East Dorset District Council

At the time of the audit, the authority was undergoing a period of change whilst entering a shared service arrangement for public health with Christchurch District Council, due to commence from 1 April 2010, and the authority was integrating its services as a whole from autumn/winter 2010.

The common format of a service plan set out in the service planning guidance in the Framework Agreement had not been adopted by the authority. However, there was a broad commitment to the development of the food service included within a recently developed document entitled ‘Public Health Food Safety Process Document’. There were no reporting arrangements to an appropriate members’ forum for approval of the proposals. The document would benefit from being expanded to include a breakdown of the food premises profile, including risk ratings and the proposed annual interventions and inspection programme, to show the scope of the authority’s food law enforcement work, and a comparison of the staff required to deliver the food enforcement service against the staff resources available to the authority to confirm that the plan is deliverable. There was also a need for annual reviews of performance, including measures taken to address any variances in meeting service plans and any required areas for improvement.

The food safety process document was being developed with a view to assist the management of document control and the review and development of procedures. Supporting documents were hyperlinked to provide an easily accessible source of relevant reference information for staff.

Under the authority’s scheme of delegation, the Head of Public Health Services authorised officers to carry out food safety law enforcement functions. The authority had not developed and implemented a documented procedure for the authorisation of officers based on their competence and needed to review the current authorisations to ensure that the authorisation documents contain references to specific and up to date legislation.

Officer training needs were determined at annual staff performance development reviews. Officers had achieved 10 hours Continuing Professional Development (CPD) training required by the Food Law Code of Practice (CoP) and several staff had recently attended training on the evaluation of food safety management systems (FSMS). In general, the team had up to date training but a training programme should be developed to establish and document individual officer and team training needs. Officer qualification and training records had not in all cases been maintained by the authority.

The authority had developed procedures for the inspection of food premises and approved establishments. The inspection procedures, including those for approved establishments, would benefit from the provision of clear guidance for officers on the validation and verification of FSMS.

Auditors noted that, except for butchers and approved establishments, there was no appropriate aide-memoire in use for officers to record detailed findings during inspections. Reporting was broadly by exception i.e. officers generally included details of legislative non-compliances rather than a broader compliance history of the business.

The authority had recently introduced a paperless system for the recording of inspection details and enforcement activities across the service. Documents and evidence were often difficult to retrieve from this system and in many cases historical documents had been shredded, making it difficult for auditors to fully assess the compliance history of the individual premises. From the limited information available, there was evidence that the authority was generally implementing an effective food premises inspection programme, but inspections were not always carried out at the minimum frequencies specified within the CoP.

The authority’s records showed that some approved establishments were currently still undergoing re-approval under Regulation (EC) No. 853/2004. Approved establishments inspections were carried out in a timely manner and generally file records were well organised, easily retrievable, and specific aides-memoire were being used to record detailed findings by officers. However, in the case of one approved establishments file examined, the authority should consider a more graduated enforcement approach to issues of non-compliance.

Food and food premises complaints were investigated effectively, including the implementation of appropriate follow-up action. Complaint records were generally found to be complete and accurate.

There was clear evidence that the authority was actively participating in both local and national sampling programmes. File checks showed that appropriate follow-up actions had been taken in all cases of unsatisfactory samples and food business operators had been informed of outcomes.

The authority had developed an enforcement policy which was generally in accordance with centrally issued guidance. Due to incomplete or illegible records, where food safety contraventions had been identified, it could not always be confirmed that a graduated approach to enforcement had been implemented in accordance with the authority’s enforcement policy.

File checks of hygiene improvement notices showed that generally the authority had issued the notices in appropriate circumstances, timely revisits had taken place and there was some evidence of internal monitoring. Follow-up actions had not always been taken in accordance with the CoP.

The Process Document included quantitative and qualitative monitoring procedures across the food law enforcement service but they had not been fully implemented. The authority should ensure that an internal monitoring procedure is developed and fully implemented across the full range of enforcement activities and that appropriate documentation of monitoring arrangements is maintained.

Dorset local authorities had previously carried out an inter-authority audit scheme. Recommencement of the scheme was being considered by the Food Liaison Group in consultation with Chief Officers.

Auditors noted good practice undertaken by the authority in response to the recommendations from the Public Inquiry into the 2005 E.coli 0157 Outbreak in South Wales including the development of a HACCP guidance pack for retail butchers, the provision of coaching, and training seminars planned for the butchers.