Environmental Health

and

Trading Standards Service

FOOD & FEED LAWENFORCEMENTSERVICE PLAN

2015-2016

Foreword

Safe food is fundamental to maintaining a healthy living environment and, as a Food Authority; St Helens Council has responsibility for ensuring the food businesses operating within the borough comply with legal requirements.

In fulfilling this important role the Council uses suitably qualified officers within both the Environmental Health and Trading Standards sections to inspect businesses and deal with food complaints or enquiries.

This Food and Feed Law Enforcement Service Plan has been compiled having regard to the framework agreement published by the Food Standards Agency. The plan sets out how, over the forthcoming year, the Council will seek to fulfil its statutory obligations and ensure that local businesses trade safely and in compliance with the law.

This year the plan has been extended to cover feedstuffs and outlines the proposed measures to ensure animal feedstuffs sold from and consumed in St Helens will not adversely affect the human food chain or harm the animals to which they are fed.

Within the plan there remains a commitment to work with and support business, to participate in both regional and national initiatives and improve nutritional standards in local businesses.

…………………………………….. , Cabinet Member for Environment and Neighbourhoods

May 2015

2

Contents

Page Number

Introduction 5

1.0 Service Aims and Objectives1.1 Aims 61.2 Links to Corporate Objectives 6

2.0 Background2.1 Profile of the Local Authority 72.2 Organisational Structure 82.3 Scope of the Food Service 82.4 Demands on the Food Service 92.5 Food businesses and the local economy 102.6 Health Inequalities 102.7 Regulation Policy 11

3.0 Service Delivery 2015/163.1 Food Premise Interventions 113.2 Complaints 133.3 Home Authority Principle 143.4 Advice to Business 143.5 Sampling 143.6 Infectious Disease Control 163.7 Food Safety Incidents 163.8 Liaison with other organisations 173.9 Promotion 173.10 Community and Business Health Promotion 183.11 Food Information to Consumers – Allergens 193.12 Food Safety Week 193.13 ATP (Adenosine Triphosphate) Monitoring 193.14 Mobile Caterers 203.15 Crucial Crew 203.16 Smoke Free 203.17 Food Standards sampling 203.18 Retail Inspection 203.19 Food Information Regulations Implementation 213.20 Caffeinated Energy Drinks 21

4.0 Resources4.1 Financial Allocation 214.2 Staffing Allocation 224.3 Staff Development Plan 22

3

5.0 Performance Indicators and Quality Assessment 23

6.0 Review of Activity in Food Standards 2014/15 25

7.0 Review of Service Delivery 2014/15 Food Standards7.1 Food Premises Interventions 257.2 Formal Action 267.3 Food Complaints 267.4 FSA Food Sampling 26 7.5 Variation from the Service Plan 27

8.0 Review of Activity in Food Safety 2014/15 27

9.0 Review of Service Delivery 2014/15 Food Safety9.1 Food Premises Interventions 309.2 Formal Action 309.3 Food Complaints 319.4 Primary Authority Partnership 319.5 Food Sampling 319.6 Infectious Disease 329.7 Food Alerts and Incidents 329.8 Promotion –Delivery of Training 329.9 Early Years Healthy Food Award 329.10 Community & Business Health Promotion 329.11 Food Safety Week 339.12 Variation from the Service Plan 34

Appendices

Appendix 1 Links to the St Helens Plan 2013-16 35

Appendix 2 Service Plan Programme 2015/16 38

Appendix 3 Organisational Structure Charts 39

Appendix 4 Food Service Work Profiles 43

Appendix 5 Sampling Plans 45

Appendix 6 Estimation of Resources for 2015/16 47

Appendix 7 Training Programme 49

Appendix 8 Feed Service Plan 50

4

Introduction

The Framework Agreement on Official Feed and Food Controls, published by the Food Standards Agency (FSA) requires Local Authorities to have Food and Feed Service Plans in place. These plans and the work undertaken are audited by the FSA. This Service Plan sets out how the nationally recognised priorities and local priorities will be addressed through local service delivery by the Authority. The plan details the achievements of the Food and Feed Service in 2014/15 and sets out the planned activity for 2015/16.

During 2014/15, the service undertook around 1019 visits to food businesses and 10 visits to feed businesses. Support provided during these visits is vital to businesses that face competing pressures in the current financial climate. Officers make sure that food and feed businesses are aware of their legal obligations and help them ensure that the food and feed they supply is wholesome and safe.

At the end of 2014/15, the base line figure for businesses being ‘broadly compliant’ with food safety legislation was 88% this has risen from 77% in 2009/10. This improvement in compliance is a measure of distinct outputs of the activities undertaken by the Food Safety team in comparison to inputs, such as number of inspections undertaken. It demonstrates that the work done by the team and the businesses has been effective and work continues to be done to target resources towards those who are less compliant.

The National Food Hygiene Rating Scheme was launched in February 2012 migrating from a local ‘Scores on the Doors’ star-rating scheme to the national numerical rating scheme. Members of the public can access food hygiene ratings at www.food.gov.uk/ratings and can see the ratings displayed at businesses.

The reforms which came into effect in 2013, to the way in which Public Health is managed and delivered, provides an opportunity to increase the contribution to the public health agenda. What we eat can make a significant difference to our health. Work around nutrition can help in reducing the health inequalities that exist within St Helens. Environmental Health and Trading Standards services are well positioned to engage and influence food businesses in relation to nutrition and healthy lifestyles. We have already done this in developing the “Chip Fryer” Awards aimed at reducing the saturated fat content of chips, encouraging salt reduction in takeaway foods and working with other stakeholders to improve the nutritional content of foods served in nurseries. All of these initiatives have been well received by local businesses. We will be undertaking further project work around diet and nutrition during 2015/16.

Food Standards work will focus on the detection and prevention of food fraud, particularly the deliberate adulteration of foods. A second focus will be to ensure that food labelling does not mislead in relation to the composition of the food, or the nutritional and health benefit it provides. Service will be delivered through a programme of targeted inspections and sampling.

Details of Feed Service Delivery, which includes the primary production of food and feed are outlined at Appendix 8.

5

1.0 Service Aims and Objectives

1.1 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, 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.

1.2 Links to corporate objectives and plans

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

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

The Food 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 affective service. The links to the St Helens Plan objectives are set out in Appendix 1 and Service Plans in Appendix 2.

6

2.0 Background

2.1 Profile of the Local Authority

The Borough of St.Helens comprises the town itself and smaller settlements such as Haydock, Newton-le-Willows, Rainford and Billinge and is situated roughly 12 miles from Liverpool City centre and 25 miles from the centre of Manchester. It enjoys a strategic position at the heart of the regional road network with good linkages to the national rail network.

St. Helens is a relatively modern town. Its historical growth was based primarily on coal, which acted as a catalyst for the expansion of a range of industries including glass, chemicals and pharmaceuticals. Coal mining and glass manufacture between them once employed around 50,000 people, well over half the workforce. After the 1970’s these industries declined, which had a significant impact on the Borough and its communities. The legacy of this industrial decline caused a reduction in jobs and business opportunities. This resulted in high levels of unemployment rates, low skill levels, derelict land affected by contamination and poor health, all of which have remained significant challenges within the Borough.

The continued regeneration of the local economy and infrastructure is an ongoing priority for the council and its partners and St.Helens has undergone considerable positive change. New businesses have set up in the area, taking advantage of the central location and a hardworking committed workforce and a warm welcome from the Council. Physically, post-industrial landscapes are being transformed and new greenways and woodland created. Major Town Centre improvements have added a host of new visitor facilities and attractions.

