Food Hygiene Service Plan 2020 2021 - Rochford District Council

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Food Hygiene Service Plan
                                            2020 - 2021

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Introduction

                 The current pandemic has resulted in an unprecedented situation where the Food
                 Standards Agency (FSA) has suspended part of the 2019 – 2020 programme and the
                 2020 – 2021 is currently suspended until further notice. As such the current guidance
                 from the FSA is that Local Authorities are not to visit food premises unless it is urgent
                 such as to investigate a food poisoning outbreak.

                 New legislation, The Health Protection (Coronavirus, Restrictions) (England)
                 (Amendment) (No2) Regulations 2020, places restrictions on food premises and has
                 required some to temporarily close.

                 These factors have meant that when writing the service plan a number of assumptions
                 have had to be made when writing this service plan and the number of due inspections
                 has been calculated as normal.

                 The pandemic has introduced an element of uncertainty into the departments planning
                 for the year and any alterations made by the FSA to the 2020 - 2021 work programme
                 will result in amendments to our service plan.

                 Social distancing requirements has meant staff have been re-deployed to work from
                 home dealing with issues such complaints, queries and advice. Investigations into
                 infectious diseases.

                 The pandemic has meant that the department has taken on additional responsibilities
                 in order to help protect the public such as enforcing the new Regulations relating to
                 what premises can trade. It is anticipated that the department will be asked to assist
                 Public Health England contact tracing and this could result in a significant amount of
                 work, details are awaited at time of writing.

1               Demands on the Food Service

1.1             Make up Of Rochford District

                As of 1 April 2020, we have identified that the service is responsible for enforcing Food
                Safety legislation in 563 food premises within Rochford District, a reduction of 98
                premises from the previous year. This is entirely due to a reduction in the number of
                premises trading. The risk assessment programme for food safety is set out in the
                Food Law Code of Practice (England) 2017, Inspection Rating Scheme. The Code of
                Practice requires that all food premises be subject to a degree of surveillance although
                the code does allow alternative enforcement methods to be used with the lowest risk
                premises.

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The 563 food premises have been categorised as follows:

                                              Number of      Number of
                         Risk category      premises 2020-   premises      Intervention frequency
                                                2021         2019-2020

                                        A         1              0         At least every 6 months

                                        B        19             21         At least every 12 months

                                       C         58             71         At least every 18 months

                                                                           At least every 2 years
                                                 187                       alternating        between
                                       D                        166
                                                                           official controls and other
                                                                           interventions

                                                                           At least every 3 years by
                                        E        291            313        alternative enforcement
                                                                           strategy

                The total number of total rated food premises in 2020 to 2020 is calculated as 556.
                The total number of rated premises in 2019 to 2020 was 571. The number of unrated
                newly registered premises in 2020 to 2021 is currently 7, and in 2019 to 2020 was 90.
                All new premises must be inspected within 28 fays of registration. Therefore, the total
                number of food premises known in 2020 is currently 563, and in 2019 it was 661.

1.1.1           The percentage of food premises in the Rochford District that score 3 or above
                (satisfactory) on the national Food Hygiene Rating Scheme (FHRS) is currently 85%.
                This is identical to the average score for nearby authorities within the Essex area.

1.1.2           Arrangements are in place via the out of hours service for contacting senior officers
                regarding matters arising outside of normal working hours e.g. food poisoning
                outbreaks, food safety incidents and food alerts.

1.2              Enforcement Policy

1.2.1           The service has adopted the Government’s “Regulators Code” which contains
                statutory guidance and means that the Council is committed to open and fair
                enforcement of the law pertaining to food safety. These principles are also embedded
                within the services enforcement policy which can be found on the Councils website or
                a paper copy can be obtained from the Council Offices. Enforcement decisions will be
                documented and monitored to demonstrate adherence with the policy.

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2               Service Delivery
2.1             Food Premises Interventions

2.1.1            The food service carries out programmed interventions of food premises to assess the
                 hygiene of those premises and the public health protection aspects of the law. A
                 programmed intervention is either an inspection by an officer or in some cases a self
                 assessment questionnaire. The service has a documented procedure for food hygiene
                 interventions which is reviewed annually and revised as and when legislation/guidance
                 changes.

2.1.2            Following every primary food hygiene intervention, the officer assesses the risk posed
                 by the business with reference to the nature of its operation, the level of compliance
                 with food safety requirements and confidence in its management. A risk rating score
                 is generated on these criteria and is used to determine the frequency of inspection
                 based on the Food Law Code of Practice.

