Food Standards Agency in Scotland

Food Standards Agency in Scotland

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 2013

Food Standards Agency Audit Branch, Scotland Food Standards/784/08 1 August 2013 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.pd f 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 Agency Audit Branch, Scotland Food Standards/784/08 2 August 2013 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 Agency Audit Branch, Scotland Food Standards/784/08 3 August 2013 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 Agency Audit Branch, Scotland Food Standards/784/08 4 August 2013 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 Agency Audit Branch, Scotland Food Standards/784/08 5 August 2013 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 Agency Audit Branch, Scotland Food Standards/784/08 6 August 2013 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 Agency Audit Branch, Scotland Food Standards/784/08 7 August 2013 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 Agency Audit Branch, Scotland Food Standards/784/08 8 August 2013 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 Agency Audit Branch, Scotland Food Standards/784/08 9 August 2013 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 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. 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]

Food Standards Agency Audit Branch, Scotland Food Standards/784/08 10 August 2013 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 Agency Audit Branch, Scotland Food Standards/784/08 11 August 2013 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 Agency Audit Branch, Scotland Food Standards/784/08 12 August 2013 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 Agency Audit Branch, Scotland Food Standards/784/08 13 August 2013 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 Agency Audit Branch, Scotland Food Standards/784/08 14 August 2013 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. Auditors: Jacqui Angus Graham Forbes Hazel Stead Food Standards Agency Audit Branch, Scotland 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]

Food Standards Agency Audit Branch, Scotland Food Standards/784/11 15 June 2015 ANNEXE A Action Plan for Moray Council Audit date: 22-23 May 2013 TO ADDRESS (RECOMMENDATION INCLUDING STANDARD PARAGRAPH) BY (DATE) PLANNED IMPROVEMENTS PROGRESS ACTION TAKEN 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] 30 September 2013 Remove reference to the Product of Animal Origin (Third Country Imports) Regulations 2007 and include the TARP (S) Regulations 2012.

Review the Authorisation Procedure to include regular review. Completed – see amended procedure and warrant card examples attached FSA Comment Jan 2015 The report specifically referred to TARP and for this there should be a reference to the “2012 No. 177 ANIMALS AGRICULTURE 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 Agency Audit Branch, Scotland Food Standards/784/11 16 June 2015 TO ADDRESS (RECOMMENDATION INCLUDING STANDARD PARAGRAPH) BY (DATE) PLANNED IMPROVEMENTS PROGRESS ACTION TAKEN 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] 31 December 2013 Our inspection system will be reviewed to ensure that there is an improvement in the inspection frequency of food standards inspections.

The review in particular will ensure that all high risk premises are inspected at a frequency that is not less than that determined under the Intervention Ratings Scheme. The food standards inspection aide memoire will be reviewed. A new inspection system has been introduced to improve efficiency. See attached. A mobile solution is presently being procured to further improve performance and should be in place by 31 March 2015. FSA Comment Jan 2015 The LAEMS return for 2012-13 shows that all high risk inspections were completed with 0 of 18 missed, for medium risk 29 of 303 were missed (about 10%) and for low risk 23 of 366 (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 Agency Audit Branch, Scotland Food Standards/784/11 17 June 2015 TO ADDRESS (RECOMMENDATION INCLUDING STANDARD PARAGRAPH) BY (DATE) PLANNED IMPROVEMENTS PROGRESS ACTION TAKEN 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] 31 March 2014 The system whereby standard letters were sent to businesses on receipt of a public analyst report on minor labelling failures will be reintroduced. Staff will be requested to define and record the scope of food standards inspections.

Completed. The new inspection system addresses this recommendation FSS Comment 13 April 2015 Suitable documentation received. recommendation closed G Forbes The Authority shall keep a record of all internal monitoring, This should be kept for at least 2 years [The Standard - 19.3] 31 March 2014 A system of monitoring performance will be developed and records will be kept for at least 2 years. This will form part of the new inspection system. FSA Comment March 2015 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 Agency Audit Branch Food Standards/784/08 18 August 2013 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 Agency Audit Branch Food Standards/784/08 19 August 2013 (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 Agency Audit Branch Food Standards/784/08 20 August 2013 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 Practice (Scotland) Government Codes of Practice issued under Section 40 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 Food Standards The legal requirements covering the safety and wholesomeness of food. 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 Agency Audit Branch Food Standards/784/08 21 August 2013 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 (FTE) A figure which represents that part of an individual 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.

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