A/HRC/13/29 scale could in some cases be helpful.17 In such cases, it might be useful to explicitly recognize the independence of the focal point structure from the parent ministry.18 31. Few States have so far proceeded to formally designate focal points for the Convention and some of the responses received for this study seemed to suggest that such functions would fall “implicitly” amongst the tasks carried out by existing disability focal points within government. However, the good practice of States, such as Guatemala or Slovenia, that have formally designated entities as focal points for the Convention should be highlighted, as well as the practice of States such as Spain that have officially revised the mandate of existing entities to explicitly include the focal point function.19 32. Beside functional focal points in concerned ministries, article 33, paragraph 1 should also be read to refer to States with multiple levels of government, so that disability focal points could be designated at the local, regional and national/federal level. B. Coordination mechanisms 33. In addition to the establishment of focal points, article 33, paragraph 1 also requests States to “give due consideration to the establishment or designation of a coordination mechanism within government to facilitate related action in different sectors and at different levels”. 34. Several States have in place coordination mechanisms on disability issues, predating in some cases the ratification of the Convention. Notwithstanding existing differences, coordinating committees usually include representatives from various ministries and organizations of persons with disabilities, and also other civil society organizations, the private sector and trade unions. Their mandate often focuses on policy development, promotion of dialogue in the disability field, awareness-raising and similar functions. Often these committees have a staffed secretariat, in several cases housed within ministries of social welfare. 35. As noted in some of the submissions received, effectiveness of existing coordination mechanisms is often low, according to organizations of persons with disabilities.20 Lack of a clear legal mandate, lack of resources made available for the functioning of the coordination mechanisms, limited involvement of persons with disabilities or exclusion of persons with certain types of disabilities, are some of the obstacles most commonly faced by existing structures.21 Furthermore, laws establishing coordinating structures have often not been operationalized through the adoptions of rules and regulations. In some cases this also applies to coordinating frameworks established by States upon ratification of the Convention, with the result that such structures are in reality not operational or functioning. 17 18 19 20 21 8 See submission by New Zealand at: http://www2.ohchr.org/english/issues/disability/ docs/NewZealand.doc. See submission by the United Kingdom Equality and Human Rights Commission to the Joint Committee on Human Rights, at http://www.equalityhumanrights.com/legislative-framework/humanrights-submissions/rights-of-disabled-people/submission-to-the-joint-committee-on-human-rights/. See submissions by Guatemala, Slovenia and Spain at http://www2.ohchr.org/english/issues/ disability/submissions.htm. Submission to this study by the International Disability Alliance, available at http://www2.ohchr.org/ english/issues/disability/docs/InternationalDisabilityAllianceDACRPDForum.doc. See for example South-North Center for Dialogue & Development, Global Survey on Government Action on the Implementation of the Standard Rules on the Equalization of Opportunities for Persons with Disabilities, pp. 74 and 75, available at http://www.escwa.un.org/divisions/sdd/news/ GlobalSurvey_Report_Jan30_07_ReadOnly.pdf. GE.09-17748