Food Standards Agency in Scotland - Report on the Audit of Local Authority Food Standards Enforcement Service in accordance with the Framework ...
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Food Standards Agency in Scotland
Report on the Audit of Local Authority
Food Standards Enforcement Service
in accordance with the Framework Agreement
on Official Feed and Food Controls by Local
Authorities
Moray Council
10 - 12 June 2013Food Standards Agency Audit Branch, Scotland
Foreword
Audits of Local Authorities food law enforcement services are part of the Food
Standards Agency’s arrangements to improve consumer protection and confidence in
relation to food and feed. These arrangements recognise that the enforcement of UK
food law relating to food safety, hygiene, composition, labelling, imported food and
feeding stuffs is largely the responsibility of Local Authorities. These Local Authority
regulatory functions are principally delivered through Environmental Health and Trading
Standards Services. The Agency’s website contains enforcement activity data for all
UK local authorities and can be found at:
www.food.gov.uk/enforcement/auditandmonitoring.
Agency audits assess Local Authorities’ conformance against the Food Law
Enforcement Standard (“The Standard”), the 5th revision of which was published in April
2010 by the Agency as part of the Framework Agreement on Official Feed and Food
Controls by Local Authorities and is available on the Agency’s website at:
http://www.food.gov.uk/multimedia/pdfs/enforcement/frameworkagreementno5.pdf
It should be acknowledged that there will be considerable diversity in the way and
manner in which Local Authorities may provide their food enforcement services
reflecting local needs and priorities.
The main aim of the audit scheme is to maintain and improve consumer protection and
confidence by ensuring that Local Authorities are providing an effective food law
enforcement service. The scheme also provides the opportunity to identify and
disseminate good practice and provide information to inform Agency policy on food
safety, standards and feeding stuffs. Parallel Local Authority audit schemes are
implemented by the Agency‘s offices in all of the countries comprising the UK.
For assistance, a glossary of technical terms used within this audit report can be found
at Annexe C.
Food Standards/784/08 1 August 2013Food Standards Agency Audit Branch, Scotland
CONTENTS
_________________________________________________________
1.0 Introduction 3
Reason for the Audit 3
Scope of the Audit 3
Background 4
2.0 Executive Summary 5
3.0 Audit Findings 6
3.1 Organisation and Management 6
Strategic Framework, Policy and Service Planning 6
Documented Policies and Procedures 6
Officer Authorisation 6
3.2 Facilities and Equipment 8
Food Establishments Database 8
3.3 Food Premises Interventions and Inspections 9
Records and Intervention Reports 9
Verification Visit to Food Premises 10
3.4 Enforcement 12
Food Complaints and Food Premises Complaints 12
Advice to Business 12
Food Inspection and Sampling 12
Food Safety Incidents 13
3.5 Monitoring 14
Internal Monitoring 14
Annexe A - Action Plan for Moray Council 15
Annexe B - Audit Approach/Methodology 17
Annexe C - Glossary 19
Food Standards/784/08 2 August 2013Food Standards Agency Audit Branch, Scotland
1.0 Introduction
1.1 This report records the results of an audit of Moray Council with regard to food
standards enforcement, under relevant headings of The Standard in The
Framework Agreement on Official Feed and Food Controls by Local Authorities
(Amendment Five, April 2010). The audit focused on the Authority’s
arrangements for organising and delivering the management of food premises
inspections, enforcement activities and internal monitoring. The report has been
made available on the Agency’s website at:
www.food.gov.uk/enforcement/auditandmonitoring/auditreports
Reason for the Audit
1.2 The power to set standards, monitor and audit Local Authority food law
enforcement services was conferred on the Food Standards Agency by Section
12 the Food Standards Act 1999 and Regulation 7 of The Official Feed and Food
Controls (Scotland) Regulations 2009. This audit of Moray Council was
undertaken under section 12(4) of the Act, and Regulation 7(4) of the
Regulations as part of the Food Standards Agency in Scotland audit programme.
