Guidance

Record keeping during enforcement visits (accessible)

Updated 6 March 2024

About the guidance

This guidance tells Immigration Enforcement officers how to maintain and use their digital pocket notebook (DPNB) that is contained in their PRONTO (police reporting and notebook organiser) enabled mobile phone.

For limited instances where PRONTO is unavailable, there is a section on how to use and maintain pocket notebooks for both officers and managers (PNBs).

Contacts

If you have any questions about the guidance and your line manager or senior caseworker cannot help you or you think that the guidance has factual errors then email Enforcement policy.

If you notice any formatting errors in this guidance (broken links, spelling mistakes and so on) or have any comments about the layout or navigability of the guidance then you can email the Guidance Rules and Forms team.

Publication

Below is information on when this version of the guidance was published:

• version 4.0
• published for Home Office staff on 15 February 2024

Changes from last version of this guidance

All references to the paper pocket notebook (PNB) have been removed from the main body and placed into a contingency section at the end of the guidance.

References to obsolete systems have also been removed.

Use and control of digital pocket notebooks (DPNB)

This page gives Immigration Enforcement officers general guidance on the purpose and control of digital pocket notebooks contained in PRONTO (police reporting and notebook organiser).

The purpose of a digital pocket notebook (DPNB)

You must always carry your digital pocket notebook (DPNB), which is contained in the PRONTO App on your phone, when on duty outside the office. You must use it only for official purposes. The information you record may be used for evidential purposes and, whether or not it is intended to pursue a criminal prosecution, the standard of record keeping must meet the necessary standards in order to allow for that possibility and to ensure consistency across all enforcement investigations.

During an investigation or operation you must use your DPNB to:

• comply with the requirements on record keeping in the Code of practice issued under the Criminal Procedure and Investigations Act 1996 (CPIA)
• meet the ‘best’ procedures for evidence
• record any significant event

You are required to make an evidential record when you:

• observe, obtain or witness any material that would be considered relevant to any criminal investigation
• take action to secure evidence after witnessing events

You must maintain a DPNB to record evidence, throughout an ongoing investigation, of what was:

• seen
• found
• heard
• done

You must expect your DPNB to be seen by third parties and your supervising officer will be able to view the content of any form once you have completed it. Your DPNB may be used to provide supporting evidence in witness statements and may be needed if you give evidence in court.

Your notes also:

• confirm the evidence was gained at the time rather than at a later date
• help colleagues, management and lawyers to see what evidence you are able to present in court

Lost or stolen PRONTO-enabled phones

What the officer must do

If your PRONTO-enabled phone is lost or stolen, you must:

• report the loss or theft to the manager on duty as soon as possible
• report the loss to the IT helpdesk so that the relevant safeguarding procedures for lost assets are followed

In all cases, you must assume the DPNB contains information that must not be in the public domain.

What the manager must do

When you have been told, you must:

• report the loss or theft to Home Office Security
• confirm that the loss has been reported to the IT helpdesk

Contingency plan in the event the PRONTO-enabled phone is lost, stolen or not working

In the event that you are not able to access your digital pocket notebook on a visit because of network access issues, then you must complete the DPNB as soon as possible after the visit.

Full details on what to do in different scenarios with limited or no access to PRONTO can be found here Pronto contingency guide.

Retention, storage and disposal of PRONTO-enabled phones

Retention of content in digital pocket notebooks

Evidence related to a criminal investigation must be retained until at least a decision is made on whether to institute proceedings against a person for an offence, see paragraphs 5.7 to 5.10 of the CPIA Code of practice.

DPNBs containing information related exclusively to administrative investigations must also be retained where they may relate to arrests, searches and seizures in cases that are under ongoing consideration. DPNB content may be required in the investigation and rebuttal of complaints and allegations.

All the contents and data recorded within the PRONTO app of a DPNB will be saved and stored on a secure database and retained for at least 6 years. Recent information up to one month old will be held in the PRONTO app on the phone.

Making digital pocket notebook entries

This page gives Immigration Enforcement officers general guidance on how to make entries in their digital pocket notebook (DPNB) contained in PRONTO (police reporting and notebook organiser).