In recent years difficult economic circumstances have returned and have again impacted on the local economy. The challenge remains for St.Helens to grow its business offer and become more diverse, bringing further economic growth and opportunity to the Borough.

The population in St.Helens has remained stable over the past ten years. The resident population is 176,221 (2013 mid-year estimate, ONS) and is predicted to increase over the next ten to twenty years. In St.Helens this increase is expected to be slightly lower than regional and national population growth rates.

St. Helens has an aging population similar to that of England’s, but has a higher proportion of people aged 50-79 and proportionally less aged 40 and under. An aging population could lead to an increase in demand and pressure upon the Council.

St. Helens is ethnically less diverse than many areas. With a vast majority of the residents being white 96.6% (Census, 2011), this is considerably lower than the national 79.8% and regional 87.1% rates. St.Helens is subject to very low levels of population churn with one of the lowest rates of migration in the country. Although the

7

largest group of migrant workers to St. Helens remains principally people from Eastern Accession States.

St.Helens is in many respects a typical northern town, with pockets of relatively high deprivation existing across the Borough. Levels of worklessness and poor health remain key challenges in these areas.

Overall unemployment in St Helens remains above the North West and National average. Unemployment has increased for men and women since 2008, with a particular increase in the past 12 months, contrary to regional and national trends.

Skill levels which were traditionally low compared to the rest of England are increasing, but further improvement is required in this area, particularly higher level skills linked to growth sectors.

The number of young people not in education, employment or training has improved, but this remains a priority area and focus for targeted support by the Council and wider partnership, particularly outcomes for vulnerable groups.

Improving the health of local people remains a priority with a number of specific challenges. Life expectancy in St.Helens continues to improve with life expectancy for males at 78.1 years (Public Health Outcomes Framework, 2013) and for females 81.6 years (Public Health Outcomes Framework, 2013). This is better than some of the neighbouring authorities but 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 10.2 year life expectancy difference for males between the most and least deprived wards and a 7.3 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 rate has doubled over the past 25 years, in St.Helens data from the Health Survey for England indicates that local obesity rates affect around a quarter of the adult population and this has remained static in the past 2 surveys. These rates are slightly higher than the North West and England obesity levels.

Data for 2013/14 shows that 13.3% of reception age children (4-5 years) in St.Helens are obese, compared to 9.9% nationally. By the time young people have reached year 6 (age 10-11) the percentage obese has increased to 22.1% compared with 19.1% nationally.

The Council's local information system SHARE provides a detailed demographic picture of St.Helens and its communities providing key statistics and comparative data on a wide range of themes. For more information please visit the website at http://share.sthelens.gov.uk/IAS/

8

2.2 Organisational Structure

Organisational structure charts for Environmental Health and Trading Standards are as attached at Appendix 3.

2.3 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:

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

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

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;

Sampling of food produced or sold in the borough;

Provision of Food Hygiene and Nutrition Training;

Registration of food premises;

Approval of food premises under EC Regulations;

Health promotional activities around food and nutrition within the community and food businesses.

The Environmental Health Section is also responsible for the enforcement of the Health and Safety at Work Act and Smoke Free legislation. 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.

The Trading Standards Section is responsible for:

9

The enforcement of food standards legislation (which includes regulation of labelling, composition and nutritional and health claims) with all food premises within the borough, using a range of interventions, such as inspections and audits.

The investigation of food complaints relating to food standards issues, including enforcement action where necessary.

Sampling of foods to check compliance against food standards legislation.

The registration and inspection of feed businesses and primary producers.

Provision of advice to businesses on food standards and feed / primary production matters.

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 and feed work.

2.4 Demands on the Food Service

Food service work profiles in respect of number and type of food premises in the borough requiring interventions in 2015/16 for Food Standards and Food Hygiene are attached in Appendix 4.

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 and standards 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.

2.5 Food businesses and the local economy

Food production, its transport and sale at retail and catering establishments are very 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.

Whilst there have been business closures in St Helens there has been a notable increase in food business turn over and new business registrations. However the total number of food business registrations remained largely static in 2014/15, with 1437 food businesses being registered at the start of 2015/16 compared to the 1390 businesses that were registered at the start of the 2014/15 business year.

10

The work undertaken 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.

Working with businesses to assist them comply with food legislation helps to ensure fair competition and allow well-run food businesses to flourish and contribute to the local economy. Specific support is offered for new companies, which can prove vital to the longer-term survival of a business.

2.6 Health Inequalities

The Environmental Health and Trading Standards services work towards delivering the Council’s priorities and vision for the Borough. What we eat can make a big difference to our health and significantly influences health inequalities that exist within St Helens. Diet, especially excess saturated fat, salt and sugar, is thought to play a role in about one third of all deaths from cancer and heart disease. Almost 70,000 premature deaths could potentially be prevented each year if UK diets matched nutritional guidelines. Officers have an influence on food provision within businesses and are in a unique position to enforce, promote, advise, educate and inform.

Food enforcement officers work with local businesses during inspections to ensure that nutritional labelling on food is accurate and claims made are not misleading. This enables consumers to make informed choices about the food that they eat. Officers also work with businesses to ensure colourings, additives and other ingredients are at safe levels and do not lead to long-term health problems for consumers.

As part of the work undertaken businesses are encouraged to provide healthy options and actively highlight these to customers. A number of food related projects are being delivered, which aim to addressing specific health issues in our area and engage with local residents about nutrition. These projects are described briefly in this report.

2.7 Regulation Policy

An enforcement policy is in place, 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 was approved by St. Helens Licensing and Environmental Protection Committee, on 18 March 2015.

11

3.0 Service Delivery 2015/16

The revised Food Law Code of Practice (England) published by the Food Standards Agency came into force on the 7 April 2015. The main changes to the Code being: Registration of premises – further clarification on what is an “establishment” and

who is the Food Business Operator

Moveable establishments – clarity on which local authority should register ships and aircraft

Competency requirement and officer authorisation – separate competency requirements have been detailed for Lead Officers, Authorised officers and for Regulatory Support Officers. Local authorities have until the 1 April 2016 to implement the new competency framework system.

Continuing regulatory reform and the development of the Food Standards Agency’s Regulatory Strategy in partnership with local authorities aim to reduce administrative burdens on businesses whilst ensuring that the agencies continue to provide effective regulatory interventions that are focussed on outcomes rather than inputs.

3.1 Food Premise Interventions

Traditionally, all food premises have been subject to food safety and food standards inspections, the frequency determined by risk rating schemes. Although the risk rating schemes remain intact and food premises continue to receive visits based on the level of risk, as an alternative to conventional inspections, on occasions, other interventions will be employed when securing compliance with food legislation:

These interventions include :-

Official controls such as : Inspections and Audits;Sampling;Monitoring;Verification;

Non-official controls such as ; Advice;Coaching;Education/training;

High -risk food premises (A’s, B’s and non compliant C’s) will continue to receive programmed food hygiene inspections or audits. Broadly complainant C rated premises, these are the premises that have been awarded a score of 10 or less 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 by an Alternative Enforcement Strategy that involves completion of a questionnaire and visits where necessary.

12

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.

Following an intervention and the calculation of an intervention rating a Food Hygiene Rating Score will, in the majority of cases, be awarded to the food premises. 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. Currently it is not a mandatory requirement to display these scores however this is currently being reviewed and this status may change. If this does occur it is anticipated that there will be a higher demand upon the Service to undertake revisits to premises for the purposes of re rating. In summary for food safety interventions, the following are required in 2015/16;

A rated premises 9

B rated premises 113

Total high risk 122

C rated premises 244

D rated premises 397

E rated premises 140

Total low risk 781

Unrated premises 57

These unrated premises are food operations that have been added to the premise database but have not yet received a programmed inspection. They consist of low risk businesses such as garage forecourts and post offices and some higher risk businesses that have changed ownership and are awaiting a first inspection.

