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Places Services

Environmental Health

and

Trading Standards Service

FOOD LAW ENFORCEMENT

SERVICE PLAN

2018-2019

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Foreword

The Food Law Enforcement Plan provides a clear strategy, which ensures that the

Environmental Health and Trading Standards services maintain a risk based approach to

their regulatory role relating to both food and animal feed.

The plan provides members of the public, local businesses and other key stakeholders with

the inspection proposals for the forthcoming year, information regarding special projects,

sampling programmes and training plans. It also reviews the achievements and provides an

indication of the performance of these services over the previous year.

Within the work proposals for this year there remains a commitment to supporting local

businesses in developing their food and feed management controls, as well as, tackling

wider public health issues such as obesity and allergen awareness.

In endorsing this plan St Helens Council recognises that maintaining the safety and quality

of both food and animal feed is fundamental to protecting the health and well-being of both

the local and wider community. The Council is fully committed to supporting it's officers

delivering the inspections, visits and key initiatives contained within the plan.

Councillor Lynn Clarke, Cabinet Member for Better Neighbourhoods

June 2018

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CONTENTS

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Page Number

Introduction 9

Service Aims and Objectives 10

Background 11

Profile of the Local Authority 11

Organisational Structure 12

Health Inequalities 12

Regulation Policy 13

FOOD SAFETY SERVICE PLAN 14

1.1 Introduction 14

1.2 Scope of the Food Service 14

1.3 Demands on the Food Service 15

1.4 Food businesses and the local economy 15

2.0 Service Delivery 15

2.1 Food Premise Interventions 16

2.1 Complaints 18

2.3 Primary Authority 18

2.4 Advice to Business 19

2.5 Sampling 19

2.6 Infectious Disease Control 19

2.7 Food Safety Incidents 20

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2.8 Liaison with other organisations 20

2.9 Promotion 20

2.10 Community & Business Health Promotion 20

2.11 Food Information for Consumer - Allergens 21

2.12 ATP (Adenosine Triphosphate) Monitoring 21

2.13 Mobile Caterers 21

2.14 Smoke Free 22

2.15 Waste Control 22

3.0 Resources 22

3.1 Financial Allocation 22

3.2 Staffing Allocation 23

3.3 Staff Development Plan 23

4.0 Indicators and Quality Assessment 23

4.1 Performance Indicators 23

4.2 Quality Assessment 24

5.0 Review of Activity in Food Safety 2017/18 24

5.1 Broad Compliance 24

5.2 Food Hygiene Rating Scheme (FHRS) 25

5.3 Staff 26

5.4 Staff Development 26

5.5 Food Premises Interventions 26

5.6 Formal Action 27

5.7 Food Complaints 27

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5.8 Primary Authority Partnership 27

5.9 Food Sampling 27

5.10 Infectious Disease Control 28

5.11 Food Standards Agency Food Alerts & Incidents 28

5.12 Community and Business Health Promotion 28

6.0 Variation from the Service Plan 215/16 29

FOOD STANDARDS SERVICE PLAN 30

6.0 Introduction 30

6.1 Scope of the Food Service 30

6.2 Demands on the Food Service 30

7.0 Service Delivery 31

7.1 Service Delivery Points 31

7.2 Identification of Premises with a Food Standards Risk 32

7.3 Inspections /Interventions 32

7.4 Complaints 32

7.5 Primary Authority / Home Authority 32

7.6 Advice to Business 33

7.7 Sampling 33

7.8 Control & Investigation of Outbreaks 34

7.9 Food Standards Incidents 34

7.10 Liaison with other organisations 34

7.11 Promotion 34

8.0 Resources 35

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8.1 Financial Allocation 35

8.2 Staffing Allocation 35

8.3 Staff Development Plan 35

9.0 Quality Assessment 36

9.1 Quality Assessment and Internal Monitoring 36

10.0 Review of Activity in Food Safety 2015/16 36

10.1 Programmed Premises Intervention 36

10.2 Formal Action 36

10.3 Food Complaints 36

10.4 Food Sampling 37

10.5 Primary and Home Authority 37

10.6 Officer Development 37

10.7 Variation from the Service Plan 2017/18 38

10.8 Areas of Improvement 38

FEED SERVICE PLAN 39

11.0 Introduction 39

12.0 Feed Service Aims and Objectives 39

12.1 Aims and Objectives 39

12.2 Links to Corporate Objectives and Plans 39

13.0 Background 40

13.1 Profile of the Local Authority 40

13.2 Organisational Structure 40

13.3 Scope of the Feed Service 40

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13.4(a) Demands on the Feed Service 40

13.4(b) Service Delivery Service Points 41

13.5 Regulation Policy 42

14.0 Service Delivery 42

14.1(a) Feed Premises Registration 42

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

14.2 Feed Complaints 43

14.3 Home and Primary Authority Scheme 43

14.4 Advice to Business 43

14.5 Feed Sampling 44

14.6 Control and Investigation of Outbreaks 44

14.7 Feed Safety Incidents 44

14.8 Liaison with other organisations 44

14.9 Feed Safety Promotional Work 45

15.0 Resources 45

15.1 Financial Allocation 45

15.2 Staffing Allocation 45

15.3 Staff Development Plan 45

16.0 Quality Assessment 45

16.1 Quality Assessment and Internal Monitoring 45

17.0 Review of 2017/18 46

17.1(a) Programmed Premises Intervention 46

17.1(b) Formal Action 46

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17.1(c) Feed Complaints 46

17.1(d) Feed Sampling 47

17.1(e) Officer Development 47

17.2 Variation from the Service Plan 47

17.3 Areas of Improvement 47

Appendix 1 Service Plan Programmed 2018/19 48

Appendix 2 Organisational Structure Charts 49

Appendix 3 Food Safety Work Profiles 53

Appendix 4 Food Safety Estimation of Resources 55

Appendix 5 Food Safety Training Programme 56

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INTRODUCTION

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As part of the Food Standards Agency’s Framework Agreement, Local Authorities are

required to have in place Food Service Plans, which are audited by them. This service plan

sets out how the nationally recognised priorities are addressed and delivered locally and the

means by which these will be achieved. It details the achievements of the Food Service in

2017/18and plans for 2018/19.

During 2017/18, the service undertook around 750 visits to food businesses, for food

standards, feed and food safety. Support provided during these visits is vital to businesses

that face competing pressures in the current financial climate. Officers make sure that food

businesses are aware of their legal obligations and help them ensure that the food they

supply is wholesome and safe.

At the end of 2017/18, the base line figure for businesses being ‘broadly compliant’ with food

safety legislation was 92% 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 has been effective and work continues to be done to target

resources towards the less compliant businesses.

All registered food premises within the borough are rated in accordance with the National Food

Hygiene Rating Scheme. Members of the public can access food hygiene ratings at

www.food.gov.uk/ratings and can see the ratings displayed at businesses.

In 2016 St Helens signed the Declaration on Healthy Weight and in partnership with Public

Health we contribute to the public health agenda with the aim of protecting the residents of St

Helens from unhealthy weight.

https://www.sthelens.gov.uk/public-health-and-wellbeing/campaigns/st-helens-healthy-

weight-alliance/about/

Environmental Health and Trading Standards services are well positioned to engage and

influence food businesses in relation to nutrition and healthier lifestyles. We have done this by

developing the “Chip Fryer” Award, launching the HOST Award (Healthier Options St Helens

Takeaways) and working with childminders offering them the “Childminders Healthy Eating

Award”

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OFFICIAL FOOD AND FEED CONTROLS

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SERVICE AIMS & OBJECTIVES

Aims

The aim of the service is “to offer services which aim to contribute to the wider protection of

the environment and strive to achieve fair and safe trading for the residents of and visitors to

St. Helens”

Objectives

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

ii. To assist consumers in achieving a healthy diet by avoidance of; contaminated,

adulterated or poor quality food.

