South Gloucestershire Council

The authority had recently carried out substantial operational and staffing restructures and at the time of the audit was currently undergoing a management review process. A review of feed law enforcement activities was also underway, all of which had impacted significantly on service provision.

A comprehensive Feed and Food Controls Service Plan for 2011/12 had been developed, which generally contained service delivery information in line with the service planning guidance in the Framework Agreement. However, future plans could usefully highlight in more detail the financial and staff resources required to deliver the feed law enforcement service, against the resources available to the authority, based on the full range of demands placed on it. The plan had been approved by a senior manager.

The authority had recently developed comprehensive policies and procedures for its feed law enforcement activities 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.

Officers were authorised generically and the list of legislation in the schedule of authorisations was comprehensive and up to date. The Lead Officer for feed was appropriately authorised, qualified and experienced. The Aauthority also needed to have regard to the FLECP for existing officers to obtain ‘level one qualification’ by 1 January 2012.

Officer training needs were identified as part of an annual personal development and performance review process. Although recent feed training had been provided, the authority had not always been able to ensure that officers had received the required minimum of 10 hours continuing professional development in accordance with the FLECP. Officers would benefit from further additional training, for example in the assessment of feed safety management systems.

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 feed business registration database was being reviewed. There remained a need to update registration returns from Feed Business Operators (FeBOs) as the authority could not confirm with certainty the number of feed premises which needed to be registered, or the registration activity codes of those premises which had been registered.

The Service identified and allocated the feed establishments for their inspection programme on an annual basis. Auditors discussed the requirement to undertake relevant interventions within 28 days of the due date in accordance with the FLECP, prioritising higher risk premises.

Audit file checks on a number of feed establishments confirmed that there was not always sufficient detail of inspection findings, in particular the officers’ assessments of feed safety management systems based on HAACP principles. Auditors recommended that the authority adapt their inspection aides-memoire to provide appropriate prompts to enable officers to record more comprehensive findings.

The authority had developed a documented policy and procedure for feed sampling. A programme for 2011/12 had been developed in liaison with SWERCOTS, their regional liaison group, having regard to the national enforcement priorities. The authority was also part of a SWERCOTS sampling grant bid to the Agency for 2011/12. No sampling was undertaken during 2010/2011 as the authority renegotiated improved service level agreements with their providers. Files examined showed that sampling had been undertaken by a trained authorised officer and results were easily retrievable. These samples had received satisfactory test results so no follow-up actions had been necessary.

The service had developed a generic enforcement policy with additional formal enforcement procedures for guidance to staff in accordance with the standard in the Framework Agreement. Auditors were advised that no formal enforcement action had been deemed necessary in the past two years.

The service had developed a feed complaints procedure. Audit record checks for a recent referral from another local authority confirmed that appropriate investigations had been undertaken with relevant advice provided to the referring authority and the business. Records were easily retrievable, detailed and up to date.

There was evidence of quantitative and qualitative internal monitoring being carried out in the form of an established structure of annual, six monthly and monthly staff development and performance reviews. The authority should implement their proposed internal monitoring procedures to also cover the full range of feed law enforcement activities.

A visit to a high-risk feed manufacturer that routinely produced animal feeds as part of its operations 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, although further detailed investigation of business processes was suggested for future inspections, particularly in relation to the necessary HACCP and hygiene assessment, and for these findings to be recorded.