North East Lincolnshire Council
Tuesday 3 May 2011
27-28 January 2011
Report on the audit of port health authority and local authority food and feed law enforcement controls of imported food and feed not of animal origin at Grimsby and Immingham port
Executive summary
The authority had not developed a food service plan for 2010/2011. The authority stated that a service plan, in line with service planning guidance in the Framework Agreement, would be developed for 2011/2012 and approved by the appropriate member forum or delegated senior officer.
The authority was undergoing a prolonged period of reorganisation and acknowledged that most of its policies and procedures involving imported food and feed were no longer up to date. The authority intended to review all policies and procedures, including those relating to imported food and feed, with a view to updating them in line with new legislation and centrally issued guidance. Auditors discussed the need to maintain a formal method of ensuring that policies, procedures and documents are reviewed and revised in line with changes in legislation, codes of practice and centrally issued guidance.
Generally, officers had been authorised in line with their qualifications, training and competency. However, there was evidence that authorisation documents also needed to be reviewed to ensure they were up to date with current legislation.
Although there was no formally documented procedure in place, the authority had created a detailed information pack for officer reference, which included legislation and guidance relevant to Regulation (EC) No. 669/2009. There were well organised, effective systems and arrangements in place in relation to the control of imported foods. The authority had developed a robust system for the identification of incoming consignments of containerised food through the systematic, detailed checking of every ship’s manifest.
Facilities and equipment for the inspection and sampling of imported food of non-animal origin (FNAO) and feed were available and commensurate with the limited range and volume of such products arriving at the port at the time of the audit.
The ports had an effective consignment control system, which enabled the authority to immediately hold any containerised consignment where further information or an inspection was required.
Imported FNAO and feed controls, including documentary checks, identity checks and random physical checks, were risk based and targeted in accordance with current legislation and officers’ previous knowledge and experience.
Appropriate action had been taken on consignments and where necessary notices had been served requiring appropriate follow-up action on food consignments.
Records maintained in relation to imported food were detailed, accurate and easily retrievable.
There were extensive liaison arrangements with central government, other enforcement bodies, professional organisations and other external stakeholders. The authority had ensured that businesses had been advised in regard to imported food control requirements, although there was scope for improving liaison arrangements with the HMRC Border Agency.
The authority had carried out some quantitative and qualitative monitoring of its imported food and feed activities, including quarterly monitoring of relevant targets, annual officer performance and development appraisals, and regular documented team meetings. In addition there was other evidence of competency monitoring and supervision especially in relation to newly appointed officers. However, this monitoring was not routinely documented. Auditors discussed the need to develop and implement a procedure to ensure that risk based monitoring of all areas of imported food and feed enforcement, including officer authorisation, was carried out on a regular basis. Records of such monitoring should be maintained.
The authority had made quarterly imported food returns and had submitted their annual 2009/2010 Local Authority Enforcement Monitoring Scheme (LAEMS) return.