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

informed choices.

iv. To assist businesses, in particular caterers, to provide healthy catering options to

help their customers to make healthier choices to assist in part to reduce obesity and

heart disease within St Helens.

v. To protect business from economic disadvantage caused by competitors not

complying with Food Safety and Food Standards legislation.

vi. To help business find the most effective way of complying with Food Safety and

Food Standards legislation and to facilitate access to appropriate training.

vii. To work with other local authorities and agencies with common objectives to provide

effective and “joined up” enforcement

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

Links to corporate objectives and plans

The Council approves the Food Law Enforcement Service plan annually. The Cabinet

Member holding the Portfolio for Better Neighbourhoods monitors progress against service

objectives during the year.

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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 effective service. St Helens Plan 2015-18 can we found on the council

website at:

https://www.sthelens.gov.uk/media/3599/sthelens-plan-2015-2018.pdf

BACKGROUND

Profile of the Local Authority

St Helens is one of five local authorities in the Merseyside region and home to 177,612

residents (ONS Mid –year estimate 2015). The Borough covers a total of 135 square

kilometres, of which approximately half is rural and half is urban.

Its proud history is linked with the industrial revolution, coal mining, and a world famous

glass industry, which employed many of the local residents. However, the industrialisation of

the Borough and its subsequent decline from the late 1970s onwards left a legacy of issues

including poor health, long-term inter-generational unemployment, low levels of enterprise

and poor environmental quality of parts of the Borough.

In more recent years St Helens has seen widespread regeneration, with the positive

transformation of many parts of the Borough and the development of new housing, business

premises, transport facilities and green and open spaces.

Yet in some respects St Helens remains a fairly typical northern town. The Borough has an

aging population with growing numbers of vulnerable people requiring support. Poor health

and worklessness remain key issues and there is relatively high deprivation and inequality to

be found in areas of the Borough. Unemployment levels and reliance on benefits are above

regional averages; whilst skill levels although improving remain comparatively low.

Despite these issues, St Helens has many strengths. The Borough enjoys a strategic

position at the heart of the North West and has great potential to increase its economic

growth and competitiveness. Business sectors such as logistics represent a major strength

due to St Helens excellent transport network and connectivity. Self-employment levels have

increased and business survival rates at 5-years are improved. The achievement and

aspirations of our young people are growing, and although still an area of challenge there

are increasing numbers of young people in education, employment or training.

Population

St Helens has an aging population structure similar to England, but with a higher proportion

of people aged 65 years and over and proportionally fewer people of working age (16-64

years). An aging population can lead to an increase in demand and pressure upon the health

and social care services.

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St Helens is ethnically less diverse than many areas, with 96.6% of the population (Census,

2011) identifying themselves as white, compared to 79.8% nationally and 87.1% in the North

West.

Economic Activity

St Helens employment rate is 71.3% (Dec 16), which is some way below the regional and

national averages, 71.6% and 74.3% respectively. Self-employment is 6.3% which remains

at much lower rate than regionally (8.2%) and nationally (9.8%).

Health and wellbeing

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 77.7

years) and for females 81.5 years (Department of Health Neighbourhood Statistics, 2012-

2014). 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 9.8 year difference for males

between the most and least deprived wards and a 3.4 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 recognized 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 2015/16 shows that 27.5% of reception age children (4-5 years) in St Helens are

overweight (including obese), compared to 22.1% nationally. By the time young people have

reached year 6 (age 10-11) the percentage overweight (including obese) has increased to

39.7% compared with 34.2% nationally (Child National Measurement Programme).

Organisational Structure

Organisational structure charts for Environmental Health and Trading Standards are as

attached at Appendix 2.

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

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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.

When working with businesses we encourage them to provide healthy options and actively

highlight these to customers via the Chip Fryer, HOST and Childminders Healthy Eating

Awards. These initiatives are detailed within this Service Plan.

Regulation Policy

We have an enforcement policy, which provides guidance to officers, businesses and the

general public on the range of options that are available to achieve compliance with

legislation enforced by St. Helens Regulatory Services. The policy has been approved by St.

Helens Licensing and Environmental Protection Committee.

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

Production follow.

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FOOD SAFETY SERVICE PLAN 2018/19

1.1 INTRODUCTION

The Food Safety Service Plan sets out how St Helens Council through it’s Environmental

Health Service will fulfil it’s responsibilities under the legislation relating to food safety,

particularly in respect to the inspection of food premises. The structure of the service plan

follows the service planning guidance contained within “The Framework Agreement on

official feed and food controls by Local Authorities” published by the Food Standards

Agency.

1.2 Scope of the Food Service

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

the Food Standards Agency Framework Agreement.

The Environmental Health Section is responsible for:

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

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

businesses.

The Service also:

Samples food produced or sold in the borough;

Provides food hygiene training;

Registers food premises;

Approves food premises under EC Regulations.

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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.

1.3 Demands on the Food Service

Food service work profiles in respect of number and type of food premises in the borough

requiring interventions in 2018/19 for food safety are attached in Appendix 3.

Service delivery is available from the office base at Wesley House, between the hours of

8.45 am and 5.15 pm, during the normal working week. However, food hygiene inspections

may necessitate out of hours visits, due to the nature of trading of relevant businesses and

therefore, enquiries are frequently taken outside of normal business hours. Other out of

hours services are available as circumstances dictate.

1.4 Food businesses and the local economy

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

parts of the economy both nationally and locally. Nationally the food and drink supply chain

accounts for 7% of GDP and employs 3.7 million people in everything from food retailing, to

restaurants and canteens, to farming and fishing. The service sector, including hotels,

distribution and catering remains the largest industry within St Helens.

There have been business closures in St Helens together with a notable increase in food

business turn over resulting in new business registrations. However, the total number of food

businesses registered at the beginning of the 2018/19 business year is 1392 this has fallen

slightly from 1410 in 2016/17.

Our work helps the changing local food economy to remain vibrant and enables the Council

to provide practical support to businesses, particularly important in difficult economic times.

The work of the food service helps maintain public confidence in the standards of our local

food industry.

We work to help businesses comply with food legislation, which helps ensure fair

competition and allow well-run food businesses to flourish and contribute to the local

economy. We offer specific support for new companies, which can prove vital to the longer-

term survival of a business.

SERVICE DELIVERY

The revised Food Law Code of Practice (England) published by the Food Standards

Agency came into force on the 7 April 2015 and was reissued in March 2017. This Code

sets out the requirements that the Council (as the Competent Authority) must adhere to in

the execution and enforcement of the relevant legislation.

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Competent Authorities have statutory duties to enforce legislation relating to food, including

the primary production of food and imported food. The purpose of enforcement is to ensure

compliance with legislation relating to food in each Competent Authority’s area in the UK.

Every Competent Authority must therefore discharge its duty as effectively as possible using

means that are appropriate to the circumstances.

The Food Standards Agency is also currently examining alternative ways in which food

safety and food standards regulation can be delivered, one of the aims being to reduce

regulatory burden on those businesses that are compliant. This programme of change is

known as “Regulating our Future”.

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

2.1 Food Premise Interventions

All food premises are subject to food safety and food standards inspections, the frequency

being determined by risk rating schemes. However dependent on the level of risk other

interventions may be employed when securing compliance with the legislation. The suite of

interventions that may be used are:

Official controls: Inspections

Audits

Sampling visits

Monitoring visits

Verification visits

Surveillance visits

Non-official controls: Advice

Coaching

Education

Information and intelligence gathering

High-risk food premises (A’s, B’s and non-compliant C’s) will continue to receive

programmed food hygiene inspections or audits. Broadly compliant C rated premises, these

are the premises that have been awarded a score of 10 or less 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. 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.