                 Intervention programme due 2020-2021

                                            Category      Interventions due         Overdue from 2019
                                                              2020-2021                  - 2020
                                               A                    0                        0
                                               B                   17                        0
                                               C                   28                        0
                                               D                   80                        11
                                               E                   84                        32
                      Unrated premises (new)                        5                        2
                      Total                                       214                        45
                      Total intervention programme                            259

2.1.3            Revisits will be undertaken where significant breaches of hygiene regulations are
                 identified during inspection. Based on the percentage of inspections previously
                 generating revisits, it is estimated that the department will have to carry out between
                 30 to 40 revisits in 2020-2021.

2.1.4            Any new food premises that register with the authority will receive an inspection where
                 the officer will provide guidance on how to run their food businesses so that they
                 produce safe food for their customers. When applicable officers will refer new food
                 business to the authorities Economic Development Team for further support from the
                 authority.

2.1.5            Any food business that meets the criteria for requiring approval, produces large
                 amounts of potentially high-risk food that is being distributed to a large market, will not
                 be allowed to trade until they have been granted approval.

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2.1.6            The Food Law Code of Practice requires 100% of premises due for inspection to be
                 inspected within 28 days of their due date. Priority is given to high risk (Category A, B
                 and C) inspections. Category D and E premises may be risk rated by alternative
                 inspection strategies such as the use of a questionnaire.

2.1.7           Food safety functions such as inspections/interventions, investigating food complaints,
                dealing with food poisoning outbreaks, enquiries, requests for advice, food sampling
                and investigation of poor sampling results are undertaken by the Environmental Health
                Team Leader and two Environmental Health Officers (EHO).

                 All officers have access to the following technical support:

                 •                Internet Access.

                 •                Primary Authority Database.

                 •                The Food Hygiene Forum Community of Practice.

                 •                FSA website, publications and seminars.

                 •                The Knowledge Hub.

                 •                Legal library resources.

2.2              Complaints about Food and Food Businesses.

2.2.1            Policy and Procedures for responding to and dealing with complaints, enquiries and
                 other requests for service are documented with in the standard operating procedures.
                 These are reviewed annually and revised as and when legislation/guidance changes
                 or improvements to client experience are identified.

2.2.2            All complaints that are investigated are done so in accordance with the services
                 enforcement policy and procedures. Emphasis is placed on those complaints that have
                 the potential to cause most harm to public health.

2.2.3            If further investigation is required, the food complaint is sent to the Public Analyst (Kent
                 and Hampshire Scientific Services) for formal analysis or to the food examiner (Public
                 Health England, Colindale) for microbiological examination.

2.2.4            Based on trends over the last four years it is estimated that the following number of
                 service requests complaints and requests for service will be received during 2020-
                 2021.

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Number of service requests received over the past four years

                                              Year                        Number of service requests
                                            2016-2017                                  192
                                            2017-2018                                  166
                                            2018-2019                                  137
                                            2019-2020                                  181
                                            2020-2021                             169 Estimated

2.3              Home Authority / Primary Authority

2.3.1            The Primary Authority Scheme’ allows a business, or the Local Better Regulation
                 Office, to nominate a Local Authority to become a central point of contact on regulatory
                 matters linked to a specific business. It is not a requirement for the company to be in
                 the nominated authorities district.

2.3.2            There are currently no formal or informal Primary Authority Partnerships set up for any
                 food business within Rochford District.

2.3.3            Extra resources would be required for meeting and advising businesses should we
                 become a primary authority for a business.

2.4              Advice to business

2.4.1            The provision of advice is given to existing or proposed food businesses on request to
                 help them comply with the law and to encourage best practice. This also reflects and
                 contributes towards the ‘Hampton Principle’ of providing authoritative, accessible
                 advice easily and cheaply. This is achieved through a range of activities including:

                 •                Advice given during inspections and other visits to premises.

                 •                Provision of advisory leaflets.

                 •                Responding to service requests and enquiries.

                 •                Through participation in the “Safer Food Better Business” scheme.

                 •                Through information placed on the Council’s website.

2.4.2            Officers give advice in accordance with recognised guidance and Codes of Practice
                 and ensure that on-site visits are made, where necessary, prior to opening of new
                 businesses that we are aware of.

2.4.3            Procedures for responding to and dealing with complaints, enquiries and other service
                 requests are documented in the standard operating procedures. These will be
                 reviewed annually and revised as and when legislation/guidance changes.

2.4.4            Extra resources would be required if the service were to have significant input into
                 business partnerships or forums.

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2.5              Food Sampling

2.5.1            A procedure for the microbiological sampling of foodstuffs is documented and is
                 reviewed annually and revised as and when legislation/guidance changes.