Presentation and constraints

Your notes must follow a minimum standard of detail which will be subject to assurance checks. In completing your notes, you must:

• make entries in a factual manner
• make entries at the time of the event being recorded or, where circumstances prevent this, as soon as practicable thereafter

At the conclusion of each shift, you must ensure that you end your shift on PRONTO to close that day’s digital notebook entries. The contents of your DPNB on your PRONTO app will be available to view on the PRONTO webmanager by the assurance team and relevant lines of command in your team.

Effective use of the index

The PRONTO app uses shifts to organise the forms you have completed. You cannot capture data in your DPNB until you have started your shift. Once written, data on your PRONTO app is time-stamped and, for audit reasons, cannot be changed or erased.

You can search previous shifts on PRONTO to see the forms you completed during those shifts. The index acts as a useful reference tool when trying to find past entries in your DPNB, particularly when referring to your notes in court.

Complete and incomplete forms

When you are sure that no further details need to be added to a form in the DPNB, you can submit the form by marking it as ‘complete’.

Marking a form as complete means:

• the form can no longer be changed
• details on the form will form part of the visit report

Forms that are not completed will show as incomplete. However, they should not be left as incomplete and should be ‘Set invalid’.

Incomplete and invalid forms can still be viewed on the web manager if required, but will not form part of the visit report. This ensures that there is a clear audit trail within the PRONTO App.

If a Form has been completed incorrectly or in error by an officer, it can be ‘Set invalid’. This does not mean the Form is deleted. Reasons have to be provided on the web manager for the Invalidation and it should be clear why the action was taken.

Sign off after duty

For the purpose of this guidance, an operational visit is defined as any visit or series of visits taking place during the course of a single rostered duty.

When using a DPNB, you must close your shift in the PRONTO app following every operational shift. This is important, as it helps to index the visits and makes it easy to search records in the future.

See also Managers’ oversight of enforcement record keeping.

Recording diagrams

These can be very useful to remind you about a certain event or location, for example a room layout. Where relevant, you must refer to any diagrams you make in your DPNB in any later witness statement.

See also:

• arrest and restraint in connection with recording cautions and the statements of suspects and witnesses
• enforcement interviews

Recording key events during enforcement operations

This page gives Immigration Enforcement officers guidance on how to make certain specific types of entries in their digital pocket notebook (DPNB) on their PRONTO app.

Types of event to be recorded

You must use DPNBs to record all significant events. It is not possible to provide a comprehensive list of what may be ‘significant’ but the following is the minimum information that you must include within your notes.

Minimum information required before the visit:

• details and information regarding intended enforcement visits, including day and time of visit and nature of visit except where other primary (original note) record exists, such as operational order or on PRONTO:
  • if the records are amended following enforcement action or visit, a full audit trail will be available on PRONTO for example additional officer attendance at the scene
• circumstances of the visit (entry by consent, warrant or Assistant Director (AD) letter)
• confirmation of officer in charge (OIC) personal protective equipment (PPE) check

Minimum information required during the visit for the PRONTO report:

• details of those present at the scene (excluding officers listed on operational order)
• means of entry, including service of warrant or Assistant Director (AD) letter, including where relevant, recording the officer identifying themselves and producing their warrant card
• summary of anything of note during visit, for example:
  • details of your encounter of a person suspected of illegal working or renting without permission
  • any safeguarding considerations
  • actions in regard to minors or adults at risk
• details of any questioning of persons and brief justification of action
• a record of what was said at the scene (in direct speech where possible), see also Arrest and restraint and enforcement interviews
• outcome of questions and justification of non-action if appropriate

• whether any consent was obtained to provide fingerprints for the GRABBA (mobile phone attachment), the details of the relevant power used, and the justification for doing so

• full details of arrested person, including grounds for arrest and relevant power used
• location of arrest (if applicable)
• details of any force used plus justification
• details of any injuries, illness or complaints
• details of any children encountered, including:
  • the circumstances of the encounter
  • full consideration of any safeguarding issues
  • if relevant, justification for not taking any further safeguarding action Minimum information for any search and seizure event:
• record of searches and justification
• description of any relevant items seized
• details of damage caused and steps taken to repair or secure property

Recording events

When using a DPNB, the time and date that you record an event will be automatically time-stamped and will therefore show if you are making the note as the event is taking place.

