Response to consultation
from
The Joint Public Affairs Committee, convened by the United Kingdom Institute for Conservation

GENERAL COMMENTS

Introduction and Aims of the Scheme
The Designation scheme has brought significant benefits to museums. It has raised the profile of collections and collection care and focussed funding. We welcome the renewed emphasis now being given to the scheme. We also give a qualified welcome to the extension of the scheme to archives and libraries.

We continue to be concerned about the fate of non-designated museums and collections and we would welcome concrete evidence being compiled by Resource to demonstrate that non-designated museums and collections have not suffered as a result of the designation scheme. We wonder whether greater emphasis could yet be put on the concept of a distributed national collection which would recognise that pre-eminence can apply to objects and collections which have not been officially designated and which are just as much worthy of celebration, funding and long-term preservation for the nation.

There are significant differences between the domains, which should be acknowledged in the preamble. The collections held in libraries and archives are subject to direct physical use in a way that museum collections generally are not. This places particular demands on collection care. Nevertheless, it could be claimed that the principles underlying designation can be applied in these domains.

Our concern applies especially to archival collections, since by definition these are usually unique, irreplaceable records that constitute legal as a well cultural continuity. Designation could impose an artificial hierarchy to the possible detriment of many collections.

In addition to these fears, we naturally would wish to see any designation-related funding increased to accommodate an increase in the number of collections designated, once an extension to cover archives and libraries is made. Simply spreading the existing support for museums across the wider domain will make very little contribution to improvements in any of them.

While designation can clearly raise the profile of a collection or institution with a local authority, there is a serious risk that collections that are denied designation, once having been applied for, are badly viewed, even ignored by their local authorities. Again, a Resource survey of the fate of applicants denied designation would be a useful strategic tool.

We also note that even designation is not a guarantee of the survival of collection care in hard times (witness for instance Northampton Museum), which emphasises the need for Resource to promote the significance of Designation with host authorities. Best Value reviews rarely take account of the need for long-term care plans and support but instead focus on short term funding priorities, in spite of national recognition of the importance of collections. Indeed such national recognition can risk the loss of local authority support since the latter incorrectly assume that national sources will take up the costs. We hope that the promotional and communications strategy for Designation will take this into account.

We think it would be helpful in the preamble to include reference to the intimate link between pre-eminence of collections, public services and collections management Such reference would be along the following lines:

In order to ensure access of the highest quality, commensurate with the significance of designated collections, it is essential that collections are cared for to the highest standard so that they will exist for as long as possible, so that they can be presented in the most attractive condition and so that their significance can be fully interpreted and appreciated.

On Page 4 reference is made to lending objects. Somewhere in the document reference should be made to the fact that lending objects places particular demands on collections management services, particularly conservation and that any relevant challenge funding should include specific support for these costs inherent in getting objects on loan and widely accessible.

There is no mention of any inspection regime to ensure that evidence claimed in the application actually exists on the ground. The indication is that the application process depends on pieces of paper and the Committee. We assume that there is a visiting regime, and this could be referred to. Similarly there is no mention of a regime to ensure subsequent monitoring for designated collections to assess whether or not they are maintaining the standards claimed, or achieving the standards to which they claim to aspire at the time of application. We are uncertain whether Resource operates such a regime. Without it the credibility of the scheme could be undermined. UKIC and the conservation community can assist with such a regime.

DETAILED COMMENTS
Notes for new applicants

Page 5, Para 1: The scheme is committed to maintaining the highest possible standards. It is not clear whether this is a reference to the collections themselves - since this is what the paragraph is all about, or whether it refers to the highest standards throughout the institution.

Eligibility
2.2.1 Museums
While we welcome reference to high standards of ethical practice, we find it arbitrary that this aspect should be given prominence for eligibility over and above all the other many aspects of a museum service. It also seems inconsistent that similar references to ethical practice are not included for archives and libraries.

2.2.2 Archives, 2.2.3 Libraries
We similarly find it inconsistent that the emphasis for archives and libraries should be on care of collection standards, whereas this is not mentioned under Museums.

It is important to refer to National Archives certification and approval requirements for archival collections as well as referring to Registration for Museums.