2.5.2            Food sampling carried out by the service is mostly undertaken for monitoring and
                 surveillance purposes on an informal basis. Occasionally formal food sampling is
                 required as part of a food poisoning investigation or prosecution.

2.5.3            The Public Health England (PHE) laboratory has produced a regional co-ordinated
                 food sampling programme for 2020-2021. This includes four co-ordinated sampling
                 initiatives organised by Local Government Regulation. Additional sampling will be
                 organised in-house based on local intelligence and previous results.

2.5.4            Other food sampling can be undertaken as part of food poisoning and complaint
                 investigations or as part of food premises inspections to monitor hygiene standards
                 and confirm adequacy of food processing systems.

2.5.5            The Public Health England (PHE) laboratory allocates the Council credits for funding
                 examinations of food carried out at Public Health England (Colindale). Rochford
                 District Council has been allocated 4000 credits for the year 2020-2021. This is the
                 same amount of credits issued as last year and based on current demand is sufficient
                 for our purposes.

2.5.6            The service has appointed Kent Scientific Services and Hampshire Scientific Services
                 as the Council’s official Public Analysts, in accordance with section 27 of the Food
                 Safety Act 1990. The Public Analyst will be used by the service when food
                 contaminants cannot be readily identified and require closer examination to discover
                 their true nature.

2.6              Control and Investigation of Outbreaks and Food Related Infectious Disease.

2.6.1            The service assesses all notifications it receives of cases of food poisoning and
                 suspected food poisoning occurring within the District and takes appropriate control
                 measures where necessary. When an outbreak is suspected the investigations are
                 carried out either jointly or in close contact with the Consultant in Communicable
                 Disease Control from PHE. Outbreak Control investigations will be conducted in
                 accordance with the Control of Communicable Disease Joint Plan of Essex Local
                 Health Protection Teams and Essex Local Authorities.

2.6.2            Procedures for the investigation of food poisoning notifications are documented in the
                 standard operating procedures and are reviewed annually and revised as and when
                 legislation/guidance changes.

2.6.3            Based on trends over the last four years it is estimated that the following number of
                 food related infectious diseases will be received during 2020-2021.

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Number of food related infectious diseases for the past four years

                                                             Number of formal notifications of food
                                              Year
                                                                 related infectious disease
                                            2016-2017                            79
                                            2017-2018                            111
                                            2018-2019                            121
                                            2019-2020                            177
                                            2020-2021                      122 Estimated

2.7              Food Alerts and Food Safety Incidents.

2.7.1            A food alert is a communication from the Food Standards Agency (FSA) to the local
                 food authority concerning a food hazard or other food incident. The food alert may or
                 may not require the food authority to act.

2.7.2            Procedures for responding to and initiating food hazard warnings are documented in
                 the authorities standard operating procedures. These are reviewed annually and
                 revised as and when legislation / guidance changes.

2.7.3           The service receives food alerts via a dedicated FSA – enforcement mailbox. This
                service delivery area is carried out in accordance with the requirements stipulated in
                the Food Law Code of Practice (England) Chapter 2:2. Based on trends over the last
                four years it is estimated that the following number of food alerts will be received during
                2020-2021.

                Number of food alerts

                                              Year                    Number of food alerts
                                            2016-2017                            66
                                            2017-2018                            49
                                            2018-2019                            98
                                            2019-2020                            189
                                            2020-2021                      100 Estimated

2.8              Liaison with other organisations

2.8.1            Rochford District Council has been represented at regular meetings of the Essex Food
                 Liaison Group by its Environmental Health Team Leader. From this year the due to
                 staff changes the representative will be an EHO. In order to encourage consistency of
                 enforcement within the 14 Essex Authorities the group formulates strategies and
                 procedures. It liaises with other professional bodies such as food trade and trade

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organisations over specific matters arising and takes advice from groups including the
                 FSA, Meat and Livestock Commission. The group also undertakes peer review
                 exercises and arranges relevant officer training.

2.8.2            This group includes representatives from authorities such as: Trading Standards, The
                 FSA and a microbiologist from the Essex Health Protection Agency Food Laboratory.

2.8.3            One of the EHO’s regularly attends the Health Protection Liaison meeting. These
                 meetings were set up to develop guidelines on infection control measures, act as
                 advisory groups, making recommendations on all aspects of communicable disease
                 (including food poisoning) conduct peer reviews and to formulate outbreak control
                 plans.

2.8.4            This group includes representatives from food authorities, the Health Authority, the
                 Primary Care Trust and Essex and Suffolk Water.