Approved Premises approved under EC Regulation 853/2004 5

(Manufacturers of foods comprised of products of animal origin. These premises require a health mark)

Premises registered under EC Regulation 852/2004 1437

(All food businesses requiring food safety enforcement within St Helens, including approved premises)

Of the total number of registered premises, 907 have been “tagged” on the database as requiring an inspection or alternative intervention during 2015/16. The service is committed to completing 96% food safety inspections of A and B rated premises. It

13

also aims to complete 80% of C and 75% of 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. The predicted shortfall described above equates to 49 C rated and 100 D rated premises. In order to complete such work, it has been determined that an additional fully qualified post would need to be provided within the Food Safety team.

Since 2011, food standards inspections have been scheduled only to all premises rated as “A” on the FSA risk rating scheme, and those rated “B” which manufacture or process food, the remainder of food standards work being intelligence led and delivered through a range of targeted projects, which have included targeted inspections.

During 2015/16, we will continue with this approach, but will also reintroduce routine inspection of certain premises types. Business sectors have been selected 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 and the use of false nutritional and health claims. The intention is to address any issues identified and to gather intelligence which will influence future work.

3.2 Complaints

It is the policy of the service that all complaints are investigated.

Food Safety and Hygiene complaints and referrals received by the Food Safety Team will be responded to within 2 working days of receipt. Food Standards complaints received by the Food Standards team will be responded to within 1 working day. All complaints will be dealt with in accordance with the services Practice and Procedure notes, which in turn require that complaints should be dealt with having regard to the Food Law Code of Practice and other relevant guidance.

It is difficult to estimate the number of complaints expected during 2015/16. However it would appear that the number of food complaints are beginning to plateau out with 383 food complaints being received during 2014/15.The majority of the food complaints related to food safety, this being 405. During the same period the food standards team investigated 39 consumer complaints relating to the composition and labelling of food.

3.3 Home Authority Principle

A small number of major food businesses have their principal base within the borough and these are offered support by the service, which fully supports both the Home Authority principle and Primary Authority Scheme.

Home Authority relationships exist with:

14

Aimia Foods Ltd Edmund Barton Limited

Soods Fine Foods Westbridge Foods (Haydock) Ltd

Nichols Foods plc The Punch Brew Company (Baroncroft) Ltd

Kapak (Europe) Ltd George Wright Brewery

Cuisine Centre Northwest Hyperformance Nutrition Ltd

The service formed a Primary Authority relationship with Palmer Harvey McLane Ltd in 2014 and this has been further developed to now include food standards within the agreement. A Primary Authority relationship is now operating with a major Liverpool based company, Princes Ltd for food safety and food standards, following an approach by that company to the authority. The services continue to work towards similar relationships with Aimia Foods Ltd, Edmund Barton Ltd and Nichols Foods plc

3.4 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.

The service has built strong links with the local Chamber of Commerce, which has enhanced and improved the level of advice and support that can now be provided to businesses in St Helens. Trading Standards provide advice to new businesses through regular participation in the New Enterprise / Start Up programme at the Chamber. The relationship with that organisation continues to produce requests for advice from fledgling businesses. Upon receipt of Food Registration notifications from new businesses, EHO’s contact the business proprietors and visits are made to advise on the requirements of the Food Hygiene Regulations prior to businesses starting to operate.

3.5 Sampling

Food Hygiene

Food Samples and environmental swabs are taken from food businesses on a regular basis for microbiological examination. There is the potential for certain high- risk foods to support the growth of micro-organisms, which in turn can cause food poisoning. By taking these samples we are seeking to confirm that the standards of food safety management systems within businesses are effective. The aim being to

15

detect contaminated food and to correct any problems with regard to the manufacture, handling or storage of food, before any illness is caused.

The major proportion of the sampling regime to be undertaken in 2015/16 is as part of National and North West Regional Sampling programmes led by Public Health England. Samples will also be taken as part of a St Helens local programme the criteria for selection based on previous poor results and high-risk operations. This year’s local sampling plans include cooked meats and sampling from mobile food traders including ice cream vendors.

A copy of the sampling programme for 2015/16 is in Appendix 5.

Results of samples will be notified to the proprietor of the business. Where results are unsatisfactory an officer will visit to give advice and discuss corrective actions to be taken, and it is likely that further sampling will be carried out.

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

Food Standards

Food standards sampling is planned based upon intelligence received and will take account of the National Sampling Priorities set by the FSA. Priority is given to sampling foods manufactured locally, in addition to responding to complaints and issues identified on inspection or other intervention.

The service will participate in Trading Standards North West (TSNW) sampling initiatives where appropriate. The authority has contracted Lancashire Scientific Services as Public Analyst for the service.

FSS (Food Surveillance System) is utilised to record our sampling activities and to gather intelligence, which assists effective targeting of sampling work.

The 2015/16 sampling programme is provided in Appendix 5.

3.6 Infectious Disease Control

Notifications of food or water borne diseases will be investigated within 2 working days of receipt; they will be dealt with in accordance with the sections’ Procedure and Practice Notes.

All notifications will be visited except for campylobacter notifications which are sent a postal questionnaire together with a general information leaflet. If there are, however, noted clusters of campylobacter notifications, visits will be made to patients in order to determine if a common source of infection can be identified.

16

Following investigations of food or water borne notifications 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.

Average notification numbers for the year would indicate that about 200 notifications will be received in 2015/16.

The team work closely with Public Health England, the infection prevention and control nurses and the public health team on managing outbreaks. The document “Arrangements between Cheshire and Merseyside PHE Centre Health Protection Team and LAs for the investigation of sporadic casers of infectious disease” was produced in March 2014. This document seeks to clarify the responsibilities of various partners in the control of infectious disease and acts as a reference document.

3.7 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 Chief Environmental Health Officer), 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.

Food Hazard warnings may be received by Trading Standards through a variety of routes, such as notifications made by the Food Standards Agency, via TS Interlink and via the Principal Environmental Health Officer for Food Safety. All such warnings will be brought to the attention of the Principal Trading Standards Officer responsible for Food Standards work (or in their absence, the Chief Trading Standards Officer). They will determine the relevant action to be taken, in line with the Food Standards Practice and Procedures and the Food Law Code of Practice. The number of warnings received and the numbers that require significant action vary from year to year. Therefore, it is difficult to predict this demand on the service. There may be a need for the Trading Standards to issue a food hazard warning in respect of food standards matters. If such a warning were to be issued then this would be done in accordance with the Food Standards Practice and Procedures and in line with the relevant section of the Food Law Code of Practice.

3.8 Liaison with Other Organisations

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

17

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.

The authority 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 Environmental Health colleagues, the Public Analysts and FSA. The group is represented at the Food Leads Meeting coordinated in the region by the FSA. The service works closely with colleagues in Environmental Health responsible for food safety enforcement.

3.9 Promotion

Training

The Service will continue to deliver the following food related training courses throughout 2015/16 to the business sector and to community groups and council employees:

Chartered Institute of Environmental Health (CIEH) level 2 course, Food Safety in Catering (6 hours)

Food Safety refresher course (3 Hours) Food Safety Awareness (3 hours)

The Service is also registered to deliver the CIEH Allergen Awareness course

Food Safety Coaching

Non-compliant caterers and proprietors of small non-compliant convenience stores, or those businesses that decline, improve and then decline again will be identified and time will be spent with these businesses, providing advice, guidance and support to instil long term behaviour change.

The Food Standards Agency Safer Food Better Business Pack is provided free of charge to all new food business operators and staff explain how to complete and implement the management system.

