food & feed law enforcement service planmoderngov.sthelens.gov.uk/documents/s85732/appendix a...

Appendix A

Places Services

Environmental Health

and

Trading Standards Service

FOOD & FEED LAW ENFORCEMENTSERVICE PLAN

2019-2020

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Foreword

The Food Law Enforcement Plan provides a clear strategy, which ensures that the Environmental Health and Trading Standards services maintain a risk based approach to their regulatory role relating to both food and animal feed.

The plan provides members of the public, local businesses and other key stakeholders with the inspection proposals for the forthcoming year, information regarding special projects, sampling programmes and training plans. It also reviews the achievements and provides an indication of the performance of these services over the previous year.

Within the work proposals for this year there remains a commitment to supporting local businesses in developing their food and feed management controls, as well as, tackling wider public health issues such as obesity and allergen awareness.

In endorsing this plan St Helens Council recognises that maintaining the safety and quality of both food and animal feed is fundamental to protecting the health and well-being of both the local and wider community. The Council is fully committed to supporting it's officers delivering the inspections, visits and key initiatives contained within the plan.

Councillor Lynn Clarke, Cabinet Member for Environmental Services

June 2019

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CONTENTS

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Page Number

Introduction 9

Service Aims and Objectives 10

Background 11

Profile of the Local Authority 11

Organisational Structure 12

Health Inequalities 12

Regulation Policy 13

FOOD SAFETY SERVICE PLAN 14

1.1 Introduction 14

1.2 Scope of the Food Service 14

1.3 Demands on the Food Service 15

1.4 Food businesses and the local economy 15

2.0 Service Delivery 15

2.1 Food Premise Interventions 16

2.1 Complaints 18

2.3 Primary Authority 18

2.4 Advice to Business 19

2.5 Sampling 19

2.6 Infectious Disease Control 19

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2.7 Food Safety Incidents 20

2.8 Liaison with other organisations 20

2.9 Promotion 20

2.10 Community & Business Health Promotion 21

2.11 Food Information for Consumer - Allergens 21

2.12 ATP (Adenosine Triphosphate) Monitoring 22

2.13 Mobile Caterers 22

2.14 Smoke Free 22

2.15 Waste Control 22

3.0 Resources 22

3.1 Financial Allocation 22

3.2 Staffing Allocation 23

3.3 Staff Development Plan 23

4.0 Indicators and Quality Assessment 23

4.1 Performance Indicators 24

4.2 Quality Assessment 24

5.0 Review of Activity in Food Safety 2018/19 24

5.1 Broad Compliance 25

5.2 Food Hygiene Rating Scheme (FHRS) 25

5.3 Staff 26

5.4 Staff Development 26

5.5 Food Premises Interventions 27

5.6 Formal Action 27

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5.7 Food Complaints 27

5.8 Primary Authority Partnership 28

5.9 Food Sampling 28

5.10 Infectious Disease Control 28

5.11 Food Standards Agency Food Alerts & Incidents 28

5.12 Community and Business Health Promotion 28

6.0 Variation from the Service Plan 2018/19 29

FOOD STANDARDS SERVICE PLAN 30

6.0 Introduction 30

6.1 Scope of the Food Service 30

6.2 Demands on the Food Service 30


7.1 Service Delivery Points 31

7.2 Identification of Premises with a Food Standards Risk 32

7.3 Inspections /Interventions 32

7.4 Complaints 32

7.5 Primary Authority / Home Authority 32


7.7 Sampling 33

7.8 Control & Investigation of Outbreaks 34

7.9 Food Standards Incidents 34


7.11 Promotion 34

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8.0 Resources 35





9.1 Quality Assessment and Internal Monitoring 36

10.0 Review of Activity in Food Standards 2018/19 36

10.1 Programmed Premises Intervention 36

10.2 Formal Action 36

10.3 Food Complaints 37

10.4 Food Sampling 37

10.5 Primary and Home Authority 37

10.6 Officer Development 37

10.7 Variation from the Service Plan 2017/18 38

10.8 Areas of Improvement 38

FEED SERVICE PLAN 39

11.0 Introduction 39

12.0 Feed Service Aims and Objectives 39

12.1 Aims and Objectives 39

12.2 Links to Corporate Objectives and Plans 39

13.0 Background 40

13.1 Profile of the Local Authority 40

13.2 Organisational Structure 40

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13.3 Scope of the Feed Service 40

13.4(a)Demands on the Feed Service 40

13.4(b)Service Delivery Service Points 41

13.5 Regulation Policy 42


14.1(a)Feed Premises Registration 42

14.1(b) Inspections / Interventions Feed and Primary Production 42

14.2 Feed Complaints 43

14.3 Home and Primary Authority Scheme 43


14.5 Feed Sampling 44

14.6 Control and Investigation of Outbreaks 44

14.7 Feed Safety Incidents 44


14.9 Feed Safety Promotional Work 44

15.0 Resources 45





16.1 Quality Assessment and Internal Monitoring 45

17.0 Review of 2018/19 46

17.1(a)Programmed Premises Intervention 46

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17.1(b)Formal Action 46

17.1(c) Feed Complaints 47

17.1(d)Feed Sampling 47

17.1(e)Officer Development 47

17.2 Variation from the Service Plan 47

17.3 Areas of Improvement 47

Appendix 1 Service Plan Programmed 2018/19 48

Appendix 2 Organisational Structure Charts 49

Appendix 3 Food Safety Work Profiles 53

Appendix 4 Food Safety Estimation of Resources 55

Appendix 5 Food Safety Training Programme 56

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INTRODUCTION

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As part of the Food Standards Agency’s Framework Agreement, Local Authorities are required to have in place Food Service Plans, which are audited by them. This service plan sets out how the nationally recognised priorities are addressed and delivered locally and the means by which these will be achieved. It details the achievements of the Food Service in 2018/19 and plans for 2019/20.

During 2018/19, the service undertook around 660 visits to food businesses, for food standards, feed and food safety. Support provided during these visits is vital to businesses that face competing pressures in the current financial climate. Officers make sure that food businesses are aware of their legal obligations and help them ensure that the food they supply is wholesome and safe.

At the end of 2018/19, the base line figure for businesses being ‘broadly compliant’ with food safety legislation was 87% (1283 premises) this is a slight downturn from the 92% at the end of 2017/18. An explanation for this being that there has been an increase in the number of new business premises within the borough which the Food Safety Team have to engage with for the first time working with them to bring about compliance. There has also been a noticeable increase in the number of fast food outlets changing ownership on a regular basis meaning that the Food Safety Team has to treat each change of ownership as a new business and start working again with the new business partner to bring about compliance. The figure does demonstrate that the work done by the team is effective and work continues to be done to target resources towards the less compliant businesses.

All registered food premises within the borough are rated in accordance with the National Food Hygiene Rating Scheme. Members of the public can access food hygiene ratings at www.food.gov.uk/ratings and can see the ratings when they are displayed at businesses.

In 2016 St Helens signed the Declaration on Healthy Weight and in partnership with Public Health we contribute to the public health agenda with the aim of protecting the residents of St Helens from unhealthy weight.

https://www.sthelens.gov.uk/news/2018/july/12/councillor-calls-on-government-for-more-support-to-tackle-obesity/

Environmental Health and Trading Standards services are well positioned to engage and influence food businesses in relation to nutrition and healthier lifestyles. We have done this by developing the “Chip Fryer” Award, launching the HOST Award (Healthier Options St Helens Takeaways) and working with childminders offering them the “Childminders Healthy Eating Award”



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OFFICIAL FOOD AND FEED CONTROLS

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SERVICE AIMS & OBJECTIVES

Aims

The aim of the service is “to offer services which aim to contribute to the wider protection of the environment and strive to achieve fair and safe trading for the residents of and visitors to St. Helens”

Objectives

i. To prevent illness resulting from food and waterborne diseases.

ii. To assist consumers in achieving a healthy diet by avoidance of; contaminated, adulterated or poor quality food.

iii. To ensure consumers have access to accurate, understandable information to make informed choices.

iv. To assist businesses, in particular caterers to provide healthy catering options to help their customers to make healthier choices to assist in part to reduce obesity and heart disease within St Helens.

v. To protect business from economic disadvantage caused by competitors not complying with Food Safety and Food Standards legislation.

vi. To help business find the most effective way of complying with Food Safety and Food Standards legislation and to facilitate access to appropriate training.

vii. To work with other local authorities and agencies with common objectives to provide effective and “joined up” enforcement

viii. To work within pre-set budgets and maximise all opportunities for income generation

Links to corporate objectives and plans

The Council approves the Food Law Enforcement Service plan annually. The Cabinet Member holding the Portfolio for Environmental Services monitors progress against service objectives during the year.

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The work of the Food and Feed Law Enforcement Service Plan is reflected in the Council’s Performance Management Framework. The Service Plan is reviewed annually taking into account corporate objectives demands on the service and any changes to the way in which the service is provided, to ensure the provision of the most cost effective service. St Helens Council Plan 2018-20 can we found on the council website at:

https://www.sthelens.gov.uk/media/7841/sthelens-council-plan-2018-20fv.pdf

BACKGROUND

Profile of the Local Authority

St Helens is one of six local authorities in the Liverpool City Region and is home to approximately 179,300 residents (ONS Mid –year estimate 2017). The Borough covers a total of 136 square kilometres, of which approximately half is rural and half is urban.

