Runnymede Borough Council

A generic service plan 2009/2010 had been developed for the Environmental Protection Division with a supplementary annexe incorporating additional food service details for the commercial team. The service plan was broadly in line with Service Planning Guidance in the Framework Agreement. However, it should be expanded to include more detail on staff resources required to deliver the food law enforcement service with regard to the demands on the food service. Annual reviews of performance of the service should include measures taken to address any variances in meeting service plans and any required areas of improvement.

Although there was no formal system in place for document control, documented policies and procedures had been developed for the majority of food law enforcement activities, which were reviewed on an annual and ad hoc basis. Documents were stored on a shared computer drive for staff access and the authority was currently reviewing methods for protecting these documents.

The authority had developed and implemented a documented procedure for the authorisation of officers, which included a means for assessing officer competency. Officers were appropriately qualified and authorised. Individual training needs were identified annually through a staff appraisal process. It was not evident in all cases that officers had achieved 10 hours continuing professional development (CPD) training required by the Food Law Code of Practice (FLCoP).

The authority had developed and implemented a food hygiene intervention (inspection) procedure. This would benefit from being expanded or a new procedure developed to cover the specific requirements for the approval and inspection of approved establishments, any alternative enforcement strategies for low risk premises, and clear guidance for officers on the validation and verification of food safety management systems (FSMS). The document should also be reviewed to address the need to undertake revisits at food businesses that fail to comply with significant statutory requirements.

File and database checks confirmed that the authority was generally implementing an effective food premises inspection programme across all risk categories, and within the timeframes and minimum frequencies specified by the FLCoP. However, there were no appropriate aides-memoire in use for officers to record detailed findings during inspections. The use of an aide-memoire would provide essential fundamental data necessary to inform subsequent inspections, a graduated approach to enforcement, and permit effective internal monitoring. Auditors were unable to confirm whether appropriate inspections, interventions and follow-up actions were being carried out, or if risk ratings were accurate.

File and database checks confirmed that in all cases examined, food and food business complaints were effectively investigated and followed up. Outcomes were communicated to all relevant parties in a timely manner.

The authority had a documented sampling procedure, policy, and sampling programme. There was clear evidence that the authority was actively participating in both local and national sampling programmes, with particular emphasis on locally produced high risk food. Database and record checks showed that in all cases of unsatisfactory sample results the authority had taken appropriate follow-up actions including revisits, resampling and comprehensive advisory letters.

The authority had developed a generic enforcement policy, and a food enforcement policy which was generally in accordance with centrally issued guidance. File checks on formal enforcement confirmed that actions taken had been justified and, with the exception of voluntary closure procedures, were generally taken in accordance with the authority’s enforcement policy and centrally issued guidance.

File checks of hygiene improvement notices showed that the authority had issued the notices in appropriate circumstances, and timely revisits had taken place. However, follow-up actions had not always been taken in accordance with the FLCoP and the authority’s own procedures.

The authority had developed a documented internal monitoring procedure which included the majority of food law enforcement activities. There was evidence of quantitative monitoring of food enforcement as well as day-to-ay qualitative monitoring through ongoing discussions within the team. The monitoring procedure should be reviewed and extended to better reflect the monitoring being carried out in practice and to include appropriate record keeping arrangements covering the full range of enforcement activities.

The authority was due to participate in the forthcoming Surrey Food Liaison Group Inter-Athority Audit scheme focused on training and authorisation of officers, inspections and internal monitoring.