Slough Borough Council
Wednesday 16 February 2011
17-18 November 2010
Executive summary
It was clear that imported food controls form an integral part of the food service provided by the food and safety and trading standards teams responsible for the enforcement of imported food controls at Slough Borough Council. Past and present service plans and discussions with officers confirmed that the enforcement of imported food controls had been long established into the work of the teams.
The authority had developed service plans for both the food safety and trading standards services, which were broadly in line with the service planning guidance in the Framework Agreement. Appropriate reference to imported food controls was made in the plans. Future service plans should however, fully reflect the requirements of the service planning guidance, including a comparison of the resources required and those available to provide the service.
Documented procedures for the authorisation of officers had been developed and implemented for both teams. These would benefit from greater detail on the assessment criteria and process for the authorisation of officers based on their individual qualifications, experience and training. Officers were found to be appropriately authorised and acting within their individual levels of authorisation. Food safety officers had received training in imported food controls and it was acknowledged that officers in the trading standards team would also benefit from undertaking some basic training on inland imported food controls.
The authority had developed policies and procedures relevant to the scope of the audit in respect of food safety, and useful guidance had been produced for officers on a range of imported food issues, including inland imported food controls and imported food checks at the enhanced remote transit sheds (ERTS). It was acknowledged that trading standards procedures would benefit from more regular and ad hoc reviews as necessary, to ensure they provided adequate and up to date guidance to officers.
There was evidence that officers made relevant checks on imported food as part of routine food hygiene and standards inspections. The food safety inspection aide-memoire had been amended to include a useful section to prompt officers to record details of their imported food traceability checks. The food standards report of inspection form required review to prompt officers to record details of the checks made on imported food during visits, including any referrals to the food and safety team.
The authority had submitted an imported food return on the Local Authority Enforcement Monitoring System (LAEMS) for 2009/2010, which broadly reflected the authority’s sampling and enforcement activity. Auditors were advised that steps were being implemented to resolve anomalies between the food standards and food safety records in respect of food businesses, which should improve accuracy of the database over time.
A draft public protection service enforcement policy had been produced, which was about to undergo consultation with external stakeholders. The policy clearly set out the authority’s graduated approach to enforcement. It was evident that appropriate follow-up action, including formal enforcement was being taken in relation to illegal food imports or high-risk imported food, where food safety issues had been identified. Notices had been served where appropriate.
It was clear that the service was proactive in providing advice to food businesses on imported food controls, for example useful guidance had been provided to the ERTS operators on changes to requirements in respect of high-risk FNAO. In addition, a newsletter had been produced for local food businesses featuring an article on imported food controls and helpful advice was provided by both teams to individual enquiries on imported food matters.
Procedures were available on both food safety and standards sampling, which included imported foods. The authority’s food sampling programme took account of the imported foods sold in the authority’s area. It was noted that paper records relating to trading standards samples were not as easily retrievable or sufficiently detailed, and could be more usefully linked to the sample records on the database.
Procedures on responding to consumer food complaints had been developed and implemented. Complaints relating to one importer were checked during the audit and it was clear that appropriate investigations had been carried out and relevant parties kept informed of progress.
The food and safety team had developed a comprehensive internal monitoring procedure and there was clear evidence of effective internal monitoring across the service, including imported food control activities. It was not evident however that similar risk-based monitoring arrangements were in place in respect of trading standards activities on imported food.
A ‘reality visit’ was undertaken to an ERTS in the district that handled imported foods. The purpose of the visit was to determine the effectiveness of the authority’s assessment and application of imported food controls in relation to third country imports, and to assess that enforcement activities at the premises meet the requirements of relevant legislation. It was evident during the reality check that the service maintained a good working relationship with the food business and that there was good knowledge of the procedures in place at the premises and the controls relating to imported foods.
