Vale of White Horse District Council

A Food Safety Service Plan for 2009/2010 had been developed, broadly in line with the Service Planning Guidance in the Framework Agreement on Local Authority Enforcement and contained service objectives, tasks and targets for the main areas of food law enforcement. The plan contained some inconsistent data, particularly involving the numbers of food premises generated by the food premises database, and the subsequent planned inspection programme for the year. The plan also required further development to provide details of how any variance in planned performance would be addressed, and to provide an objective estimate of the resources required to deliver an effective service, including all statutory and reactive responsibilities.

The authority had recently developed policies and procedures covering most areas of its food law enforcement activities. In the majority of cases, auditors were unable to fully assess whether these had been fully implemented. There was a system in place for planned and ad-hoc reviews of these documents. A small number of additional procedures needed to be developed and some amendments were required to existing documents.

A documented procedure for the authorisation of officers had been recently developed. The procedure required review to include a mechanism for identifying and linking officer competencies to levels of authorisation. In addition, the schedule of authorisation required review to ensure that it included the full range of food safety legislation referred to in the body of the authorisation procedure, and in accordance with the Food Law Code of Practice.

Staff secondments had lead to significant gaps in the skills and competencies of specialist officers in the team. Officers' general training needs were assessed as part of the authority’s staff appraisal process, which was linked to a corporate training matrix. However, there was little evidence that these assessments clearly identified all officers’ individual training needs, specifically in relation to individual levels of officer authorisation. In addition, the service had not developed a detailed documented annual training programme and it was not clear that all officers, including the Lead Officer, had received relevant or up to date specialist training in the more complex food production processes, including approved establishments and the assessment of Hazard Analysis and Critical Control Point (HACCP) based food safety management systems.

The quality of data on the food premises database was checked on an ad-hoc basis, but the authority did not routinely verify the accuracy of data and had not developed a documented procedure to ensure its food premises database was accurate and capable of supplying accurate management information and accurate information to the Food Standards Agency in its annual returns.

Database reports requested before and during the audit revealed a number of anomalies and inconsistencies regarding the information required for National Indicator (NI) 184. Some anomalies in food premises risk scoring were also discussed and it was confirmed that these issues would be addressed.

Historically, the authority had not always inspected premises at the minimum frequency prescribed by the Food Law Code of Practice. Audit checks revealed a backlog of overdue food premises inspections, including several higher risk premises. It was clear however that the authority was aware of this issue, and was generally prioritising the inspection of higher risk overdue premises.

The service needed to review its inspection aides-memoire to provide prompts covering the relevant legal requirements for all types of food premises, including approved establishments, and for officers to record detailed findings of food business compliance, including HACCP requirements.

Although officers were able to provide businesses with advice, and identify serious legal contraventions in higher risk food establishments, timely business compliance had not always been achieved. The authority needed to review all its higher risk premises files, particularly those highlighted by officers as having extra associated risks, to ensure that appropriate actions had been taken to remove any immediate risk to public health.

The authority needed to develop a documented procedure regarding the approval and inspection of approved establishments. Files contained insufficient evidence to confirm the approval status for several premises. The authority needed to establish whether these premises were still in operation, and whether they required approval under Regulation (EC) No. 853/2004.

The authority had developed a documented enforcement policy and associated enforcement procedures. File checks related to Hygiene Improvement Notices (HIN), and Simple Cautions confirmed that the actions had been taken broadly in compliance with the Food Law Code of Practice. However, there was insufficient information on files for auditors to make a full assessment regarding the voluntary closures that had taken place in the last two years.

There was little evidence of any routine qualitative monitoring of different aspects of the service, although an internal monitoring procedure had recently been developed. There was a need to further develop and implement the internal monitoring procedure to ensure that all food law enforcement activities were subject to effective and risk based internal monitoring, including record keeping and file checks.

The service had not participated in any inter-authority or internal audits since May 2004, to verify its conformance to the Food Law Code of Practice or the Standard in the Framework Agreement on Local Authority Enforcement.