1.3 The audit followed a desktop food standards monitoring exercise carried out in
February 2013. The purpose of the audit was to consider the detail of official
controls and enforcement carried out by local authorities to gain assurances that
food standards law enforcement is effective.
1.4 Previous FSA audits of Moray Council took place in 2006, 2009 and 2011.
Scope of the Audit
1.5 The audit covered the Local Authority services for the delivery of official controls,
and in particular:
to ensure that regulation is effective, risk based and proportionate and
leads to food produced or sold in the UK being safe to eat, and
to ensure that regulation is effective, risk-based, consistent and
proportionate and thereby ensuring that consumer interests are protected
from fraud and other risks.
1.6 The Audit brief was sent to the Authority in advance of the audit programme
beginning and is available at
http://www.food.gov.uk/multimedia/pdfs/enforcement/enfs13005.pdf
1.7 The audit examined Moray Council’s arrangements for food premises
interventions and internal monitoring with regard to food standards law
enforcement. This included a verification check at a food business to assess the
effectiveness of official controls implemented by the Authority at the food
business premises and, more specifically, the checks carried out by the
Authority’s Officers to verify food business operator (FBO) compliance with
legislative requirements. The scope of the audit also included an assessment of
the Authority’s overall organisation and management, and the delivery of other
related food law enforcement activities.
Food Standards/784/08 3 August 2013Food Standards Agency Audit Branch, Scotland
1.8 The audit examined key food law enforcement systems and arrangements to
determine that they were effective in supporting business compliance, and that
local enforcement was managed and delivered effectively. The on-site element
of the audit took place at the Authority’s Environmental Services office at the
Council Office, High Street, Elgin, IV30 1BX on 10-12 June 2013.
Background
1.9 The Food Law Enforcement Service is contained within the Environmental Health
section of the Development Services Division. The service is provided through
two multi-disciplinary teams divided on a geographical basis across Moray.
The staffing allocation available to undertake all core food law enforcement is 6
full time equivalent (FTE) Officers as advised in the 31st January 2013 return of
the Food Standards Questionnaire (December 2012). The authority is not able to
accurately quantify the specific resources for food standards enforcement. The
authority has advised that this number has reduced to 5 due to budgetary cuts for
2013/14.
1.10 The profile of Moray Council’s food businesses as detailed in the Food
Enforcement Service Plan 2013-2014 was as follows:
Type of premises Number
Primary Producers 35
Abattoirs 1
Manufacturers /Packers 118
Distributors/Transporters 22
Retailers 219
Caterers inc. Restaurants, 794
Manufacturers mainly selling by retail 26
Total 1189
Food Standards/784/08 4 August 2013Food Standards Agency Audit Branch, Scotland
2.0 Executive Summary
2.1 The Authority had developed and implemented a Food Law Enforcement Service
Plan for 2012-2013, which had been appropriately approved and which satisfies
the Service Planning Guidance in the Framework Agreement.
2.2 The Authority had developed documented policies and procedures relating to
their food law enforcement responsibilities, including food safety interventions
and enforcement decisions,. These documents were available to all Officers in
electronic format on a central directory and those procedures evaluated during
the audit contained up to date references to legislation and official guidance.
2.3 All officers carrying out food standards enforcement activities had been
appropriately authorised in accordance with the Authority’s procedures. The
Scheme of Delegation allows authorisation to be delegated by the Director of
Environmental Services to the Head of Development Services
2.4 Officers were subject to regular performance review (Employee Development and
Review Process) to ensure that their competency levels were maintained for their
level of authorisation and training needs identified. Training records contained
evidence that each Officer had completed a minimum 10 hours relevant training,
including food standards, in the last year.
2.5 The procedures and documentation provided for inspections were generally
being followed and detailed observations were adequately recorded in
accordance with the Food Law Code of Practice, centrally issued guidance and
the authority’s own policies and procedures.