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Of the total 1392 registered premises, 721 have been “tagged” on the database as requiring

an inspection or alternative intervention during 2018/19

In summary for food safety interventions the following are required in 2018/19;

A rated premises 2 (2 x inspections per year)

B rated premises 136 (1x inspection per year)

Total high risk 138

C rated premises 233 (1xinspection per 18 months)

D rated premises 239 (1xinspections per 24 months)

E rated premises 68

Total low risk 540

Unrated premises 43

(E rated premises do not form part of the inspection programme as they are by their nature

deemed to be low risk premises and unrated premises have registered with the authority and

are awaiting inspected their first inspection prior to opening following which an intervention

rating is awarded)

There are also a number of food premises which are registered and approved under EC

Regulation 853/2004 by the authority. These premises handle/process /produce products of

animal origin and are subject to a stringent set of criteria they are also required to have a

health mark. These business do not receive a food hygiene rating score, (FHRS)

Total Approved Premises registered under EC Regulation 852/2004 7

With the staff available, the service is committed to completing a minimum of 96% food

safety inspections of A and B rated premises. It also aims to complete at least 80% of C and

D rated premises interventions. In respect of the C and D rated premises, which do not

receive their programmed interventions, this work will be carried forward and completed

during the following year. In the worst case scenario, this shortfall equates to 47 “C” rated

and 48 “D” rated premises, which will not receive inspections or interventions in accordance

with statutory guidance.

Following an inspection and the calculation of an intervention rating a Food Hygiene Rating

Score will also be awarded. These scores, which range from 0 (urgent improvement needed)

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to 5 (very good) may be displayed at the food premises. All scores are uploaded on a

monthly basis onto the Food Standards Agency’s website and are publicly available.

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

There are a number of safeguards available to businesses ranging from appealing/disputing

a food hygiene rating score to requesting a revisit for a re-rating assessment. As public

awareness of FHRS continues to grow it is expected that there will be an increase in the

number of food businesses exercising these safeguards.

From March 2017, the Food Standards Agency has made a change in policy which now

allows local authorities in England to introduce cost recovery for requested FHRS re-

inspections/revisits, if they so wish. The Service will consider the introduction of a cost

recovery scheme during 2018/19 in line with the amended FHRS Brand Standard.

2.2 Complaints

Food Safety and Hygiene complaints and referrals received by the Food Safety Team will be

responded to within 2 working days of receipt. Where sufficient information is obtained from

a complainant a full investigation will be undertaken. All complaints will be dealt with in

accordance with food service Practice and Procedure notes, which in return requires that the

complaints should be dealt with having regard to the Food Law Code of Practice and other

relevant guidance.

Whilst it is difficult to estimate the number of complaints that will be received we do know

that 306 food complaints were received during 2017/18. Past trends would indicate that a

similar number will be received during 2018/19. The majority of which will relate to food

safety issues.

2.3 Primary Authority

Primary Authority is a statutory scheme in which a business can choose to form a

partnership with a local authority and this affects the way in which the business is then

regulated by all local authorities. The purpose of these partnerships is to establish a key

point of contact for the business with the other enforcing authorities, in whose areas other

parts of the business operate. As a primary authority we are able to share compliance

information and guide other enforcing authorities on their actions regarding partner

businesses. Primary Authority Partnerships are:

Princes Foods

2U Foods

Aimia Foods

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2.4 Advice to Business

The service provides advice and support to businesses. In undertaking such a role, it is

anticipated that legitimate business will be informed and encouraged to meet the highest

standards of trading to the benefit of themselves, and consumers. Provision of advice and

support will be provided in line with the Food Standards Agency Code of Practice and clear

distinction will be made between statutory requirements and good practice in such

communications.

2.5 Sampling

Food Samples and environmental swabs are taken from food businesses on a regular basis

for microbiological examination. There is the potential for certain high- risk foods to support

the growth of microorganisms, which in turn can cause food poisoning. By taking these

samples we are seeking to confirm that the standards of food safety management systems

within businesses are effective. The aim being to detect contaminated food and to correct

any problems with regard to the manufacture, handling or storage of food, before any illness

is caused.

During 2018/19 samples will be taken from businesses, the criteria for selection will take into

consideration the nature of the business any hazards identified during an inspection and the

past history of compliance. The Service will also contribute to the national sampling program

led by Public Health England.

Results of samples will be notified to the proprietor of the business. Where results are

unsatisfactory an officer will visit to give advice and discuss the corrective actions to be

taken.

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

Enforcement Policy.

2.6 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 and wherever possible face to face interviews will take place.

Following these interviews, further investigations may be made of food businesses that have

been identified, in order to ensure that appropriate food safety control measures are in

place.

The document “Arrangements between Cheshire and Merseyside PHE Centre Health

Protection Team and LAs for the investigation of sporadic casers of infectious disease”

seeks to clarify the responsibilities of various partners in the control of infectious disease and

acts as a reference document.

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2.7 Food Safety Incidents

Food Hazard Alerts received by e-mail from the FSA, are passed immediately to the

Principal Environmental Health Officer, Commercial Services with responsibility for Food

Safety (in their absence to the 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.

2.8 Liaison with Other Organisations

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

The Environmental Health service has links with the authorities in the Merseyside and

Cheshire area, the Food Standards Agency and Public Health England, through the

Environmental Health Cheshire and Merseyside (EHCM) Food Safety Subgroup, and

through this to neighbouring subgroups of Lancashire, Cumbria and Greater Manchester.

The subgroup meets every 6 weeks.

2.9 Promotion

Training

The Service will deliver the CIEH Foundation food training course and the in house

Introduction/Refresher food safety course to the business sector, community groups and

council employees.

Food Safety Coaching

For non-compliant caterers and proprietors of small non-compliant convenience stores,

officers spend time with these businesses providing advice, guidance and support aimed at

bringing about long term improvements.

Those businesses that do not improve following this intervention will be visited and in order

to ensure compliance, the stepped enforcement approach will be implemented by the

sending of letters and the use of Hygiene Improvement Notices as required.

This stepped approach should improve food safety compliance and the ‘broadly compliant’

indicator that is reported to the agency each year.

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

2.10 Community and Business Health Promotion

In 2015 the Council’s Public Health Division funded the post “Community and Business

Health Promotion” initially this was for two years, however due to the success of this

initiative the post is now permanent.

The key role of this post is to deliver initiatives linked to and supporting the Council’s

Wellbeing Strategy and the The Healthy Weight Declaration which was signed in 2017.

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The programmes in place are:

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

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

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

HOST

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

businesses/

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

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

healthy-eating-award/

During 2018/19 work will continue in partnership with public health to increase the number of

businesses receiving awards in each category

2.11 Food Information for Consumers – Allergens

From 13 December 2014, all food businesses who sell open food have to declare any of 14

identified allergenic ingredients which are used in non- pre-packed or loose foods that are

sold or provided. The Service ensures that this issue is discussed during inspections and is

an issue which now contributes to the scoring awarded in respect to the FHRS confidence in

management criteria.

During 2018/19 further work will take place in raising awareness of the responsibilities that

businesses have in ensuring that the food they serve is safe for those customers who have

identified food allergies.

2.12 ATP (Adenosine Triphosphate) monitoring

These monitoring units enable officers to demonstrate to food businesses the effectiveness

of their cleaning, disinfection and sanitising regimes. Surface swabs are taken of work

surfaces or equipment and are then placed in the handheld reader unit. A numerical reading

is displayed which is indicative of the level of environmental contamination and may indicate

a failure in cleaning systems. The use of these units will continue.

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2.13 Mobile Caterers

The Commercial Services Team, is responsible for enforcing the Street Trading Consent

Scheme. Currently there are 40 mobile food traders who are consented to street trade within

the borough. Each mobile unit is subject to annual inspections for food safety and food

hygiene ratings are awarded following each inspection.

2.14 Smoke free

The service is responsible for enforcing the smoke free legislation in businesses. During

inspections of premises if an officer discovers evidence of smoking within a workplace the

necessary advice and action is taken in accordance with the Enforcement Policy.

2.15 Waste Control

During visits/inspections of food premises officers are confirming if a waste removal contract

is in place for all generated waste. If this is not the case the proprietor is required to obtain a

contract.

3. RESOURCES

3.1 Financial Allocation

The Environmental Health Service is responsible for the enforcement of legislation relating

to Food Safety, Health & Safety, Pollution, Drainage, Public Health nuisance, Refuse,

Animal Health & Welfare. It also provides Pest Control and Dog Warden services and has a

Public Health funded Business and Community Health Promotion function.

Food Safety 2017/18

Employment Costs £246,611

Supplies, Services & Transport £40,695

Recharges & Premises £89,033

LESS Income -£1051

Cost of Food Safety £375,288

Food Safety is allocated 36% of the overall budget.

