West Yorkshire Joint Services

The service had developed a Food and Feed Service Plan for 2011/2012 that included focused delivery objectives for the feed law enforcement service. This 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 the resources available to the service, based on the full range of demands placed upon it. The service carried out and reported on regular reviews of its progress against key service performance indicators.

The service operated an accredited quality system, which included a quality manual of procedures relevant to the feed law enforcement service. There were a number of procedures required by the Framework Agreement that had not been developed, and it was agreed that their need would be reviewed in light of the plan to have a newly qualified officer working in the team later in the year.

The service had a documented procedure for the authorisation of officers including those working in feed law enforcement. This set out the means by which officers were authorised, based on their qualifications, training, experience and competency. It was clear that the lead officer for feed had received an appropriate level of relevant training and that an officer intending to work in the team was also receiving appropriate training for their intended role.

It was evident at the time of the audit that the register of feed establishments was incomplete and not being routinely maintained. Following the audit, the list was updated with information obtained from the constituent local authorities and a significant number of farm premises requiring registration were provided with a nominal activity code. Audit database checks on a random selection of feed businesses in a commercial directory confirmed that these were generally present on the database but not necessarily included in the inspection programme or on the register of feed establishments.

The service had identified the feed establishments that it considered to be high-risk and had undertaken to inspect these on an annual basis. It was not evident that medium and low risk establishments were included or targeted as part of a risk-based inspection programme. Files generally included information on the visits that had been undertaken, including information on samples taken and referrals relating to the business. However, there was insufficient information in visit reports and inspection records to indicate the officers’ assessment of feed safety management systems or their implementation by the operators and whether any follow-up actions were required. It was also not clear that intelligence from industry audits was being used to effectively inform the focus of the inspection.

The service’s sampling programme was based around sampling from the establishments that were inspected as high risk. It was discussed that future reviews of the sampling policy and programme should in addition take close account of the national enforcement priorities on feed. It was not clear that unsatisfactory sample results relating to similar issues from successive visits were being adequately investigated or resolved, or that the information from such sampling results was informing the focus of future inspections.

The service had developed a comprehensive enforcement policy which included the feed law enforcement activities. There were in addition some enforcement procedures that formed part of the quality manual. These required further development to cover all available enforcement options for feed. The service advised that there had been no formal enforcement actions in the past two years.

The service had developed complaints procedures that covered feed, and these included referral arrangements from other local authorities. Audit record checks confirmed that, in general, appropriate investigations had been undertaken with relevant advice provided to businesses, and there had been effective liaison and communication with other local authorities where appropriate.

It was evident that there was an established structure for reporting the results of quantitative monitoring throughout the service and to members. While auditors were advised that there were mechanisms in place for some qualitative monitoring activities, there were no records to confirm this took place.

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 demonstrate a satisfactory working knowledge of animal feed enforcement.

A visit to an establishment that processed surplus food into 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 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 general feed hygiene requirements and the procedures for the removal of waste packaging from the product.