2.8.5            The service liaises with other departments within Rochford District Council including
                 Economic Development, Community Safety, Building Control, Planning and Licensing.

2.8.6            The service is regularly consulted on planning and building regulation applications
                 regarding new and existing food premises and in respect of licensing applications for
                 which we act as a responsible authority. These are used to identify new food business
                 and changes to existing operations.

2.9              Food Safety Promotion
2.9.1            We will continue as an authority take part in the National Food Safety Week and the
                 Essex Tuck In project that both promotes healthy / healthier eating within the district.
                 Both these projects encourage food business on the district to provide health options
                 to their customers by reducing the amount of salt and fat in food. The service will work
                 with business encouraging as many as possible to partake and help those that do to
                 maximise their involvement.

2.9.2            Substantial information regarding food and infectious disease has been placed on the
                 Environmental Health section of the Council’s website.
2.10             Safer Food Better Business Coaching Sessions
2.10.1 The service provides one to one coaching sessions on “Safer Food Better Business”
       with caterers and retail premises within the district that request our help. We will
       contact businesses that are known or suspected to have had difficulties with the
       implementation of a food safety management system and identify such premises
       during routine inspections.
2.11             Food Hygiene Rating System / Charging for re-rating Visits
2.11.1 The National FHRS has been operating in Rochford District since February 2011. We
       will continue to promote this scheme to both members of the public and businesses
       with the message that maintaining a high standard of food hygiene is good for
       business.
2.11.2 Part of the scheme involves carrying out re-ratings of premises that want to improve
       their rating such re-rating requests, these visits are carried out between the planned

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statutory hygiene inspections at the request of the food business operators. Whilst
                limited within Rochford these visits do place an additional burden on staff resources.
2.11.3 The current FSA guidance allows authorities to make a charge for requests received
       for an FHRS re-rating inspection on a cost recovery basis only using powers available
       under the Localism Act 2011.
2.11.4 When calculating the charge for carrying out a re-rating consideration was given to the
       guidance issued by HM Treasury on “Managing Public Money” and based upon the
       average hourly rate for an officer to undertake an inspection, including the completion
       of the associated administration arising from the visit. The current fee for a re-rating
       ahead of its routine schedule is £123.80.
2.11.5 No food business chose to pay for a re-rating during 2019 – 2020.

3                Resources
3.1              Staffing Allocation

3.1.1            One of the EHOs was on extended sick leave throughout most of 2019, it was therefore
                 decided that a contractor would be engaged to cover them until they were able to
                 return to work. Without this appointment the department would not have been able to
                 meet all of its statutory obligations and this would mean the public would be placed at
                 an increased risk from food borne illness and the Authority from criticism from the Food
                 Standards Agency who regulate this function. The EHO returned to work in November
                 2019.

3.1.2            The resources available to undertake food law enforcement during 2020-2021 will be
                 1.85 full time equivalent officers as detailed below:

                                               Officer                 Full time equivalent (FTE)
                                            Team Leader                            0.15
                                     Environmental Health Officer                  0.9
                                     Environmental Health Officer                  0.8
                                                Total                              1.85

3.1.3            Two members of the team fall into a health protection category meaning that on current
                 Government advice they should not come into close contact with the public. For as
                 long as this guidance remains in effect safe working methods such as use of
                 appropriate personal protective equipment would be required to carry out normal work
                 activities. Failure to establish a safe working system would significantly impact on the
                 resources available to carry out food hygiene inspections.

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3.2              Staff Development Plan

3.2.1            Officers authorised to undertake inspections and other enforcement duties must be
                 suitably qualified, experienced and competent as set out in Chapter 4 of the Food Law
                 Code of Practice (England) 2017.

3.2.2            As part of the personal performance and development appraisal scheme all authorised
                 food safety officers undergo annual performance reviews which include review of their
                 training requirements and personal development objectives. Regular team meetings
                 are organised to discuss matters and issues of consistency.

3.2.3            The staff covering this service will continue to be encouraged, motivated and trained
                 to develop their potential and use their talents for the benefit of the people of the
                 district.

3.2.4            The Food Law Code of Practice (England) 2017 requires all food officers to undergo
                 at least 20 hours of continuing Professional Development each year in order to remain
                 competent. The Environmental Health Team Leader is responsible for checking that
                 all food competent staff fulfil this requirement.

3.2.5            Officers whose knowledge in relation to food matters has lapsed or has become out
                 of date must undergo structured revision training before resuming food law
                 enforcement duties. Records of ongoing training are kept by the Environmental Health
                 Team Leader.