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

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3.2 Staffing Allocation

The Commercial Services section is staffed as follows:

Principal EHO Commercial 70% of time

5 Senior EHOs 80% of time

Commercial services officer 30% of time

Community and Business Health Promotion Officer 100% of time

3.3 Staff development plan

All officers are appraised annually in accordance with the Authority’s appraisal and

development scheme and procedures. Individual development needs are identified during

this process. Officer development and progress is reviewed after 6 months. Training needs

are fed into the Divisional Training plan for 2018/19.

In accordance with the revised Food Law Code of Practice (England), which came into effect

on 6 April 2015 (revised March 2017), lead food officers and authorised food officers must

obtain a minimum of 20 hours CPD per year split into:

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

official controls:

10 hours on other professional matters. This could include training needs identified by

the Principal Environmental Health Officer during appraisals.

All officers have completed a competency matrix which will form the basis of their individual

appraisals and which will ensure that officers are correctly authorised to undertake their

duties which is dependent on their training and years of experience.

The training programme is attached in Appendix 5.

4.0 INDICATORS AND QUALITY ASSESSMENT

The service monitors its performance against the Food Law Enforcement Service Plan at

regular intervals. The Service Manager Regulatory Services 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 relevant Cabinet

member endorses the Service plan.

4.1 Performance Indicators

Infectious disease investigation response times;

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Service request response times (food safety complaints);

Number of high- risk inspections undertaken;

Number of businesses broadly compliant.

4.2 Quality Assessment

All officers are monitored on a monthly basis to ensure that targets are being met with

regard to response times and inspections due. The inspections due are identified by priority

by rating are discussed during each team meeting and any inspections that are “overdue”

are identified. The PEHO will also examine in detail the post inspection administration and

actions taken by one officer each month. All approved premise files are examined after

inspection and all notices and prosecutions are examined before action is taken.

All officers are accompanied by the Principal Officer during visits at least once during the

year to ensure that inspections and any enforcement actions are carried out in accordance

with the legislation, the appropriate Code of Practice and Practice and Procedure notes. The

Principal Officer keeps a record of these visits and any discrepancies discussed with the

inspecting officer.

All food sampling results are examined as they are received from the laboratory. Food

related service requests will be assessed at a rate of 2 per individual officer per month.

Calibration records of temperature thermometers and probes are checked every 6 months.

Peer Review

The nine local authorities who form the Merseyside and Cheshire Food Safety Sub group

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.

5.0 REVIEW OF ACTIVITY IN FOOD SAFETY 2017/18

During the year a Senior EHO took maternity leave and another Senior EHO continued the

secondment to Environmental Protection, supervising the work of the newly created

Environmental Wardens Team. These situations necessitated a revision of roles and

responsibilities within the team. All senior inspectors have a food safety responsibility for

inspecting identified food premises within identified wards.

5.1 Broad Compliance

The base line figure for businesses being broadly compliant with food safety legislation has

risen from 86% in 2015/16 to 92% in 2017/18. This improvement in compliance provides an

indication of output from the activities of the food safety team in comparison with the inputs,

25

such as the number of inspections. It demonstrates that the work of the team has been

effective and that the work has been focused on priority areas.

5.2 Food Hygiene Rating Scheme (FHRS)

The purpose of the FHRS is to allow consumers to make informed choices about the places

where they eat out or shop for food and, through these choices, encourage businesses to

improve their hygiene standards. The overarching aim is to reduce the incidence of food-

borne illness and the associated costs to the economy.

Food Hygiene Rating Scores are awarded following an inspection of the premises, in

accordance with the Food Standards Agency’s Brand Standard. Premises are scored on the:

suitability of the structure of the premises;

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

inspection;

the confidence in the management of the food businesses.

Scores from 0 to 5 are then awarded to each to each premise. A zero score indicates failure

to comply with the legislative requirements and a score of 5 demonstrates very good

compliance. A score of 3 is deemed to be the accepted legal standard. Of the total number

of premises 573 have a rating of 5 (41%), 278 a rating of 4 (20%) and 158 a rating of 3

(11%)

Any business which scores below 3 is subject to further interventions from the food safety

team which can range from one to one coaching in the implementation of the Safer Food,

Better Businesses practices package, to the service of Health Improvement Notices or, in

the most serious of cases, prosecution for failing to comply with the food safety regulations.

All scores are uploaded on a monthly basis and are available to be viewed on the Food

Standard Agency’s website at www.food.gov.uk/ratings

In 2017, Senior EHOs, the Principal EHO and the Commercial Services Officer took part in

the national Food Standards Agency web based consistency exercise. The aim being to

promote the consistent application of the Food Hygiene Rating Scheme Brand Standard.

5.3 Staff

The five experienced senior EHO’s within the team provide a dedicated service aimed at the

protection of the public health, the improvement of food safety and they also consider the

health and safety standards within food businesses dealing with matters of evident concern

during food safety inspections.

The Community and Business Health Promotions Officer is responsible for developing

programs of work which will:

26

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.

The Business and Community Health Promotion Officer is responsible to developing,

implementing and managing the Chip Fryer, HOST and Childminders’ awards.

5.4 Staff Development 2017/18

All food safety staff received the minimum of 10 hours Continuous Professional

Development training on food safety related topics as required by the Chartered Institute of

Environmental Health.

Staff training was undertaken in the following areas:

PHE Sampling foods workshop

PHE laboratory visit

PHE training in conducting investigations into shigella flexneri infections

PHE Listeria Focus workshop

Environmental Health Officer and Health Protection Team workshop

FHRS National Consistency Exercise (FSA web based)

FHRS Appeals (England) on line

5.5 Food Premises Interventions

The following number of businesses that were due an intervention in 2017/18 and the

number of interventions completed are as follows:

High risk businesses:

2 x A due – completed 2

139 x B due – completed 136 (3 visits done outside of 24-day window, in one case due to

inaccessibility and in two cases service demands – accident investigations)

Low risk businesses:

238 x C due – completed 224

151 x D due – completed 134

77 x E due - completed 79

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(E rated premises do not form part of the inspection programme as they are by their nature

deemed to be low risk premises, for example clothing retailers that are registered as food

businesses because they sell chocolate/sweet gifts).

In line with National Guidance from the Food Standards Agency, resources were focused on

the high risk premises such as caterers of high risk foods where the full suite of interventions

are likely to be undertaken. This ensures that the resources available to the Service are

used in the best way to ensure an improvement in the standards of the higher risk premises.

In total 98% of all due A & B rated premises were inspected in accordance with the

requirements of the Code of Practice. Of the “C” rated premises 224 were inspected that is

94% within the required time frame and for the “D” rated premises 134 were completed that

is 89%.

5.6 Formal Action

A total of 7 Hygiene Improvement Notices were served on a number of different premises.

Examples of issues where notices were served included requiring business owners to

undertake deep cleaning of their premises, provide suitable and sufficient food safety

management systems and provide a constant supply of hot running water. Two premises

voluntarily closed both because they had no hot water supply.

5.7 Food Complaints

421 food complaints were investigated and appropriate action taken within the two-day

response time. This is an increase from the 378 received in 2016/17.

5.8 Primary Authority Partnership

The Team are 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 recognition of the professionalism and quality of the Council’s front line environmental

health staff.

5.9 Food Sampling

The Service undertook sampling following inspections of premises where problems with

cleaning and food handling practices are identified. This intervention proves useful when

explaining to food business operators the importance of good food safety management

practices. All borderline and unsatisfactory sample results are further investigated and

advice is given to food business operators. This is then followed by further sampling to

confirm if improvements have been made.

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In addition, all reports of samples and findings are reported to PHE as they form part of the

National Studies Report which is circulated to all local authorities.

5.10 Infectious Disease

44 infectious diseases were investigated and appropriate action was taken in all cases.

5.11 Food Standard Agency Food Alerts & Food Incidents

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

5.12 Community and Business Health Promotion

The Health Survey for England indicated that obesity rates in St Helens affected

approximately a quarter of the adult population. It is also a concern that 8% of children aged

4-5 years are deemed to be obese this is only 1.5% below the national average and by the

time young people have reached 10-11 years of age this figure has increased to 19.7%,

which is more than the national average of 19.2%. For these reasons obesity and excess

weight have become one of the eight priorities within the St Helens Health and Wellbeing

Strategy 2013-16.