2.2.4 Joint Applications

• A uniform or integrated approach to intellectual access. This appears to be the only place where this phrase is used, and it is hard to see why intellectual access as opposed to other kinds of access should be singled out here. Should it simply read ‘integrated approach to access’.
  
• An ‘internal’ loan system and regular loan arrangements… Reference should be made here to the extra demands on collection care that such arrangements demand, and assurance sought that such services are available.

3.0 The Designation Criteria

…Many successful applicants may not currently satisfy the “desired” standards for public and collections services. Here, and elsewhere in the document, there is too much emphasis on how easy it is to achieve designation without reaching the desired standards. While we recognise the need to encourage applicants, and also that designation will enable services to be improved, it is not appropriate in a scheme that promotes the very best collections to be simultaneously rewarding less than satisfactory services. A shift of emphasis here and in similar references would be sensible.

..but will demonstrate that they are aware of the areas where improvement is needed, and can provide evidence of their intention to address such weaknesses in formally approved policy and related strategic planning documentation. This lacks sufficient bite. Anybody can produce evidence of good intentions. It is another matter whether these are carried out. It should be clearly indicated that the Designation inspection regime will be following up at regular intervals to ensure that good intentions are implemented.

There appears to be no mention of this aspect within the document, as mentioned above. The scheme needs teeth if it is to be really effective.

3.1 The Collections Criteria
Significance
We believe there is work to be done on the development of tools to assess significance, particularly since it is held to be one of the principal reasons for designating a collection. Work by English Heritage to do this for the built heritage is already well advanced. The MA and UKIC have suggested to Resource that we assist with a pilot study to explore how this could be taken forward. This would be of relevance not only for Designation.

3.2 The Collections Management/Public Services Criteria
Here and elsewhere in the document we cannot see why these are joined with a forward slash. The use of “and” would give these topics their proper weight.

Para 1: It is recognised that many will have weaknesses in some areas when the application is made See comments above about reinforcing low standards.

stewardship It was our understanding that this term is no longer being used by Resource, perhaps because of its ill-defined qualities. For instance, does stewardship include collections management? If so, then it is partly redundant here. If it extends e.g. to security, then perhaps this should be separately identified.

In this context the assessment will primarily consider public services to be those which relate closely to the use of collections. Not entirely sure what this means. Is it meant to ignore e.g. catering facilities, education activities, shops etc?

Para 3: While they may only currently meet “essential” standards in these areas….. Again an emphasis on shortcomings, at odds with a scheme and an organisation (Resource) that espouses the highest standards.

The Committee… Not I think referred to elsewhere. It would be helpful to explain the way in which the scheme is administered and by whom judgements are made. Does the Committee include preservation professionals?

Appendix 1

The text in the pre-amble neglects any mention of collections management standards.

Quality : Evidence
If your collection includes artefacts they should be supported by high quality relevant contextual material. It is unclear what is meant here. What is a collection if it is not a collection of artefacts or objects (or do you mean something else)? Are the contents of archives and libraries ‘artefacts’? If not, why should artefacts be singled out for contextual material? This statement needs to be clarified.

Collection Management/Public Services (replace / with ‘and’ )
Why are MGC Standards only listed as Desirable? We think they are essential. Are they not part of Registration standards?

We welcome the emphasis given to Resource’s Benchmarks document

Benchmarks… is italicised in one column, not the other.

Applicants will be expected to demonstrate that they are aware of and are working towards the desired standards. This is in the column “Desired standards”. The implication then is that they do not have to meet desired standards. Yet there is no time-scale given for achieving them. We recommend a realistic times-scale be stated, such as three years, at which time progress will be assessed, and if not met within five years designation might be withdrawn (for example).

Documentation and internal research and communication related to the collection Why internal only?

At least one appropriately qualified member of staff, with specialist knowledge of the designated collection. This could be wholly inadequate in relation to a very large collection. There should be some proportionality introduced here, i.e. the number of members of specialised staff should be in proportion to the size of the collection.

Presumably it is deliberate policy not to refer to other categories of staff, e.g. public service staff or collections management staff? Is this because this would be taken care of by the embedded registration standards?

A range of general and scholarly publications, informative website. Evidence that the collection is actively used for teaching and research. It is staggering that that this requirement can be classed as only “desirable”.

In general we feel this page needs considerably more work and refinement.

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