Cotswold District Council

The service had developed a comprehensive 'Intervention Plan for Food Law Enforcement 2008/2009', which detailed the local aims and objectives and outlined a detailed intervention strategy based on the Food Law Code of Practice. It also provided council members with details of the demands upon the service and the resources required for its effective delivery. The service was able to provide significant evidence regarding its current and past performance monitoring with regard to food safety, against its local and some national targets.

The authority had recently started the process of reviewing all its documented policies and procedures, and whil this process was not complete, those new procedures that had been developed were generally comprehensive. It was clear that the authority had considered many of the latest influences and developments affecting food safety enforcement when developing its Intervention Plan and enforcement procedures, including relevant references to recommendations made at the Inquiry into the 2005 E.coli 0157 outbreak in Wales.

Officers had generally been authorised in accordance with the Food Law Code of Practice, and officers had generally received training commensurate with their duties and their level of authorisation. Auditors noted the significant impact on the service made by the relatively large number and types of approved establishments in its area, requiring its officers to develop and maintain a wide range of highly specialist skills and knowledge. The authorisation procedure required further development to ensure that the authority was able to clearly demonstrate how officer competencies and skills were linked to the level of officer authorisation.

The food premises database held accurate information relating to inspections and other food law enforcement activities. The authority needed to implement its new database management procedure to ensure that the accuracy of the data exported to the Local Authority Enforcement Monitoring System (LAEMS) is not compromised.

While the authority maintained easily retrievable information in premises files, the authority needed to further develop its inspection report forms and aides-memoire to provide clear evidence that officers were fully assessing food businesses, including approved establishments, against current hygiene legislation, the Food Law Code of Practice and centrally issued guidance. Although past performance reports showed that the authority had made considerable progress in reducing its historic backlog of inspections, a significant number had remained overdue. Auditors noted however that the authority had applied a risk based approach to this issue, and the majority of premises affected were in the medium to lower risk category.

The authority needed to ensure that all establishments approved prior to new legislation in 2006, were re-assessed and appropriately re-approved, in accordance with this new legislation.

The authority was able to demonstrate its ability to use a wide range of formal enforcement actions to achieve business compliance with food hygiene legislation in accordance with its enforcement policy. However, auditors noted that on some occasions, follow-up actions had been taken that appeared contrary to the authority’s enforcement policy, and timely compliance had not been achieved. The authority had recently developed an enforcement review process to help address this issue.

While the authority had routinely performed detailed quantitative performance monitoring, and had started to develop several ad-hoc qualitative monitoring techniques, the service needed to develop a coherent and comprehensive internal monitoring policy and procedure, covering all its food law enforcement activities, including interventions and follow-up actions. Formal enforcement actions, where taken, generally conformed to the requirements of the Food Law Code of Practice. File checks also revealed that the authority had undertaken a range of sampling and complaint investigations, in accordance with the Food Law Code of Practice and its own policies and procedures.

Auditors noted that the service had recently been the subject of a robust internal audit, undertaken by the authority’s own internal audit team. Several of the issues identified by this audit had previously been identified, and the service had recently prepared an appropriate action plan to address these issues.