Having developed the “Chip Fryer” award in 2013/14 and following on from this success

Public Health commissioned further work from the Service and funded for 2 years a new

post, “Community and Business Health Promotion Officer”. The aim being to improve the

nutritional content of food offered by hot food takeaways and to improve the nutritional

content of food offered to pre-school children. In 2017 following a review of the work done

and the successful engagement with local businesses and childminders, Public Health

agreed to make this a permanent post with continued funding.

During 2017/18 the Chip Fryer Award was further promoted with a total of 18 businesses

now having the Gold Award or Platinum award. The HOST Award (Healthier Options St

Helens) has been developed which consists of a number of health “pledges” that hot food

takeaway businesses can sign up to, which demonstrate their commitment to providing

healthier options on their menus. Seven businesses have now signed up to the pledges and

52 samples of dishes have been taken in order to analyse the % salt and/or fat content of

each meal. These results provide a base line for identified dishes in each business and

enables the business owners to make changes to their recipes in order to reduce the levels

of fat/salt. Dishes are resampled following the changes to determine if reductions have been

made. To date a pizza business has been able to remove all salt from the pizza dough which

is used.

During the year the Childminders Health Eating Awarded was further promoted and in total

21 childminders have now received awards. This award recognises the good work being

done by childminders in promoting the “healthy eating” message to children in their care and

also to parents and carers.

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6.0 Variation from the Service Plan 2017/18

There was no variation from the plan

30

________________________________________________________

FOOD STANDARDS SERVICE PLAN 2018/19

_________________________________________________________

6.0 INTRODUCTION

The Food Standards Service Plan sets out how St Helens Council through its Trading

Standards Service will fulfil its responsibilities under the legislation relating to food

standards, particularly the labelling and composition of food. The structure of the service

plan follows the service planning guidance contained within the Food Standards Agency

(FSA) Framework Agreement on Local Authority Food Law Enforcement. Other Activities

performed by the authority in respect of consumer protection legislation are detailed in the

Departmental, Divisional and Action Plans detailed in Appendix 2.

6.1 Scope of the Food Standards Service

The enforcement of food standards legislation, which includes regulation of compositional

standards relating to food, food labelling and nutritional and health claims made in

connection with food, with all food businesses based or trading within the borough.

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

businesses.

To undertake sampling of food based on the National Co-ordinated Food Sampling

Programme Priorities published by the FSA, local priorities and food incidents.

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

food standards.

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

enforcement policy.

The Trading Standards Section is also responsible for the enforcement of a wide range of

consumer protection legislation, including Fair Trading, Product Safety and Weights and

Measures. Wherever possible, this is combined with food work.

6.2 Demands on the Food Standards Service

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

authority area:

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FSA

Category Description A Rated B Rated C Rated TOTAL

A Primary Production 0 0 61 61

B Slaughterhouses 0 0 0 0

C & D Manufacturers & Packers 6 11 0 17

E Importers / Exporters 0 2 0 2

F Distributors 0 3 17 20

G Retailers 2 128 355 485

H Restaurants & Caterers 0 132 866 998

I Materials and Articles

Manufacturers & Suppliers 0 1 1 2

J Manufacturers mainly selling by

retail 0 0 0 0

TOTAL 8 277 1300 1585

In general, the food businesses based in the area pose a low to medium risk and 97% of

premises are rated as “broadly compliant” under the Food Law Enforcement Code of

Practice (Guidance). High Risk premises are food manufacturers and packers, producing

meat products, soft drinks, beverages, breakfast foods, hospital meals, and pickles. The

majority of the food manufacturers and packers in the area are members of accreditation

schemes such as BRC (British Retail Consortium).

7.0 SERVICE DELIVERY

7.1 Service Delivery Points

The Food Standards Service is delivered by the Trading Standards Section, based at

Wesley House, Corporation Street, St Helens, WA10 1HE. Office hours are 8.45 am to 5.15

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pm Monday to Friday. Out of hours service is available should it be required. Contact can be

made by telephone to: 01744 676299 or by e mail to: tradingstandards@sthelens.gov.uk.

7.2 Identification of Premises with a Food Standards Risk

The Food Standards Service shares a premises database with the Environmental Health

Food Safety Service, hence all food premises registered with the authority under the Food

Safety requirements are known to the Food Standards Service. Regular checks are made on

the database to ensure that all food premises have been risk rated and thus brought into the

inspection programme. Food premises also become known through requests for advice from

the business, complaints and enquiries about the business, as well as officers’ knowledge of

the local area, which will lead to them being recorded on the premises database.

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

All food premises which are “A rated” will be inspected annually as required by the Food Law

Enforcement Code of Practice. Food premises rated “B”, which manufacture or process food

will also be inspected annually.

The remainder of Food Standards work is intelligence led and delivered through a range of

targeted projects, which include targeted inspections and interventions. In addition to

reacting to complaints relating to specific businesses, business sectors will be targeted

where there is a perceived national or local issue, such as the traceability of meat,

substitution of meat species, the re dating of foods, failure to provide accurate allergen

information, the sale of illicit alcoholic drinks, particularly wine and vodka and the use of

false nutritional and health claims. The intention is to address any issues identified and to

gather information which will influence future work.

7.4 Food Standards Complaints

Food Standards complaints are received by the service by telephone, letter, e mail or

referrals via the Citizens Advice Consumer Service. All complaints are responded to within 1

working day.

Where the complaint relates to the contamination, adulteration, composition and labelling of

food the complaint will be fully investigated, with a view to tackling the root cause of the

problem, to avoid it happening again. Where appropriate, enforcement action will be taken,

having regard to the Enforcement Policy and Statutory Codes of Practice.

7.5 Home Authority and Primary Authority Scheme

The service operates in accordance with the Home Authority Principle, acting as a point of

contact for businesses based in St Helens that trade within and outside the area. Home

Authority relationships exist with:

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

Soods Fine Foods Westbridge Foods (Haydock) Ltd

George Wright Brewery Baroncroft Ltd (t/a Punch Brew Company)

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Food Pack Ltd The service is working to develop Primary

Authority relationships with appropriate food business. Primary Authority relationships

including Food Standards exist with:

Aimia Foods Ltd

Princes Ltd

Nichols Foods plc.

7.6 Advice to Business

The Food Standards Service will make all reasonable attempts to provide advice and

education to businesses in a practical and cost effective manner. The intention is to equip

the business with information that will allow the business to meet legal and best practice

requirements. Advice may be provided through a number of means including:

➢ During routine inspections / visits and follow up visits

➢ Following investigation of a complaint

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

➢ Telephone conversations with businesses

➢ Provision of seminars, displays and talks to businesses.

7.7 Food Sampling

Food sampling is planned based upon intelligence received and will take account of the

National Co-ordinated Food Sampling Programme Priorities published by the FSA. The

service will participate on Trading Standards North West (TSNW) sampling initiatives where

appropriate.

In previous years the service has taken advantage of funding made available through TSNW

participation in the FSA co-ordinated sampling programme. The FSA are no longer providing

this funding so the co-ordinated sampling programme will not take place in 2018/19, which is

a financial loss to the service, as in addition to analysis costs being covered by the funding,

we were able to claim £30 per sample which contributed towards sampling costs.

The service has given careful consideration to project work for the year ahead, and at

present no food standards projects are included within the planned work. Capacity within the

Trading Standards Service has been reduced with the loss of a further post in 2017. The

service is currently working on a reactive basis and work is intelligence led, targeting issues

identified as posing the most significant detriment to residents and businesses in St Helens.

Should intelligence identify a food standards risk, a project will be planned and undertaken

where appropriate.

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

34

FSS (Food Surveillance System) is utilised to record our sampling activities and to gather

intelligence, which assists effective targeting of sampling work.

Results of any official samples undertaken will be notified to the proprietor of the business.