2.6 File checks of six food standards files confirmed that the Authority was
completing inspections in accordance with their procedures. Food business
operators were provided with reports and / or letters confirming the findings from
inspections, although this was often later than that required by the Procedure.
2.7 The Authority had a documented sampling policy and procedure. Files checks,
however, indicated that timely action had not always been taken following
unsatisfactory results.
2.8 Database checks and monitoring returns indicated that the inspection programme
was not always achieving the inspection frequency for food standards.
2.9 Discussion and review of internal monitoring procedures and practices indicated
that the Authority was not recording but were carrying out routine monitoring of
many aspects of food law enforcement work.
Food Standards/784/08 5 August 2013Food Standards Agency Audit Branch, Scotland
3.0 Audit Findings
3.1 Organisation and Management
Strategic Framework, Policy and Service Planning
3.1.1 The Authority has a Food Law Enforcement Service Delivery Plan for 2012-2013
that follows the Service Planning Guidance in the Framework Agreement and
was approved by the Planning and Regulatory Services Committee on 9 October
2012. The Service Plan included the review of the plan for 2011-2012. Variances
and areas for improvement were identified.
The targets set in the Service Plan are in accordance with the Food Law Code of
Practice.
3.1.2 In the Food Law Enforcement Service Delivery Plan, the Council’s Aims include
the following:
“To maintain and improve the public health within Moray by carrying out the
Council’s food safety enforcement responsibilities in a consistent, planned and
accountable manner ensuring that:
“the quality, composition, labelling and presentation and advertising of
food and materials in contact with food are satisfactory”
Documented Policies and Procedures
3.1.3 The Authority had developed documented policies and procedures relating to
their food standards law enforcement responsibilities. Review of documented
policies and procedures was evident from documents examined as all revisions
were clearly listed on the document cover. There are procedures in place for,
amongst others, training and development, authorisation, document control,
database validation, food safety incidents, food safety interventions, enforcement
decisions, food complaints and chemical sampling.
3.1.4 The Environmental Health Manager has overall responsibility for the document
control system, and the Principal Environmental Health Officer is responsible for
ensuring that all legislation, guidance and standards documents are maintained
and kept up to date. Evidence of the system in operation was provided. Policies
and procedures are reviewed regularly and officers have electronic access to
these documents through a system called “Sharepoint”. Legislation and centrally
issued guidance is available from the internet.
Officer Authorisation
3.1.5 The Authority has documented procedures for both Training & Development and
Authorisation. The Scheme of Delegation allows authorisation to be delegated
by the Director of Environmental Services to the Head of Development Services.
Revised authorisation cards, signed by the Head of Development Services, had
very recently been issued to Officers.
Food Standards/784/08 6 August 2013Food Standards Agency Audit Branch, Scotland
The authorisations cover the range of legislation required, however, they
referenced out of date legislation, in particular, the Products of Animal Origin
(Third Country Imports) Regulations 2007.
3.1.6 Copies of qualifications and training certificates (pre 2006) were on file. Individual
training needs are discussed at annual Employee Review and Development
meetings. Lists of completed training for officers were available from 2007
onwards and there was evidence on file that officers had generally met the
required 10 hours CPD requirement. Evidence of appropriate training covered the
range of activities, processes and technologies that were reasonably expected to
be found during food standards interventions in the authority’s area.
Recommendation
3.1.7 The Authority shall:
Set up, maintain and Implement a documented procedure for the
authorisation of officers based on their competence and in
accordance with the relevant Codes of Practice and any centrally
issued guidance.
[The Standard - 5.1]
Food Standards/784/08 7 August 2013Food Standards Agency Audit Branch, Scotland
3.2 Facilities and Equipment
Food Establishments Database
3.2.1 The Authority has an electronic database which is used to record inspection data
and provide inspection programme dates of food establishments in its area that
are subject to food standards enforcement. There is a documented procedure for
database validation which manages the integrity of the database. All electronic
records requested were retrievable.
