South Tyneside Council

The authority had developed a comprehensive food law safety service plan for 2010/2011, in line with the service planning guidance in the Framework Agreement. The plan included detailed links with wider council objectives, and contained details of demands upon the service and an estimate of the resources required to deliver these services effectively.

The authority had developed comprehensive policies and procedures covering the range of enforcement activities undertaken by the service. These included a system of document review and control with most procedures having been recently reviewed to take account of changes to legislation and centrally issued guidance. The authority planned to undertake further procedural reviews once a regional intervention strategy had been completed.

The authority had developed a documented system for issuing officer authorisations. This system required further review to provide a suitable method of linking officer competency assessments and officer authorisations and the subsequent identification of risk based officer training needs.

Officer training needs were identified during annual appraisals, and, in general, the authority was able to demonstrate that authorised officers had undertaken the required minimum 10 hours relevant training, based on the principles of continuing professional development.

At the time of the audit, auditors and the authority had identified a significant number of food business establishments that had never been subject to a hygiene intervention or where a routine food hygiene intervention was overdue. Although some overdue inspections had historically involved higher risk establishments, the majority related to medium and lower risk establishments. The service was targeting the highest risk premises with the resource available.

Inspection aides-memoire in use at the time of the audit required further development to prompt officers to record detailed findings during food safety inspections. In particular they required development to capture detailed officer assessments of food business operator (FBO) compliance with legal requirements related to HACCP and food safety management system (FSMS). Aides-memoire were sometimes only partially completed, or in some cases were missing from files, making it difficult for officers to justify risk scores or their choice of follow-up actions.

The authority was able to provide detailed documentation relating to the approval and assessment of approved establishments in the borough. Files generally contained detailed routine inspection records using appropriate aides-memoire, including details of officer assessments of FBO compliance with HACCP and FSMS and other legal requirements. Auditors discussed the benefits of recording all decisions involving conditional approvals where continuing legal contraventions were noted by officers.

Letters and correspondence to businesses following inspections were generally comprehensive, clearly outlining inspection findings, differentiating between legal contraventions and recommendations and providing suitable timescales for completion.

An officer interview and a 'reality check' visit at a food business were undertaken during the audit. The main objectives were to assess the officer’s knowledge of HACCP and FSMS, the authority’s own systems and procedures and to evaluate the effectiveness of the authority’s assessment of food business compliance with food law requirements. In each case officers were able to demonstrate an understanding of HACCP and FSMS.

Record checks confirmed that officers were willing and able to undertake a range of formal enforcement actions to help secure business compliance. However, auditors noted that the authority had not always adopted a graduated approach to enforcement at some higher risk establishments where repeated serious breaches of food hygiene legislation had been recorded.

A range of enforcement actions were reviewed, including hygiene improvement notices. In most cases the actions taken were appropriate to the circumstances and had generally been undertaken in accordance with the Food Law Code of Practice, including regular contact and follow-up with the FBO.

The authority maintained comprehensive food and food premises complaint investigation details and had undertaken appropriate investigations in relation to the complaint in each of the cases reviewed during the audit.

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

The service was able to provide detailed evidence of quantitative monitoring relating to inspection numbers and targets. However, there was little documentary evidence of any risk based internal monitoring relating to the quality of officers work across the full range of food law enforcement activities performed by the service.

An area of good practice was identified during the audit relating to the follow-up of inspection findings. FBOs were routinely requested to sign and return a receipt form to confirm that they understood the contents of any inspection reports and that they would address any contraventions identified, including any issues relating to HACCP and FSMS. The form also gave FBOs the opportunity to request further help and explanation regarding the inspection findings.