If you are not making a DPNB entry at the time, but as soon as possible afterwards, you must:

• note the time the event took place
• briefly explain the reason for any significant delay in making your notes

Recording a search

In all cases, notes of the search must be to an evidential standard. In all cases the search officer must record in their DPNB:

• the address of the searched premises
• the date, time and duration of the search
• the authority used for the search
• if the search was made in exercise of a statutory power to search premises without warrant, the power which was used for the search and the reasonable grounds required to justify the search
• the name of the officer in charge of the search
• all other officers and authorised persons who conducted the search
• the names of any people on the premises, if they are known
• any grounds for refusing any request from the occupier to have someone present during the search
• a list of any articles seized or the location of a list and, if not covered by a warrant, the grounds for their seizure
• whether force was used, a description of the force and the reason
• details of any damage caused during the search, and the circumstances
• whether the ‘Notice to Occupier’ was given to the occupier
• if applicable, the reason it was not practicable to give the occupier a copy of the ‘Notice to Occupier’
• when the occupier was not present, the place where copies of the ‘Notice to Occupier’ and search warrant were left on the premises

For guidance on conducting a search see Search and seizure.

Recording an incident

In addition to recording an incident in your DPNB, you also need to complete a formal incident report in accordance with health and safety policy on Accidents and incidents at work.

If there is necessary discussion following an incident between those who have witnessed it, then you must record the fact that the discussion has taken place, and the reasons, in your DPNB. This is necessary to guard against accusations that witnesses have colluded in recording an incident.

For further information on incidents which include any use of force or pursuit, see Arrest and restraint.

Recording intelligence and sensitive information

When a person is signing a form on the DPNB, they will only be able to see the contents of that form.

These guidelines apply to:

• information requested for intelligence reasons
• personal data recorded in relation to a person questioned during any immigration enforcement operation, this may include, but is not restricted to:
  • biographic data
  • medical information
  • statements made by potentially vulnerable adults in relation to forced marriage and modern slavery
• surveillance tactics used to gather information
• any other information thought to be sensitive, for instance, because the Home Office has a duty to protect personal data under the Data Protection Act 2018, or there is a need to ensure the safety of suspects, witnesses and officers present

Official - sensitive: start of section

The information in this section has been removed as it is restricted for internal Home Office use.

Official - sensitive: end of section

Witness statements in administrative cases

A witness statement is a document recording the evidence of an officer or a person to whom you have spoken, which is signed by that person to confirm that the contents of the statement are true. In general, the statement should only contain information on what the witness saw, and not what others have said to them.

However, it is important to record anything that may open up a new line of enquiry or help in corroborating other information.

Witness statements are a routine means of recording evidence that might be presented in court and can be useful where a witness changes their evidence to demonstrate that they have previously provided a different version of events.

Inconsistent accounts may cast doubt on the witness’s credibility.

In non-criminal investigations, such as administrative breaches of immigration law, marriage enquiries or cases where evidence is being sought to support a civil penalty, it may be appropriate and useful to take a voluntary witness statement.

These may take the form of:

• narrative statements:
  • made by people who have played a part in the event at issue
• production statements:
  • made by people who have access to computer systems or documents

Where the statement is not made in English, you must provide a translation in a separate statement by a translator or interpreter.

When completing a witness statement to provide supporting evidence in a case of an administrative immigration breach, you must avoid any reference to confidential information or sources. You must ensure that:

• it is concise and to the point
• as far as possible, it is in their words

The statement should, where possible, deal with matters within the witness’s direct knowledge. Relevant hearsay evidence may be included in a witness statement related to an administrative immigration decision, but an immigration tribunal is entitled to attach less or no weight to it.

A civil witness statement must, if practicable, be in the intended witness’s own words, express the statement in the first person and state:

• the full name of the witness
• their residential address or, if they are making the statement in their professional, business or other occupational capacity, the address at which they work, the position they hold and the name of their firm or employer
• their occupation, or if they have none, their description
• if appropriate, the fact that they are a party to the proceedings or are the employee of such a party

A witness statement must indicate:

• which of the statements in it are made from the witness’s own knowledge
• which are matters of information or belief
• the source for any matters of information or belief

You must always give the witness the opportunity to check the contents of the statement and make any corrections before they sign it. The witness must number and initial the foot of each page beneath the last line of text and sign in full beneath the last line of the text on the final page in the statement.

You must make sure the person making the statement:

• consecutively numbers and initials all the sheets
• initials all alterations and deletions
• signs in full beneath the last line of the text on the final page.

