Liverpool City Council

The authority had developed a Food Safety Service Plan for 2010/2011 that was broadly in line with the Service Planning Guidance in the Framework Agreement. Future service plans would, however, benefit from the inclusion of a comparison of the staff resources required to deliver the food law enforcement service against the resources available to the authority. There were concerns over the authority’s ability to undertake all its statutory functions, including planned food premises interventions, given the unfilled officer vacancies, the number and nature of the food establishments and the impending long-term absence of the lead food officer.

The authority had completed a detailed review of the previous year’s service plan and had identified variances. Although some inspections that had been planned for the year had not all been achieved, the service had targeted food premises previously considered as high risk, and each of these had received an inspection. Increased service demands and continuing staff shortages had been identified as the basis for the variances. However, the service had not detailed within the service plan the measures that would be taken to address the variances.

The authority maintained a number of policies and procedures covering their food law enforcement activities but did not have a formal structured document control system to facilitate regular document review or authorisation.

There was an effective system in place to authorise officers in accordance with their individual qualifications, experience and competency. Training needs were identified during yearly appraisals and, in general, the authority was able to demonstrate that authorised officers had undertaken the recommended minimum 10 hours relevant training, based on the principles of continuing professional development, including recent HACCP training.

Inspection forms in use at the time of the audit were inadequate to prompt officers to record comprehensive findings during food safety inspections. In particular, they failed to capture the level of assessment of food safety management systems completed by the officer.

Specific aides-memoire were not routinely used to record detailed findings following approved establishment inspections. Due to the lack of records, it was not always possible to determine whether the approved establishments complied fully with legislative requirements, or to establish the basis for officers’ decisions regarding business compliance. Some concern was also raised by auditors regarding an apparent failure to follow official guidance when granting conditional approval to one establishment.

At the time of the audit the authority had identified a significant number of food businesses premises which were either unrated or overdue an intervention. Although, due to their limited resources, the service was targeting the most high risk premises, there were a large number of premises where the levels of food safety management compliance was presently unknown.

Record checks confirmed that officers were taking a graduated approach to enforcement in accordance with the authority’s enforcement policy. Although hygiene improvement notices were appropriately detailed, it was not always evident that a timely check on compliance had been undertaken or that letters had been issued to food business operators confirming compliance with the notice.

The authority maintained comprehensive complaint investigation details. However, investigations were not always completed within the timescales specified within the authority’s own complaint procedure.

The service had undertaken sampling in accordance with their sampling programme and had taken appropriate actions where unsatisfactory results had been obtained.

Although the service had developed a process for monitoring officers’ work and there was evidence of significant quantitative internal monitoring, qualitative monitoring did not presently include all aspects of the authority’s food law enforcement activities.

A 'reality check' visit at a food business was undertaken during the audit. The main objective was to evaluate the effectiveness of the authority’s assessment of food business compliance with food law requirements. Although some structural issues were identified during the visit, the checks completed by the officer were appropriate, with the officer demonstrating an understanding of the businesses’ food safety management system.