Its proud history is linked with the industrial revolution, coal mining, and a world famous glass industry, which employed many of the local residents. However, the industrialisation of the Borough and its subsequent decline from the late 1970s onwards left a legacy of issues including poor health, long-term inter-generational unemployment, low levels of enterprise and poor environmental quality of parts of the Borough.

In more recent years St Helens has seen widespread regeneration, with the positive transformation of many parts of the Borough and the development of new housing, business premises, transport facilities and green and open spaces.

Yet in some respects St Helens remains a fairly typical northern town. The Borough has an aging population with growing numbers of vulnerable people requiring support. Poor health and worklessness remain key issues and there is relatively high deprivation and inequality to be found in areas of the Borough. Although unemployment figures are below both national and regional figures, the claimant count for out-of-work benefits is higher than the rates seen regionally and nationally. St Helens also has much higher numbers of the working age population who are economically inactive, principally due to high levels of poor health and disability. Skill levels although improving remain comparatively low. Improving the performance in relation to the attainment of children and young people remains a significant challenge.

Despite these issues, St Helens has many strengths. The Borough enjoys a strategic position at the heart of the North West and has great potential to increase its economic growth and competitiveness. Business sectors such as logistics represent a major strength due to St Helens’ excellent transport network and connectivity. Self-employment levels have increased and business survival rates at 5-years are improved.

The latest job growth data shows that St Helens recorded the second largest growth in jobs in the country, with an additional 4,000 employee jobs created between 2016 and 2017. The rate of employment increased by nearly 3%. Investment interest in St Helens continues to grow with recent permissions received and granted for a number of large logistics

https://www.sthelens.gov.uk/media/7841/sthelens-council-plan-2018-20fv.pdf

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developments. There is also significant ambition for the future of the Town Centre, with a Town Centre Strategy underpinning future ambitions.

Population

St Helens has an aging population structure similar to England, but with a higher proportion of people aged 65 years and over and proportionally fewer people of working age (16-64 years). An aging population can lead to an increase in demand and pressure upon the health and social care services. ONS Population Projections suggesting that numbers of residents in their 80’s will nearly double, whilst numbers of residents in their 90’s will nearly triple by 2037.

St Helens is ethnically less diverse than many areas, with 96.6% of the population (Census, 2011) identifying themselves as white, compared to 79.8% nationally and 87.1% in the North West.

Economic Activity

The latest employment rate in St Helens is 72.7% (Dec 2018), which is below the regional and national averages(73.8% and 75.1%) respectively. Self-employment is 8.1% which remains at a lower rate than regionally (9.3%) and nationally (10.6%).

Relatively high levels of deprivation and inequality exist within the Borough. The Index of Multiple Deprivation ranks St Helens as the 36th most deprived local authority in England out of 326. Nearly a quarter of all neighbourhoods within the Borough fall within the most 10% deprived of neighbourhoods nationally.

Residents’ average gross weekly pay of £517 is below the North West average of £530, and the national average of £575.

Health and wellbeing

Improving the health of local people remains a priority with a number of specific challenges. Life expectancy in St Helens for males is 77.5. years) and for females 80.9 years), which is a small decrease compared to the increases that have been seen in recent years. Although better than some of the neighbouring authorities, life expectancy in the borough remains worse than regional and national averages. However, there are significant variations in life expectancy between the most and least deprived wards. There is a 11.7 year difference for males between the most and least deprived wards and a 8.7 year gap between females.

Circulatory diseases and cancers are the biggest killers in St Helens and are within the top 10 causes of hospital admissions. Respiratory diseases are the third biggest killer. Pneumonia, COPD and asthma are the some of the most significant causes of hospital admissions.

Healthy weight has been recognised as a challenge in St Helens and for this reason has been identified as a key priority in the Health and Wellbeing Strategy. In the UK the obesity

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rate has doubled over the past 25 years. In St Helens, the percentage of adults who are overweight or obese is 72.1%, higher than the regional (63%) and national (61%) figures.Data for 2018/19 shows that 28.6% of reception age children (4-5 years) in St Helens are overweight (including obese), which is the second highest figure in the North West. By the time young people have reached year 6 (age 10-11) the percentage overweight (including obese) has increased to 38.1%, which is the sixth highest in the North West.

In 2017/18, St Helens had the sixth highest national rate for hospital admissions for alcohol specific conditions (per 100,00 population). The rate of 1,100 per 100,000 was nearly double the England average of 570.

Organisational Structure

Organisational structure charts for Environmental Health and Trading Standards are as attached at Appendix 2.

Regulation Policy

We have an enforcement policy, which provides guidance to officers, businesses and the general public on the range of options that are available to achieve compliance with legislation enforced by St. Helens Regulatory Services. The policy has been approved by St. Helens Licensing and Environmental Protection Committee.

Detailed Service Plans for Food Safety, Food Standards, Feed Hygiene and Primary Production follow.

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FOOD SAFETY SERVICE PLAN 2019/20

1.1 INTRODUCTION

The Food Safety Service Plan sets out how St Helens Council through its Environmental Health Service will fulfil its responsibilities under the legislation relating to food safety, particularly in respect to the inspection of food premises. The structure of the service plan follows the service planning guidance contained within “The Framework Agreement on official feed and food controls by Local Authorities” published by the Food Standards Agency.

1.2 Scope of the Food Service

In accordance with the standards set out in the Food Standards Agency Code of Practice and the Food Standards Agency Framework Agreement.

The Environmental Health Section is responsible for:

Registering food premises and the enforcement of food safety legislation in all food premises within the borough using a range of interventions such as inspections and audits;

The investigation of food complaints, including contamination by micro-organisms, chemical contamination and contamination by mold or foreign matter of food products made or purchased in the borough, followed where necessary by the appropriate enforcement action;

The investigation of notifications of food-borne and water borne diseases, outbreaks of gastro-enteritis, including food poisoning outbreaks, in accordance with the Health Protection Agency, Cheshire and Merseyside Communicable Disease Operational Procedures

Health promotion activities focusing on food and nutrition within the community and food businesses.

The Service also:

Samples food produced or sold in the borough

Provides food hygiene training

Approves food premises that handle/process/manufacture foods containing products of animal origin

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The Environmental Health Section is also responsible for the enforcement of the Health and Safety at Work Act, Smoke Free legislation and also has responsibility for animal welfare and pest control. The frequency of health and safety inspections is dictated by separate guidance and whenever possible they are carried out at the same time as the food safety inspections in food businesses.

1.3 Demands on the Food Service

Food service work profiles in respect of number and type of food premises in the borough requiring interventions in 2019/20 for food safety are attached in Appendix 3.

Service delivery is available from the office base at Wesley House, between the hours of 8.45 am and 5.15 pm, during the normal working week. However, food hygiene inspections may necessitate out of hours visits, due to the nature of trading of relevant businesses and therefore, enquiries are frequently taken outside of normal business hours. Other out of hours services are available as circumstances dictate.

1.4 Food businesses and the local economy

Food production, its transport and sale at retail and catering establishments are significant parts of the economy both nationally and locally. Nationally the food and drink supply chain accounts for 7% of GDP and employs 3.7 million people in everything from food retailing, to restaurants and canteens, to farming and fishing. The service sector, including hotels, distribution and catering remains the largest industry within St Helens.

The total number of food businesses registered at the beginning of the 2019/20 business year is 1417 this is a slight increase from the 1392 registered at the beginning of 2018/19. There has been a noticeable increase in food business turn over that is businesses changing ownership on a regular basis.

Our work helps the changing local food economy to remain vibrant and enables the Council to provide practical support to businesses, particularly important in difficult economic times. The work of the food service helps maintain public confidence in the standards of our local food industry.

We work to help businesses comply with food legislation, which helps ensure fair competition and allow well-run food businesses to flourish and contribute to the local economy. We offer specific support for new companies, which can prove vital to the longer-term survival of a business.

SERVICE DELIVERY

The revised Food Law Code of Practice (England) published by the Food Standards Agency came into force on the 7 April 2015 and was reissued in March 2017. This Code sets out the requirements that the Council (as the Competent Authority) must adhere to in the execution and enforcement of the relevant legislation.

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Competent Authorities have statutory duties to enforce legislation relating to food, including the primary production of food and imported food. The purpose of enforcement is to ensure compliance with legislation relating to food in each Competent Authority’s area in the UK.Every Competent Authority must therefore discharge its duty as effectively as possible using means that are appropriate to the circumstances.

The Food Standards Agency is also currently examining alternative ways in which food safety and food standards regulation can be delivered, one of the aims being to reduce regulatory burden on those businesses that are compliant. This programme of change is known as “Regulating our Future”.

https://www.food.gov.uk/sites/default/files/media/document/About%20ROF.pdf 2.1 Food Premise Interventions

All food premises are subject to food safety and food standards inspections, the frequency being determined by risk rating schemes. However dependent on the level of risk other interventions may be employed when securing compliance with the legislation. The suite of interventions that may be used are:

Official controls: Inspections

Audits

Sampling visits

Monitoring visits

Verification visits

Surveillance visits

Non-official controls: Advice

Coaching

Education

Information and intelligence gathering

High-risk food premises (A’s, B’s and non-compliant C’s) will continue to receive programmed food hygiene inspections or audits.

