1Food Service Plan 2004/5
FOOD SERVICE PLAN
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2Food Service Plan 2004/5
Legislation for food standards and feedingstuffs is enforced by the Trading
Standards Service and County Analyst and Scientific Adviser’s Service,
working together in partnership to deliver a comprehensive service to the
businesses and consumers of Lancashire. This joint Service is titled “The
In addition, the County Analyst and Scientific Adviser holds the appointment
of Public Analyst and Agricultural Analyst, and the laboratory is designated as
an Official Food Control Laboratory.
1 Service Aims and Objectives
1.1 Aims and objectives
The aim of the Food Service is to ensure all food and feedingstuffs in
Lancashire comply with all relevant legal requirements.
This is achieved by:
• Inspecting food and feedingstuffs businesses against the requirements of
the Food Safety Act and Agriculture Act, in accordance with applicable
codes of practice and guidelines, and at a frequency specified in the
LACORS risk rating scheme, Codes of Practice and FSA guidance. This is
done for the purpose of:
o Assessing the degree of compliance in meeting legal requirements.
o Where applicable, working with businesses to identify and agree
corrective and preventive action to ensure that compliance with food
standards law is maintained.
o To employ alternative enforcement approaches where a business
remains noncompliant, or there is a significant nonconformance that
demands alternative action as a first approach.
• Planning and carrying out sampling programmes of food and feedingstuffs,
from both inside and outside Lancashire, to determine, by analysis, if
compositional, quality, contamination and labelling requirements are being
met, and to confirm enforcement activities have been effective. This may
be achieved by working in partnership with local and national agencies.
• Planning and implementing business/consumer advice and educational
activities that promote understanding of rights and obligations with respect
to food and feedingstuffs legislation, resulting in improved compliance.
• Developing, promoting and actively supporting trader self-regulation
schemes in order to promote compliance and maximise the use of
• Providing a helpline for advice and education to businesses seeking to
comply with legislation. Fostering a better understanding and consistent
interpretation and implementation of legislation. Supporting this the Food
Service adopts the Home Authority principle, with a view to working with
local businesses and other agencies to improve compliance.
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• Responding promptly to consumer complaints regarding food and
feedingstuffs and taking action commensurate with the seriousness of the
1.2 Links to Corporate objectives and plans
The Food Service Delivery Plan links to the following corporate objectives:
• Feel safe:
o Provides confidence that food for sale in Lancashire is safe,
contains no harmful additives and is correctly described and
labelled, so that informed decisions can be made by the
• Live healthy lives:
o Ensures food meets minimum compositional requirements. This
is particularly important to those who are socially and
• Get help when needed:
o Provides access to professional help and advice to both
businesses and consumers on rights and obligations,
interpretation and application of legal requirements.
• Have jobs and a good standard of living:
o Removes the competitive advantage that some businesses have
over those endeavouring to comply, and provides confidence for
consumers and businesses in the foods and feedingstuffs they
purchase. This promotes job security for those working in food
and feedingstuffs businesses within Lancashire.
The Food Service Delivery Plan is an integral part of Service Planning
designed to meet the requirements of FSA Framework Agreement,
stakeholders and the DTI’s National Performance Framework. In addition, it
contributes to achieving the Best Value Performance Indicator BV166.
2.1 Profile of the Local Authority
Nestling between the Irish Sea and the Pennine moors in the North West of
England, Lancashire boasts lively coastal resorts, elegant city centres and
time-honoured mill towns, where new businesses flourish alongside more
traditional industries. The County is rich in natural beauty, from wild moorland
to gentle farmland and shady woodlands, and features dozens of traditional
villages and hamlets.
Lancashire is the fourth largest County Council Authority in England covering
an area of 289,972 hectares, serving a population of 1.14 million and
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4Food Service Plan 2004/5
business premises in excess of 35,000. There are twelve district councils
within the administrative area of the County.
Unlike most other shire counties, Lancashire does not have a dominant ‘city
region’. It has a unique settlement pattern of over 20 medium sized urban
areas, which include 2 cities. None are self-contained for jobs, homes,
shopping or cultural activities.