3.2.2 The database is capable of providing the Food Standards Agency with the
information required for the Local Authority Enforcement Monitoring System
(LAEMS) returns. Reports can be run to provide managers with information to
assist in the effective delivery of the service.
Food Standards/784/08 8 August 2013Food Standards Agency Audit Branch, Scotland
3.3 Food Premises Interventions and Inspections
3.3.1 Included in the 2012-2013 Food Law Enforcement Service Plan is a statement
that there are 7 high risk, 180 medium risk and 274 low risk food standards
premises on the authority database. There is no alternative enforcement strategy
in use. All food standards inspections are carried out by appropriately qualified
officers at the same time as food hygiene inspections at the frequency according
to the highest risk assessment, whether it is food hygiene or food standards. This
may result in some premises being inspected more frequently than required
which may have an impact on the remainder of the inspection programme. For
example, the Local Authority Enforcement Monitoring System (LAEMS) return
submitted by the Authority for 2011-2012 shows there was a shortfall of 11%,
31% and 14% of high, medium and low risk food standards premises inspections
respectively.
3.3.2 Officers are required to follow the Food Standards Intervention Procedures which
refer to aide-memoires for non-approved and sector specific approved premises.
Aide–memoires cover both food hygiene and food standards. In two identified
cases, premises have been scored as manufacturing and yet the inspection
records were collected on a non-manufacturing aide-memoire. A review of the
aide-memoires will improve consistency
Recommendation
3.3.3 The Authority shall:
Carry out interventions/inspections (as required by the relevant Code
of Practice) at all food hygiene, food standards and feedingstuffs
establishments in their area, at a frequency which is not less than that
determined under the intervention rating schemes set out in the
relevant legislation, Codes of Practice, or other centrally issued
guidance.
[The Standard - 7.1]
Records and Intervention Reports
3.3.4 File and database record checks confirmed that food standards inspections were
being implemented and were generally being carried out in accordance with the
specific requirements in the Inspections chapter of the Food Law Code of
Practice (CoP) and the Authority’s Food Safety Intervention Procedures.
3.3.5 File checks of six food standards premises confirmed that the Authority had
completed inspections in accordance with the minimum frequency laid out in the
CoP. For all files examined, there were reports and risk rating forms for the most
recent interventions and the inspection records were legible and retrievable.
Food Standards/784/08 9 August 2013Food Standards Agency Audit Branch, Scotland
3.3.6 Officers are required to follow the Food Standards – Inspection Scope in the Food
Safety Intervention procedure. As food standards inspections are carried out at
the same time as food hygiene, an inspection aide memoire for Regulation (EC)
No 852/2004 on the hygiene of foodstuffs is used. This has an area to record
“Food Standards Non Manufacturing Premises” which is required to be either
supplemented or replaced with a dedicated “Report of Food Standards
Inspection” report.
The “Non manufacturing premises” aide memoire was sufficiently detailed for the
areas included and required notes to be recorded. The “Report of Food
Standards Inspection” requires Officers to record significant details but does not
fully meet the requirements of Annex 6 of the Food Law Code of Practice as it did
not include designation of the authorised officer, contact details of the authorised
officer and food authority name and address.
3.3.7 The Food Standards Intervention Procedure requires officers, in clearly defined
circumstances, to furnish the food business operator with a hand written pre-
printed “Report of Food Standards Inspection” at the end of the inspection. In all
other cases a letter is to be sent. This was found to take as long as one month in
some cases whereas the procedure requires correspondence to be issued within
10 days.
3.3.8 It was evident from audit checks that officers were following the authority’s
approach to enforcement and were actively working with businesses to achieve
compliance.
3.3.9 Officers are required to update the premises’ file on the database following each
intervention and there was evidence of that having taken place. Risk rating of the
premises was complete, accurate and in accordance with the Food Law Code of
Practice requirements.