Broadly compliant C rated premises, these are the premises that have been awarded a score of 10 or less (on a scale of zero to 25 where zero is excellent and 25 is very bad) in the categories of food hygiene, structural condition and confidence in food management practices, may receive other official controls as appropriate.

Low risk food businesses (D rated premises) will alternate between official controls and other interventions. The lowest rated food businesses (E rated premises) will be assessed

https://www.food.gov.uk/sites/default/files/media/document/About%20ROF.pdf

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by an Alternative Enforcement Strategy that involves completion of a questionnaire and visits where necessary. The choice of intervention undertaken will be determined by the individual Environmental Health Officers (EHO) on a case-by-case basis, under the supervision of the Principal EHO.

Of the total 1417 registered premises, 762 have been “tagged” on the database as requiring an inspection or alternative intervention during 2019/20

In summary for food safety interventions the following are required in 2019/20;

A rated premises 5 (2 x inspections per year)

B rated premises 141 (1x inspection per year)

Total high risk 146

C rated premises 221 (1 x inspection per 18 months)

D rated premises 212 (1 x inspections per 24 months)

E rated premises 124

Total low risk 557

Unrated premises 59

(E rated premises do not form part of the inspection programme as they are by their nature deemed to be low risk premises and unrated premises have registered with the authority and are awaiting inspected their first inspection prior to opening following which an intervention rating is awarded)

There are also a number of food premises which are registered and approved under EC Regulation 853/2004 by the authority. These premises handle/process /produce products of animal origin and are subject to a stringent set of criteria they are also required to have a health mark. These business do not receive a food hygiene rating score, (FHRS)

Total Approved Premises registered under EC Regulation 852/2004 5

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With the staff available, the service is committed to completing a minimum of 96% food safety inspections of A and B rated premises. It also aims to complete at least 80% of C and D rated premises interventions. In respect of the C and D rated premises, which do not receive their programmed interventions, this work will be carried forward and completed during the following year. In the worst case scenario, this shortfall equates to 44 “C” rated and 42 “D” rated premises, which will not receive inspections or interventions in accordance with statutory guidance.

Following an inspection and the calculation of an intervention rating a Food Hygiene Rating Score (FHRS) will also be awarded. These scores, which range from 0 (urgent improvement needed) to 5 (very good) may be displayed at the food premises. All scores are uploaded on a monthly basis onto the Food Standards Agency’s website and are publicly available.

http://ratings.food.gov.uk/

There are a number of safeguards available to businesses ranging from appealing a food hygiene rating score, requesting a revisit for a re-rating assessment to placing comments on the FSA website with the agreement of the authority. As public awareness of FHRS continues to grow it is expected that there will be an increase in the number of food businesses exercising these safeguards.

From March 2017, the Food Standards Agency has made a change in policy which now allows local authorities in England to introduce cost recovery for requested FHRS re-inspections/revisits, if they so wish. The Service will consider the introduction of a cost recovery scheme during 2019/20 in line with the amended FHRS Brand Standard.

2.2 Complaints

Food Safety and Hygiene complaints and referrals received by the Food Safety Team will be responded to within 2 working days of receipt. Where sufficient information is obtained from a complainant a full investigation will be undertaken. All complaints will be dealt with in accordance with food service Practice and Procedure notes, which in return requires that the complaints should be dealt with having regard to the Food Law Code of Practice and other relevant guidance.

Whilst it is difficult to estimate the number of complaints that will be received we do know that 311 food complaints were received during 2018/19. Past trends would indicate that a similar number will be received during 2019/20. The majority of which will relate to food safety issues.

2.3 Primary Authority

Primary Authority is a statutory scheme in which a business can choose to form a partnership with a local authority and this affects the way in which the business is then regulated by all local authorities. The purpose of these partnerships is to establish a key point of contact for the business with the other enforcing authorities. As a primary authority we are able to share compliance information and guide other enforcing authorities on their actions regarding our partner businesses. Primary Authority Partnerships are:

http://ratings.food.gov.uk/

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Princes Foods 2U Foods Aimia Foods

2.4 Advice to Business

The service provides advice and support to businesses. In undertaking such a role, it is anticipated that legitimate business will be informed and encouraged to meet the highest standards of trading to the benefit of themselves, and consumers. Provision of advice and support will be provided in line with the Food Standards Agency Code of Practice and clear distinction will be made between statutory requirements and good practice in such communications.

2.5 Sampling

Food samples and environmental swabs are taken from food businesses for microbiological examination. There is the potential for certain high- risk foods to support the growth of microorganisms, which in turn can cause food poisoning. By taking samples we are seeking to confirm that the standards of food safety management systems within businesses are effective. The aim being to detect contaminated food and to correct any problems regarding the manufacture, handling or storage of food, before any illness is caused.

During 2019/20 samples will be taken from businesses, the criteria for selection will take into consideration the nature of the business any hazards identified during an inspection and the compliance history. The Service will also contribute to the national sampling program led by Public Health England.

Results of samples will be notified to the proprietor of the business. Where results are unsatisfactory an officer will visit to provide advice and discuss the corrective actions to be taken.

Any actions taken as a result of sampling will be in accordance with the Council’s Enforcement Policy.

2.6 Pest Control

Pest control officers work closely with EHOs advising where necessary on pest control//proofing issues in food businesses where evidence of pest activity has been found.

The Services is also able to offer a “commercial “pest control service to all food and non- food businesses in the Borough .

2.6 Infectious Disease Control

Notifications of food or water borne diseases are received from PHE Merseyside and Cheshire on a weekly basis and will be investigated within 5 working days of receipt; they will be dealt with in accordance with the sections’ Procedure and Practice Notes.

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Wherever possible face to face interviews will take place. Following these interviews, further investigations may be made of food businesses that have been identified, in order to ensure that appropriate food safety control measures are in place.

The document “Arrangements between Cheshire and Merseyside PHE Centre Health Protection Team and LAs for the investigation of sporadic casers of infectious disease” seeks to clarify the responsibilities of various partners in the control of infectious disease and acts as a reference document.

2.7 Food Safety Incidents

Food Hazard Alerts received by e-mail from the FSA, are passed immediately to the Principal Environmental Health Officer, Commercial Services with responsibility for Food Safety (in their absence to the Regulatory Services Manager), who will then decide what action should be taken depending on the category of the Food Hazard Alert, and the information given in the warning. Action will be taken having regard to the Code of Practice. The number of warnings received, and the number requiring significant action varies each year, it is therefore difficult to predict the demand on the service.

2.8 Liaison with Other Organisations

The Food Service adheres to the Home Authority and Primary Authority principles.

The Environmental Health service has links with the authorities in the Merseyside and Cheshire area, the Food Standards Agency and Public Health England, through the Environmental Health Cheshire and Merseyside (EHCM) Food Safety Subgroup, and through this to neighbouring subgroups of Lancashire, Cumbria and Greater Manchester. The subgroup meets every 6 weeks.

2.9 Promotion

Training

The Service will deliver the CIEH Foundation food training course and the in house Introduction/Refresher food safety course to the business sector, community groups and council employees.

Food Safety Coaching

For non-compliant caterers and proprietors of small non-compliant convenience stores, officers spend time with these businesses providing advice, guidance and support aimed at bringing about long term improvements.

Those businesses that do not improve following this intervention will be visited and in order to ensure compliance, the stepped enforcement approach will be implemented by the sending of letters and the use of Hygiene Improvement Notices as required.

This stepped approach should improve food safety compliance and the ‘broadly compliant’ indicator that is reported to the agency each year.

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For all new businesses the “Safer Food Better Business Pack” is provided free of charge.

2.10 Community and Business Health Promotion

In 2015 the Council’s Public Health Division funded the post “Community and Business Health Promotion” initially this was for two years, however due to the success of this initiative the post is now permanent.

The key role of this post is to deliver initiatives linked to and supporting the Council’s Wellbeing Strategy and The Healthy Weight Declaration which was signed in 2017.

The programmes in place are:

Chip Fryer Award - recognises those businesses who operate frying methods that result in a “healthier” chip, that is a reduction in fat content.

https://www.sthelens.gov.uk/business/community-healthy-businesses/chip-fryer-award/

Healthier Options St Helens Takeaways (HOST) – recognises those businesses who can demonstrate that they have made changes to the preparation of some dishes that has resulted in a reduction of salt or fat content. Reductions are verified by sampling of dishes before and after changes have been made.Businesses who focus on healthier foods/menus as their “brand” are now included within HOST

https://www.sthelens.gov.uk/business/community-healthy-businesses/takeaway-businesses/

Childminders Healthy Eating Award which recognises good practice within childminding settings in promoting healthy/ nutritional food messages.

https://www.sthelens.gov.uk/business/community-healthy-businesses/childminders-healthy-eating-award/

During 2019/20 work will continue in partnership with public health to increase the number of businesses receiving awards in each category

2.11 Food Information for Consumers – Allergens

From 13 December 2014, all food businesses who sell open food have to declare any of 14 identified allergenic ingredients which are used in non- pre-packed or loose foods that are sold or provided. The Service ensures that this issue is discussed during inspections and is an issue which now contributes to the scoring awarded in respect to the FHRS confidence in management criteria.