Where any sample results are unsatisfactory an officer will visit to give advice and discuss

corrective actions to be taken, and it is likely that further sampling will be carried out. In

instances where the adverse result relates to food manufactured outside the authority area,

officers will liaise with the relevant Primary or Home Authority.

Any enforcement actions taken as a result of sampling will be in accordance with the

Council’s Enforcement Policy.

7.8 Control and Investigation of Outbreaks of Food Related Infectious Diseases

Should a food safety incident be linked with a food standards issue the Food Standards

officers will liaise with the Food Safety Team to investigate the issue.

7.9 Food Standards Incidents

All Food Standards alerts are received from the Food Standards Agency via e mail alert. The

majority of alerts are for information only, whilst a small number will require an immediate

response.

Food Standards alerts and warnings are responded to be an appropriate officer, usually the

Lead Food Standards Officer, who will determine the action to be taken, which will be as

directed by the warning notification received and in accordance with the Food Law Code of

Practice.

Should there be a need for the Trading Standards Service to issue a Food Hazard Warning

in respect of food standards matters, this would be undertaken in line with the relevant

requirements of the Food Law Code of Practice and our Food Standards Practice and

Procedures.

The authority has an emergency response system in place for any incidents that occur

outside of normal office hours.

7.10 Liaison with Other Organisations

The service ensures that the food standards service delivered is consistent with that of its

neighbouring authorities through participation in the Trading Standards North West (TSNW)

Food Standards Group, which also includes partner organisations involved in similar work,

such as MHRA (Medicines and Healthcare Regulatory Agency), FSA Wine Standards

Branch and Port Health. The service has a close working relationship with colleagues in

Environmental Health responsible for Food Safety Enforcement.

7.11 Food Standards Promotional Work

The service is committed to raising public awareness of food standards issues and will

provide information through a variety of means whenever possible, including media articles,

websites and events.

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8. RESOURCES

8.1 Financial Allocation

The officers engaged in Food Standards delivery also undertake other duties and the costs

of the service are contained within the total approved budget for the Trading Standards

Service.

Inspection, intervention work and sampling must be funded through the Trading Standards

Service budget. At present approximately £3000 is available for analysis of Food Standards

samples.

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

Employment Costs: £19,157

Supplies Service and Transport: £2,409

Recharges and Premises: £6,693

TOTAL: £28,259

Food Standards is allocated 5.7% of the overall Trading Standards Budget

8.2 Staffing Allocation

A list of officers currently authorised to undertake Food Standards enforcement work is

maintained, together with a record of training and continuing professional development

hours awarded. Currently this is 3 authorised food standards officers, one of which is

authorised as Lead Food Standards Officer. In addition, 1 officer has obtained the DCATS

(Diploma in Consumer Affairs and Trading Standards) Food Standards module and

undertakes supervised work, thus obtaining practical experience, which will lead to wider

authorisation. It is estimated that 0.45 FTE time is allocated to Food Standards service

delivery.

Food Standards work is undertaken by the following officers:

1 x Principal Trading Standards Officer: 15% of time

2 x Senior Trading Standards Officer: 10% of time

1 x Senior Consumer Protection Officer: 5% of time

1x Operational Support Assistant 5% of time

8.3 Staff Development Plan

All training needed to deliver the Food Standards Service Plan is managed in accordance

with corporate training procedures and with consideration to the requirements for continuing

professional development identified in the Food Law Enforcement Code of Practice. The

service will utilise training provided by TSNW and the FSA.

36

9.0 QUALITY ASSESSMENT

9.1 Quality Assessment and Internal Monitoring

The Service monitors its performance of the Food Standards Service Plan at regular

intervals. The Chief Trading Standards Officer monitors performance on a monthly and

quarterly basis. In addition, each year performance is compared as part of the service

planning process. The service has documented practice and procedures in relation to Food

Standards service delivery, which are subject to regular review and performance is audited

against these.

All officers are monitored on a monthly basis to ensure that targets are being met with

regard to response times and inspections due. The Lead Food Standards Officer monitors

work recording and follow up actions taken on a regular basis and may on occasion

accompany Food Standards officers during visits, to ensure that inspections and

enforcement actions are carried out in accordance with legislation, the Food Law

Enforcement Code of Practice and internal Practice and Procedure notes.

10.0 REVIEW OF ACTIVITY IN FOOD STANDARDS 2017-18

10.1 Programmed Premises Interventions

The Food Standards Team achieved 8 of the 10 programmed inspections of High Risk (A

rated) premises and were able to work with these businesses on particular issues

throughout the year. One inspection was not made, as the business had moved out of the

area, and the second was not completed, as the business is a meat cutting plant subject to

FSA approval, and the visit was postponed due to the FSA announcing a programmme of

unannounced visits to such premises, in light of recent food incidents concerning meat

cutting plants. As the food standards risk posed by the business is low, it was felt that the

risk of interference with the FSA work should be avoided.

Although not performing programmed inspection visits to the remainder of the food

businesses, the service continued to engage with and challenge Low and Medium Risk

businesses (B and C rated), by reacting to intelligence received and complaints.

10.2 Formal Action

The Food Standards Team has completed a lot of work in relation to infringements identified

through intelligence received. Much of this work has been the provision of business advice in

order to resolve problems and prevent future infringements. The majority of non-compliant

businesses were brought into compliance by the end of the year through this process. Other

issues have been resolved through liaison with the Primary or Home Authority for the

business concerned.

10.3 Food Complaints

During 2017/18 a total of 14 Food Standards complaints were received, the majority of which

related to the sale of low microbiologically stable foods after the marked “best before” date.

37

Other complaints included; the misdescription of a ready meal; undeclared use of

Genetically Modified oils in takeaway food premises; and the description of battery produced

eggs as “free range”.

The team also responded to a number of requests for advice received from new food

businesses on the composition, labelling and advertising of their products, particularly

businesses selling home baked cakes and confectionary.

It is believed that the drop in complaints received may be due to the use nationally of the

Citizens Advice Consumer Helpline, as the contact point for Trading Standards enquiries, as

consumers may not realise that food complaints can be made through this route. 9 of the 14

complaints received came direct to the Food Standards team by E mail, the remaining 5

being reported via Citizens Advice Consumer Helpline.

10.4 Food Sampling

The FSA did not provide any funding for food standards sampling during 2017/18, as a

consequence no sampling was undertaken, as none of the complaints received or issues

identified in inspection required a sample to be taken in order to remedy the issue.

10.5 Primary and Home Authority

The Primary Authority relationship with Princes Ltd continues to develop, with the business

seeking advice and support on a wide range of issues, some of which are complex and

technical. The service has assisted with the development of control procedures utilised in

the businesses manufacturing plants, in addition to providing extensive labelling advice.

Towards the end of the year, a new Primary Authority relationship was formed with Aimia

Foods Ltd, of Haydock. The business has requested support to validate the control

procedures they have in place, and to ensure the food they produce is labelled correctly.

Primary Authority work is charged for at cost recovery.

10.6 Officer Development

All Food Standards enforcement officers attended a minimum of 10 hours CPD (Continuing

Professional Development) training, as is required by the Food Law Enforcement Code of

Practice. All officers attended at least one external training event, most of which were

provided through the TSNW Food Standards Group. Courses attended during the year

include:

Allergen Management

Food Standards Update

Food Fraud

38

In addition, officers have undertaken extensive research in order to provide comprehensive

business advice on a number of issues, which has contributed to the officers’ knowledge

base.

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

10.7 Variation from the Service Plan

The projects planned for 2017/18 were not undertaken, and we were not able to complete as

many intelligence led retail inspections as we anticipated due to other demands on the

service.

We had planned a project looking at the issue of allergens and non-permitted colours in

takeaway meals, following an incident in early 2017, where a consumer had an allergic

reaction to nuts in a meal, sold as “nut free”. Similar work conducted in other authorities in

the north west concluded, that it is not possible to produce an allergen free meal in a typical

takeaway kitchen, due to cross contamination, with the majority of foods sampled as

nut/allergen free being found on analysis to contain nuts/allergens. Hence the project was

not progressed.

The second planned project had been to work with the School Meals / Catering service

within the authority, in relation to their procurement of food. Research was undertaken with

the authorities Audit team, and it was concluded that this work would have little if any value

to the authority, so the project was not taken further.

