Minutes of Food Safety Sub Committee: 10 March 2008

Present
Craig Brown - South Lanarkshire Council, West of Scotland Liaison Group (Chair)
Craig Smith - West Lothian Council, Lothian and Borders Liaison Group
Frank Feechan - Dundee City Council, East of Scotland Liaison Group
James McLennan - The Moray Council, North of Scotland Liaison Group
Catherine Reilly - North Ayrshire Council, West of Scotland Liaison Group
Rod House - Health Protection Scotland
Mark Duncan – Scottish Food and Drink Federation

Apologies
Andrew Morrison - Food Standards Agency Scotland
Mary Lawton - Scottish Consumer Council

Minutes of previous meeting – 14th January, 2008, Irvine
Matters of accuracy

Page 1, point 3 should refer to “fish” hygiene working group and not food.

Page 3, reference to West Lothian report. City of Edinburgh Council provided pest control training.

Page 4, North of Scotland report reference to lead auditing course should read ISO22000.

Matters arising
Food Hygiene Information Scheme
Frank Feechan indicated that he believed that North Lanarkshire Council has introduced its own star rated information scheme. This was noted as an interesting development in advance of the FSA report on such schemes.

FSA HACCP Training Course
Craig Brown indicated that the course was not just intended for lead officers in food safety.

Low-cost training
Catherine Reilly questionned whether the food and nutrition labelling training being offered in England would be available to officers in Scotland at some time. Agreed that this should be put forward as a request for low cost training programme.

EU review of Article 5
It is understood that the EU are still considering the extent of businesses to which article 5 requirements should apply. In light of this ongoing consideration, Craig Brown would continue to hold back from SFELC the groups guidance on article 5 compliance.

Suppliers to Approved Establishments
A previous question as to whether suppliers to approved establishments had to be approved seems to be answered in the code of practice. Craig Brown highlighted that the COP indicates that such businesses should be approved.

Use of Remedial Action Notices
Members to get feedback from liaison groups on use of RANs, if they are to be extended to non – approved establishments. In particular looking for specific circumstances in which they could be served. Also would be useful to have feedback on where they have been served in approved establishments.

Childminders
A consultation document on inspection of childminders for food hygiene is still to be circulated by FSA. There are concerns regarding the inspections being undertaken by the Care Commission. The FSSC are to consider potential for use by local authorities of alternative enforcement strategies for such businesses. Feedback and ideas from liaison groups is required. Catherine Reilly suggested that North Lanarkshire had done some work in this area.

CPD Working Group
Frank Feechan is to chair the group. He has already been provided with details of group members by all liaison groups with exception of Lothian & Borders. Craig Smith to pursue a response from his group, and get back to Frank Feechan asap.

Other issues
Craig Brown raised the issue of the national food policy and the current Scottish Government document – Choosing the right ingredients. Lydia Wilkie had given a report to SFELC and mentioned that there had been a meeting with the Scottish Government on food safety enforcement in Scotland.

Mark Duncan had attended a SFAC stakeholder meeting on 5th March to discuss at the bigger issues in relation to national food policy, e.g, food and tourism, training for industry, schools etc.

It was agreed that this would a good opportunity to include food safety enforcement issues within the role of food and health issues. The document currently makes little if any mention of food protection issues. From general discussion a number of members have been involved in these issues at a local level with health boards etc. It would be appropriate for those involved in food enforcement to consider a response to the document to ensure their role is given appropriate consideration.

SFELC workshop feedback
FSA had collated discussion points from Thursday meeting for SFELC meeting on the Friday. These have been emailed to group by Craig Brown. Craig Brown had responsibility for taking forward two areas; policy to delivery, and outcomes and influence. Craig Brown has provided some outline and initial thoughts on these two areas, and the group had a general discussion regarding them.

Craig Brown is seeking feedback from FSSC group and liaison groups on the issues raised within his reports. In particular comments are sought regarding:

• policy to delivery report, page 4 'suggested improvement and the way forward', and page 5, 'recommendations'
• outcome and influence report, page 2 'recommendations'
• should SFELC have a 'business plan' set up to demonstrate workplan activities and progress made etc.?