There is separate guidance on interviewing employers and employees during an illegal working operation. See also Enforcement interviews.

Managers’ oversight of enforcement record keeping

This page tells Immigration Enforcement managers what assurance checks to make on digital pocket notebooks (DPNBs) contained in PRONTO (police reporting and notebook organiser).

Inspection of digital pocket notebook records

Managers must ensure that, as part of their monthly digital pocket notebook inspection, the latest version of both PRONTO and Android are being used by the officer concerned. They must also ensure that access to all PRONTO-enabled mobile phones is controlled.

Chief Immigration Officers (CIOs), Her Majesty’s Inspectors (HMIs) and other managers must check and sign off all Immigration Officer (IO) DPNBs regularly to assure the standard of completion. DPNBs must be assured monthly and managers should check at least one of each of the different forms that an officer has completed on PRONTO each month.

DPNBs must be signed off by a manager of at least one grade above the holder. This sign-off will generally be done by the direct line manager. In the absence of the direct line manager, the countersigning manager must make arrangements to ensure that DPNB sign-off is completed.

When a countersigning or assurance officer reviews the contents of the DPNB in PRONTO in the web manager using the ‘Management Checks Complete’ feature, the action is time-stamped to show when the contents were viewed. You must also keep a separate record of errors made, and detail remedial action taken in line with the performance development review (PDR) process.

Assurance verification visits will assure the presence and quality of managers’ DPNB checks, including that they were checked within the specified timeframe.

Managers must check that any loss of PRONTO-enabled mobile phones have been properly reported, See Lost or stolen pocket notebooks or PRONTO-enabled phones.

Managers must check that officers are complying with the mandatory instructions on making pocket notebook entries and that all officers:

• maintain full and timely records of all operational activity, legibly and in a full and factual manner
• record means of entry, including service of warrant or Assistant Director (AD) letter, including where relevant, recording the officer identifying themselves and producing their warrant card
• where appropriate, refer to the operational order for the names of all officers present rather than list all officers present within their DPNB
• record all officers present at visit within their DPNB when undertaking reactive work where no formal operational order exists
• record all persons spoken to and persons present during any search.
• record correctly when a caution or explanation upon administrative arrest has been given - managers must check that the correct caution or explanation was given at the appropriate time
• record any consent obtained to provide fingerprints for the GRABBA (mobile phone attachment), the details of the relevant power used, and the justification for doing so
• record persons encountered and checks undertaken
• record their justification for any use of force - such records must be in sufficient detail that they could be relied upon in court
• record the use of the administrative arrest explanation and power and grounds of arrest
• record any significant statements and/ or replies to caution, including that the explanation was understood
• record full details of any children encountered, including:
  • the circumstances of the encounter
  • full consideration of any safeguarding issues
  • if relevant, justification for not taking any further safeguarding action
• record full details of any items they have seized and the power used to do so

Managers must identify cases where an officer does not conduct the arrest as soon as reasonably practicable. They must establish the grounds and the necessity of any delay.

Contingency section for pocket notebooks (PNB)

This section gives Immigration Enforcement officers general guidance on the purpose and control of pocket notebooks in the event that PRONTO experiences a significant system wide outage.

For more information about contingency planning please visit Pronto contingency guide.

The purpose of a pocket notebook (PNB)

You must always be prepared to produce your PNB to your supervising officer and expect it to be seen by third parties. It may be used to provide supporting evidence in witness statements, and may be needed if you give evidence in court.

Lost or stolen pocket notebook (PNB)

What the officer must do

If your PNB is lost or stolen, you must:

• report the loss or theft to the manager on duty as soon as possible
• tell them if any specific sensitive information has been written down in it

In all cases, you must assume the PNB contains information that must not be in the public domain.

What the manager must do

When you have been told you must:

• report the loss or theft to Home Office Security
• tell them the facts and whether any specific sensitive information has been written down in it

If it is likely their details may have been recorded in the lost PNB, you must tell the investigation officers.

Retention, storage and disposal of pocket notebooks

It is not possible in all circumstances to stipulate how long to store PNBs after being taken out of use but, as a general rule, retain them for at least 6 years. They may be retained longer where there is a specific purpose, for instance where they are the primary source of evidence in ongoing consideration of cases.

