Leicestershire County Council

The authority had developed a service plan for food standards enforcement, which was an annexe to the overarching trading standards service plan and covered the key elements of feed law enforcement. the plan generally was in line with the service planning guidance in the Framework Agreement. However, it would benefit from being further developed to include a realistic comparison of the resources required to deliver the feed law enforcement service against resources available to the authority, based on the full range of demands placed upon it. The service carried out quarterly reviews of its progress against key service performance indicators.

The service operated a process of regular review and improvement in relation to their documented operational processes and a robust control system was in place.

The authority needed to develop and implement a documented procedure for the authorisation of officers for feed enforcement, to set out the means by which officers were authorised based on their qualifications, training, experience and competency. The existing generic authorisations needed to be reviewed and considered by the council’s legal department to ensure that officers were appropriately authorised under relevant legislation to include specific enforcement powers and at a level which reflects their individual level of experience, training and competence. Whereas it was clear that the Lead Officer for Feed had received an appropriate level of relevant training, other officers currently carrying out feed law enforcement or authorised to do so as part of contingency measures, had not received sufficient training relevant to feed law enforcement.

The authority had an electronic database for the recording of feed law enforcement activities, which was capable of providing information necessary for official returns.

Although the authority had recently provided the Agency with their updated feed premises register, the service had recognised that a significant number of farm premises had still not been registered and was addressing this matter. Audit database checks on a random selection of agricultural premises in a commercial directory confirmed that these were generally present on the database.

The service had developed a concise and clear documented procedure for the inspection of feed establishments and it was evident from audit checks that all high risk premises were being inspected annually. Although some medium risk premises had also been inspected each year, medium and low risk establishments were not included or targeted as part of a risk-based inspection programme. Officers left inspection reports with feed business operators after inspections, but it was not clear which part of the business processes had been examined during the visit or how compliance was assessed. In general, both hard copy and electronic records of premises inspections did not include sufficient detail of the inspection, any assessment or adequate information about the premises and its operations.

The authority carried out feed sampling during every inspection of high risk establishments and additionally on an ad hoc basis. However, the service would benefit from developing a feed sampling policy and sampling programme to ensure that feed sampling activity is appropriately targeted at areas of highest risk in accordance with the national enforcement priorities. It was not always clear from available records whether appropriate follow-up action had been taken following the receipt of unsatisfactory sampling results.

The authority had developed a comprehensive trading standards enforcement policy together with additional useful and concise formal enforcement procedures. Audit file checks on improvement notices served confirmed that these had been an appropriate course of action and due legal process had been followed with timely follow-up checks carried out.

The authority had not developed a feed complaints procedure, including referral arrangements. However, audit record checks confirmed that, in practice, appropriate investigations had been undertaken with relevant advice given to businesses and effective liaison and communication undertaken with other local authorities. Records were easily retrievable, detailed and up to date and internal monitoring was noted during and on completion of each investigation.

While it was evident that the lead officer was monitoring the investigation of complaints and referrals and was carrying out quantitative monitoring against performance targets, there were no records to show that feed inspection activities and formal enforcement were subject to internal monitoring by the service.

An officer who regularly carries out feed law enforcement was interviewed to determine if they were able to demonstrate an appropriate level of competency and knowledge of the service’s procedures. The officer was able to show a satisfactory working knowledge of animal feed enforcement.

A visit to a local feed manufacturer was carried out as part of the audit. The purpose of the visit was to assess the effectiveness of the officer’s evaluation of the compliance of the feed business with legislative requirements. The officer was familiar with the operations taking place at the business. The visit demonstrated that the officer clearly understood the key operations and risks at the establishment.