During 2019/20 further work will take place in raising awareness of the responsibilities that businesses have in ensuring that the food they serve is safe for those customers who have identified food allergies.

https://www.sthelens.gov.uk/business/community-healthy-businesses/chip-fryer-award/





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2.12 ATP (Adenosine Triphosphate) monitoring

These monitoring units enable officers to demonstrate to food businesses the effectiveness of their cleaning, disinfection and sanitising regimes. Surface swabs are taken of work surfaces or equipment and are then placed in the handheld reader unit. A numerical reading is displayed which is indicative of the level of environmental contamination and may indicate a failure in cleaning systems. The use of these units will continue.

2.13 Mobile Caterers

The Commercial Services Team, is responsible for enforcing the Street Trading Consent Scheme. Currently there are 40 mobile food traders who are consented to street trade within the borough. Each mobile unit is subject to annual inspections for food safety and food hygiene ratings are awarded following each inspection.

2.14 Smoke free

The service is responsible for enforcing the smoke free legislation in businesses. During inspections of premises if an officer discovers evidence of smoking within a workplace the necessary advice and action is taken in accordance with the Enforcement Policy.

2.15 Waste Control

During visits/inspections of food premises officers are confirming if a waste removal contract is in place for all generated waste. If this is not the case the proprietor is required to obtain a contract.

3. RESOURCES

3.1 Financial Allocation

The Environmental Health Service is responsible for the enforcement of legislation relating to Food Safety, Health & Safety, Pollution, Drainage, Public Health nuisance, Refuse, Animal Health & Welfare. It also provides Pest Control and Dog Warden services and has a Public Health funded Business and Community Health Promotion function.

Food Safety 2019/20

Employment Costs £250,453

Supplies, Services & Transport £39,603

Recharges & Premises £73,654

LESS Income -£2793

Cost of Food Safety £360,917

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Food Safety is allocated 37% of the overall budget.

Further details of the estimation of resources are in Appendix 4.

3.2 Staffing Allocation

The Commercial Services section is staffed as follows:

Principal EHO Commercial 70% of time

5 Senior EHOs 80% of time

Commercial services officer 30% of time

Community and Business Health Promotion Officer 100% of time

3.3 Staff development plan

All officers are appraised annually in accordance with the Authority’s appraisal and development scheme and procedures. Individual development needs are identified during this process. Officer development and progress is reviewed after 6 months. Training needs are fed into the Divisional Training plan for 2019/20

In accordance with the revised Food Law Code of Practice (England), which came into effect on 6 April 2015 (revised March 2017), lead food officers and authorised food officers must obtain a minimum of 20 hours CPD per year split into:

A minimum of 10 CPD hours on core food matters directly related to the delivery of official controls:

10 hours on other professional matters. This could include training needs identified by the Principal Environmental Health Officer during appraisals.

All officers have completed a competency matrix which will form the basis of their individual appraisals and which will ensure that officers are correctly authorised to undertake their duties which is dependent on their training and years of experience.

The training programme is attached in Appendix 5.

4.0 INDICATORS AND QUALITY ASSESSMENT

The service monitors its performance against the Food Law Enforcement Service Plan at regular intervals. The Service Manager Enforcement and Regulatory Services Manager monitor performance on a monthly and quarterly basis. In addition, each year performance is compared as part of the service planning process; the relevant Cabinet member endorses the Service plan.

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4.1 Performance Indicators

Infectious disease investigation response times;

Service request response times (food safety complaints);

Number of high- risk inspections undertaken;

Number of businesses broadly compliant.

4.2 Quality Assessment

All officers are monitored on a monthly basis to ensure that targets are being met with regard to response times and inspections due. The inspections due are identified by priority by rating are discussed during each team meeting and any inspections that are “overdue” are identified. The PEHO will also examine in detail the post inspection administration and actions taken by one officer each month. All approved premise files are examined after inspection and all notices and prosecutions are examined before action is taken.

All officers are accompanied by the Principal Officer during visits at least once during the year to ensure that inspections and any enforcement actions are carried out in accordance with the legislation, the appropriate Code of Practice and Practice and Procedure notes. The Principal Officer keeps a record of these visits and any discrepancies discussed with the inspecting officer.

All food sampling results are examined as they are received from the laboratory. Food related service requests will be assessed at a rate of 2 per individual officer per month. Calibration records of temperature thermometers and probes are checked monthly.

Peer Review

The nine local authorities who form the Merseyside and Cheshire Food Safety Sub group meet regularly, to discuss food safety/standard issues of common interest and exchange examples of good practice. This leads to a consistency in approach to regulation and enforcement across the region. Representatives from other agencies such as the Food Standards Agency and Public Health England also attend these meetings.

5.0 REVIEW OF ACTIVITY IN FOOD SAFETY 2018/19

During the year a Senior EHO continued the secondment to Environmental Protection, supervising the work of the Environmental Wardens Team and another SEHO from April onwards started to work a 3 day week. These issues obviously impacted upon the resources available and the geographical areas of responsibility for these two officers had to be reviewed to take account of their reduced hours.

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5.1 Broad Compliance

The base line figure for businesses being broadly compliant with food safety legislation in 2018/19 is 87% (1283 businesses), this is a slight downturn from the 92% at the end of 2017/18. An explanation for this being that there has been an increase in the number of new business premises within the borough which the Food Safety Team had to engage with for the first time working with them to bring about compliance. There has also been a noticeable increase in the number of fast food outlets changing ownership on a regular basis (business “churn”) meaning that the Food Safety Team has to treat each change of ownership as a new business and start working again with the new business partner to bring about compliance. The figure does demonstrate that the work done by the team is effective and work continues to be focused on priority areas..

5.2 Food Hygiene Rating Scheme (FHRS)

The purpose of the FHRS is to allow consumers to make informed choices about the places where they eat out or shop for food and, through these choices, encourage businesses to improve their hygiene standards. The overarching aim is to reduce the incidence of food-borne illness and the associated costs to the economy.

Food Hygiene Rating Scores are awarded following an inspection of the premises, in accordance with the Food Standards Agency’s Brand Standard. Premises are scored on the:

suitability of the structure of the premises;

the food hygiene practices that are observed within the premises at the time of the inspection;

the confidence in the management of the food businesses.

Scores from 0 to 5 are then awarded to each to each premise. A zero score indicates failure to comply with the legislative requirements and a score of 5 demonstrates very good compliance. A score of 3 is deemed to be the accepted legal standard.

Any business which scores below 3 is subject to further interventions from the food safety team which can range from one to one coaching in the implementation of the Safer Food, Better Businesses practices package, to the service of Health Improvement Notices or, in the most serious of cases, prosecution for failing to comply with the food safety regulations.

All scores are uploaded on a monthly basis and are available to be viewed on the Food Standard Agency’s website at www.food.gov.uk/ratings

In 2018, Senior EHOs, the Principal EHO and the Commercial Services Officer took part in the national Food Standards Agency web based consistency exercise. The aim being to promote the consistent application of the Food Hygiene Rating Scheme Brand Standard.

http://www.food.gov.uk/ratings

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5.3 Staff

The five experienced senior EHO’s within the team provide a dedicated service aimed at the protection of the public health, the improvement of food safety and they also consider the health and safety standards within food businesses dealing with matters of evident concern during food safety inspections.

The Community and Business Health Promotions Officer is responsible for developing programs of work which will:

improve the nutritional content of food offered from hot food takeaways improve the nutritional standards of food offered to pre school children

The Business and Community Health Promotion Officer has developed, implemented and manages the Chip Fryer, HOST and Childminders’ awards.

The Commercial Services Officer is responsible for managing the street trading consent scheme. This ensures that all mobile food traders which are consented to trade within the borough are regularly inspected for food safety and health and safety compliance. The mobile traders all receive a food hygiene rating. This officer also provides operational support to EHOs.

5.4 Staff Development 2018/19

All food safety staff received the minimum of 10 hours Continuous Professional Development training on food safety related topics as required by the Chartered Institute of Environmental Health.

Staff training was undertaken in the following areas:

PHE Sampling foods workshop PHE laboratory visit PHE training in modelling and challenge testing PHE Introduction to Outbreak Investigations Environmental Health Officer and Health Protection Team workshop FHRS National Consistency Exercise (FSA web based) FHRS Appeals (England) on line Approved Premises E coli

5.5 Food Premises Interventions

The following number of businesses that were due an intervention in 2018/19 and the number of interventions completed are as follows:

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High risk businesses:

2 x A due – completed

199 x B due – completed 136

Low risk businesses:

233 x C due – completed 211

239 x D due – completed 208

68 x E due - completed 52

(E rated premises do not form part of the inspection programme as they are by their nature deemed to be low risk premises, for example clothing retailers that are registered as food businesses because they sell chocolate/sweet gifts).

In line with National Guidance from the Food Standards Agency, resources were focused on the high risk premises such as caterers of high risk foods where the full suite of interventions are likely to be undertaken. This ensures that the resources available to the Service are used in the best way to ensure an improvement in the standards of the higher risk premises.

In total 100% of all due A & B rated premises were inspected in accordance with the requirements of the Code of Practice. Of the “C” rated premises 211 were inspected that is 90% within the required time frame and for the “D” rated premises 208 were completed that is 87%.

5.6 Formal Action

A total of 9 Hygiene Improvement Notices were served on a number of different premises. Examples of issues where notices were served included requiring business owners to undertake deep cleaning of their premises, provide suitable and sufficient food safety management systems and provide a constant supply of hot running water. Two premises voluntarily closed both because they had no hot water supply.