The team are generic trading standards officers, and so deal with a wide range of consumer

protection issues. At present the major areas of detriment in the area relate to rogue trading,

particularly in the home maintenance / building sector, doorstep crime and scams, in

addition to issues with the purchase of used cars. Hence, as the service is intelligence led,

work has been focused on this type of work.

10.8 Areas of Improvement

To build capacity through allowing the one officer who obtained the DCATS Food Standards

module during 2015/16 to gain practical experience and hence become fully authorised

Food Standards Officers.

To continue to review officers’ qualifications, skills and competencies against the Food Law

Enforcement Code of Practice requirements and review authorisations as required.

To review Practices and Procedures to ensure compliance with the revised Food Law

Enforcement Code of Practice.

To continue to improve the standard of inspection recording.

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_____________________________________________________

FEED SERVICE PLAN 2018/19

_________________________________________________________

11.0 INTRODUCTION

The Feed Service Plan sets out how St Helens Council through its Trading Standards

Service will fulfil its responsibilities under the legislation relating to animal feed, fertilisers

and the primary production of food. The structure of the plan follows the service planning

guidance contained within the Food Standards Agency (FSA) Framework Agreement on

Local Authority Food Law Enforcement. Other activities performed by the authority in respect

of consumer protection legislation are detailed in the Enforcement Services Service Plan.

12.0 FEED SERVICE AIMS AND OBJECTIVES

12.1 Aims and Objectives

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

labelled;

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

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

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

12.2 Links to Corporate Objectives and Plans

The Council approves the Feed Service Plan. The Cabinet Member holding the Portfolio for

Better Neighbourhoods monitors progress against service objectives during the year.

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

The Feed Service Plan is reviewed annually, taking into account corporate objectives,

demands on the service and any changes in the way in which the service is provided, to

ensure the provision of the most cost effective service. The links to the St Helens Plan

objectives are set out in Section1.3.

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13.0 BACKGROUND

13.1 Profile of the Local Authority

A profile of the authority is provided on page 11.

Whilst St Helens is a mainly urban area, there are small rural communities around the

outskirts, where farming remains as a full time occupation, in addition to a number of small

holdings, and hobby farms.

13.2 Organisational Structure

The Feed Service is provided by the Trading Standards Service, the organisational structure

which is shown in Appendix 2.

13.3 Scope of the Feed Service

To conduct a programme of inspections of feed businesses and primary production

businesses at the frequency required under the Feed Law Code of Practice published by the

Food Standards Agency.

To undertake sampling of animal feed based on the National Feed Priorities published by

the FSA, local priorities and feed incidents.

To react to feed safety incidents, complaints, referrals and requests for advice relating to

animal feed and the primary production of food.

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

enforcement policy.

13.4(a) Demands on the Feed Service

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

the authority:

FSA

Category

Description Number of premises

R5 Placing on the market of compound feeds 3

R6 Manufacture of Pet Foods 1

R7 Manufacture and / or placing on the market of

feed materials 21

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FSA

Category Description Number of premises

R8 Transporting of feed and feed products

5

R10/11

Mixing feed on farm with additives and

premixtures/ with compound feeding stuffs that

contain additives

11

R12 Food businesses selling co products of the food

industry which are destined as feed materials

2

R13 Livestock Farm 21

R14 Arable Farm 43

TOTAL 107

In general, the feed businesses based in the area pose a low to medium risk and all

premises are rated as either “broadly compliant” under the NTSB risk rating scheme. Only

30% of the registered feed businesses are members of recognised feed assurance

schemes.

The highest risk premises are the on farm mixers (R10/11) who generally only mix their own

grain with compound feeds supplied by reputable suppliers, the food businesses disposing

of waste food and co products (R7 and R12) into the feed supply chain, with varying control

measures in place, and the new manufacturer of pet food (R6).

13.4(b) Service Delivery Points

The Feed Service is delivered by the Trading Standards Section, based at Wesley House,

Corporation Street, St Helens, WA10 1HE, office hours being 8.45am to 5.15pm Monday to

Friday. Out of hours service is available should it be required. Contact can be made by

telephone to 01744 676299 or by email to tradingstandards@sthelens.gov.uk.

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13.5 Regulation Policy

The Feed Service adheres to the Regulatory Services Enforcement Policy which is available

via the website www.sthelens.gov.uk.

14.0 SERVICE DELIVERY

14.1(a) Feed Premises Registration

The Feed Service has proactively sought registration of feed business establishments under

the feed hygiene requirements and continues to do so, when affected businesses are

identified. Third party assurance information is incorporated into the Feed Hygiene Register

maintained by the service.

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

Production Premises

Feed and primary production inspection frequency is conducted according to the NTSB risk

scheme. Inspections are conducted in accordance with the Feed Law Enforcement Code of

Practice. The table below details the inspection programme for the premises currently on the

Feed Hygiene Register.

The following elements, in varying depth depending on the identified risks of the business,

will be undertaken during feed and primary production inspections:

Registration / checks on the registration categories of feed businesses including food

businesses supplying into the animal feed chain;

Examination of the processes to ensure that feed / food (at primary production) is

compositionally and nutritionally correct, not adulterated or contaminated and is properly

labelled;

Determining the efficiency and effectiveness of HACCP systems used in the

manufacture and use of feed and the primary production of food and feed.

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

production;

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

Provision of advice on legal requirements

The following inspection visits are planned for 2018/19:

1 x R5 Placing on the market of compound feeds

1 x R6 Manufacturer of pet foods

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1 x R7 Food business disposing of surplus food

1 x R8 Transporter of feed

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

1x R12 Food businesses selling co products

1 x High Risk Primary Production Food Hygiene Inspection

Consideration will also be given to utilising Alternative Enforcement Strategies (AES) to

validate information we hold in relation to feed businesses that have not been inspected for

over 3 years.

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.

14.2 Feed Complaints

Feed and primary production complaints are received by the service by telephone, letter,

email or referrals via Citizens Advice Consumer Service. All complaints are responded to

within 1 working day.

Where the complaint relates to the contamination, adulteration, composition and labelling of

feed or food produced at the primary production level the complaint will be fully investigated,

with a view to tackling the root cause of the problem, to avoid it happening again. Where

appropriate, enforcement action will be taken, having regard to the Enforcement Policy and

Statutory Codes of Practice.

14.3 Home Authority and Primary Authority Scheme

The service operates in accordance with the Home Authority Principle, acting as a point of

contact for businesses based in St Helens that trade within and outside the area. We 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.

14.4 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

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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

14.5 Feed Sampling

Feed sampling is planned based upon intelligence received and will take account of the

National Enforcement Priorities set by the FSA. The service will participate in Trading

Standards North West (TSNW) sampling initiatives where appropriate.

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

service.

At present no reason for sampling has been identified for 2018/19, however, samples will be

programmed should intelligence be received or initiatives be developed by TSNW or the

FSA.

14.6 Control and Investigation of Outbreaks of Food Related Infectious Disease

Should a food safety incident linked with a primary production premise, or a feed business

arise, the feed officers will liaise with the food safety team to investigate the issue, as

described within the Food Service Plan

14.7 Feed Safety Incidents

All feed alerts are received from the Food Standards Agency via e mail alert. The majority of

alerts are issued for information only, whilst a small number will require an immediate

response.

Feed hazard warnings are responded to by an appropriate officer, usually the lead feed

officer, who will determine the action to be taken which will be as directed by the warning

notification received and in accordance with the Feed Law Code of Practice.

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

normal office hours.

14.8 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 APHA

(Animal and Plant Health Agency), VMD (Veterinary Medicines Directorate) and Port Health.

The group is represented on the National Agriculture Panel (NAP). We work directly with

APHA when required. The service liaises with colleagues in Environmental Health

responsible for Animal Health enforcement.

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14.9 Feed Safety Promotional Work

The service is committed to raising public and business awareness of feed safety issues and

will provide information through a variety of means whenever possible, including media

articles, websites and events.

15.0 RESOURCES

15.1 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 2018/19 is £1912 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.