3.2.6            To fulfil training needs, officers attend seminars and courses arranged by the Essex
                 Food Liaison Group, Central Government advisory bodies, other local authorities and
                 external training organisations.
3.3              Quality Assessment
3.3.1            The quality of service provided by the unit is assessed by:

                 •                Monitoring performance against service and officer targets.

                 •                Monthly reporting on work conducted and progress towards established
                                  targets to the Assistant Director and Team Leader.

                 •                Monitoring actual working practices against procedures and protocols for:

                                  −         Inspection of food businesses

                                  −         Investigation of complaints and food poisoning notifications

                                  −         Carrying out sampling

                                  −         Enforcement

                                  −         Undertaking customer satisfaction surveys of local businesses receiving
                                            inspection
3.3.2            Performance monitoring will be undertaken by generating monthly reports from the
                 Uniform database on:

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•                Inspections, for comparison against the annual programme and

                 •                Complaints and other service requests to monitor progress.
3.3.3            The Environmental Health Team Leader will carry out audits and monitor working
                 practices internally. Should the need arise for additional monitoring of the food
                 function we would approach the Essex Food Liaison Group.

3.3.4            In order to ensure consistency, the team will take part in the annual consistency
                 exercises run by the FSA and the Essex Food Group. In addition, all officers including
                 the Environmental Health Team Leader will take turns shadowing the other team
                 members to monitor working practices.

3.3.5            At the end of the service plan period the Authority will compare the years performance
                 targets and performance standards included in this service plan. Any variation and the
                 reasons for the variation will be included in the review and any service development
                 or improvement will be identified, as necessary.

4                Review of 2019-2020
4.1              An annual review of the previous year’s service plan is completed at the start of each
                 financial year.

4.2              One of the EHOs was on extended sick leave up until November 2019 resulting in the
                 need to employ a contractor to maintain department capacity. However, it was
                 necessary to prioritise the workload to the detriment of other areas of work such as
                 sampling and inspecting new premises.

4.3              Total number of interventions completed

                 Non programmed food hygiene inspections are new premises that open on the district,
                 revisits and high-risk premises that become due twice in that year.
                                                            Inspections       Actual           Percentage
                                                              due for       carried out        completed
4.3.1                                                        2019-2020
                    Programmed food hygiene
                   interventions due at start of                363             320               88%
                           programme
                  Non programmed food hygiene
                                                                   50           48                96%
                       inspections – revisits

Breakdown of programmed Interventions

                                      Category         Interventions due    Actual carried      Percentage
                                                           2019-2020             out            completed
                                   A (high risk)               0                     0             n/a
                                   B (high risk)               18                  18             100%

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Category     Interventions due      Actual carried        Percentage
                                                       2019-2020               out              completed
                             C (moderate risk)            47                   47                 100%
                                    D (low risk)          65                   51                  78%
                                    E (low risk)         143                   114                 80%
                      Unrated premises (new)              90                   90                 100%

4.4              Reactive work 2019-2020

                This is the reactive work that varies from year to year.

                                                     Actual carried out        Estimated for 2020-2021
                  Reactive food hygiene
                                                               31                           -
                       interventions
                  Food hazard warnings                      189                            100
                  Food related infectious
                                                            177                            122
                         diseases
                  Hygiene rating appeals                     0                              -
                Number of service requests                  189                            169

4.5              Prosecutions/notices served 2019-2020

                 Hygiene Improvement Notices                        –     13

                 Hygiene Emergency Prohibition Notice               –     0

                 Hygiene Emergency Prohibition Order                –     0

                 Simple Cautions issued                             –     0

                 Prosecutions                                       –     0

4.6              Sampling Visits

4.6.1           The Sampling Officer (EHO) was on extended sick leave for a significant proportion of
                the year but despite this the team still managed to achieve a total of 18 sampling visits
                during 2019-2020.

                The target for 2020-2021 is to complete all planned sampling visits, as stated in the
                new 2020-2021 sampling plan.

4.7              Promotional activities

4.7.1           Leaflets were distributed to butchers for ongoing distribution to their customers
                regarding barbecue and turkey safety during appropriate seasonal periods.

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4.8              The current Coronavirus (COVID-19) pandemic

4.8.1           The Current pandemic resulted in the FSA suspending the inspection programme
                nationally before the end of the year. All of the outstanding 43 interventions were low
                risk premises due questionnaires and not a full inspection. They had all been sent a
                questionnaire and the team was in the process of calling each premises to chase there
                return. If the FSA had not suspended the work programme it is anticipated that they
                would have all been contacted and the questionnaires completed over the phone and
                the programme completed.

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