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.

18

Food Standards Promotion

Trading Standards will promote publicise and raise awareness of food standards issues as and when identified as necessary. This will be done through the issuing of press releases, development of advice literature and through direct communication to traders and consumers as appropriate. Prosecution outcomes of note will be publicised for information. Most of the Food Standards projects to be undertaken are designed to raise awareness of food standards, food labelling and nutrition. These projects are ideal vehicles for promoting the service, consumer and business education being integral to the success of the project.

3.10 Community and Business Health Promotion

This work is undertaken in partnership with the Council’s Public Health Division and the Health Improvement Team. From March 2015, Public Health are funding for two years the Community and Business Health Promotion Officer’s post. This will enable all of the businesses to gain from good health advice.

The key role of this post is to deliver initiatives linked to the Council’s Health Weight Strategy (2014-17). The “Chip Fryer” award is to be further promoted and following this further work with hot food takeaways is to be undertaken in order to encourage businesses to introduce “healthier” menu options. This initiative has already attracted 19 businesses to make health improvements.

The “Early Years Healthy Food Award” which forms part of the St Helens Council Healthy Early Years Status (HEYS) award which is presented to early years settings is to continue. Recipients of the healthy food award complete a part of the status assessment required for HEYS, which also encompasses physical activity (active play), safety, emotional health and well-being and personal, social and health education. Settings that obtain the Food Award often view this as the starting point for their application for HEYS. Environmental Health are active members of the early years steering group. EHO’s reassess the validity of Healthy Food Awards, if held, each time a setting is inspected for the purposes of food safety. Settings must obtain at least a Food Hygiene Rating of 3 in order to either apply for or maintain a Healthy Food Award. At present all 40 Early Year Settings have received an Award for improvements made. It is envisaged that in order to promote the “healthy eating” message within the community a further HEYS style award will be developed in partnership with the other stakeholders that will recognise the work done by child-minders.

19

3.11 Food Information for Consumers – Allergens

From 13 December 2014, all food businesses must declare any of 14 identified allergenic ingredients which are used in non- prepacked or loose foods that are sold or provided. The Service ensures that at the time a business is notified of its Food Hygiene Rating Score, information relating to how the business can comply with this requirement is also sent out and businesses are signposted to the relevant Food Standards Agency resources.

3.12 Food Safety Week

Each year the Food Standards Agency co-ordinates a Food Safety Week. This year it will run from 18-24 May and is “The 2015 Chicken Challenge”. The aim is to cut campylobacter food poisoning by half by the end of 2015. Members of the public are to be asked to promise to:

Bag and store raw chicken separately from other food, covered and chilled on the bottom shelf of the fridge

Not wash raw chicken as it splashes germs Wash everything that’s touched raw chicken in soap and hot water – your hands

and utensils Check chicken is cooked properly- no pink meat, steaming hot and the juices run

clear.

During the week visits will be made to children’s centres, community group meetings, butchers shops and other venues where the “Chicken Challenge” messages will be promoted. Members of the public will also be encouraged to sign the “pledge” through social media .

3.13 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, which may indicate a failure in cleaning systems.

The Service is committed to utilising the ATP unit in any survey which may be directed by the Food Standards Agency.

3.14 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.

20

3.15 Crucial Crew

The Service is committed to delivering, together with partner agencies the Crucial Crew initiative which is aimed at all year 5 children who attend schools within the borough.

Crucial Crew is a fun way in which children’s safety awareness is enhanced as they take part in interactive scenarios. For 2015/16 the event is to be hosted by Saints RLFC.

3.16 Smokefree

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.

3.17 Food Standards Sampling

The authority has participated in a bid made by the TSNW regional group for FSA funding for 2015/16 linked with the Coordinated Risk Based Food Sampling Programme delivered by the FSA. The outcome of that bid is not yet known, however the funded sampling will form the core of the sampling work for the year.

3.18 Retail Inspection

In addition to the inspection of the high risk (A rated) and manufacturing premises, we intend to complete routine inspections of retail premises. The inspections will be intelligence led and will focus on particular trade sectors and perceived issues. The intention is not only to assess compliance but to gather information relating trading practices and from the businesses on issues they may have noted, which will be used to direct future work. This work will include butchers, bakers, greengrocers, general / discount stores and licensed premises.

3.19 Food Information Regulations – Implementation

The food standards team will continue to provide advice and support to local food businesses to assist them in complying with the changes in labelling requirements, particularly the requirement to provide nutritional information on all pre packed foods, due for implementation in 2016. The team will continue to work alongside the food safety officers in providing advice to businesses on the provision of allergen

21

information. This advisory work will be further supported with sampling activities to check for compliance.

3.20 Caffeinated and Sugary Drinks

Trading Standards are working with Public Health partners, via a Schools Nutrition Action Group (SNAG) to reduce the consumption of sugary, caffeinated energy and sports drinks by school age children, as consumption is thought to be linked with behavioural issues, poor attainment, obesity and dental health. This work will include provision of information to retailers to encourage the voluntary regulation of the sale of these products, in additional to supporting delivery of advice and guidance to young people, parents and schools.

4.0 Resources

4.1 Financial Allocation

For 2015/16 the Environmental Health and Trading Standards Services have an overall estimated net budget of £1,494 538 and employ 37.5 Full Time Equivalent staff.

Food Standards

Employment Costs £24,902Supplies, Services &Transport £2,270Recharges & Premises £5,310LESS Income £0

Cost of Food Standards £32,482

Food Safety

Employment Costs £281,573Supplies, Services & Transport £33,188Recharges & Premises £53,015LESS Income -£4,563

Cost of Food Safety £363,213

Food Safety is allocated 24.30% of the overall budget.

Food Standards is allocated 2.17% of the overall budget

22

The Services are responsible for the enforcement of legislation relating to Food Safety, Health & Safety, Consumer Safety, Pollution, Drainage, Housing, Refuse, Weights and Measures, Fair Trading, Trade Descriptions, Prices, Consumer Credit, Consumer Advice, Animal Health & Welfare and Road Traffic. It also provides a Pest Control, Dog Warden services and Health Promotion

Further details of the allocation of resources are in Appendix 6.

4.2 Staffing Allocation

The Commercial Services section is staffed as follows:

Principal EHO Commercial 70% of time6 Senior EHOs 80% of time

Environmental Health Graduate 90% of time Commercial services officer 30% of timeBusiness & Community Health Promotion Officer 100% of time

The Food Standards section is staffed as follows:

1 x Principal TSO 20% time2 x Senior TSO 15% time1x Operational Support Officer 10% time

(The figures stated above for Food Standards are a minimum as the section work flexibly in order to accommodate needs, such as dealing with food hazard situations, when more resources will be made available).

All staff hold suitable qualification and experience for the tasks that they are required to perform. The Principal TSO and Senior TSO’s hold the Diploma in Trading Standards (DTS) and the lead assessor qualification, all 3 are authorised and utilised to inspect A rated premises.

The Operational Support Officer is not food qualified so is not an authorised food officer and only participates in food work in a supporting role.

4.3 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 2015/16.

23

In accordance with the revised Food Law Code of Practice (England), which came into effect on 6 April 2015, 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 EHO during appraisals.

The Council has until the 6 April 2016 to revise the existing competency framework system and implement the new arrangements as deemed necessary.

The training programme is attached at Appendix 7.

5.0 Performance Indicators and Quality Assessment

The Division monitors its performance of the Food Law Enforcement Service Plan at regular intervals. The Chief Environmental Health Officer and Chief Trading Standards Officer monitor performance on a monthly and quarterly basis. In addition, each year performance is compared as part of the service planning process; the Cabinet member endorses the Service plan.