5.7 Food Complaints

311 food complaints were investigated and appropriate action taken. One complaint received involved a container load of imported tomatoes where there was evidence that illegal immigrants had been travelling in the container. Because of the potential risk of contamination of the load, the food business operator agreed to destroy the food.

5.8 Primary Authority Partnership

The Team are partners with Princes Foods Ltd who are world leaders in the supply of canned foods. Within this partnership, the team are responsible for dealing with all food complaints received from other enforcement authorities involving Princes branded or own branded products produced by Princes.

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Partnerships provide a means through which Environmental Health can be seen to support local and national businesses and gives front line officers an opportunity to enhance their skills working within a commercial environment. It is considered an achievement that the Service has been chosen over several other authorities as the companies’ preferred partner and recognition of the professionalism and quality of the Council’s front line environmental health staff.

5.9 Food Sampling

The Service undertook sampling following inspections of premises where problems with cleaning and food handling practices are identified. This intervention proves useful when explaining to food business operators the importance of good food safety management practices. All borderline and unsatisfactory sample results are further investigated and advice is given to food business operators. This is then followed by further sampling to confirm if improvements have been made.In addition, all reports of samples and findings are reported to PHE as they form part of the National Studies Report which is circulated to all local authorities.

5.10 Infectious Disease

44 infectious diseases were investigated and appropriate action in conjunction with Public Health England was taken in all cases.

5.11 Food Standard Agency Food Alerts & Food Incidents

Food alerts were received throughout the year and responded to accordingly. In one case the Food Standards Agency contacted the Team requesting assistance with an ongoing investigation into suspected food fraud involving a food broker registered in the Borough.

5.12 Community and Business Health Promotion

The St Helens Public Health Annual Report 2017/18 confirmed that 71.3% of adults in St Helens are classed as overweight or obese, which would correspond to an estimated 100,000 people in the borough. This is significantly higher than the England average and the second highest rate in the North West. Obesity and excess weight is a public health priority as it is a major risk factor to diseases such as heart disease and type 2 diabetes. Consequently the promotion of healthier and more nutritionally balanced foods and menus in local food businesses remains a key element of the plan.

Having developed the “Chip Fryer” award in 2013/14 and following on from this success Public Health commissioned further work from the Service and funded for 2 years a new post, “Community and Business Health Promotion Officer”. The aim being to improve the nutritional content of food offered by hot food takeaways and to improve the nutritional content of food offered to pre-school children. In 2017 following a review of the work done and the successful engagement with local businesses and childminders, Public Health agreed to make this a permanent post with continued funding.

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During 2018/19 the Chip Fryer Award was further promoted with a total of 18 businesses now having the Gold Award or Platinum award. The assessment for this award is to be amended to include a question about the selling of energy drinks and if a allergens poster is displayed in the shop.

The HOST Award (Healthier Options St Helens) has been developed which consists of a number of health “pledges” that hot food takeaway businesses can sign up to, which demonstrate their commitment to providing healthier options on their menus. 13 businesses have now signed up to the pledges and samples of dishes have been taken in order to analyse the % salt and/or % fat content of each meal. These results provide a base line for identified dishes in each business and enables the business owners to make changes to their recipes in order to reduce the levels of fat/salt. Dishes are resampled following the changes to determine if reductions have been made. To date a pizza business has been able to remove all salt from the pizza dough which is used. An Indian Takeaway has a range of dishes that they advertise as being under 500cals and sampling has verified that this is the case.

During the year the Childminders Health Eating Awarded was further promoted and in total 21 childminders have now received awards. This award recognises the good work being done by childminders in promoting the “healthy eating” message to children in their care and also to parents and carers.

Work was started with local food banks with meal planning and recipe planning based on the ingredients provided in the food parcels handed out to customers. A cookery demonstration was given and there is more work planned with the food banks and other charities.

Sandwich project – focusses on sandwich bars and delicatessens encouraging the provision of healthier sandwiches/salad boxes

6.0 Variation from the Service Plan 2017/18

There was no variation from the plan

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________________________________________________________

FOOD STANDARDS SERVICE PLAN 2019/20

_________________________________________________________

6.0 INTRODUCTION

The Food Standards Service Plan sets out how St Helens Council through its Trading Standards Service will fulfil its responsibilities under the legislation relating to food standards, particularly the labelling and composition of food. The structure of the service plan follows the service planning guidance contained within the Food Standards Agency (FSA) Framework Agreement on Local Authority Food Law Enforcement. Other Activities performed by the authority in respect of consumer protection legislation are detailed in the Departmental, Divisional and Action Plans detailed in Appendix 2.

6.1 Scope of the Food Standards Service

The enforcement of food standards legislation, which includes regulation of compositional standards relating to food, food labelling and nutritional and health claims made in connection with food, with all food businesses based or trading within the borough.

To conduct a programme of risk based, intelligence led inspections and interventions at food businesses.

To undertake sampling of food based on the National Co-ordinated Food Sampling Programme Priorities published by the FSA, local priorities and food incidents.

To react to food standards incidents, complaints, referrals and requests for advice relating to food standards.

To take appropriate enforcement action, when necessary, in accordance with the authority’s enforcement policy.

The Trading Standards Section is also responsible for the enforcement of a wide range of consumer protection legislation, including Fair Trading, Product Safety and Weights and Measures. Wherever possible, this is combined with food work.

6.2 Demands on the Food Standards Service

Detailed below is a summary of the premises with a Food Standards risk rating within the authority area:

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FSA Category Description A Rated B Rated C Rated TOTAL

A Primary Production 0 0 60 60

B Slaughterhouses 0 0 0 0

C & D Manufacturers & Packers 4 13 0 17

E Importers / Exporters 0 2 0 2

F Distributors 0 3 18 21

G Retailers 1 115 370 486

H Restaurants & Caterers 0 116 912 1028

I Materials and Articles Manufacturers & Suppliers

0 2 1 3

J Manufacturers mainly selling by retail

0 1 0 1

TOTAL 5 252 1361 1618

In general, the food businesses based in the area pose a low to medium risk and 97% of premises are rated as “broadly compliant” under the Food Law Enforcement Code of Practice (Guidance). High Risk premises are food manufacturers and packers, producing meat products, soft drinks, beverages, breakfast foods, hospital meals, and pickles. The majority of the food manufacturers and packers in the area are members of accreditation schemes such as BRC (British Retail Consortium).

7.0 SERVICE DELIVERY

7.1 Service Delivery Points

The Food Standards Service is delivered by the Trading Standards Section, based at Wesley House, Corporation Street, St Helens, WA10 1HE. Office hours are 8.45 am to 5.15

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pm Monday to Friday. Out of hours service is available should it be required. Contact can be made by telephone to: 01744 676299 or by e mail to: [email protected].

7.2 Identification of Premises with a Food Standards Risk

The Food Standards Service shares a premises database with the Environmental Health Food Safety Service, hence all food premises registered with the authority under the Food Safety requirements are known to the Food Standards Service. Regular checks are made on the database to ensure that all food premises have been risk rated and thus brought into the inspection programme. Food premises also become known through requests for advice from the business, complaints and enquiries about the business, as well as officers’ knowledge of the local area, which will lead to them being recorded on the premises database.

.3 Inspections (Interventions) at Premises with a Food Standards Risk

All food premises which are “A rated” will be inspected annually as required by the Food Law Enforcement Code of Practice. Food premises rated “B”, which manufacture or process food will also be inspected at least biannually.

The remainder of Food Standards work is intelligence led and delivered through a range of targeted projects, which include targeted inspections and interventions. In addition to reacting to complaints relating to specific businesses, business sectors will be targeted where there is a perceived national or local issue, such as the traceability of meat, substitution of meat species, the re dating of foods, failure to provide accurate allergen information, the sale of illicit alcoholic drinks, particularly wine and vodka and the use of false nutritional and health claims. The intention is to address any issues identified and to gather information which will influence future work.

7.4 Food Standards Complaints

Food Standards complaints are received by the service by telephone, letter, e mail or referrals via the Citizens Advice Consumer Service. All complaints are responded to within 1 working day.

Where the complaint relates to the contamination, adulteration, composition and labelling of food the complaint will be fully investigated, with a view to tackling the root cause of the problem, to avoid it happening again. Where appropriate, enforcement action will be taken, having regard to the Enforcement Policy and Statutory Codes of Practice.

7.5 Home Authority and Primary Authority Scheme

The service operates in accordance with the Home Authority Principle, acting as a point of contact for businesses based in St Helens that trade within and outside the area. Home Authority relationships exist with:

Edmund Barton Ltd Compass Group (t/a Cuisine Centre Northwest)

Soods Fine Foods George Wright Brewery

Baroncroft Ltd (t/a Punch Brew Company) Food Pack Ltd

mailto:[email protected]

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The service is working to develop Primary Authority relationships with appropriate food business. Primary Authority relationships including Food Standards exist with:

Aimia Foods Ltd 2 U Foods Ltd

Princes Ltd Nichols Foods plc.