Verification Visit to Food Premises
3.3.10 During the audit, a verification visit was undertaken to a retail butchers premises.
The Authorised Officer who had carried out the most recent programmed
inspection accompanied the auditors on the verification visit. The main objective
of the visit was to assess the effectiveness of the Authority’s assessment of food
business compliance with the food law requirements of Regulation (EC) No.
178/2002 laying down the general principles and requirements of food law.
3.3.11 The specific assessments included the preparation for the inspection, the
conduct of the preliminary interview of the FBO by the officer and the general
checks to verify compliance with food standards requirements examined during
the last intervention.
3.3.12 An interview was held with the Officer before the verification visit took place to
confirm the contents of the file records and to explain the format and objectives of
the visit. It also gave the Officer the opportunity to explain the inspection
process, i.e. the preparatory work carried out prior to an inspection and the
general process while on site, which included the following of the authority’s Food
Standards Intervention Procedures.
Food Standards/784/08 10 August 2013Food Standards Agency Audit Branch, Scotland
3.3.13 The reality visit verified that the officer was using the appropriate inspection aide
memoire and following the procedure appropriately. The officer clearly had a
good working relationship with the business and it was clear that the focus of the
inspection had not been food standards but had been been cross contamination
and beef labelling. The issues raised about beef labelling had been partially
addressed by the food business operator at the time of the reality visit.
3.3.14 The reality visit informed the auditors that the officer had generally followed the
format of the aide-memoire and had conducted an inspection that included an
element of food standards. However, the lack of evidence for some areas of food
standards enforcement, without satisfactory records, was not in accordance with
the Food Law Code of Practice.
Recommendation
3.3.15 The Authority shall:
Carry out interventions / inspections in accordance with the relevant
legislation, Codes of Practice, centrally issued guidance and the
Authority’s policies and procedures.
[The Standard - 7.2]
Food Standards/784/08 11 August 2013Food Standards Agency Audit Branch, Scotland
3.4 Enforcement
3.4.1 The Authority has an Environmental Health Enforcement Policy which was
approved by the Planning and Regulatory Services Committee in August 2008.
3.4.2 In the enforcement policy there is a reference that The Moray Council has
adopted the 'Enforcement Concordat', which sets out the Council's commitment
to the principals of good enforcement.
3.4.3 The Authority had developed an “Enforcement Decisions” procedure for formal
food law enforcement actions. Included in the term 'enforcement' are advisory
visits and assisting with compliance as well as formal enforcement action.
Reference is made to the Food Law Code of Practice and associated guidance
and other centrally issued guidance.
Good Practice
The Authority had systems and procedures in place for identifying and tackling
food fraud. They are pro-active in their approach to food fraud during
interventions and priority is given to food fraud complaints and intelligence.
They provide assistance to other local Authorities in Scotland, as required.
Food Complaints and Food Premises Complaints
3.4.4 The Authority has a documented policy and procedure for complaints and all
complaints that were examined had been dealt with effectively and records
maintained.
Advice to Business
3.4.5 Food standards advice is given during inspections, in the course of food
complaint investigations and to new / prospective food business operators. The
Food Standards Interventions Procedures detail that advice on good food
standards practice should be given at the closing meeting. Evidence of this, in
the form of recommendations, was documented in files examined.
Food Inspection and Sampling
3.4.6 The Authority has a documented sampling policy, procedure and programme.
The sampling programme is developed in line with central and local relevant
sampling priorities (e.g. surveys and complaints), with a focus on locally
produced foods. The plan includes numbers of samples, premises type and
commodities. Sampling data is entered on to the United Kingdom Food
Surveillance System (UKFSS).
Records of seven samples were reviewed. However, in four cases where there
was evidence of unsatisfactory results, they had not been appropriately followed
through to completion. The samples results were reported by the Public Analyst
to the Authority during the period of May 2012 to January 2013.