Performance Indicators

Infectious disease investigation response times;Service request response times (food safety complaints)Number of high- risk inspections undertaken (food safety/standards)Number of businesses broadly compliant (food safety);

Quality Assessment

Food Safety

All officers are monitored on a monthly basis to ensure that targets are being met with regard to response times and inspections due. The Principal EHO 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 EHO 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 EHO keeps a record of these visits and any discrepancies discussed with the inspecting officer. Each officer will also peer review

24

a colleague once a year, with shadow visits forming part of the exercise and officers completing a record of reflective learning.

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 every 6 months.

Peer Review

The regional Merseyside and Cheshire Environmental Health Food subgroup will continue to undertake peer review exercises. The 9 local authorities which form this subgroup meet regularly, in order 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.

Food Standards

The Service monitors its performance of the Food 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 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 Officer monitors work recording and follow up actions taken on a regular basis and may on occasion accompany food 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.

Throughout the Division.

The Environmental Health service and the Trading Standards service produce annual service plans and a joint food service plan, which are approved by the authority.

Both services produce a half yearly monitoring report for the authority based on performance against the targets set in the service plans.

25

6.0 Review of Activity in Food Standards 2014/15

During the course of 2014/15, the Food Standards Team managed to achieve all the targets set for the year. Fundamental to completing this particular outcome was the efficient planning and monitoring undertaken during the course of the year.

Staff

The team of a Principal Trading Standards Officer and two Senior Trading Standards Officers continued to work as generic officers, covering the full range of trading standards legislation in their work, in addition to food standards inspections, complaints, investigations and projects.

Staff DevelopmentAll food standards authorised food officers received the minimum of 10 hours CPD training required under the Food Law Code of Practice, the majority of which was provided free of charge via the FSA. Subjects covered by this training included: Food Information Regulations (FIR’s) (general provisions), allergen specific requirements under the FIR’s and use of Improvement Notices.

Other officers within the wider Trading Standards team attended food standards related training, including the FSA Food Standards Update and Evidence Gathering / Investigation Skills training.

7.0 Review of Service Delivery in Food Standards 2014/15

7.1 Programmed Premises Interventions

The Food Standards Team achieved all of their programmed inspections of High Risk (A rated) premises and were able to work with these businesses on particular issues throughout the year. All Medium Risk (B rated) food manufacturers and packers were also subject to a focused inspection or other intervention. In particular officers provided advice and support in relation to the changes the businesses needed to make to their food labelling, so as to meet the requirements of the newly implemented Food Information Regulations.

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. Through this approach approximately 100 interventions were completed, 50% of which included a primary inspection. Early interventions were made to remove problems and special focus was applied to the few non-compliant businesses in the area, encouraging them to take corrective actions within short timescales.

26

Project work was completed during the summer, timed to coincide with the FIFA World Cup and other sporting events, looking at food fraud in relation to spirit drinks offered for sale in local public houses. The work was combined with a check on the measure of beer served. Visits were targeted to premises identified through intelligence and local knowledge as the most likely to adulterate or sell illicit spirits, with 25 premises being visited. Approximately 60 spirit drinks were tested. No issues were found with the spirit drinks, but around 15% of the beer served was not a full “pint” and so warning letters were issued to the none compliant businesses.

7.2 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.

Following a seizure of counterfeit vodka, some of which was unfit for human consumption and mis-described whisky in 2012, the service secured the conviction of the owner of a local public house and its manager. The case was heard at Liverpool Crown Court in August 2014, with the defendants being convicted in relation to offences under the Food Safety Act 1990, and the Trade Marks Act 1994. The elderly owner of the public house received a 2 year conditional discharge, whilst the manager received a 9 month custodial sentence. Recently, the service has been successful with an action under the Proceeds of Crime Act against the same individuals, with a total of £88 000 being confiscated from them. This prosecution was partly funded through the FSA Fighting Fund (£13,000).

7.3 Food Complaints

33 food standards complaints were investigated and appropriate action taken. The majority of complaints related to the sale of food after the marked “Best Before” date and the sale of individual packs split form multipacks by local convenience stores. These complaints were dealt with through trader education.

There were also a number of complaints relating to the alleged sale of counterfeit and illicit alcohol, mainly from local stores.

7.4 FSA Food Sampling

The service was pleased to obtain funding from the FSA for food sampling through a TSNW regional bid, which allowed us to take a total of 55 food standards samples.

Through this sampling the following issues were identifed:

27

50% of samples taken from Indian Takeaway premises contained peanut, which was not declared as an allergen. This issue is being dealt with through the provision of advice to the businesses and a check will be made through further sampling.The use of non-permitted (Southampton) colours in Chinese Takeaway meals. This problem seems to arise through the use of bought in flavour and spice mixes, which contain the non-permitted colours, which can be used in certain food types, but not takeaway meals. Advice will be provided to the businesses on the use of such bought in flavour mixes and further samples will be taken to ascertain whether the advice has been effective.

The presence of more added water being in chicken breast products than was declared on the label was identified as an issue at a local manufacturing business. The service is now working with the FSA to address this problem.

The undeclared irradiation of imported chilli powders, which has been brought to the attention of the Home / Primary Authority for the importer concerned.

A variety of non-permitted nutrition and health claims being made in relation to a wide range of body building and work out / fitness products. Some of the products concerned are produced by a local business, and appear on their website, rather than the product itself. We are providing detailed advice to the packer with a view to the offending claims being removed. The majority of false claims have been brought to the attention of the Home/ Primary Authority for the manufacturer or importer of the food supplements, so that they may in turn take appropriate action.

7.5 Variation from the Service Plan 2014/2015

There was no variation from the planned work during 2014/15.

8.0 Review of Activity in Food Safety 2014/15

Following the merging of the Health and Safety Specialist team with the Food Safety Specialist team to form the Commercial Services team in January 2013, further temporary changes to the team were seen in 2014. A Senior EHO was seconded to the Environmental Protection Team in June 2014 for 12 months and the Environmental Health Graduate took maternity leave from August 2014.These changes caused a revision of roles and responsibilities within the Team, with all Senior Inspectors being given a food safety responsibility for inspecting identified food premises. In order to maintain a sampling programme, inspectors were also encouraged to undertake food and environmental sampling during inspection visits.

Broad Compliance

The base line figure for businesses being broadly compliant with food safety legislation has risen from 77% in 2009/10 to 88% in 2014/15. This improvement in

28

compliance measures an output from the activities of the food safety team in comparison with the inputs, such as the number of inspections. It demonstrates that the work of the team has been effective and that the work has been focussed on priority areas.

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 for each premises. A zero score indicates failure to comply with the legislative requirements and a score of 5 demonstrates a very good compliance. A score of 3 is deemed to be the accepted legal standard.

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

In St Helens the profile of businesses replicates the national picture with 39% businesses obtaining a score of 5, 27% a score of 4 and 22% a score of 3. 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 application of the Safer Food, Better Businesses management 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.

In March 2014 all officers responsible for food safety inspections attended a “Consistency of Risk Rating” half day course provided by Environmental Health Cheshire and Merseyside, Food Sub group. This aim being to lead to consistency in the awarding of scores to businesses across Merseyside and Cheshire.

In July 2014 the Service took part in the pilot FSA inter authority audit which aimed to support the consistent implementation and operation of the FHRS in accordance with the “Brand Standard” guidance both within local authorities and between and across local authority area. The 9 authorities in the region took part in this exercise.

Audits were conducted over 1.5 days and consisted of:

29

Pre-visit questionnaire File checks Data base checks Reality check visit Officer interviews Procedure checks

The audit demonstrated that the Service was meeting the general requirements of the Brand Standard.