The Food Standards Service will make all reasonable attempts to provide advice and education to businesses in a practical and cost effective manner. The intention is to equip the business with information that will allow the business to meet legal and best practice requirements. Advice may be provided through a number of means including:

➢ During routine inspections / visits and follow up visits

➢ Following investigation of a complaint

➢ Provision of information sheets / advice letters in hard copy of via relevant websites

➢ Telephone conversations with businesses

➢ Provision of seminars, displays and talks to businesses.

7.7 Food Sampling

Food sampling is planned based upon intelligence received and will take account of the National Co-ordinated Food Sampling Programme Priorities published by the FSA. The service will participate on Trading Standards North West (TSNW) sampling initiatives where appropriate.

In previous years the service has taken advantage of funding made available through TSNW participation in the FSA co-ordinated sampling programme. The FSA are no longer providing this funding so the co-ordinated sampling programme will not take place in 2019/20, which is a financial loss to the service, as in addition to analysis costs being covered by the funding, we were able to claim £30 per sample which contributed towards sampling costs.

The service has given careful consideration to project work for the year ahead, and at present no food standards projects are included within the planned work. Capacity within the Trading Standards Service has been reduced with the loss of a post in 2017, in addition to officers in post no longer maintaining competency. The service is currently working on a reactive basis and work is intelligence led, targeting issues identified as posing the most significant detriment to residents and businesses in St Helens. Should intelligence identify a food standards risk, a project will be planned and undertaken where appropriate.

The authority has contracted Lancashire Scientific Service as Public Analyst for the service.

Results of any official samples undertaken will be notified to the proprietor of the business. Where any sample results are unsatisfactory an officer will visit to give advice and discuss

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corrective actions to be taken, and it is likely that further sampling will be carried out. In instances where the adverse result relates to food manufactured outside the authority area, officers will liaise with the relevant Primary or Home Authority.

Any enforcement actions taken as a result of sampling will be in accordance with the Council’s Enforcement Policy.

7.8 Control and Investigation of Outbreaks of Food Related Infectious Diseases

Should a food safety incident be linked with a food standards issue the Food Standards officers will liaise with the Food Safety Team to investigate the issue.

7.9 Food Standards Incidents

All Food Standards alerts are received from the Food Standards Agency via e mail alert. The majority of alerts are for information only, whilst a small number will require an immediate response.

Food Standards alerts and warnings are responded to be an appropriate officer, usually the Lead Food Standards Officer, who will determine the action to be taken, which will be as directed by the warning notification received and in accordance with the Food Law Code of Practice.

Should there be a need for the Trading Standards Service to issue a Food Hazard Warning in respect of food standards matters, this would be undertaken in line with the relevant requirements of the Food Law Code of Practice and our Food Standards Practice and Procedures.

The authority has an emergency response system in place for any incidents that occur outside of normal office hours.


The service ensures that the food standards service delivered is consistent with that of its neighbouring authorities through participation in the Trading Standards North West (TSNW) Food Standards Group, which also includes partner organisations involved in similar work, such as MHRA (Medicines and Healthcare Regulatory Agency), FSA Wine Standards Branch and Port Health. The service has a close working relationship with colleagues in Environmental Health responsible for Food Safety Enforcement.

7.11 Food Standards Promotional Work

The service is committed to raising public awareness of food standards issues and will provide information through a variety of means whenever possible, including media articles, websites and events.

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8. RESOURCES


The officers engaged in Food Standards delivery also undertake other duties and the costs of the service are contained within the total approved budget for the Trading Standards Service.

Inspection, intervention work and sampling must be funded through the Trading Standards Service budget. At present approximately £3000 is available for analysis of Food Standards samples.

The cost of providing a Food Standards Service is as follows:

Employment Costs: £8,880

Supplies Service and Transport: £947

Recharges and Premises: £2,576

TOTAL: £12,403

Food Standards is allocated 2.5% of the overall Trading Standards Budget.


A list of officers currently authorised to undertake Food Standards enforcement work is maintained, together with a record of training and continuing professional development hours awarded. Currently this is 2 authorised food standards officers, one of which is authorised as Lead Food Standards Officer. Other officers holding a relevant qualification are in post, but require update activities in order to bring them into competence as required by the Code of Practice. It is estimated that 0.20 FTE time is allocated to Food Standards service delivery.

Food Standards work is undertaken by the following officers:

1 x Principal Trading Standards Officer: 5% of time

1 x Senior Trading Standards Officer: 10% of time

1x Operational Support Assistant 5% of time

8.3 Staff Development Plan

All training needed to deliver the Food Standards Service Plan is managed in accordance with corporate training procedures and with consideration to the requirements for continuing professional development identified in the Food Law Enforcement Code of Practice. The service will utilise training provided by TSNW and the FSA.

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9.0 QUALITY ASSESSMENT

9.1 Quality Assessment and Internal Monitoring

The Service monitors its performance of the Food Standards Service Plan at regular intervals. The Chief Trading Standards Officer monitors performance on a monthly and quarterly basis. In addition, each year performance is compared as part of the service planning process. The service has documented practice and procedures in relation to Food Standards service delivery, which are subject to regular review and performance is audited against these.

All officers are monitored on a monthly basis to ensure that targets are being met with regard to response times and inspections due. The Lead Food Standards Officer monitors work recording and follow up actions taken on a regular basis and may on occasion accompany Food Standards officers during visits, to ensure that inspections and enforcement actions are carried out in accordance with legislation, the Food Law Enforcement Code of Practice and internal Practice and Procedure notes.

10.0 REVIEW OF ACTIVITY IN FOOD STANDARDS 2018-19

10.1 Programmed Premises Interventions

The Food Standards Team were programmed to complete inspections of 7 “A” rated (high risk) premises. Two of the businesses closed prior to inspection, and one business which is based in 2 premises was dealt with by way of Primary Authority work, whilst the remaining 3 premises were inspected, with no major issues identified.

Inspections were also made of 4 “B” rated manufacturing businesses, again no major issues were identified, but advice was provided to assist improvements in compliance.

One of these businesses is a contract packing business, which has undergone changes in ownership and personnel during the last 12 months. This business has been provided with support on food labelling matters, as they intend to launch their own product ranges, for which they will have responsibility for the labelling, which is new to the business.

Although not performing programmed inspection visits to the remainder of the food businesses, the service continued to engage with and challenge Low and Medium Risk businesses (B and C rated), by reacting to intelligence received and complaints.

10.2 Formal Action

The Food Standards Team has completed a lot of work in relation to infringements identified through intelligence received. Much of this work has been the provision of business advice in order to resolve problems and prevent future infringements. The majority of non-compliant businesses were brought into compliance by the end of the year through this process. Other issues have been resolved through liaison with the Primary or Home Authority for the business concerned.

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The team dealt with a food incident, brought to their attention by Felixstowe Port Health, which related to a large consignment of tea, which had been imported as Organic tea, and was intended to be sold as such. The importer, based in Manchester did not hold Organic status with the Soil Association, and hence the tea had lost it’s organic status. The tea was detained by Port Health and was held in supervised detention in St Helens, which required the Food Standards team to liaise with the importer to ensure the product was not placed on the market. The tea was eventually returned to Sri Lanka for repacking as a standard non organic product.

10.3 Food Complaints

During 2018/19 a total of 15 Food Standards complaints were received, the majority of which related to the sale of foods after the marked “best before” or “use by” date.

Two complaints related to allergen issues, one being in relation to a prepacked product and found to be unjustified on further investigation. The second related to the sale of a “gluten free” pasta meal at a restaurant, which caused a reaction requiring hospital treatment. The investigation revealed that the business had not used their “approved” gluten free pasta, and that staff had not checked that the replacement product used was in fact gluten free. Work was undertaken with the business to assist them in improving their procedures with regard to procurement and allergens.

The team also responded to a number of requests for advice received from new food businesses on the composition, labelling and advertising of their products, particularly businesses selling home baked cakes and confectionary.

It is believed that the low level of consumer complaints received may be due to the use nationally of the Citizens Advice Consumer Helpline, as the contact point for Trading Standards enquiries, as consumers may not realise that food complaints can be made through this route.

10.4 Food Sampling

The FSA did not provide any funding for food standards sampling during 2018/19, as a consequence no sampling was undertaken, as none of the complaints received or issues identified in inspection required a sample to be taken in order to remedy the issue.

10.5 Primary and Home Authority

The Primary Authority relationship with Princes Ltd continues to develop, with the business seeking advice and support on a wide range of issues, some of which are complex and technical. Of particular note this year has been their request for assistance in ensuring continued compliance following the EU Exit.

Primary Authority work is charged for at cost recovery.

10.6 Officer Development

All Food Standards enforcement officers attended a minimum of 10 hours CPD (Continuing Professional Development) training, as is required by the Food Law Enforcement Code of

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Practice. Officers attended a number of training events, most of which were provided through the TSNW Food Standards Group and the FSA.

In addition, officers have undertaken extensive research in order to provide comprehensive business advice on a number of issues, which has contributed to the officers’ knowledge base.

All officers have completed a competency matrix which will form the basis of their individual appraisals and which will ensure that officers are correctly authorised to undertake their duties which is dependent on their training and years of experience.

10.7 Variation from the Service Plan

There was no variation from the Service Plan.

10.8 Areas of Improvement

To build capacity through updating competency of officers who have not undertaken food work for several years, in order to increase the pool of fully authorised Food Standards Officers.

To continue to review officers’ qualifications, skills and competencies against the Food Law Enforcement Code of Practice requirements and review authorisations as required.