Food Standards/784/08 12 August 2013Food Standards Agency Audit Branch, Scotland
The Chemical Sampling Procedure appropriately refers to Scottish Food
Enforcement Liaison Committee – Effective Food Sampling – Guidance for Local
Authorities as well as other guidance documents. There are no action timescales
specified in the Chemical Sampling Procedure, Food Sampling Policy or the
Food Complaint policy & procedure, although the latter document states “Food
complaints notified to the Environmental Health Section shall be dealt with in a
prompt and consistent manner in accordance with the relevant legislation and
codes of practice.” This is likely to make management and monitoring of
individual sample results and investigations difficult.
Food inspection is not explicitly covered in a documented procedure; however,
policies, procedures and forms substantially address this requirement.
Food Safety Incidents
3.4.7 There is a Food Safety Incidents Procedure in place which complies with the
Framework Agreement requirements. Records of three food alerts received
during late 2012 to early 2013 showed detail of action required.
Food Standards/784/08 13 August 2013Food Standards Agency Audit Branch, Scotland
3.5 Monitoring
Internal Monitoring
3.5.1 Internal Monitoring is covered within the Authority’s Intervention Procedure which
aims to ensure the minimum frequency of inspections and that the quality and
consistency of inspections are maintained and comply with relevant legislation
and Codes of Practice.
Ad hoc monitoring of inspection reports and letters is carried out as well as
database monitoring and fortnightly audits of the inspection programme. Annual
monitoring of food complaints and non-survey samples takes place prior to
submission of LAEMS data to the Agency. No records of quantitative monitoring
are maintained, other than the risk assessments being signed off by the
responsible Principal Officer.
There were no records of the additional required monitoring of a new officer.
However, the officer had established his own self-assessment systems for
inspections and records. The Authority is considering adopting a similar self-
assessment system. The auditors discussed the benefits of this system and peer
checking. Outcomes of internal monitoring feed into officer training plans.
Recommendation
3.5.2 The Authority shall:
Keep a record of all internal monitoring. This should be kept for at least
2 years.
[The Standard – 19.3]
Auditors: Jacqui Angus
Graham Forbes
Hazel Stead
Food Standards Agency
Audit Branch, Scotland
Food Standards/784/08 14 August 2013Food Standards Agency Audit Branch, Scotland
ANNEXE A
Action Plan for Moray Council Audit date: 22-23 May 2013
TO ADDRESS
BY
(RECOMMENDATION INCLUDING PLANNED IMPROVEMENTS PROGRESS ACTION TAKEN
(DATE)
STANDARD PARAGRAPH)
The Authority shall set up, maintain and 30 Remove reference to the Product Completed – see amended procedure
implement a documented procedure for September of Animal Origin (Third Country and warrant card examples attached
the authorisation of officers based on 2013 Imports) Regulations 2007 and
their competence and in accordance with include the TARP (S) Regulations FSA Comment Jan 2015
the relevant Codes of Practice and any 2012. The report specifically referred to
centrally issued guidance. TARP and for this there should be a
Review the Authorisation reference to the “2012 No. 177
[The Standard - 5.1] Procedure to include regular ANIMALS AGRICULTURE
review. The Trade in Animals and Related
Products (Scotland) Regulations
2012” made under the European
Communities Act 1972, as the Food
Law Code of Practice (Scotland) 2014
states:
The Authorisation procedure should
be suitably amended to include the
relevant references to enforcement
action under TARP..
FSS Comment 13 April 2015
Suitable documentation received.
