Cumbria County Council

The authority had developed a 'Trading Standards Feed and Food Controls Service Plan for 2011/12' that was broadly in line with service planning guidance in the Framework Agreement. The benefits of including a comparison of the resources required to deliver the feed law enforcement service against resources available to the authority were discussed, together with a more detailed annual review of feed enforcement activities. The authority had also developed a 'Food/Feed Improvement Plan for 2011/12'.

The authority had recently developed a number of procedures for the service’s feed law enforcement activities, which were up to date with current legislation, the Feed Law Enforcement Code of Practice and centrally issued guidance. Further procedures should be developed and implemented to cover the full range of feed law enforcement activity.

The authority should implement the recently developed officer authorisation procedure, linking the procedure to officer qualifications and competency. Generally officers had received training in accordance with continuing professional development requirements and those officers interviewed were able to demonstrate a good working knowledge of feed legislation controls.

The authority had not developed and implemented a procedure to ensure the feed premises database was accurate and up to date, although some useful work instructions were being utilised by officers.

The authority had developed an annual feed premises inspection programme for 2011/12. Historically, only inspections on high-risk premises had been routinely carried out, although there was some evidence that some medium-risk premises such as on-farm mixers were being inspected on an 'eyes and ears' basis with significant problems reported to qualified officers to action. However, the 'eyes and ears' interventions were not always effectively documented. Consequently, medium and low-risk feed premises had not been routinely inspected at the frequency required by the Feed Law Enforcement Code of Practice. There was some evidence that some inspection activity at the lower-risk premises was being carried out by officers carrying out project work and in the course of reactive work such as sampling and dealing with referrals. However, these checks did not meet the minimum criteria of a full primary inspection. In addition, the inspection aide memoire in use did not provide sufficient prompts for officers to record details such as Hazard Analysis and Critical Control Point (HACCP) assessments and other information required by the Feed Law Enforcement Code of Practice.

The authority had effective liaison arrangements in place both locally and nationally and had set up a system for receiving consignment records from a local port operator in receipt of imported feed.

Record checks were carried out on unsatisfactory feed samples and in all cases it was found that the authority had taken appropriate action and ensured feed business operators had been informed of the results.

Record checks were also carried out in regard to a number of complaints and referrals that had been made to the authority regarding feed businesses in the area. In all cases examined it was found that the authority had dealt effectively with these enquiries and had made appropriate contact with the feed business operators.

The authority had developed and implemented a procedure for the receipt of feed incidents and Rapid Alert System for Food and Feed (RASFF) notifications in accordance with the Feed Law Enforcement Code of Practice.

Records in relation to samples and complaints/referrals had been effectively maintained, were up to date and easily retrievable. However, premises records and records of other feed law enforcement activities such as inspections provided insufficient information for auditors to fully assess whether these activities had been carried out in accordance with Feed Law Enforcement Code of Practice. Consequently, it was also not clear that the authority recorded and retained sufficient information to determine appropriate intervention decisions and to facilitate effective internal monitoring.

The authority had not developed and implemented a documented procedure on internal monitoring. However, there was evidence that both qualitative and quantitative monitoring had been undertaken in the past, although this was not routinely recorded or documented. Auditors discussed the benefits of developing and implementing a documented monitoring procedure to ensure risk-based and proportionate monitoring to cover the full range of enforcement activities in relation to feed controls.