Storing and disposing of pocket notebooks (PNB)

PNBs must be stored securely. Access to them must be controlled. Each PNB must have a serial number.

If a PNB is taken out of use before it is full, you must:

• initial and date it
• add the text ‘end of notebook’ directly after the last entry
• line through the unused space on the most recently used page, and all unused pages

You must return completed PNBs to the officer with responsibility for issuing new PNBs. This PNB control officer is responsible for ensuring that PNBs are kept securely. Any loss of a PNB must be reported in writing immediately to relevant line managers. You must return the PNB on completion of your term of duty in the office.

The PNB control officer must:

• maintain a control log, each PNB having a serial number alongside full records of issue, including date, time, issuing manager and officer issued to
• look at and sign full or withdrawn PNBs at the first available opportunity
• make sure all pages are intact and all unused pages are lined through and approved
• sign and date the inside rear cover of the PNB
• approve the control record
• store completed or withdrawn PNBs securely in official accommodation
• never post original PNBs to anyone

If other officers, typists or the solicitor’s office require a completed or withdrawn PNB, you must give the person asking for it a copy of the relevant section of the PNB.

Presentation and constraints

In completing your notes, you must:

• make entries in a factual manner
• make entries at the time of the event being recorded or, where circumstances prevent this, as soon as practicable thereafter

Additionally, in completing your notes in your PNB, you must:

• make entries legibly in black ballpoint pen
• record day, date and time against any relevant entry
• use block letters when writing names, days, dates, times, places, addresses and compass points
• record times in the 24-hour clock
• ensure any acronyms or shorthand is consistent throughout the entire PNB

When making entries in your PNB, you must follow the ‘no ELBOWS’ rule. No:

• E - erasures
• L - leaves torn out
• B - blank spaces
• O - overwriting
• W - writing between lines
• S - statements not written in direct speech

When using a PNB, you must sign and rule off the entry at the conclusion of each shift.

Your notes must follow a minimum standard of detail which will be subject to assurance checks. You may use shorthand or abbreviations when completing your notes but these must be consistent throughout the content of your PNB and all notes must be legible.

You must produce your PNB on demand, on a monthly basis, to relevant Chief Immigration Officer (CIO), Her Majesty’s Inspector (HMI) or Assistant Director (AD).

Effective use of the index

The Home Office PNBs, (known as IE100A), have an index at the front.

At the time of making an entry into your PNB you must complete the index with the:

• date of the entry
• subject of the entry
• pages the entry covers

The index acts as a useful reference tool when trying to find past entries in your PNB, particularly when referring to your notes in court.

When to use a separate PNB page

For the purpose of this guidance, an operational visit is defined as any visit or series of visits taking place during the course of a single rostered duty.

When making entries in your PNB, it is not necessary to start a new page for every place or premises visited or person encountered provided that they occur on the same duty and are authorised in common.

Sign off after duty

You must sign the PNB following every operational shift. Signatures must include first name and surname, grade and warrant number.

Blank spaces and deletions

When using a PNB, you must:

• rule through, sign, date and time any blank spaces at the end of a series of entries
• where a deletion is necessary, make it with a single line, initialled and dated You must not:
• leave blank spaces between words or any lines left between entries
• use correction fluid or other types of erasing products
• rub out mistakes with an eraser or strike through deletions in heavy pen

Recording key events during enforcement operations

This page gives Immigration Enforcement officers guidance on how to make certain specific types of entries in their pocket notebook (PNB).

Types of event to be recorded

You must use PNBs to record all significant events, and any details recorded in a PNB should be scanned and uploaded to the PRONTO visit record as soon as PRONTO is available again. It is not possible to provide a comprehensive list of what may be ‘significant’ but the following is the minimum information that you must include within your notes.

Minimum information required before the visit:

• details and information regarding intended enforcement visits, including day and time of visit and nature of visit except where other primary (original note) record exists, such as operational order
• circumstances of the visit (entry by consent, warrant or Assistant Director (AD) letter)
• confirmation of officer in charge (OIC) personal protective equipment (PPE) check

Minimum information for any search and seizure event:

• record of searches and justification
• description of any relevant items seized
• details of damage caused and steps taken to repair or secure property

Recording events

When using a PNB, you must write the time you make the entry in the margin. If you:

• are making the note as the event is taking place the event time will be the same as the entry time
• do not make the entry at the time, and you are making it as soon as possible afterwards, you must:
  • note the time the event took place in the body of the PNB
  • note the time you are making the entry in the margin
  • briefly explain the reason for any significant delay in making your notes

If you make a late entry after you have ruled through, signed, dated and timed an entry then you must bring it to the attention of the senior investigating officer (SIO) or Her Majesty’s inspector (HMI). They must then countersign your cross-referenced changes.