Recommendation closed
G Forbes
Food Standards/784/11 15 June 2015Food Standards Agency Audit Branch, Scotland
TO ADDRESS
BY
(RECOMMENDATION INCLUDING PLANNED IMPROVEMENTS PROGRESS ACTION TAKEN
(DATE)
STANDARD PARAGRAPH)
The Authority shall carry out 31 Our inspection system will be A new inspection system has been
interventions/inspections (as required by December reviewed to ensure that there is introduced to improve efficiency. See
the relevant Code of Practice) at all food 2013 an improvement in the inspection attached. A mobile solution is
hygiene, food standards and frequency of food standards presently being procured to further
feedingstuffs establishments in their inspections. The review in improve performance and should be
area, at a frequency which is not less particular will ensure that all high in place by 31 March 2015.
than that determined under the risk premises are inspected at a
intervention rating schemes set out in the frequency that is not less than FSA Comment Jan 2015
relevant legislation, Codes of Practice, or that determined under the The LAEMS return for 2012-13 shows
other centrally issued guidance. Intervention Ratings Scheme. that all high risk inspections were
completed with 0 of 18 missed, for
[The Standard - 7.1] medium risk 29 of 303 were missed
The food standards inspection (about 10%) and for low risk 23 of 366
aide memoire will be reviewed. (about 6%). These are encouraging
figures as they are an improvement
on the previous year and have
delivered on the action plan of
completing all high risk inspections.
FSS Comment 13 April 2015
Suitable documentation received.
Recommendation closed
G Forbes
Food Standards/784/11 16 June 2015Food Standards Agency Audit Branch, Scotland
TO ADDRESS
BY
(RECOMMENDATION INCLUDING PLANNED IMPROVEMENTS PROGRESS ACTION TAKEN
(DATE)
STANDARD PARAGRAPH)
The Authority shall carry out 31 March The system whereby standard Completed. The new inspection
interventions / inspections in accordance 2014 letters were sent to businesses system addresses this
with the relevant legislation, Codes of on receipt of a public analyst recommendation
Practice, centrally issued guidance and report on minor labelling failures
the Authority’s policies and procedures. will be reintroduced. Staff will be FSS Comment 13 April 2015
requested to define and record Suitable documentation received.
[The Standard - 7.2] the scope of food standards recommendation closed
inspections. G Forbes
The Authority shall keep a record of all 31 March A system of monitoring This will form part of the new
internal monitoring, This should be kept 2014 performance will be developed inspection system.
for at least 2 years and records will be kept for at
least 2 years. FSA Comment March 2015
[The Standard - 19.3]
The Standard 19.3
No evidence has been provided; as it
is part of the new inspection system a
copy of that system is requested.
FSS Comment 09 June 2015
Suitable documentation received.
recommendation closed
G Forbes
Actions Accepted by Auditors : Audit File Closed 23 June 2015
Food Standards/784/11 17 June 2015Food Standards Agency Audit Branch
ANNEXE B
Audit Approach/Methodology
The audit was conducted using a variety of approaches and methodologies as
follows:
(1) Examination of LA policies and procedures.
The following LA policies, procedures and linked documents were examined before
and during the audit:
Food Law Enforcement Service Delivery Plan 2012-2013
Review of Performance against the 2011/2012 Food Law Enforcement
Service Plan
Food Safety Document Control procedure (April 2013)
Scheme of Delegation (March 2011)
Training and Development procedure (May13)
Authorisation Procedure (April 2013)
Database Validation procedure (April 2013)
Food Safety Incidents procedure (March 2013)
Environmental Health Enforcement policy (12.08.08)
Notes of Environmental health Staff meetings
Complaints Handling policy (10 October 2012, v1.2)
Complaints handling policy and procedure (September 2012, v1.1)
Quarterly Monitoring Statements
Food Safety Intervention procedures (April 2013)
Enforcement Decision Procedures (April 2013)
Intervention lists
Food Complaint policy and procedure
Bacteriological Sampling Procedure (May 2013)
Chemical Sampling Procedure (May 2013)
Food Sampling policy (April 2013)
Inspection Aide memoir – ECR 852-2004
(2) File reviews
The following file records were reviewed during the audit:
Training files & Qualifications
Food Premises inspection reports
Food Samples
Authorisations
Food Alerts : “For Action”
Food Standards/784/08 18 August 2013Food Standards Agency Audit Branch
(3) Officer interviews
The following Officers were interviewed:
Audit Liaison Officer
Authorised Officer who carried out the most recent inspection at the
premises selected for a verification visit.
