Worthing Borough Council

This report covers audit checks on actions taken by the authority to address the priorities identified in an earlier audit, as well as a wider assessment of key areas of activity targeted at achieving food business compliance, across all types of food businesses.

The audit in February 2010 confirmed that since November 2008, the authority had made some changes and improvements relating mainly to the development and implementation of recently produced procedures. In particular:

• the introduction of a more comprehensive aide-memoire for general food premises inspections to improve the consistency of assessment of compliance and the information held on food businesses
• detailed internal qualitative and quantitative internal monitoring records relating to the delivery of the inspection programme, and the organisation and administration of inspection records
• focused peer review exercises involving file reviews by the manager from a neighbouring local authority

Officers had generally been authorised in accordance with their individual level of training and qualifications, and evidence was provided that officers’ training needs were being identified and addressed. Officers had generally received sufficient training to inspect the types of food establishments that operated in the Borough.

The authority was able to produce accurate reports relating to its food premises database, and had introduced measures to routinely verify its accuracy.

Auditor checks found that premises files were generally well organised with easily retrievable inspection information, and inspection findings were well recorded, with officers able to demonstrate that businesses were being inspected broadly in accordance with the requirements of the Food Law Code of Practice. This fact was further demonstrated by a verification visit made to a local food business, where auditors were accompanied by an officer from the authority.

Where formal follow-up actions had been taken, other than revisits, an assessment of the relevant records confirmed that they had generally been undertaken in accordance with the Food Law Code of Practice.

Several further issues were, however, raised by the latest audit, some of which had also been previously identified during the initial audit in 2008:

• The Service needed to review and expand its food safety work plan to include specific details of premises numbers by risk type and subsequent inspection requirements to fully support its estimates of resource needs. In addition the plan would have benefited from the inclusion of estimates of the numbers of likely revisits, and their impact on resource requirements.
• Further file checks relating to several higher risk food premises produced similar findings to the initial audit of 2008, regarding the authority’s inability to demonstrate timely and effective follow-up actions where serious breaches of hygiene legislation was recorded by officers. Although it was evident that officers were willing to help businesses achieve compliance with legal requirements, there appeared to be an over reliance on one type of enforcement option, namely revisits, which frequently failed to achieve business compliance.
• In several cases, there was little or no documentary evidence to support the choice of enforcement option chosen by officers, even when it appeared to be inconsistent with the authority’s enforcement policy. Furthermore, the Service needed to clearly state its commitment to a graduated approach to enforcement in its environmental health enforcement policy, to support officers from the authority in their attempts to achieve timely business compliance in accordance with the Food Law Code of Practice and centrally issued guidance.
• There appeared to be inconsistencies in the interpretation of inspection findings and subsequent risk scores and risk ratings, between different officers. The authority needed to introduce measures to ensure a consistent approach amongst officers in these matters.
• Despite detailed evidence of internal monitoring regarding the quality of inspection records, the authority needed to further review, expand and fully implement its monitoring procedures to cover all aspects of the food law enforcement service, focusing particularly upon higher risk inspection files and any associated follow-up actions.

Auditors identified an example of good practice, with regard to the peer review exercises that had been introduced by the authority to improve the quality and consistency of the recording of officer’s inspection findings.