Nottinghamshire County Council

The authority had recently undergone substantial operational and staffing restructures and was committed to a systems thinking approach to their service. As a result of a recent review of their quality manual they were undertaking a complete review of their food and feed law enforcement activities.

The authority had developed a Food and Feed Law Service Plan for 2011/12, which generally contained service delivery information in line with the service planning guidance in the Framework Agreement. The plan would benefit from being further developed to highlight the staff and financial resources available to the authority compared with the resources required to deliver the service. Further details and confirmation of the feed inspection programme for the year based on the findings of the review, together with a breakdown of the premises profile in the area, including known unrated premises, would also be essential.

The quality manual contained a range of feed policies and procedures in accordance with the standard in the Framework Agreement and the Feed Law Enforcement Code of Practice (FLECP). All documents examined for the audit were up to date and contained reference to appropriate legislation and centrally issued guidance.

Authorisations should be reviewed by the council’s legal department to ensure that officers were appropriately authorised under all relevant legislation. The authority also needed to ensure that individual officers were appropriately authorised at a level that reflected their individual level of experience, training and competence.

Training needs were identified as part of an annual performance review process. Officers would benefit from additional training, for example in the assessment of feed safety management systems, and to maintain competency training in accordance with the FLECP.

The authority had an electronic database for the recording of feed law enforcement activities, which was capable of providing information necessary for official returns. The authority could not confirm with certainty the number of feed premises that needed to be registered or the registration activity codes of those premises that had been registered, although these issues were being addressed as part of the ongoing review.

The service had identified feed establishments that it considered to be high risk, and had undertaken to inspect these on an annual basis. Auditors discussed the requirement to undertake relevant interventions in medium and low risk premises in accordance with the FLECP.

Audit file checks on a number of high risk feed establishments confirmed that there was not always sufficient detail of inspection findings, in particular the officers’ assessment of feed safety management systems based on Hazard Analysis and Critical Control Point (HACCP) principles. The authority had recently been awarded a grant from the Agency to support official controls at targeted feed businesses and subsequently, with the addition of prompts on the inspection form, were recording more comprehensive details.

The authority had developed a documented policy and procedure for feed sampling, based upon officers using individual discretion during visits at high risk establishments. Auditors advised that, following the review of the feed premises in the area, the service would benefit from developing a proactive sampling programme to ensure that feed sampling activity was targeted at areas of highest risk in accordance with the national enforcement priorities. Files examined showed that sampling results had been followed up where necessary and, in accordance with the FLECP, that feed business operators had been advised of the outcomes and appropriate advice had been issued.

The service had developed a generic enforcement policy but would benefit from the development of further procedures covering the full range of enforcement options available to officers. Auditors were advised that there had been no formal enforcement actions in the past two years.

The service had developed a feed complaints procedure. Audit record checks confirmed that, in general, appropriate investigations had been undertaken with relevant advice provided to businesses. Feed complaint records were easily retrievable, detailed and up to date.

There was evidence of an established structure of annual, six monthly and monthly staff development reviews. The authority would benefit from also developing and implementing a flexible and risk-based internal monitoring procedure to cover the full range of feed law enforcement activities, in accordance with the requirements of the standard in the Framework Agreement.

An officer who regularly carried 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 demonstrate a satisfactory working knowledge of animal feed enforcement.

A visit to a large manufacturer co-producing feed 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 feed businesses' compliance with legislative requirements. The officer was familiar with the operations taking place at the business, although further detailed investigation of business processes was suggested for future inspections, particularly in relation to key feed hygiene requirements and the HACCP assessment.