The Howard League for Penal Reform, says not enough attention has been paid to the issue of restraint and the safety of children in the consultation, which is being led by Ofsted.
It adds that there is “scant detail” as to why the consultation questions are being asked, what the drivers for change are, and how inspections will be carried out in practice.
The Howard League’s consultation response points to the fact that two children, Gareth Myatt and Adam Rickwood, have died in STCs, while Youth Justice Board statistics show incidents of restraint in the youth secure estate increased between 2009/10 and 2010/11.
The charity also criticises Ofsted for failing to consult or engage with expert organisations in the field of child custody and children generally.
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