The needs of minority ethnic communities, the very old, very young, disabled
or socially disadvantaged, exist in concentrations in Lancashire, but not on the
scale found in the established ‘big cities’. Total service needs are spread
unevenly across the County as a whole and highlight the requirement for an
effective county-wide service, addressing the needs of the consumers of, and
visitors to, Lancashire.
The unique blend of population and mixture of rural and urban communities
within Lancashire requires that the County Council provide a broad-based
enforcement service to protect consumers and businesses alike. The service
needs to be able to quickly respond to the needs of individual groups and
communities of Lancashire and flexible enough to meet the changing
requirements of new legislation and trading patterns.
2.2 Organisational Structure
Of f ice of theChief Executiv e
Education and Graham Harding
Resources Social Serv ices
CulturalServ ices Env ironment
Paul Burgess Assistant Director
Section Manager Assistant Director Manager
Assistant Director Highway s
Transport Policy Planning Traf f ic &Saf ety
Public Protection Consultancy
Welf areRights Emergency Planning County Analy st & Registration
Serv ice Serv ice Scientif ic Adv iser Serv ice
Metrology Section Quality Section Factory Inspections: Analytical sections (7.6FTE)
Fair Trading & Safety Kevin Randall, PTSO Avril Whittaker, PSO Food
Section 4 X Senior TSO's 2.6 X Scientific Officers Agriculture
1 X TSO 1 x Admin Officer Microbiology
4 X FTO's (enforcement)
1.5 X Technical/Support
• The Food Service operates within the Environment Directorate (see
organisation chart above), headed by Paul Burgess, Assistant Director,
Public Protection; and heads of Service, Jim Potts, Chief Trading
Standards Officer, and Karen Swan, County Analyst and Scientific Adviser.
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• The nominated officer with specialist responsibility for food standards and
feedingstuffs is Kevin Randall, Principal TSO (Quality), who acts as first
point of contact for all internal/external agencies and Home Authority
2.3 Scope of the Food Service
As an upper tier Authority Lancashire County Council has a duty to
enforce legislation relating to food standards and feedingstuffs. This
duty is implemented by the joint Food Service, which carries out:
• Business inspection/audits for compliance against legislation
• Sampling programmes and analysis of food for compliance
• Investigations of complaints
• Advice and education to businesses and consumers
• Special investigation projects on targeted areas.
• Takes formal action, when necessary, in accordance with the
County Council’s enforcement policy
The following services are delivered alongside Food Service activities
to provide a comprehensive and seamless service to the food and
feedingstuffs businesses of Lancashire and consumers:
• Enforcement of all relevant trading standards legislation
• Business and Consumer advice on legislation applying in addition
to food and feedingstuffs
• Investigation and legal process
• Special projects into trading malpractices
• Consumer Advice Centre responsible for taking and logging
consumer complaints in respect of food.
• Analytical services are provided to the District and Unitary
Authorities in Lancashire as part of their enforcement activities.
2.4 Demands on the Food Service
The County Council has a large and important food industry operating
in diverse sectors. A large agricultural industry supplies produce from
arable farms and market gardens; and the farming industry produces
dairy products such as milk, cheese and yoghurt, as well as bacon,
pork, poultry, beef and lamb.
In addition, the day-to-day demands of the 1.14 million residents and
the requirements for advice and support of businesses in Lancashire
are an important demand on the Food Service.
The profile of Lancashire’s food processing business premises shows
that the majority of businesses are meat, poultry, and game
processors, fish and fish products. Other types of businesses include
flour and confectionery, dairy products, ready meals, pizzas and sugar
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Lancashire has a total of 9780 food and feedingstuffs premises liable to
inspection, of which 4823 are tagged for inspection in 2004/5. These
are currently divided into risk bands as follows:
High 595 (12.3%) Medium 2289 (47.5%) Low 1939 (40.2%)
572 (11.8%) of these premises are producers, manufacturers or
There are 65 premises registered as milk bottlers, requiring regular
sampling, the majority of which are on farms
The combined range of skills, knowledge, expertise and competencies
available within the Food Service is considered to be sufficient to meet
the needs for enforcing legislation relating to food and feedingstuffs.
The Food Service operates throughout the County from two locations
based centrally in Preston. Access to the Service is available during
normal office hours of 8.45am – 5pm, Monday to Friday. An out of
office hours telephone answering service is available.