15.2 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.

15.3 Staff Development Plan

All training needed to deliver the Feed Service Plan is managed in accordance with

corporate training procedures and with consideration to the requirements for continuing

professional development identified in the Feed Law Enforcement Code of Practice.

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

16.0 QUALITY ASSESSMENT

16.1 Quality assessment and internal monitoring

The Service monitors its performance of the Feed Service Plan at regular intervals. The

Chief Trading Standards Officer monitors performance on a monthly and quarterly basis. In

addition, each year performance is compared as part of the service planning process.

The Service has documented practices and procedures in relation to feed service delivery,

which are subject to regular review and performance is audited against these.

All officers are monitored on a monthly basis to ensure that targets are being met with

regard to response times and inspections due. The Lead Feed Officer monitors work

recording and follow up actions taken on a regular basis and may on occasion accompany

46

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.

17.0 REVIEW

17.1 Review against the Service Plan 2017-18

17.1(a) Programmed Premises Interventions

During 2017/18 the service completed the following inspection visits, all funded through the

NTSB / FSA regional funding awarded:

1 x R5 Placing on the market of compound feeds

2 x R7 Food business disposing of surplus food

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

1 x R14 Arable farm

No major issues were identified through the inspections, but advice was provided to assist

improvement, particularly with regard to record keeping.

The Feed team have now had contact with all registered feed businesses in the area and

have inspected over 70% of those businesses over the last 5 years and have completed an

Alternative Enforcement Strategy with a further 10%, in order to maintain current records of

the feed business in the area. The majority of businesses not inspected are supermarkets

disposing of bakery waste for feed use, and small scale hobby farmers, neither of which

pose no significant risk.

17.1(b) Formal Action

No Formal Action was required as no significant infringements were identified. Advice was

provided to a number of Feed Business / Primary production Establishments to assist

improvement.

17.1(c) Feed Complaints

During 2017/18 the service saw a significant increase in feed related enquiries, dealing with

a total of 10 issues, 2 of which were consumer complaints relating to pet food which was out

of date, and cat food which appeared to cause hair loss following re formulation.

There were 4 requests for advice from persons considering manufacturing dog treats at

home, another from a business planning to import feed for Shrimp, and a request for advice

from a haulier carrying feed. There was also an allegation that an established dog grooming

business was manufacturing dog treats without the required APHA approval in place. This

issue was resolved through advice.

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The service dealt with a feed incident relating to the use of illegal Co products, produced and

supplied by a food business in a neighbouring authority to a local livestock farm. The food

business was not registered to supply co-products and failed to provide the farm with the

required documentation to demonstrate trace ability. The farmer was cooperative with the

service, and it was established that none of the food waste had been fed to his stock, as he

had found it to be very poor in quality, hence there was no feed safety risk.

17.1(d) Feed Sampling

A review was made of the National Sampling Priorities which did not indicate the need for

any sampling No issues arose during the year which required samples to be taken.

17.1(e) Officer Development

The lead feed enforcement officers achieved in excess of 10 hours CPD (Continuing

Professional Development) training, as is required by the Feed Law Enforcement Code of

Practice. The Lead Feed Officer attended training on Feed Contaminants and Earned

Recognition. In addition, the Lead Feed Officer attends the TSNW Agriculture Group and

undertakes individual research relating to legislation and best practice. The second feed

officer did not achieve the required CPD hours, so will only undertake supervised work until

their CPD has been updated.

17.2 Variation from the Service Plan

There was no variation from the planned work during 2017/18.

17.3 Areas of Improvement

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

risk Rating Scheme.

To improve the standard of inspection recording, utilising the FSA standard forms and

guidance on completion provided.

To review our Practices and Procedures to ensure compliance with the revised Code of

Practice on Feed Law Enforcement.

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APPENDIX 1

SERVICE PLAN PROGRAMME 2018/19

Departmental and Divisional Service and Action Plans can be viewed on the council’s web

based PMF (Performance Management System).

Paper copies of the plans are available on request.

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APPENDIX 2

ORGANISATIONAL STRUCTURE CHARTS

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

1) Department - Management Team

2) Division - Environmental Health

- Trading Standards

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Place Services

Department

STRATEGIC DIRECTOR PLACE SERVICES

Senior Assistant Director

Development & Growth

Senior Assistant Director

Trading Services

Service Manager Estates

Management

Service Manager

Development & Growth

Service Manager Assets a& Buildings

Service Manager Schools, Depot &

Care Services

Service Manager Recreational

Services

Service Manager Environment &

Transport Services

Service Manager Regulatory Services

Service Manager

Engineering Services

CHIEF EXECUTIVE

Business Support

Manager

Senior Assistant Director Built Environment

& Regulatory Services

Environmental Health Trading Standards Licensing & Land Charges Building Control

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Built Environment & Regulatory Services Division

Environmental Health

Service Manager Regulatory

Services

Senior Assistant Director Built

Environment & Regulatory Services

Principal EHO

Commercial Services Principal EHO

Environmental Control

5 x Senior EHO

(Commercial Services)

Commercial

Services Officer

2 x Environmental Control Officers

3 x Scientific Officer

Air Quality, Contaminated Land, Noise

Dog Welfare &

Enforcement Officer

4 x Environmental

Wardens

Community & Business Health

Promotions Officer

Supervisor

Pest Control

4 x Pest Control Officers

Environmental

Warden Support

Officer

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Built Environment and Regulatory Services Division

Trading Standards

Service Manager Regulatory

Services

Principal Trading Standards Officer

Admin Officer

Senior Consumer Protection Officer

Senior Trading

Standards Officer

Operational Support

Assistant

2 x Clerical

Officers

Senior Assistant Director Built

Environment & Regulatory Services

Principal Trading Standards Officer

Chief Trading Standards Officer

Senior Trading

Standards Officer

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APPENDIX 3

FOOD SAFETY PREMISES/WORK PROFILE 2017/18

Code Establishments A B C D E Total

101 Manufacturers and Packers 1 2 6 1 0 10

103

Distributors/Transporters 0 1 0 3 2 6

105

Supermarket/Hypermarket 0 0 2 4 5 11

06

Smaller retailers 0 5 21 62 16 104

107

Retailer – other 0 1 4 10 5 20

109

Restaurants/café/canteen 0 8 52 46 0 106

110

Hotel/Guest House 0 1 1 1 0 3

111

Pub/Club 0 4 26 33 9 73

112

Takeaway 0 18 67 18 0 103

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Code Establishments A B C D E Total

113

Caring establishments 0 59 21 4 1 85

114

School/College 0 29 19 13 1 62

115

Mobile food unit 0 0 4 20 8 32

116

Restaurants and caterers -

other

0 6 18 20 21 57

Total due an

intervention in

2018/19 2 134 233 235 68 672

Inspection

Frequency 6 months

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.

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APPENDIX 4

COMMERCIAL SERVICES TEAM -

ESTIMATION OF RESOURCES FOR 2018/19

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

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

540 Low Risk Inspections (C-E)

380 Food Complaints

80 Infectious Disease Investigations

250 Revisits (may rise if the display of the Food Hygiene Rating Score becomes mandatory)

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

Advice to businesses

Sampling

Food Standards Agency Food Alerts

Liaison with other Agencies

Food Safety and Healthy Eating Promotion

Training and coaching food safety

Business and Community Health Promotion

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APPENDIX 5

FOOD SAFETY TRAINING PROGRAMME 2018/19

All officers will receive training so as to enable them to comply with the requirements of the

Code of Practice, which states that all authorised officers and the Lead officer must obtain a

minimum of 20 hours CPD per year, spilt into:

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

official controls

10 hours on other professional matters. This could include training needs identified

during the competency assessments and appraisals.

The following areas of training will be dealt with during the coming year, some by shared low

cost training with Environmental Health Cheshire and Merseyside;

FSA Update Sessions / Consistency Exercises

Public Health England –sampling workshop

Other update courses as they become available throughout the year.

All officers are also briefed during regular team meetings of any changes to internal Practice

and Procedure Notes.

When officers attend courses on any food or related issue then the appropriate cascade

training will be organised so that the team will benefit.