Opinions, comments and views raised during Officer Interviews remain confidential
and are not referred to directly within the report.
(4) Verification visits:
A verification visit was made with an Officer from the Authority to a local food
business. The purpose of the verification visit was to verify the outcome of the most
recent programmed inspection carried out by the Local Authority, and to assess the
extent to which enforcement activities and decisions met the requirements of
relevant legislation, the Food Law Code of Practice (Scotland) and other official
guidance.
Food Standards/784/08 19 August 2013Food Standards Agency Audit Branch
ANNEXE C
Glossary
Audit Audit means a systematic and independent examination
to determine whether activities and related results
comply with planned arrangements and whether these
arrangements are implemented effectively and are
suitable to achieve objectives.
Authorised Officer A suitably qualified Officer who is authorised by the
Local Authority to act on its behalf in, for example, the
enforcement of legislation.
E. coli Escherichia coli microorganism, the presence of which
is used as an indicator of faecal contamination of food or
water. E. coli 0157:H7 is a serious food borne
pathogen.
Food Law Code of Government Codes of Practice issued under Section 40
Practice (Scotland) of the Food Safety Act 1990, Regulation 24 of the Food
Hygiene (Scotland) Regulations 2006 and Regulation 6
of the Official Feed and Food Controls (Scotland)
Regulations 2009, as guidance to Local Authorities on
the enforcement of food legislation.
Food hygiene The legal requirements covering the safety and
wholesomeness of food.
Food Standards Food standards interventions are part of the system for
ensuring that food meets the requirements of food
standards law, including proper presentation, labelling
and advertising so as not to confuse or mislead;
compliance with compositional standards; and the
absence of non-permitted or excessive levels of
additives, contaminants and residues.
Food Standards Agency The Food Standards Agency is an independent
Government department set up by an Act of parliament
in 2000 to protect the public's health and consumer
interests in relation to food.
Everything we do reflects our vision of Safe food and
healthy eating for all.
Framework Agreement The Framework Agreement consists of:
Chapter One Service Planning Guidance
Chapter Two The Standard
Chapter Three Monitoring of Local Authorities
Chapter Four Audit Scheme for Local Authorities
Food Standards/784/08 20 August 2013Food Standards Agency Audit Branch
The Standard sets out the Agency’s expectations on
the planning and delivery of food law enforcement.
The Monitoring Scheme requires Local Authorities to
submit an annual return to the Agency on their food
enforcement activities i.e. numbers of inspections,
samples and prosecutions.
Under the Audit Scheme the Food Standards Agency
will be conducting audits of the food law enforcement
services of Local Authorities against the criteria set out
in The Standard.
Full Time Equivalents A figure which represents that part of an individual
(FTE) Officer’s time available to a particular role or set of
duties. It reflects the fact that individuals may work part-
time, or may have other responsibilities within the
organisation not related to food enforcement.
HACCP / FSMS Hazard Analysis and Critical Control Point – a food
safety management system (FSMS) used within food
businesses to identify points in the production process
where it is critical for food safety that the control
measure is carried out correctly, thereby eliminating or
reducing the hazard to a safe level.
LAEMS Local Authority Enforcement Monitoring System is an
electronic system used by local authorities to report their
food law enforcement activities to the Food Standards
Agency.
Member forum A local authority forum at which Council Members
discuss and make decisions on food law enforcement
services.
Risk rating A system that rates food premises according to risk and
determines how frequently those premises should be
inspected. For example, high risk premises should be
inspected at least every 6 months.
Service Plan A document produced by a Local Authority setting out
their plans on providing and delivering a food service to
the local community.
Food Standards/784/08 21 August 2013You can also read