The Food Service adopts a balance of techniques and approaches in
order to ensure the safety and well-being of the public and of the
environment and does not rely on any one method. We believe that
assisting compliance is every bit as important as detecting
noncompliance. The targeting of resources where they are most
effective and at areas of highest risk is essential in providing the public
with an effective service.
The County Council is a signatory to the Enforcement Concordat,
which sets out what businesses and others being regulated can expect
from Enforcement Officers.
A copy of the enforcement policy can be found at
www.tradingstandards.gov.uk/ lancashire/ business
3 Service Delivery
3.1 Food and Feedingstuffs premises inspections
Programmed inspections at food and feedingstuffs businesses seek to
assess the degree of compliance against relevant legislation and agree
with the business corrective and preventive action where appropriate.
Part of this approach entails advising and educating business in
practical ways of complying with legislation, so the learning can be
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applied to other similar situations. On occasion it may be necessary to
take more formal approaches where others fail.
An integral part of the inspection is to obtain samples of food and
feedingstuffs during the visit. Samples may be obtained at key control
points of the processing operations where the composition of the
product may be affected. Subsequent analysis confirms, or otherwise,
that food and feedingstuffs standards are being met, and/or that
enforcement action has been effective.
To provide consistency and allow for benchmarking with other similar
Authorities, each business within Lancashire receives a score, in
accordance with the LACORS risk rating scheme. This is to help direct
‘appropriate enforcement actions’ to deal with the risk posed by the
business in respect of noncompliance with trading standards laws. The
Food Service aims to inspect all food and feedingstuffs premises at
frequencies recommended by the Scheme.
At present the recommended frequencies are at least once each year
for high-risk premises and at least once every two years for medium
risk. Low risk premises are assessed using alternative enforcement
actions at least once every 5 years1.
Alternative enforcement actions are taken with low-risk premises. Having regard to all the circumstances,
and the benefits to be gained, most low-risk premises are initially assessed by letter. The response
determines if an inspection is necessary. A representative sample of responses will be audited for validity.
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Food Businesses Profile:
Primary producers 220 199
Manufacturers/processors 257 313
Packers 80 60
Importers/exporters 18 17
Distributors/transporters 195 187
Retailers 4248 4019
Restaurants & other caterers 3809 4118
Manufacturers mainly selling by retail 76 120
Total 8903 90332
Feedingstuffs businesses profile
Feedingstuffs commercial compounders 31 26
liable to inspection/sampling
Feedingstuffs wholesale/retail premises 119 108
liable to inspection/sampling
Premises registered or approved under 408 414
Establishment & Intermediary
Total 558 548
Planned inspection programmes
Number of programmed inspections of 6358 4823
food and animal feedingstuffs premises
Estimate of the number of other visits 400 400
(including revisits and advisory visits)
Detailed plans will be developed and implemented to achieve the above.
These plans will form the basis for monitoring process
In addition, the following projects have been identified for implementation
• To develop and implement a plan to change the emphasis by TS from
routine inspections to auditing food businesses, in accordance with the
LACORS protocols for inspections. Involve all sections of County
Analyst, Quality, Metrology, and Fair Trading and Safety.
• Lancashire County Council contractors/schools. A programme of
visits/sampling to be developed and implemented.
• Agriculture: Develop and implement a plan to introduce audit-type visits
to businesses. Emphasis to change to informal sampling from formal
sampling. A reduction in formals will allow for an increase in informals
for similar costs. Contingency will be needed for formal samples,
follow-ups, etc. Balance to be drawn between Fertilisers, Feedingstuffs
and pet foods.
In addition, there are 199 other visits including mail order, recreational/hire and
administrative companies, which are not accounted for in these figures, making a
total of 9780.
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3.2 Food and Feedingstuffs complaints
In 2003/4 the total number of complaints and Service Requests
regarding food and feedingstuffs was 799. The Public Analyst reports
on approximately 150-200 food complaint samples each year,
submitted by the Food Service, District Councils and Unitary
Authorities of Lancashire.
Food complaints received by the Food Service are recorded and
evaluated to determine an appropriate response. It is the policy of the
Service to respond within one working day to any incident or complaint
involving products that present an imminent danger, or where a delay
would prejudice effective enforcement.