Staff

The six 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 Environmental Health Graduate continues to support the EHO’s in terms of sampling, investigation of food complaints and infectious disease investigations. This officer also contributes to the food safety and nutrition training programme, food safety promotional work and the Crucial Crew event, which promotes children’s safety messages to all year 5 children who attend schools in the borough.

The Community and Business Health Promotions Officer is responsible for developing programmes 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 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.

Staff Development 2014/15

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:

Intervention Risk Rating – Consistency Enforcement Sanctions HACCP

30

Use of sous vide in food establishments Ethnic Minorities Public Health England – sampling Food Information Regulations/Consumers – Allergens Food Allergens – online training FSA TB in animals Food labelling – e learning Vac Packing

9.0 Review of Service Delivery 2014/15 – Food Safety

9.1 Food Premises Interventions

The following number of interventions including inspections were carried out during the year:

High risk (A,B rated) 123 Low risk (C,D,E rated) 566

All scheduled inspections to high risk premises were undertaken. (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 focussed on the high risk premises such as caterers of high risk foods where the full suite of interventions can 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.

9.2 Formal Action

Five voluntary closures were accepted. These ranged from premises that ceased trading for a matter of a few hours whilst their water supply was reconnected to a premises that was closed for a week following the discovery of a heavy mouse infestation..

A total of 19 Hygiene Improvement Notices were served on 8 different food business operators and all were complied with, without the need for further enforcement action.

9.3 Food Complaints

383 food complaints were investigated and appropriate action taken within the two day response time. This was a decrease of 69 complaints from the 452 received in 2013/14.

31

9.4 Primary Authority Partnership

The Better Regulation Delivery Office’s Primary Authority Partnership Scheme is seen as a gateway to simpler, more successful local regulation. The scheme which is established under the Regulatory Enforcement and Sanctions Act 2008, gives businesses the right to form a statutory partnership with a single local authority. This authority then provides robust and reliable advice for other councils to take into account when carrying out inspections or dealing with non- compliance.

The Commercial Services Team now have partnerships with Palmer & Harvey McLane Ltd. This Company is the UK’s largest wholesale distributor, supplying ambient, grocery, chilled and frozen foods, health and home products to a diverse range of retail outlets, including supermarkets, multiple forecourts and convenience store operators. This partnership covers both food safety and health and safety regulatory work. The Team are also partners with Princes 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 a Princes branded or own branded product produced by Princes.

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 a recognition of the professionalism and quality of the Council’s front line environmental health staff.

9.5 Food Sampling

A total of 108 samples were taken throughout the year as part of national, regional and local surveys. Of these 55 were food and water samples and 53 were swabs of equipment, food surfaces and cloths. Local sampling concentrated on mobile food businesses such as ice cream units and the Service also undertook to utilise sampling during the inspection of 0,1,2 and 3 rated food premises as per the regional sampling plan.

6 ice cream vendors were sampled with a total of 26 samples of food and swabs being taken. Results indicated that 21 samples were satisfactory, 2 were borderline and 3 were unsatisfactory. A total of 6 premises were sampled with 48 samples being taken. These results showed that 39 samples were satisfactory, 4 were borderline and 5 were unsatisfactory. No results were found to be hazardous.

All borderline and unsatisfactory sampling 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.

32

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. In the case of regional initiatives reviews are undertaken by the Environmental Health Cheshire and Merseyside Food Safety subgroup.

9.6 Infectious Disease

180 infectious diseases were investigated and appropriate action was taken in all cases. This is in response to the statutory responsibilities and in liaison with Public Health England. The Environmental Health Service has a responsibility to inform Public Health where outbreaks are clustered.

9.7 Food Standard Agency Food Alerts & Food Incidents

Food alerts were received throughout the year and responded to accordingly.

9.8 Promotion - Delivery of Training

The following training courses were delivered:

CIEH - Level 2 Food Safety in Catering (6 hours accredited course) x 1 Food Safety Refresher (2 hour course) x 1 Food Safety Awareness (3 hour course) x 5

9.9 Early Years Healthy Food Award (HEYS)

In total, 40 settings now have the HEYS award of which the Early Years Food Award forms part. In March 2015, a celebratory event was held at the Town Hall hosted by the partners for the new award holders. Settings must have at least a Food Hygiene Rating of 3 in order to be eligible to be considered for this award. An assessment is then made as to the setting’s compliance in respect to:

Drinks that are provided for children How individual dietary needs are accommodated How parents/carers are involved in menu planning The provision of a balanced diet Principles of food preparation

9.10 Community and Business Health Promotion

The Health Survey for England indicated that two thirds of men and half of women in St Helens are overweight. It is also a concern that the proportion of children who are

33

obese almost doubles from 12% at reception to 22% in year 6, higher than the national average.

For these reasons obesity and excess weight have become one of the eight priorities within the St Helens Health and Wellbeing Strategy 2013-16. In January 2014, Public Health undertook to fund a six week project which aimed to review and improve upon the fat content of takeaway foods. This project focussed on the use of oils in takeaways and in particular the frying of chips.

In St Helens there are 72 takeaway shops that have traditional range fryers. A survey was undertaken of 30% of these businesses. Questions were asked to determine the type of oil being used, how often oil is changed, whether the oil was filtered, what temperature chips were fried at and if other foods were cooked in the same oil. It was established from the survey that there was a trend in low cooking temperatures of 150 as opposed to a recommended minimum temperature of 175. This in effect means that chips would contain more saturated fat as the chips are in the oil for longer periods of time and therefore more oil is absorbed. It was agreed that businesses needed to be encouraged to increase the cooking temperature for chips.Initial results from the project suggest that there could be up to 24% reduction in the saturated content of chips fried at 175 in oil that is well maintained. This base data was used to formulate the project and based on the Food Standard’s Agency “Top Tips for Chips”, St Helens launched the “Chip Fryer Awards”. These gold and platinum awards recognised the good practices being employed by businesses in respect to the frying of chips. Businesses that reviewed their frying practices, and with a Food Hygiene rating of 3 or more were, upon receipt of an application and following a verification visit, awarded the Gold Award. For those businesses that went further in respect to filtering their oil, using test strips to determine when oil needed to be changed dependent upon its rate of deterioration and the use of five holed salt shakers were awarded the Platinum Award. A total of 18 businesses were awarded a Chip Fryer Award.

Following the success of this project Public Health commissioned further work from the Service. It was agreed that a new post be funded for 2 years with effect from March 2015. The aims of the new post will be 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.

The Chip Fryer Award is to be further promoted and work will be undertaken in partnership with the Council’s Healthy Living Team in delivering and expanding compliance of the Healthy Early Years Status, in particular developing an Early Years Food Award that is appropriate for child-minders.

9.11 Food Safety Week 2014

The theme for food safety week was “Don’t Wash Your Chicken””. This Food Standards Agency initiative took place between 16- 22 June. Visits were made to

34

community groups and a market stall was used to promote the message of how to safely handle and cook chicken within the home. The aim of the campaign is to reduce the incidence of campylobacter food poisonings and forms part of the FSA strategy ACT (acting on campylobacter together).

9.12 Variation from the Service Plan 2013/14

There were no variations from the plan.

35

36

APPENDIX 1

LINKS TO THE ST HELENS PLAN 2013-16

Vision for St Helens

“To make St. Helens a modern, distinctive, economically prosperous and vibrant Borough”

The Plan outlines 3 areas they want to achieve;

Improving People’s LivesWe want people to be:

Healthy and activeSkilled and educatedIndependent and Empowered

Creating a Better PlaceWe want St Helens to be:A safer and Stronger PlaceA Cleaner, Greener and Accessible PlaceA Thriving, Vibrant & Competitive Place

Delivering Effectively TogetherWe want all partners to:Share the same principles and valuesConsult, engage & empower our communitiesBe open, accessible & transparentBe successful

‘Healthy and Active’

Food Services proactively visit premises, investigate complaints and incidents to ensure local businesses comply with legislation and thereby maintain safe food, products and workplaces.

