HABONIM DROR’S COMMENT ON THE DRAFT REGULATIONS RELATING TO MINIMUM UNIFORM NORMS AND STANDARDS FOR PUBLIC SCHOOL INFRASTRUCTURE GG 36062; GN 6 of 2013; 8 JANUARY 2013
We are young and emerging leaders of Habonim Dror Southern Africa - a secular Jewish youth movement. Our priorities include equality and service to humanity. A primary aim of ours is to achieve social justice in communities, through outreach, advocacy, activism and education.
We are concerned fundamentally with educating youth and developing young leaders. To us it is critically important that we recognize the education crisis in this country and strive to achieve equal and quality education for all.
Thus, we feel obligated to comment on the published draft of Minimum Norms and Standards for School Infrastructure.
Although we are pleased that the Bill has been drafted we believe it needs to be drastically improved.
Firstly, the draft is generally unspecific, vague and open-ended. It is unclear what qualifiers such as “adequate” actually mean; it speaks of “educational spaces” without specificity and talks only of “progressively” instituting these norms and standards. It appears that instead of creating a set of standards which is honestly intended to create accountable governance and implementation, they are designed with loopholes and ambiguity to reduce that accountability.
Perhaps most serious in this regard is the allowance it makes for government to use time and resource constraints as excuses for lack of delivery. The right to education is not “progressively realisable”, such that government can decide the timeline for satisfying these rights, and only do so when resources allow. It is an immediate right, and should be treated with urgency. The draft must include deadlines and targets for implementation – not simply a deadline for the publishing of non-binding guidelines.
Secondly, we think the following points mentioned in the draft itself are distressing.
• The draft refers to “Education spaces” without specifying whether these spaces are indoors or outdoors, their capacity, or their structural requirements.
• The draft only requires a school to have either a library, or a computer center or a science laboratory. We feel every school is entitled not merely to one of these, but to all of them.
• The draft speaks vaguely about adequate sanitation, while not specifying:
o the acceptable pupil to toilet ratio
o the definition of an adequate toilet
o the required accompanying structures
• The draft does not require that a school has access to electricity, it merely mentions “some form of energy”.
• The draft isn’t clear on the requisite means of communication which a school must have. We also feel it should be all schools which are legally required to have access to communication, and not only schools for which the government deems it “practicable”.
• The draft is unclear on the process by which the norms and standards themselves are revisited and revised.
• The draft must specify which laws it is referring to when it speaks of “relevant” or “applicable” laws.
• The draft must be more specific in its stipulation of what constitutes an acceptable sports field, as we feel the current provision is insufficient. Extracurricular activities such as sport are essential for youth safety and development, often even more so in poorer communities, and such provisions must therefore not be sidelined.
Thirdly, a number of important areas go unmentioned by the draft.
• There is no requirement in the draft to immediately fix school structures which are unsafe.
• The draft does not include requirements for school security.
• The draft does not specify maximum school capacity.
• The draft does not specify a minimum size of school grounds.
• The draft ignores the necessity for space for cultural activity such as music and/or drama.
• There is no explanation of how and who it is that will be monitoring that these standard are and continue to be met.
• The draft does not explain provisions in regular schools, or otherwise, for wheelchair access and other infrastructural issues of accessibility for those with disabilities.
• The draft does not mention classroom ergonomics: lighting requirements, ventilation requirements, or acoustic requirements in classrooms.
We therefore feel the points outlined show that the draft does not address the current problems in the South African education system. We believe serious change needs to be made in order to make these norms and standards a tool to equalize and improve our school system. We have gone over the 2008 draft and believe that there is much detail there which needs to be included in the current draft.
The current draft sends a cynical and disheartening message to South African youth. It says that the government doesn’t sincerely care about their education, and won’t properly commit itself to fixing what most definitely is a crisis.
We hope that the next draft sends a stronger, more hopeful and committed message.
As members of Habonim Dror Southern Africa