To review Practices and Procedures to ensure compliance with the revised Food Law Enforcement Code of Practice.

To continue to improve the standard of inspection recording.

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____________________________________________________

FEED SERVICE PLAN 2019/20

_________________________________________________________

11.0 INTRODUCTION

The Feed Service Plan sets out how St Helens Council through its Trading Standards Service will fulfil its responsibilities under the legislation relating to animal feed, fertilisers and the primary production of food. The structure of the plan follows the service planning guidance contained within the Food Standards Agency (FSA) Framework Agreement on Local Authority Food Law Enforcement. Other activities performed by the authority in respect of consumer protection legislation are detailed in the Regulatory Services (Trading Standards) Service Plan.

12.0 FEED SERVICE AIMS AND OBJECTIVES

12.1 Aims and Objectives

To ensure all animal feed, including pet foods are safe for consumption and are properly

labelled;

To ensure that animal feeds are produced, transported, stored and used hygienically;

To continue to register and / or approve all feed business establishments;

To ensure that food and feed produced at Primary Production is safe for consumption.

12.2 Links to Corporate Objectives and Plans

The Council approves the Feed Service Plan. The Cabinet Member holding the Portfolio for Better Neighbourhoods monitors progress against service objectives during the year.

The work of the Feed Service is reflected in the Council’s Performance Plan.

The Feed Service Plan is reviewed annually, taking into account corporate objectives, demands on the service and any changes in the way in which the service is provided, to ensure the provision of the most cost effective service. The links to the St Helens Plan objectives are set out in Section1.3.

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13.0 BACKGROUND

13.1 Profile of the Local Authority

A profile of the authority is provided on page 11.

Whilst St Helens is a mainly urban area, there are small rural communities around the outskirts, where farming remains as a full time occupation, in addition to a number of small holdings, and hobby farms.

13.2 Organisational Structure

The Feed Service is provided by the Trading Standards Service, the organisational structure which is shown in Appendix 2.

13.3 Scope of the Feed Service

To conduct a programme of inspections of feed businesses and primary production businesses at the frequency required under the Feed Law Code of Practice published by the Food Standards Agency.

To undertake sampling of animal feed based on the National Feed Priorities published by the FSA, local priorities and feed incidents.

To react to feed safety incidents, complaints, referrals and requests for advice relating to animal feed and the primary production of food.

To take appropriate enforcement action, when necessary, in accordance with the authorities’ enforcement policy.

13.4(a)Demands on the Feed Service

Detailed below is a summary of the premises registered as Feed Business Operators with the authority:

FSA

Category

Description Number of premises

R5 Placing on the market of compound feeds 3

R6 Manufacture of Pet Foods 1

R7 Manufacture and / or placing on the market of feed materials 21

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FSA

CategoryDescription Number of premises

R8 Transporting of feed and feed products3

R10/11Mixing feed on farm with additives and premixtures/ with compound feeding stuffs that contain additives

11

R12 Food businesses selling co products of the food industry which are destined as feed materials 3

R13 Livestock Farm 21

R14 Arable Farm 43

TOTAL 106

In general, the feed businesses based in the area pose a low to medium risk and all premises are rated as either “broadly compliant” under the NTSB risk rating scheme. Less than 30% of the registered feed businesses are members of recognised feed assurance schemes.

The highest risk premises are the on farm mixers (R10/11) who generally only mix their own grain with compound feeds supplied by reputable suppliers, the food businesses disposing of waste food and co products (R7 and R12) into the feed supply chain, with varying control measures in place, and a manufacturer of pet food and treats (R6).

13.4(b)Service Delivery Points

The Feed Service is delivered by the Trading Standards Section, based at Wesley House, Corporation Street, St Helens, WA10 1HE, office hours being 8.45am to 5.15pm Monday to Friday. Out of hours service is available should it be required. Contact can be made by telephone to 01744 676299 or by email to [email protected].

mailto:[email protected]

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13.5 Regulation Policy

The Feed Service adheres to the Regulatory Services Enforcement Policy which is available via the website www.sthelens.gov.uk.

14.0 SERVICE DELIVERY

14.1(a)Feed Premises Registration

The Feed Service has proactively sought registration of feed business establishments under the feed hygiene requirements and continues to do so, when affected businesses are identified. Third party assurance information is incorporated into the Feed Hygiene Register maintained by the service.

14.1(b) Inspections (Interventions) at Feed Business Establishments and Primary Production Premises

Feed and primary production inspection frequency is conducted according to the NTSB risk scheme. Inspections are conducted in accordance with the Feed Law Enforcement Code of Practice. The table below details the inspection programme for the premises currently on the Feed Hygiene Register.

The following elements, in varying depth depending on the identified risks of the business, will be undertaken during feed and primary production inspections:

Registration / checks on the registration categories of feed businesses including food businesses supplying into the animal feed chain;

Examination of the processes to ensure that feed / food (at primary production) is compositionally and nutritionally correct, not adulterated or contaminated and is properly labelled;

Determining the efficiency and effectiveness of HACCP systems used in the manufacture and use of feed and the primary production of food and feed.

Examination of the traceability systems for feed, feed ingredients and food at primary production;

Sampling for analysis of feed, feed ingredients and food at primary production.

Provision of advice on legal requirements

The following inspection visits are planned for 2019/20:

1 x R5 Placing on the market of compound feeds

1 x R6 Manufacturer of pet foods

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3 x R7 Food business disposing of surplus food

1 x R10/11 On farm mixer of feed (with & without feed additives)

1x R12 Food businesses selling co products

1 x R13 Livestock Farm

All of the planned inspections will be funded by FSA/ NTSB via a regional funding bid. The level of inspection detailed above and the associated work can be met with the resources available.

The Feed Officer is qualified and maintains competency as per the requirements of the Feed Law Enforcement Code of Practice for Authorised Officer and Lead Feed Officer activities.

14.2 Feed Complaints

Feed and primary production complaints are received by the service by telephone, letter, email or referrals via Citizens Advice Consumer Service. All complaints are responded to within 1 working day.

Where the complaint relates to the contamination, adulteration, composition and labelling of feed or food produced at the primary production level the complaint will be fully investigated, with a view to tackling the root cause of the problem, to avoid it happening again. Where appropriate, enforcement action will be taken, having regard to the Enforcement Policy and Statutory Codes of Practice.

14.3 Home Authority and Primary Authority Scheme

The service operates in accordance with the Home Authority Principle, acting as a point of contact for businesses based in St Helens that trade within and outside the area. We are Primary Authority for Aimia Foods Ltd who are a food manufacturing and packing business, businesses that disposes of waste for use as animal feed. The service is working to develop Primary Authority relationships with appropriate food and feed businesses.


The feed service will make all reasonable attempts to provide advice and education to businesses in a practical and cost effective manner. The intention is to equip the business with information that will allow the business to meet legal and best practice requirements. Advice may be provided through a number of means including:

During routine inspections / visits and follow up visits

Following investigation of a complaint

Provision of information sheets / advice letters in hard copy or via relevant websites

Telephone conversations with businesses

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Provision of seminars, displays and talks to businesses

14.5 Feed Sampling

Feed sampling is planned based upon intelligence received and will take account of the National Enforcement Priorities set by the FSA. The service will participate in Trading Standards North West (TSNW) sampling initiatives where appropriate.

The authority has contracted Lancashire Scientific Services as agriculture analyst for the service.

At present no reason for sampling has been identified for 2019/20, however, samples will be programmed should intelligence be received or initiatives be developed by TSNW or the FSA.

14.6 Control and Investigation of Outbreaks of Food Related Infectious Disease

Should a food safety incident linked with a primary production premise, or a feed business arise, the feed officers will liaise with the food safety team to investigate the issue, as described within the Food Service Plan

14.7 Feed Safety Incidents

All feed alerts are received from the Food Standards Agency via e mail alert. The majority of alerts are issued for information only, whilst a small number will require an immediate response.

Feed hazard warnings are responded to by an appropriate officer, usually the lead feed officer, who will determine the action to be taken which will be as directed by the warning notification received and in accordance with the Feed Law Code of Practice.

The authority has an emergency response system in place for any incidents that occur out of normal office hours.


The service ensures that the feed service delivered is consistent with that of its neighbouring authorities through participation in the Trading Standards North West (TSNW) Agriculture Group, which also includes partner organisations involved in similar work, such as APHA (Animal and Plant Health Agency) and VMD (Veterinary Medicines Directorate). The group is represented on the National Agriculture Panel (NAP). We work directly with APHA when required. The service liaises with colleagues in Environmental Health responsible for Animal Health enforcement.

14.9 Feed Safety Promotional Work

The service is committed to raising public and business awareness of feed safety issues and will provide information through a variety of means whenever possible, including media articles, websites and events.

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15.0 RESOURCES


The officer engaged in feed service delivery also undertakes other duties and the costs of the service are contained within the total approved budget for the Trading Standards Service. In addition, the service applies for funding from NTSB for feed delivery work, via a regional TSNW bid. The funding won for 2019/20 is £2456 in relation to inspection visits. No funding was bid for in relation to sampling, hence any sampling will need to be funded through the services budget.


A list of officers currently authorised to undertake feed and primary production enforcement work is maintained, together with a record of training and continuing professional development hours awarded. Currently this is 1 authorised feed officers, who is also qualified and authorised as Lead Feed Officer. It is estimated that less than 0.1 FTE officer time is allocated to feed service delivery.