Infectious disease control investigates notifications from GP’s and hospitals of any food poisoning. Investigations control the spread, ensure businesses comply with the law and provide advice to residents of safe food preparation in the home.

Underage tobacco and alcohol sales work and child safety within the ‘Crucial Crew’ project also contribute to the health agenda.

Environmental Health Officers and Trading Standards Officers are in a unique position as they visit all food businesses and hence have an influence on food provision and use these

37

opportunities to enforce, promote, advise, educate and inform with regard to food law and nutritional messages.

Focal points for action within the plan are to tackle inequalities in health and to reduce obesity. Specific project work to support the points are;

nutritional improvements in caterers and hot food takeaways, food safety and nutrition training

Two of the seven key measures of success for ‘Healthy and active’ relate to the Percentage of obese school children in reception year and the number of smoking quitters per thousand of the population

The Early Years Healthy Food Award, which focuses on improving nutritional standards within nurseries, crèche and childminders and the work undertaken in respect of enforcing Smoke Free legislation and engaging in the work of the St HelensTobacco Control Group directly contribute to these key performance measures.

‘Skilled and Educated’

Food Services aim to work with local food businesses through the provision of training and coaching. It is also proposed to undertake an evaluation of how the level 2 training courses delivered could be better focussed on young people, who are NEET (not in education, employment or training).

This latter project directly contributes to the key measure of success aimed at Reducing the Percentage of 16 – 18 year old, who are NEET.

‘Independent and empowered’

The Crucial Crew project supports one of the areas for improvement identified, ‘ensuring that children and vulnerable adults are safe from harm’. The food service leads this project which engages with 2000 school children including those with special educational needs, promoting safety messages.

‘A Cleaner, Greener and Accessible Place’

As part of the food safety work undertaken by officers, effective management of waste in food businesses is a core consideration. In fulfilling the planned inspection programme officers will therefore be contributing directly to improving environmental cleanliness.

‘A Thriving, Vibrant & Competitive Place’

The work helps the changing local food economy to remain vibrant and enables the council to provide practical support to businesses. Compliance with legislation helps fair competition and we offer support for new companies. All aspect of the work undertaken support

38

businesses in order to ensure that healthy, competitive and successful food businesses proliferate within the borough.

Delivering Effectively TogetherWe want all partners to:Share the same principles and valuesConsult, engage & empower our communitiesBe open, accessible & transparentBe successful

Considerable partnership working exists with the following agencies for example;

Public Health England, Food Standards Agency, NHS Merseyside, St Helens Clinical Commissioning Group, Merseyside Police, Bridgewater Community Healthcare Trust, HM Customs and Revenue, Merseyside Fire and Rescue Service, Regional, neighbouring local authorities,

39

APPENDIX 2

SERVICE PLAN PROGRAMME 2015/16

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.

40

APPENDIX 3

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

41

Director of Environmental Protection

Assistant DirectorEnvironmental & Civic

Pride Services

Chief EnvironmentalHealth Officer

Chief Trading Standards Officer

Environmental Protection DepartmentManagement Team

42

Assistant DirectorEngineering & Civils

Business SupportManager

Environmental Protection Department Environmental Health

43

Chief Environmental HealthOfficer

Director of Environmental Protection

Principal EHOCommercial Services

Principal EHOEnvironmental Control

6 x Senior EHO(Commercial

Services)

Commercial Services Officer

Environmental Health Graduate

3 x Environmental

Control Officers

3 x Scientific OfficerAir Quality,

Contaminated Land, Noise

Senior and Dog Welfare &

Enforcement Officer

4 x Environmental

Wardens

Dog Welfare & Enforcement

Officer

Dog Welfare & Support Officer

Community & Business

Health Promotions Officer

Environmental Protection DepartmentTrading Standards

44

Chief Trading Standards Officer

Principal Trading Standards Officer

Principal Trading Standards Officer Admin Officer

2 x Consumer Protection Officers

Senior Trading Standards Officer

0.5 x Fair Trading Officers

Operational Support Assistant

Senior Trading Standards Officer

Senior Consumer Protection Officer

2 x Clerical Officers

Director of Environmental Protection

APPENDIX 4

FOOD STANDARDS & FOOD HYGIENE

Food Standards – Premise / Works Profile 2015/16

Code Establishments High Risk

MediumRisk

Low Risk

No Risk

Total food businesses

A Producers 0 7 33 0 40

B Slaughterhouses 0 0 0 0 0

C& D Manufacturers & Packers 7 12 0 0 19

E Importers / Exporters 0 2 0 0 2

F Distributors 0 5 18 0 23

G Retailers 2 234 237 0 473

H Restaurants & caterers

0 245 790 0 1035

I

Materials & Articles

Manufacturers & suppliers

0 1 1 0 2

J

Manufacturers, sale mainly by

retail0 0 2 0 2

Unspecified 0 0 0 0 0

Total food businesses 9 506 1081 0 1596

InspectionFrequency

Every year

Every 2 years

Every 5 years

Target due an intervention in

2014/159 *472 *852 0 *1333

* Please see comments Section 3.1 in relation to our approach to targeted interventions

45

Food Hygiene – Premise / Work Profile 2015/16

Code Establishments A B C D E Total

101 Manufacturers and Packers

1 3 6 4 1 15

103Distributors/Transporters

0 0 0 3 4 7

105Supermarket/Hypermarket

0 0 2 18 6 26

106Smaller retailers

0 7 38 92 25 162

107Retailer – other

0 0 2 9 4 15

109Restaurants/café/canteen

2 7 51 57 1 118

110Hotel/Guest House

0 0 1 2 0 3

111Pub/Club

0 4 32 68 21 125

112Takeaway

6 24 56 22 0 108

113Catering establishments

0 55 16 20 38 129

114School/College

0 9 12 41 1 63

115Mobile food unit

0 1 9 20 11 41

116 Restaurants and caterers -other 0 3 19 41 28 91

Total due an

intervention in 2014/15

9 113 244 397 140 903

InspectionFrequency

6months

12 months

18 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.

46

APPENDIX 5

FOOD STANDARDS TEAM -SAMPLING PROGRAMME FOR 2015/2016

As one objective for the Food Standards Team is to react to local events, issues and projects as they arise, locally and nationally, so as to be as effective as possible, sample numbers are not specified in the Service Plan. The sampling budget for 2015/16 is £10 000, but we will make use funding opportunities, wherever possible, so as to extend our budget. It is anticipated that the numbers sampled taken will be approximately:

30 Formal Samples

50 Informal Samples

These will include:

Samples connected to a consumer complaint

Samples of products produced by businesses for which we are the Home Authority

Samples taken from factories during routine inspections

Samples following a formal food hazard warning

Samples to obtain data for use in connection with business and consumer education

Samples taken as part of a local, regional or national programme

Priority will be given to sampling food produced by local traders and in areas where a problem has been identified by the team or nationally.

The team will also undertake a number of food labelling checks of product from High Risk / Manufacturing Premises and as part of the identified ‘in-house’ sampling for identification of the need for officers to provide advice and guidance to business about labelling issues. Similarly in house testing of spirits utilising will continue to be a part of our routine work, as well checks on the labelling and traceability of products.

47

FOOD SAFETY TEAM -SAMPLING PROGRAMME FOR 2015/2016

North West Regional, (Cumbria, Merseyside, Lancashire, Greater Manchester) Sampling Surveys (Organised by PHE):

May 2015

Microbiological study of prepacked ready to eat chicken for use in sandwiches and/or catering.

