THE threat of whole school inspection and the introduction of an appeals system which, they consider unsatisfactory are among the issues contained in the Education Bill that are causing teachers and school principals the greatest concern. The fact that the Bill is being hyped as a pro parent - and therefore in their eyes anti-teacher - document is making matters worse. Understandably, teachers are feeling bruised and angry.

Of all the teacher unions, the ASTI is the most vociferous in its condemnation of the Bill which, it says, will present schools with a bureaucratic nightmare, create a bonanza for lawyers and reduce teaching time. Teachers and school principals are also worried about the fact that the inspectorate is for the first time to be placed on a statutory footing. "Giving a legal force to the inspectors' activities gives more power to the Minister," says John White, the ASTI's assistant general secretary.

Under the Bill, the inspectorate is to be split into two parts - regional and central. The central inspectorate's responsibilities will include the formulation and development of national education policies. At regional level each school will be allocated an inspector who will act in a supportive and advisory capacity. Regional inspectors too will be attached to the regional education boards and will also work in teams to conduct whole school inspections.

These latter inspections will involve the evaluation of management and the quality and effectiveness of both teaching and learning. School principals say that the Minister has given into union pressure and there is now less emphasis on the inspection of teachers than was originally intended. School management will now bear the brunt of inspections, they say.

No inspector who is acting as an advisor to a school will be involved in the inspection of that school. According to Dr Don Thornhill, secretary of the Department of Education, this will enable schools to forge better relationships with their inspectors. In their day to day dealings with inspectors teachers will feel less threatened.

However, this issue is causing problems for the INTO. Only an inspector who has been working closely with a school for a considerable time and understands its needs is suitable to evaluate a school, argues John Carr, the INTO's general treasurer. National schools enjoy regular contact with Department inspectors - Carr describes the relationship between schools and inspectors as "a partnership model".

At second level, however, because of a shortage of inspectors, visits are a rarity. "I've been a principal for nine years," says Michael McCann, president of the Secondary Schools Principals' Association, "and we've been visited by an inspector only twice. Many teachers have never even seen an inspector."

At one time ASTI members refused to allow inspectors in the classroom while they were teaching. The ASTI is concerned that the inspections proposed in the Bill will be intrusive. "It would be a serious and retrograde step if we returned to the days when teachers trembled at the prospect of an inspection," says White.

Meanwhile, the TUI's general secretary, Jim Dorney, is adamant that, while members accept that they are accountable to the inspectorate, any changes in the present procedures will have to be negotiated. "It must be done through negotiation or agreement," he says, "or we won't play ball."

The TUI's agreement on vocational school inspections dates back to 1985 and includes the organisation of the school, the learning environment, the interaction of the school with the community and the quality of teaching and learning. There are no similar inspection procedures in any other second level sector, according to the TUI.

Although the term "whole school inspection" is omitted in the Bill, the Department is drawing a connection between the Bill and its "Whole School Inspection Consultative Conference" booklet. However, educators are dismayed at this and argue that this booklet is seriously flawed.

There is also concern that whole school inspection has been placed ahead of the school plan. Teachers are particularly worried about the section in the booklet covering performance indicators and performance criteria. In this the quality of school management, school planning and the quality of teaching and learning will be measured on a scale which runs from very good, through good and fair to weak.

There is widespread concern that league tables will be introduced but the Minister has promised that this will not happen. According to a Department spokesperson the booklet is a consultative document and will be revised.

"Whole school inspection is about achieving co operation," says the official. It won't be imposed by the Department but will be brought into play by consultation and agreement between the Department, teachers the regional education boards and the managers.

Principals are also concerned that aspects of the Bill including whole school inspection and the creation of the school plan (the onus of which falls upon boards of management) will place extra burdens upon them. Principals will need extra administrative and middle management support if they are to complete this work, they say.

"Much of the administrative work carried out by principals could be done by others," says Diarmaid O Murchu, president of the Association of Community and Comprehensive Schools. "I would like to see support structures for principals to enable them to give more time to educational planning." Teachers too need support, he says, since their jobs have become more difficult in recent years. "Teacher morale needs to be supported in a way that has not been recognised," he says.

Michael McCann says that the stated objectives of whole school inspection are fine "but you have to consider the practicalities. Whole school inspection has been going in the UK for a number of years and they discovered that the findings of the inspectors coincided with principals' appraisals of situations. No principal needs an inspector to tell him if a teacher is under performing. If you're going to identify weaknesses you need a system to deal with those weaknesses."

Educators are doubtful whether the Department will be able to supply enough inspectors to carry out the duties outlined in the Bill. Currently at second level there are 55 inspectors dealing with almost 800 schools. The Association of Community and Comprehensive Schools estimates that to carry out a thorough whole school inspection of every second level school in the country every four years, the Department would have to employ an extra 70 inspectors.

However, the Bill allows for the secondment of teachers for short term periods to the Department to work as inspectors in the schools. The unions are in favour of this. "There's a credibility factor here," says Dr Thornhill. "Teachers prefer to take advice from other teachers rather than from people who have been out of the classroom for years."

By seconding teachers for short term periods the Department will also ensure a steady flow of personnel and restore gender balance. At the moment most inspectors are male. It's understood that that the Department has had difficulty ink recruiting inspectors in recent times and very few women apply, fearing that the job will involve a lot of travel or a move away from home.

THE BILL allows for appeals by parents or by students over 6 years of age in cases where "a decision of a teacher or other member of staff of a school materially affects the education of a student". These appeals are to be made first to the board of management and then to the regional education boards.

According to Michael McCann, the appeals system is "the single most upsetting part of the whole thing". Schools fear that unless the Bill is tightened considerably, they will be involved in countless frivolous and time consuming appeals and that teachers will spend more time involved in appeals than in the classroom.

"We're concerned that reference is made to the decisions of teachers rather than schools," says Rose Malone. "The kind of decisions that effect students would be made by the school rather than the teachers." McCann is also concerned about the phrase "materially affect" which, he says, needs to be defined.

"If you give 16 year olds the opportunity to object you could undermine the whole discipline structure in the school," says Brian Cannon, principal of Malahide Community School, Co Dublin. "If you decide to suspend a pupil, who then appeals against that decision - is he allowed - to stay on the premises? People have a right to appeal but sometimes you need to be able to take summary action."

As it stands it's possible that parents and students could appeal decisions on Leaving Cert levels. Cannon points out that in Britain students are now taking legal action because they feel that they failed to achieve the results they deserved. There is real fear that this could happen here. Already parents of students who have not been allowed to take honours Leaving Cert have taken legal advice on whether they could insist on their offspring taking the higher levels.

There is also concern that the Bill makes no provision for teacher representation in any appeal process. "We feel that the appeals system as outlined will be cumbersome and that teachers should be part of any appeals process," says the INTO's John Carr. "Even in the Labour Court there is an employees' representative. You can't have confidence in an appeals procedure which lacks employee representation."

Major complaints against teachers should be heard by a teaching council, he says. "It's regrettable that the Minister didn't take the opportunity to establish a teaching council so that teachers themselves could be responsible for the regulation of their profession.

THE creation of the regional education boards is a further source of concern. Educators say that extra money must be found to set them up and that schools should suffer no reduction in funding.