Recording intelligence and sensitive information

It is important you take care when completing PNBs to make sure you write down any sensitive information that could be important evidence separately.

To record sensitive information in your PNB:

• you must rule through the space underneath the previous entry to the end of the double page and initial, date and time it
• you must then record the sensitive information on the following pages
• when you have finished the sensitive recording, you must rule through a blank space at the end of the notes to the bottom of the page, initial, date and time it
• continue normal recording on the next available blank double page

By following the above guidelines you can ensure that a suspect or witness does not see sensitive material when being asked to sign the PNB.

Managers’ oversight of enforcement record keeping for pocket notebooks

This page tells Immigration Enforcement managers what assurance checks to make on pocket notebooks (PNBs).

Inspection of pocket notebook records

Managers must ensure that:

• PNBs are stored securely
• access to PNBs is controlled
• full records of issue are kept, including:
  • date
  • time
  • issuing manager
  • PNB serial number
  • officer issued to

Chief Immigration Officers (CIOs), Her Majesty’s Inspectors (HMIs) and other managers must check and sign off all Immigration Officer (IO) PNBs regularly to assure the standard of completion. This must either be once a PNB is completed or once a month, whichever comes first.

PNBs must be signed off by a manager of at least one grade above the holder. This sign-off will generally be done by the direct line manager. In the absence of the direct line manager, the countersigning manager must make arrangements to ensure that PNB sign-off is completed.

Countersigning officers must write their full name and date in the PNB after inspection in red ink along with the entry ‘PNB standard check completed’. You must also keep a separate record of errors made, and detail remedial action taken in line with the performance development review (PDR) process.

Assurance verification visits will assure the presence and quality of managers’ PNB checks, including that they were checked within the specified timeframe.

Managers must check that completed PNBs are being returned to the officer with responsibility for issuing new pocket notebooks. This PNB control officer is responsible for ensuring that books are kept securely for as long as needed (see retention, storage and disposal of pocket notebooks). Managers must check that any loss of PNBs have been reported in writing immediately to relevant line managers.

Managers must check that officers are complying with the mandatory instructions on making pocket notebook entries and that all officers:

• maintain full and timely records of all operational activity, legibly and in a full and factual manner
• record means of entry, including service of warrant or Assistant Director (AD) letter, including where relevant, recording the officer identifying themselves and producing their warrant card
• where appropriate, refer to the operational order for the names of all officers present rather than list all officers present within their PNB
• record all officers present at visit within their PNB when undertaking reactive work where no formal operational order exists
• record all persons spoken to and persons present during any search.
• record correctly when a caution or explanation upon administrative arrest has been given - managers must check that the correct caution or explanation was given at the appropriate time
• record any consent obtained to provide fingerprints for the GRABBA (mobile phone attachment), the details of the relevant power used, and the justification for doing so
• record persons encountered and checks undertaken
• record their justification for any use of force - such records must be in sufficient detail that they could be relied upon in court
• record the use of the administrative arrest explanation and power and grounds of arrest
• record any significant statements and/ or replies to caution, including that the explanation was understood
• record full details of any children encountered, including:
  • the circumstances of the encounter
  • full consideration of any safeguarding issues
  • if relevant, justification for not taking any further safeguarding action
• record full details of any items they have seized and the power used to do so

In addition to the above, managers must check that when using paper PNBs, officers:

• ensure all entries are clearly timed and dated, using the 24-hour clock
• sign every PNB entry at the end of their shift - signatures must include first name and surname, grade and warrant number
• record their notes in black ballpoint pen
• use block letters when writing names, days, dates, times, places, addresses and compass points
• ensure all entries fully adhere to the ‘no ELBOWS’ rule - see presentation and constraints
• record that checks of their personal protective equipment (PPE) were conducted prior to operations

Managers must identify cases where an officer does not conduct the arrest as soon as reasonably practicable. They must establish the grounds and the necessity of any delay.