West Lindsey District Council

The service had recently been restructured and was subject to resource constraints, including vacant officer posts and resources being diverted into preparation for a large and protracted prosecution case. The authority was however able to report that they had still achieved their food hygiene inspection programme for 2009/2010, with the assistance of a part-time consultant Environmental Health Officer.

The authority had developed a food service plan for 2010/2011 that was in line with the Service Planning Guidance in the Framework Agreement and was due to be submitted for approval by relevant members. The plan would benefit from the inclusion of a clear comparison of the resources required to deliver the food service against the staff resources available to the authority. The previous year’s plan had not been subject to review however it was intended to review the current plan at the end of the financial year.

The authority had developed and implemented policies and procedures covering most areas within the scope of this audit, however additional formal enforcement procedures required development. Existing procedures had been subject to recent review. A means of document protection was required to prevent any unauthorised amendments.

The authority had documented procedures on the authorisation of officers which took account of officer qualifications, experience and competency. A combination of identity cards and individual authorisation documents confirmed the appropriate level of authorisation for individual officers. There were a number of improvements required to the authorisation documents to ensure they included all legislative references and enforcement options.

The authority maintained training records for all authorised officers carrying out food law enforcement activities, and officers had completed a minimum 10 hours relevant training in the previous year based on the principles of continuing professional development (CPD). It was noted in particular that officers had recently undertaken update training on HACCP. All training activities were not being recorded, for example attendance on internal training courses.

The authority had developed and implemented procedures on food hygiene inspections and the approval and inspection of approved establishments. Although it was clear from inspection records that officers were assessing compliance of premises during inspections, there was not always enough information recorded in every case to confirm some key information and the officers’ overall assessment of compliance. Consistent full completion of the inspection aide-memoire would assist in ensuring that comprehensive records were maintained. Either a letter or a report of inspection was issued after each inspection which provided clear guidance to the business.

Audit checks identified that detailed findings from inspections of approved establishments were not consistently recorded on the appropriate form for the type of approval, which resulted in some key information missing from the records. It was also not clear that all establishments had been re-approved as necessary under current legislation. The authority had recently been audited by an officer from a neighbouring authority. The audit focused on the Service’s enforcement activities in approved establishments. The audit had been specifically commissioned by the authority and they were implementing an action plan to address the issues that had been identified.

Audit checks confirmed that the authority was implementing a risk based programme of inspections, however, some inspections of general and approved establishments were not always being carried out within the time frames specified in the Food Law Code of Practice. It was clear that the authority was concentrating its resources on higher risk premises.

The authority had produced a sampling policy, procedure and programme and file checks confirmed that appropriate follow-up action had been taken on unsatisfactory sampling results. It was noted that results from sampling undertaken as part of a national sampling programme had been used to contribute to a well-received local initiative involving butchers as part of the authority’s response to the Pennington Inquiry.

The authority had implemented a policy and procedure on the investigation of food complaints. The procedure required development to include the investigation of complaints about food premises. It was not always clear that appropriate follow-up action had been taken to fully investigate complaints relating to hygiene in food premises.

The authority had a specific public protection enforcement policy which was due for review as part of a corporate initiative. There was evidence that officers were providing support and guidance to businesses and where appropriate were adopting a graduated approach to enforcement where businesses had consistently failed to properly implement a food safety management system (FSMS). The hygiene improvement notices (HIN) reviewed during the audit were generally issued in accordance with central guidance however the records did not confirm that in all cases there had been a timely follow-up to check on compliance.

Internal monitoring of inspections was detailed in the food premises inspection procedure, however this needed to be expanded to cover monitoring of all food law enforcement activities. In practice there was evidence of some quantitative and qualitative internal monitoring activities which included quarterly management reports, recorded one-to-one meetings with officers and paperwork 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 officer was able to demonstrate a thorough knowledge of the FSMS in place, and it was confirmed that the officer had carried out an effective and thorough evaluation of the compliance of the food business at the most recent inspection.