Arun District Council

The authority had developed and implemented a detailed food service plan for 2009/2010, which had been approved and was broadly in line with the Service Planning Guidance in the Framework Agreement. Auditors discussed the requirement to include details of the likely demands on the food enforcement service, with an estimate of staffing resources required, compared with the staff resources available to deliver the service, and also to consider the measures necessary to address identified variances against the previous year’s service plan.

The authority had developed a portfolio of documented policies and procedures relating to their food law enforcement responsibilities, including a very detailed procedure to assist officers undertaking interventions at general food premises. All policies and procedures were managed by the Principal Environmental Health Officer, who maintained responsibility for any amendments.

Auditors discussed the benefit of developing a specific procedure for the approval of establishments. It was not clear from the authority’s records whether all aspects of Annex 12 of the Food Law Practice Guide had been satisfied or whether officers had completed a full evaluation of the HACCP-based food safety management systems held on the files for the authority’s approved establishments.

Their service had a procedure and an authorisation matrix to assess the competence of individual officers; audit checks confirmed that generally officers employed by the authority had been correctly authorised in accordance with their qualifications and experience. The procedure would benefit from expansion to include a method for continued assessment to ensure that officers’ schedules of authorisation are reflective of their actual duties.

Individual officer training needs were identified as part of their annual performance review. All training records contained evidence that each officer had completed a minimum 10 hours relevant training in the last year, including recent training in HACCP principles and methods for effectively auditing HACCP-based food safety management systems.

The authority was, in general, implementing an effective risk-based food premises inspection programme, although file checks identified historical evidence of some high risk premises that had not been inspected at the minimum risk frequency as required by the Food Law Code of Practice.

File checks of five general food hygiene premises confirmed that in all cases the authority were completing detailed inspections, including the assessment of HACCP-based food safety management systems. Food business operators were provided with clearly worded letters confirming the main findings from inspections. The information retained within the premises files provided sufficient evidence to support the basis for officers’ enforcement decisions.

It was evident from audit checks that officers were taking a graduated approach to enforcement and actively worked with businesses to achieve compliance. The information reviewed relating to hygiene improvement notices and prosecution files identified that in each case the enforcement decisions reached were appropriate to the contraventions identified. However, in some cases, where hygiene improvement notices had been served, there was not always evidence of timely follow-up to check that the work required was being undertaken.

The authority had implemented a documented food sampling procedure. In all cases audit checks confirmed that unsatisfactory sampling results had been properly followed up, the food business operator informed and the appropriate action taken.

Audit checks of five complaint records confirmed that on each occasion officers had followed the authority’s documented procedure, completed timely investigations of all complaints and notified the complainant of the investigation findings.

Discussion and review of internal monitoring procedures and practices indicated that the authority was not routinely monitoring all aspects of food law enforcement work. The authority was already aware of the gap in their monitoring arrangements and were in the process of expanding their monitoring procedures.