15.3 Staff Development Plan

All training needed to deliver the Feed Service Plan is managed in accordance with corporate training procedures and with consideration to the requirements for continuing professional development identified in the Feed Law Enforcement Code of Practice.

The service will utilise free and low cost training provided by TSNW when possible.

16.0 QUALITY ASSESSMENT

16.1 Quality assessment and internal monitoring

The Service monitors its performance of the Feed Service Plan at regular intervals. The Chief Trading Standards Officer monitors performance on a monthly and quarterly basis. In addition, each year performance is compared as part of the service planning process.

The Service has documented practices and procedures in relation to feed service delivery, which are subject to regular review and performance is audited against these.

All officers are monitored on a monthly basis to ensure that targets are being met with regard to response times and inspections due. As the Lead Feed Officer is currently the only authorised feed officer in post, the Chief Trading Standards Officer monitors work recording and follow up actions taken and may accompany the feed officer during visits to ensure that inspections and enforcement actions are carried out in accordance with legislation, the Feed Law Enforcement Code of Practice and internal Practice and Procedure notes.

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17.0 REVIEW

17.1 Review against the Service Plan 2018-19

17.1(a)Programmed Premises Interventions

During 2018/19 the service completed the following inspection visits, all funded through the NTSB / FSA regional funding awarded:

1 x R5 Placing on the market of compound feeds, it was established that the business had vacated their address, but research indicated that the business had relocated and work is being undertaken to ensure compliance continues.

1 x R6 Pet food manufacturer, which is an established dog grooming business which started production of pet foods, such as pies, cakes and general treats, using a custom built manufacturing facility, subject to APHA approval.

1 x R7 Food business disposing of surplus food, a supermarket disposing of unsold bakery goods.

1 x R8 Haulier, it was established that the business no longer carries or stores animal feed.

1 x R10/11 On farm mixer of feed with feed additives, the inspection identified significant changes in the mixing process since the last inspection.

1 x R14 Arable farm, which is a major vegetable grower, selling to major supermarkets, and so was also inspected as a Primary Producer, the visit also established that the farm disposes of waste vegetable matter to a farm, and hence falls into the R12 category, and registration was revised.

No major issues were identified through the inspections, but advice was provided to assist improvement, particularly with regard to record keeping. The main issue found is that businesses are not registered in the correct category for their current activity, and do not update the authority when their business changes significantly.

The Feed team have now had contact with all registered feed businesses in the area and have inspected over 40% of those businesses over the last 5 years and continue to utilise questionnaire, in order to maintain current records of the feed business in the area. The majority of businesses not inspected are supermarkets disposing of bakery waste for feed use, and small scale hobby farmers, neither of which pose no significant risk.

17.1(b)Formal Action

No Formal Action was required as no significant infringements were identified. Advice was provided to a number of Feed Business / Primary production Establishments to assist improvement.

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17.1(c) Feed Complaints

During 2018/19 the increased level of feed related enquiries was maintained, with a total of 10 issues, 2 of which were consumer complaints relating to pet food of an unsatisfactory quality.

There were 2 requests for advice from persons considering manufacturing dog treats at home, and an issue of a newly established “raw” pet feed business manufacturing cakes and other treats for dogs, when not registered as a feed business or approved by APHA, this issue was resolved through advice.

The service dealt with an issue where another authority identified that an vegetable grower was supplying the vegetable tops, and lower quality product to another farm, with no documentation, and hence no traceability. Enquiries made revealed that the vegetable grower was not registered as a co-product supplier in category R12, and was not aware that records were to be kept for this activity, despite being a member of an approved farm assurance scheme (Red Tractor) and being audited by major customers. This is issue was resolved through advice.

17.1(d)Feed Sampling

A review was made of the National Sampling Priorities which did not indicate the need for any sampling No issues arose during the year which required samples to be taken.

17.1(e)Officer Development

The lead feed enforcement officers achieved in excess of 10 hours CPD (Continuing Professional Development) training, as is required by the Feed Law Enforcement Code of Practice. The Lead Feed Officer attended training on Inland Feed Inspections. In addition, the Lead Feed Officer attends the TSNW Agriculture Group and undertakes individual research relating to legislation and best practice.

17.2 Variation from the Service Plan

There was no variation from the planned work during 2018/19.

17.3 Areas of Improvement

To continue to review the risk rating of feed premises on our database in line with the NTSB risk Rating Scheme.

To improve the standard of inspection recording, utilising the FSA standard forms and guidance on completion provided.

To review our Practices and Procedures to ensure compliance with the revised Code of Practice on Feed Law Enforcement.

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APPENDIX 1

SERVICE PLAN PROGRAMME 2019/20

Departmental and Divisional Service and Action Plans can be viewed on the council’s web based PMF (Performance Management System).

Paper copies of the plans are available on request.

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APPENDIX 2

ORGANISATIONAL STRUCTURE CHARTS

Attached on the following pages are copies of organisational structure charts for: -

1) Department - Management Team

2) Division - Environmental Health

- Trading Standards

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Place ServicesDepartment

STRATEGIC DIRECTOR PLACE SERVICES

Senior Assistant Director Development & Growth

Senior Assistant Director Trading Services

Service Manager Estates

Management

Service Manager

Development & Growth

Service Manager Assets a& Buildings

Service Manager Schools, Depot &

Care Services

Service Manager Recreational

Services

Service Manager Environment &

Transport Services

Service Manager Regulatory Services

Service Manager

Engineering Services

CHIEF EXECUTIVE

Business Support Manager

Senior Assistant Director Built Environment & Regulatory Services

Environmental HealthTrading StandardsLicensing & Land ChargesBuilding Control

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Built Environment & Regulatory Services DivisionEnvironmental Health



Principal EHOCommercial Services

Principal EHOEnvironmental Control

5 x Senior EHO(Commercial

Services)

Commercial Services Officer

2 x Environmental Control Officers

3 x Scientific Officer

Air Quality, Contaminated Land, Noise

Dog Welfare & Enforcement Officer

4 x Environmental Wardens

Community & Business Health

Promotions Officer

Supervisor Pest Control

4 x Pest Control Officers

Environmental Warden Support

Officer

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Built Environment and Regulatory Services DivisionTrading Standards


Principal Trading Standards Officer

Admin Officer

Senior Consumer Protection Officer

Senior Trading Standards Officer

Operational Support Assistant

2 x Clerical Officers


Principal Trading Standards Officer

Chief Trading Standards Officer

Senior Trading Standards Officer

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APPENDIX 3

FOOD SAFETY PREMISES/WORK PROFILE 2019/20

Code Establishments A B C D E Total

101 Manufacturers and Packers 1 3 3 3 1 11

103Distributors/Transporters

0 1 0 3 3 7

105Supermarket/Hypermarket

0 0 2 8 4 14

06Smaller retailers

0 5 17 47 33 102

107Retailer – other

0 1 2 3 10 16

109Restaurants/café/canteen

0 11 51 42 1 105

110Hotel/Guest House

0 0 1 2 0 3

111Pub/Club

0 5 23 25 27 80

112Takeaway

2 15 64 21 0 102

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Code Establishments A B C D E Total

113Caring establishments

1 61 20 7 16 105

114School/College

0 35 18 10 0 63

115Mobile food unit

0 0 2 17 16 35

116 Restaurants and caterers -other

0 5 18 22 15 60

Total due an intervention in

2018/194 142 221 210 126 703

Inspection

Frequency6 months 12

months18

months 24months 36months

The number of targeted interventions for food standards and food safety differ, due to the different risk rating required by the Food Standards Agency.

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APPENDIX 4

COMMERCIAL SERVICES TEAM -

ESTIMATION OF RESOURCES FOR 2019/20

To achieve the inspection plan as shown in Appendix 3, each inspector will work to individual targets amongst the team the following is an estimate of the anticipated workload:

150 High Risk Inspections (A-B) (A’s inspected twice a year)557 Low Risk Inspections (C-E) 380 Food Complaints80 Infectious Disease Investigations250 Revisits (may rise if the display of the Food Hygiene Rating Score becomes

mandatory)

Other areas of work will be dealt with by the Team as detailed in the Food Service Plan include,

Advice to businesses

Sampling

Food Standards Agency Food Alerts

Liaison with other Agencies

Food Safety and Healthy Eating Promotion

Training and coaching food safety

Business and Community Health Promotion

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APPENDIX 5

FOOD SAFETY TRAINING PROGRAMME 2019/20

All officers will receive training so as to enable them to comply with the requirements of the Code of Practice, which states that all authorised officers and the Lead officer must obtain a minimum of 20 hours CPD per year, spilt into:

A minimum of 10 CPD hours on core food matters directly related to the delivery of official controls

10 hours on other professional matters. This could include training needs identified during the competency assessments and appraisals.

The following areas of training will be dealt with during the coming year, some by shared low cost training with Environmental Health Cheshire and Merseyside;

FSA Update Sessions / Consistency Exercises

Public Health England –sampling workshop and microbiology

Other update courses as they become available throughout the year.

All officers are also briefed during regular team meetings of any changes to internal Practice and Procedure Notes.

When officers attend courses on any food or related issue then the appropriate cascade training will be organised so that the team will benefit.

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