Test Valley Borough Council
Friday 10 September 2010
23-24 March 2010
Executive summary
The authority had developed a Food Service Plan for 2009/2010 that was broadly in line with the service planning guidance in the Framework Agreement. The plan required further development to include more detailed information specified by the service planning guidance, in particular a reasoned estimate of the resources required to deliver these duties effectively, against those available and the identification of any risks to the delivery of the food law enforcement activities, for example database administration. The plan had been approved at the appropriate Council member forum.
In response to the Pennington Report into the E.coli O157 outbreak in South Wales the authority had developed a fact sheet which provided useful advice to food business operators in regard to the food safety risks, the routes of contamination and how the risks can be minimised. This had been distributed to all the butchers’ shops in the area.
The authority did not have a documented procedure for the regular review and updating of policies and procedures. Although policies and procedures were generally up-to-date, the authority acknowledged that, on occasion, it had not always been able to keep up-to-date with revisions.
The authority had a documented procedure for the authorisation of officers based on their individual qualifications, experience and competency. Record checks showed that all officers had been appropriately authorised and authorisation documents covered the full range of food law enforcement legislation. Auditors discussed the need to link officer training to the authority’s ‘uuthorisation matrix’.
Officer training needs were identified on an annual basis through the staff appraisal process and at monthly one-to-one monitoring meetings. Record checks showed that, generally, officers had undertaken the required number of hours of continuing professional development (CPD) and recent Hazard Analysis and Critical Control Point (HACCP) training. However, some records of officer CPD training were incomplete.
The authority had developed a food premises inspection procedure, which provided useful guidance to officers carrying out food law interventions. File checks showed that officers were generally carrying out thorough food hygiene inspections, including the assessment of food safety management systems (FSMS), in line with the procedure.
The authority had developed, in conjunction with the local food liaison group, a useful and appropriate general food premises inspection aide- memoire. In response to the Pennington Report the aide-memoire had been further developed to enable officers to fully record their detailed findings in relation to assessments of FSMS.
There was no evidence on file that the authority’s single approved establishment had been re-approved under current legislation as required. Product specific aides-memoire had not been used recently to record detailed findings following approved establishment inspections. In addition, the most recent inspection at the premises had been carried out by an officer who had not achieved the required level of authorisation. Generally, the approved establishment file was well organised and contained most of the information listed in Annexe 12 of the Food Law Code of Practice Guidance.
The service had developed an enforcement policy which was generally in line with centrally issued guidance. The policy contained useful food law related guidance on the graduated use of enforcement actions. The authority had developed and implemented a procedure to cover the full range of enforcement activities, including the use of simple cautions and prosecution.
There was clear evidence that the authority was willing to take appropriate and effective enforcement action when required, including the use of hygiene improvement notices (HINs) and prosecution. File checks showed that the use of HINs had been appropriate in all cases. In all cases examined the use of prosecution had been the appropriate course of action. However, there was no documented evidence on file that the enforcement policy had been considered in the decision to take legal proceedings. Auditors also discussed the need for officers to fully record the reasons for any departure from the authority’s enforcement policy.
Records confirmed that complaints about food and food premises were investigated effectively with appropriate follow-up action being taken. Complaint records were found to be complete and accurate.
Records relating to unsatisfactory food sample results showed that the authority had notified food business operators of the results and had taken appropriate follow-up action in all cases.
The authority had developed and implemented a procedure for internal monitoring, and there was clear evidence that documented quantitative and qualitative monitoring was being carried out. This included monthly one to one meetings to assess inspection targets and ongoing reactive work, documented accompanied inspections and inspection record checks.
A reality check visit at a food business was undertaken during the audit. The main objective was to assess the effectiveness of the authority’s assessment of food business compliance with food law requirements. The visit confirmed that the checks carried out by the officer in relation to HACCP and FSMS requirements were generally thorough and covered the majority of food law requirements.