Craig Brown requested a response on these matters by end of March / beginning of April to allow him to prepare response for SFELC meeting in April.

Updates from Food Liaison Groups
Lothian & Borders

A meeting had been held in Edinburgh to consider groups response to food law code of practice consultation.

East Lothian had hosted the REHIS food and health course for enforcement officers.

West Lothian continue to have issues with the application of the vac pac guidance requirements for challenge testing, and the difficulty in getting any further technical guidance or advice on valid and acceptable testing methods for Clostridium Botulinum.

East of Scotland
There is an increasing issue with non-English labelling of products within Polish operated businesses.

Concern had been expressed by group regarding lack of link up between Audit Scotland and FSA in relation to statutory performance indicators. Also concern about FSA approach to the better regulation agenda.

North of Scotland
The issue of approving stand alone egg packers had been discussed in the group.

Inspection of primary producers and the issues involved had been discussed.

Concerns have been expressed regarding the increased information required by the new LAEMS.

Have organised training in allergen awareness, lead assessor, food and health.

West of Scotland
The group has run a food and health course.

The group has had a meeting to discuss a response to the food law code of practice.

The group has had a discussion regarding the SFELC workshop.

There was an issue raised regarding the application of the new licensing act and implications for food safety. In particular whether previous Section 23 certificates no longer applied and that all businesses would require to re – apply for new certificates. There appeared to be different opinions within different licensing sections.

FSA update
There was no representative from FSA. However, update report is circulated to all local authorities.

HPS update
E.coli task force report has been looked at. Draft guidance for consultation is expected by end of March.

A board has been established to look at GI work. Remit is to oversee and direct work of GI team in all aspects.

SCC update
No report.

Industry update
Mark Duncan indicated that the issue of article 5 application and EU consideration of the matter was an issue of concern at this time.

Working Group updates
Fish Hygiene Working Group

There had been a visit by Russian delegation to inspect premises supplying Russian market. Local authorities involved were Aberdeenshire, Shetland, and Highland. SEERAD were also involved and would like on involved in future LA inspections of these plants, due to being authority responsible for signing export certificates.

The group would like to be included on the SFELC website.

The group would like FSA to consider running the BIP training course again as part of low cost training programme.

Legislation/Code of Practice issues
Allergens aide memoire / Continental Markets Guidance
Both documents have been produced by North of Scotland group. It was agreed that these could be taken back to liaison groups for consideration and subsequent referral to SFELC to be agreed as guidance / good practice.

Childminders
As per earlier point, this matter is to be discussed with liaison groups to consider how best to take forward.

Food Law Code of Practice consultation
Response to consultation to be with agency by 14th March, 2008. Craig Brown will be involved in considering the responses. He will require agency guidance on what, if any, differences can exist between Scotland and the rest of the UK. FSA have indicated that feedback, in particular, is sought regarding officers with higher certificates serving HEPN.

Frank Feechan indicated this matter had been discussed by East of Scotland group, and that there was a mixture of authorities supporting and being against officers with higher certificates serving HEPN.

Current consultations
Audit arrangements
The FSSC has been asked to make a response in relation to this consultation. The deadline for responses is 21st April, 2008. Liaison group and individual responses are requested to be with Craig Brown by end of March to allow a response to be compiled.

Court cases
None reported.

Correspondence
There were no items.

Referrals to SFELC
The following items were to be referred to next SFELC meeting:

• feedback on reports from Craig Brown regarding SFELC workshop, i.e. policy to delivery, and outcomes and influence
• request from fish hygiene working group for narrative on the group to be added to SFELC website
• request for low cost training, food and nutrition course, and BIP training regarding fish products

Referrals to Liaison Groups
The following items were to be taken back to liaison groups for comment:

• North of Scotland allergen aide memoire for inspections
• North of Scotland guidance on continental markets
• measuring broadly compliant status of businesses within local authorities – learning from different approaches
• remedial action notices – requests for examples and guidance on use
• proposals for alternative enforcement strategies for childminders

James McLennan raised the issue of changes in charging regime for fish hygiene inspections. It is now a legal requirement for establishments to make a return, and therefore all local authorities should be enforcing the legislation.

Date of next meeting
12 May 2008, County Buildings, Linlithgow