Hertfordshire County Council

The authority had developed a Trading Standards Service Food and Feed Law Enforcement Service Plan 2011/12 that was broadly in line with the 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 recently developed and implemented a single document containing the procedures for the service’s feed law enforcement activities, which were generally up to date with current legislation, the Feed Law Enforcement Code of Practice (FLECP) and centrally issued guidance. Further procedures should be developed and implemented to cover the full range of feed law enforcement activity.

The authority had developed and implemented an officer authorisation procedure and had linked the procedure to officer qualifications and competency. However, the authority should review the scheme of delegation to ensure that all relevant feed law enforcement legislation has been appropriately and unambiguously delegated. 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 developed and implemented a procedure to ensure the feed premises database was accurate and up to date. However, the authority reported that some data had been lost during a recent transfer to a new database system, including feed premises usage codes. At the time of the audit the authority had implemented a programme to contact feed businesses to update the database in regard to their current feed activities.

The authority had developed an annual feed premises inspection programme for 2011/12, although historically only inspections of high-risk premises had been routinely carried out, medium and low-risk feed premises had not been inspected at the frequency required by the FLECP. There was some evidence of inspection activity at lower risk premises by officers carrying out animal health work, and in the course of reactive work such as sampling and dealing with referrals, but 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 FLECP.

The authority had effective liaison arrangements in place both locally and nationally.

Record checks on unsatisfactory feed samples found in all cases that the authority had communicated the results to the feed business operator. However, it was not always apparent from the records if any action had been taken or appropriate advice issued in respect of the results.

Record checks on a number of complaints and referrals made to the authority regarding feed businesses in the area showed that the authority had contacted the relevant feed business operator and carried out an investigation, but from the records it was not always possible to establish the outcome.

The authority had developed and implemented a procedure for the receipt of feed incidents in accordance with the FLECP.

Premises records and those of other feed law enforcement activities, such as inspections, samples and complaints, provided insufficient information for auditors to fully assess whether these activities had been carried out in accordance with FLECP. 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 developed and implemented a documented procedure on internal monitoring. 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 ensuring that documented risk-based and proportionate monitoring was extended to cover the full range of enforcement activities in relation to feed controls.