Environmental samples of premises handling raw and ready to eat chicken MRSA in meat products Unpasteurised milk for direct consumption sampled at point of sale Salads from takeaways and self-serve counters

Other regional sampling programmes have not yet been confirmed.

St Helens Environmental Health local surveys throughout the year:

Ready to eat foods from Approved Premises Cooked meats Mobile caterers food and swabs Sampling in 0,1,2 and 3 rated premises

Other samples will be taken as necessary, following complaints or other incidents.

All sampling is funded and analysis undertaken by the Public Health England, Preston Laboratory, using a regional credit system.

48

APPENDIX 6

FOOD STANDARDS TEAM - ESTIMATION OF RESOURCES FOR 2015/16

To achieve the inspection as shown in appendix 4, each officer will work to individual targets, which will reflect the officers’ skills and experience/qualification. Individual targets will also take into account the workload of officers in other Trading Standards areas, such as Safety, Metrology and Fair Trading, as the same officers enforce these areas of legislation.

The average workload, at current staffing levels, would be:

3 High Risk Inspections236 Medium risk Inspections/ interventions426 Low Risk Inspections16 Consumer Complaints8 Requests for business advice3 Home Authority referrals40 Formal/Informal Samples

We intend to continue to nurture good relationships with our businesses, to be able to provide advice and prevent problems before they occur, reducing the need for time and resource consuming enforcement actions.

49

COMMERCIAL SERVICES TEAM - ESTIMATION OF RESOURCES FOR 2015/2016

To achieve the inspection plan as shown in Appendix 4, each inspector will work to individual targets amongst the team the following is an estimate of the anticipated workload:

116 High Risk Inspections (A-B) (A’s inspected twice a year)

451 Low Risk Inspections (C-E)

380 Food Complaints

165 Infectious Disease Investigations

400 Revisits

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

50

APPENDIX 7

TRAINING PROGRAMME 2015/16

All officers will receive training so as to enable them to comply with the requirements of the Code of Practice, which states that a minimum of 20 hours CPD type training will be given to all food safety officers and food standards officers each year.

Food Safety Officers

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 SessionsSous Vide TrainingPublic Health England –sampling workshopA regional best practice dayFood Information Regulations Other update courses as they become available throughout the year.

Briefings 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.

Food Standards Officers

All authorised food standards officers will receive the 20 hours CPD required by the Food Law Code of Practice. The service will take advantage of the low cost training offered by the FSA and the TSNW Food Standards Group. It is anticipated that this training will cover current issues in food standards and labelling, imported food, nutrition and health claims and legal processes.

Two Senior Consumer Protection officers within the Trading Standards Section will also be working towards the DCATS Food Standards module, and it is hoped they will be able to participate in food standards work by the end of the year.

51

APPENDIX 8

FEED SERVICE PLAN 2015/16

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 Departmental, Divisional and Action Plans detailed in Appendix 2.

1.0 FEED SERVICE AIMS AND OBJECTIVES

1.1 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.

To reduce the use of and impact of antibiotics in the food chain.

1.2 Links to Corporate Objectives and Plans

The Council approves the Feed Service Plan. The Cabinet Member holding the Portfolio for Environment and 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 Appendix 1 and Service Plans in Appendix 2.

2.0 BACKGROUND

2.1 Profile of the Local Authority

52

A profile of the authority is provided at Section 2.1St Helens contains a small number of rural communities around the outskirts of the borough where farming is the principal occupation. There are also small holdings and hobby farms handling animal feed.

2.2 Organisational Structure

The Feed Service is provided by the Trading Standards Service, the organisational structure of which is shown in Appendix 3.

2.3 Scope of the Feed ServiceTo 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.

2.4(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 1

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

18

R8 Transporting of feed and feed products 4

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

14

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

1

R13 Livestock Farm 23

R14 Arable Farm 48

TOTAL 109

53

In general the feed businesses based in the area pose a low to medium risk and all premises are rated as either “satisfactory” (3%) or “broadly compliant” (97%) under the NTSB risk rating scheme. Only 26% 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, and the food businesses disposing of waste food and co products (R7 and R12) into the feed supply chain, with varying control measures in place.

2.4(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 6765842 or by email to tradingstandards@sthelens.gov.uk.

2.5 Regulation Policy

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

3.0 SERVICE DELIVERY

3.1(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.

3.1(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;

54

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 2015/16:

4 x R7 – Food business disposing of surplus food

1 x R10/11 – On farm mixers of feed

1 x R12 – Food manufacturer supplying co products

5 x R13 – Livestock farm

16 x R14 – Arable Farm

A number of the inspections will be funded by NTSB via a regional funding bid. The level of inspection detailed above and the associated work can be met with the resources available. Feed Officers are qualified and maintain competency as per the requirements of the Feed Law Enforcement Code of Practice for Level 1 and Level 2 activities.

3.2 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.

During 2014/15 no feed or primary production complaints were received by the service. It is anticipated that it is unlikely that there will be any significant rise in complaint levels.

55

3.3 Home Authority and Primary Authority SchemeThe 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 do not currently act as a “Primary Authority” for any feed business, but do have Home Authority relationships with two food businesses that dispose of waste for use as animal feed. The service is working to develop Primary Authority relationships with appropriate food and feed businesses.

3.4 Advice to Business

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

Provision of seminars, displays and talks to businesses

3.5 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 2015/16, however, samples will be programmed should intelligence be received or initiatives be developed by TSNW or the FSA.

3.6 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

3.7 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.

56

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.

3.8 Liaison with Other Organisations

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 AHVLA (Animal Health Veterinary Laboratory Agency), VMD (Veterinary Medicines Directorate) and Port Health. The group is represented on the National Agriculture Panel (NAP). The service liaises with colleagues in Environmental Health responsible for Animal Health enforcement.

3.9 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.

4.0 RESOURCES

4.1 Financial Allocation

The officers engaged in feed service delivery also undertake 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 2015/16 is £4860 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.

4.2 Staffing Allocation

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 2 authorised feed officers, one of which is authorised as Level 2 / Lead Feed Officer. It is estimated that 0.2 FTE officer time is allocated to feed service delivery.

4.3 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 training provided by TSNW and the FSA.

57

5.0 QUALITY ASSESSMENT

5.1 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. The Lead Feed Officer monitors work recording and follow up actions taken on a regular basis and may on occasion accompany feed officers 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.

6.0 REVIEW

6.1 Review against the Service Plan

During 2014/15 the service completed the following inspection visits, all funded through the NTSB / FSA regional funding awarded:

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

1 x R13 – Livestock Farm

1 x R14 - Arable Farm

In addition Alternative Enforcement Sanctions were utilised with the following premises:

2 x R13 - Livestock Farm

2 x R14 Livestock Farm

No significant issues were identified; the main issue found being that record keeping could be improved.

A Feed Incident was identified by the FSA during the year, which related to a feed manufactured elsewhere in the UK, which had been found to be contaminated with a GM (genetically modified) substance. The affected feed had been supplied to a local business, which in turn had supplied it elsewhere. The incident allowed us to identify a feed business operator not previously known to the service. That business is now registered under category R5 (placing on the market compound feeds) with the authority and the incident was brought to a satisfactory conclusion. The business does not pose a significant risk, as they essentially act as a wholesale business, making no change to the feed they handle and the majority is supplied onward to third countries.

58

6.2 Variation from the Service Plan

There was no variation from the planned work during 2014/15.

6.3 Areas of Improvement

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

To consider training of an additional officer to a standard sufficient for them to undertake Level 1 feed work.

59