Brentwood Borough Council

The authority had developed and implemented a comprehensive food service plan for 2009/2010 that was in line with the service planning guidance in the Framework Agreement. The plan had been agreed by appropriate members. The plan for 2010/2011 was being finalised and will also be submitted for Member approval in due course. The plan would benefit from the addition of a clear comparison of the resources required to deliver the food service against the staff resources available to the authority.

The authority had detailed documented procedures on the authorisation of officers. The procedure and schedules of authorisation had recently been reviewed and were comprehensive, including all the key legislative references. The authority needed to ensure that all officers are appropriately authorised in line with their levels of experience.

The authority maintained training records for all authorised officers, including contractors, and officers had completed a minimum 10 hours relevant training in food matters in the past year based on the principles of continuing professional development. It was noted in particular that officers had recently undertaken update training on HACCP and that contractors were invited to participate in training activities.

The authority had in place a comprehensive inspection aide-memoire to prompt officers to fully record their inspection findings and their assessment of the food business operator’s (FBO) food safety management systems (FSMS). However, records were not always clearly legible or sufficiently detailed to confirm that a thorough assessment of the business's FSMS had been carried out. Consistent full completion of the inspection aide-memoire would assist in ensuring that comprehensive records are maintained. In addition, it was not clear that timely follow-up action was always being taken where serious contraventions had been found.

Audit checks confirmed that the authority was implementing a risk based programme of inspections. While it appeared that there may have been some historic issues in maintaining a risk based inspection programme, it was noted that the programme was being closely managed and there did not appear to be a backlog at the time of the audit. It was noted, however, that the limited capabilities of the food hygiene database presented challenges in the management of the food hygiene inspection programme.

A procedure on the approval of approved establishments had been developed and recently reviewed. The authority reported one approved establishment in the district. It appeared that this has only been recently re-assessed under the requirements of Regulation (EC) No. 853/2004 and that a decision on approval is currently being considered.

The authority had produced a sampling policy, procedure and programme. While it was clear that re-sampling took place following unsatisfactory results, it was not evident in all circumstances that contraventions identified as part of the sampling investigation were duly followed up.

The authority had a complaints policy and a comprehensive procedure on the investigation of food and food premises complaints. While thorough investigations of the complaints were made, which included linking the complaint with the effectiveness of the FSMS in place, it was not evident that complaints were always investigated within the response targets.

The authority had an enforcement policy appended to the service plan in addition to further policy guidance contained within the enforcement procedure. The procedure had been recently reviewed and it was identified that it needs to be expanded to cover all available enforcement options. The authority was adopting a graduated approach to enforcement and there were a number of examples of hygiene improvement notices (HINs) being served on FBOs for failing to develop and implement an effective FSMS. These were, in general, drafted in accordance with the Food Law Code of Practice and centrally issued guidance, although timely visits to check on compliance were not being made and some time had elapsed before a revisit took place.

The authority had developed comprehensive internal monitoring procedures covering the range of enforcement activities. It was clear that quantitative monitoring was being carried out, particularly in relation to adherence to the inspection programme, but there was limited evidence of the qualitative monitoring set out in procedures other than examples of accompanied inspections with officers and completed checklists for HINs.

A reality check visit at a food business was undertaken during the audit. The main objective was to assess the effectiveness of the authority’s assessment of food business compliance with food law requirements. The officer was able to demonstrate a thorough knowledge of the FSMS in place, and it was possible to confirm that the officer had carried out an effective evaluation of the compliance of the food business at the most recent inspection. An appropriate risk assessment was carried out and the officer identified areas where improvements need to be made to the FSMS.