC
Taxi
PHC
9
9
9
9
9
9
Category
Safety
Safety
SubCategory
Tyres/Wheels
Tyres/Wheels
Safety
Tyres/Wheels
Safety
Safety
Brakes
Brakes
Safety
Brakes
Safety
Safety
Safety
Steering /
Suspension
Steering /
Suspension
Steering /
Suspension
General
General
Safety
General
Safety
Safety
Lighting
Lighting
Defect
Descriptor
High Risk / Obvious
Med-High Risk / Detectable by
Routine Maintenance
Med Risk / Undetectable by
Routine Maintenance
High Risk / Obvious
Med-High Risk / Detectable by
Routine Maintenance
Med Risk / Undetectable by
Routine Maintenance
High Risk / Obvious
Code
Penalty
Points
TA7
TA5
7
5
TA2
2
TB7
TB5
7
5
TB2
2
TC7
7
TC5
5
TC2
2
TD7
TD5
7
5
TD2
2
TE7
TE5
7
5
TE2
2
TF1
1
9
9
9
9
9
9
9
9
9
9
9
9
Safety
9
9
Safety
9
9
9
9
9
9
9
9
9
9
9
9
Safety
Lighting
9
9
Insurance
9
9
MOT
Not Present (MOT Valid)
TG2
1
9
9
TH1
1
9
Not Present
TI1
1
9
9
If
meter
fitted
Registration
Document V5
Registration
Document V5
Tariff Card
Not in operators name
9
Documents,
etc.
Documents,
etc.
Documents,
etc.
Documents,
etc.
Documents,
etc.
Med-High Risk / Detectable by
Routine Maintenance
Med Risk / Undetectable by
Routine Maintenance
High Risk / Obvious
Med-High Risk / Detectable by
Routine Maintenance
Med Risk / Undetectable by
Routine Maintenance
High Risk / Obvious
Med-High Risk / Detectable by
Routine Maintenance
Med Risk / Undetectable by
Routine Maintenance
Not Present (Insurance Valid)
Not Present / Illegible
TJ3
3
Documents,
etc.
Documents,
etc.
Documents,
etc.
Documents,
etc.
Documents,
etc.
Taximeter
Drivers ID
Card
Drivers ID
Card
Licence plate
Not Present
TK5
5
Incorrectly Displayed
TK3
3
Not Present
TL5
5
Licence plate
Incorrectly Displayed
TL3
3
Taxi Sign
Not Present / Incorrectly
Displayed
Unsealed (Not ‘False or Unjust’
and with Reasonable Excuse)
TM3
3
TN3
3
Safety+
Standards
Safety+
Standards
Safety+
Standards
Fire
extinguisher
Fire
extinguisher
First aid kit
Not Present
TO1
1
Unacceptable Standard
TP1
1
Not Present
TQ1
1
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
If
meter
fitted
9
9
9
9
9
9
9
Meter
3
Applicability
Operator
Driver
Taxi
PHC
Taxi
PHC
9
9
9
Appearance/
Utility
Appearance/
Utility
Appearance/
Utility
Appearance/
Utility
Appearance/
Utility
Appearance/
Utility
Appearance/
Utility
Appearance/
Utility
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
Licensee
Behaviour
9
9
9
9
Licensee
Behaviour
9
9
9
9
Category
9
Licensee
Behaviour
SubCategory
Spare Wheel
External
Cleanliness
External
Appearance
Advertising
Internal
Cleanliness
Internal
Appearance
Controls &
Fittings
Drivers
Cleanliness /
Appearance
Other Breach
of Conditions
/ Act
Other Breach
of Conditions
/ Act
Accident
Damage
Defect
Descriptor
Code
Penalty
Points
Not Present
TR1
1
Unacceptable Standard
TS1
1
Unacceptable Standard
TT1
1
Unacceptable Standard (Honest,
Decent & Truthful)
Unacceptable Standard
TU2
2
TV2
2
Unacceptable Standard
TV1
1
Unacceptable Standard
TW1
1
Unacceptable Standard
TX1
1
Written Warning
TY5
5
Oral Warning/ Written Notice
TY3
3
Failure to Report
TZ2
2
4