Human Rights and Disability A Manual for National Human Rights Institutions 4.3. GENERAL COMMENTS, OPINIONS, STATEMENTS AND GUIDELINES Rule 47 of the CRPD Committee’s Rules of Procedure allow it to adopt ‘general comments’. These are important for NHRIs as they clarify the Committee’s position on complex questions of policy and practice regarding implementation of the UN CRPD. They will also likely inform the way the Committee appraises the performance of States during its examinations. The Committee also produces statements to engage with and seek to influence topical developments, to reinforce its position or to encourage action. These statements can be useful for NHRIs acting at the international level or within their own States. The Committee has also issued guidelines regarding its working methods and on how different actors, including civil society and NHRIs, can engage with its work. At the time of writing, the Committee has published four general comments. General Comment No. 1 (2014) concerns article 12 on equal recognition before the law; General Comment No. 2 (2014) concerns article 9 on accessibility; General Comment No. 3 (2016) concerns article 6 on women and girls with disabilities; and General Comment 4 (2016) concerns article 24 on the right to inclusive education.138 The Committee is also planning a general comment on article 19 (living independently and being included in the community). Two NHRIs made submissions in relation to the general comment on education. The Danish Institute for Human Rights described its ‘gold standard’ indicators on education and highlighted the importance of enforcing rights though complaints. In its submission, the Equal Opportunities Commission of Hong Kong focused on assessment, (in)sufficient training for teachers and other supports.139 With respect to the proposed general comment on community living, the Committee received written submissions from the Belgian Interfederal Centre for Equal Opportunities, the New Zealand Human Rights Commission and the European Union Fundamental Rights Agency (not strictly an NHRI but a close analogue for the EU).140 The seven-page submission from Belgium focused on a culture of institutionalisation and the lack of an overall policy and funding for community living. It concluded with a number of succinct and useful “points for attention for the general comment”. The five-page submission made by the New Zealand Human Rights Commission connected article 19 (community living) with article 12 (supported decision-making). This is especially innovative and should have an impact when the Committee finalises its general comment. The three-page submission of the EU Fundamental Rights Agency drew attention to its impressive set of indicators on article 19 and its ongoing work on the practical steps that need to be undertaken to move from institutions to community living. The annex usefully directs readers to the rich literature the Agency has produced on the topic. This snapshot reveals a strong degree of engagement by NHRIs in the work of the Committee to prepare its general comments. The Committee has also published the following statements and guidelines, which are available on its website: • Guidelines on Article 14 of the UN Convention on the Rights of Persons with Disabilities: the right to liberty and security of persons with disabilities (2015) • Statement of the Committee on the Rights of Persons with Disabilities on including the rights of persons with disabilities in the post-2015 agenda on disability and development 60 138 The four general comments are available at www.ohchr.org/EN/HRBodies/CRPD/Pages/GC.aspx. 139 These and other submissions are available at www.ohchr.org/EN/HRBodies/CRPD/Pages/DGDontherighttoeducationforpersons withdisabilities.aspx. 140 These and other submissions are available at www.ohchr.org/EN/HRBodies/CRPD/Pages/CallDGDtoliveindependently.aspx.