Other complaints are investigated within a reasonable time, subject to
available resources. Some complaints may be deferred until an
inspection of the business is due, or the information is used to assess
trading patterns and malpractices, or for campaigns to amend or
improve legislative requirements.
Documented procedures exist for transferring food complaints falling to
be dealt with by the District Council food authorities, e.g. ‘foreign
3.3 Home Authority Principle
Lancashire County Council has adopted the LACORS ‘Home Authority’
and in support of this the Food Service provides comprehensive advice
and education to businesses of Lancashire, and actively assists
originating authorities and other enforcing authorities to resolve matters
originating within the County.
3.4 Advice to Business
It is the policy of the Authority to make all reasonable attempts to
provide advice and education to businesses that can be applied by
them in a practical and cost effective manner. The intention is to equip
the business with information for them to help themselves in similar
situations. Examples of this are:
• Advice provided during routine inspections/visits and follow-ups.
• Advice provided following investigation of a complaint
• Provision of Trader Information Sheets explaining legislation
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• A website where information can be downloaded, including Trader
• Telephone helplines, manned at all times, for local businesses to
• Provision of seminars, displays, and talks, etc on business-related
• Active support to businesses in trader self-regulation schemes,
such as the ‘Curry Club’ and ‘Made in Lancashire’.
In 2003/4 there were approximately 117 Service Requests for
assistance and 38 complaints from businesses. The resources required
for this were approximately 1 (FTE) officer.
3.5 Food and Feedingstuffs Inspection and Sampling
Sampling by the Food Service focuses on
• Inspections at food processing and certain non-processing
businesses, with sampling/testing being an integral part of the
• Supporting regional, national and/or international sampling/testing
programmes as they affect the residents and businesses of
• Responding to complaints regarding food and feedingstuffs
Samples may be obtained following an assessment of a perceived risk
that needs further information to arrive at a conclusion; or, to verify
enforcement activities, and that corrective and preventive actions taken
by business have been effective.
Samples are analysed at the Food Control Laboratory and reported on
by the Public Analyst/Agriculture Analyst for Lancashire
Food Sampling programme 2003/4 2004/5
Number of samples of foods and raw 1100 1100
materials from Lancashire’s food processing
Number of samples of labelling assessed 850 1000
from food processing businesses
Number of samples from premises registered 166 160
as milk bottlers
Number of samples from retail businesses as 220 240
part of specified planned programmes
Other foods, e.g. food complaints, school Actual 157 Up to 200
meals, other surveys, e.g. foods targeted for
consumption by vulnerable people
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Feedingstuffs sampling programme
Number of feedingstuffs samples from 50 10 formals
manufacturers and producers 70
Number of feedingstuffs samples from on- 40 50
*Note: the difference in the number of samples of labelling assessed
from food processing businesses in 2003/4 compared with 2004/5 is
due to a change in the way those samples are recorded.
3.6 Control and investigation of Outbreaks and Food Related
The Food Service has no direct responsibility in respect of outbreaks
and food-related infectious diseases. But, it is recognised that the
health and well-being of the residents of Lancashire is of prime concern
and every effort will be made to assist the appropriate authorities to
carry out their responsibilities.
3.7 Food Safety Incidents
Food hazard warnings are received electronically and actioned in
accordance with the Food Safety Act Code of Practice No. 16. It is not
anticipated that such warnings will place a significant demand on
resources, although time has to be allocated for liaison with
Environmental Health Departments throughout the County and
consideration of any action by the Food Service, which may include
provision of press releases, or mail-shot communication to appropriate
traders. During 2003/4 48 such warnings or updates were received and
3.8 Liaison with other organisations
The Food Service liases in the following ways:
• Represents Lancashire on the LACORS North of England Food and
Agriculture working group.
• Member of the Lancashire Environmental Health Food Officer
• Member of the Lancashire local authorities monitoring organisation
RADMIL, to share resources and provide an efficient and effective
means of investigating Lancashire’s radiological environment, which
includes measurements of internal exposure from foods.
• Representative of the Food Standards Agency Working Party on
Radionuclides in Food
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• Membership of the Association of Public Analysts (APA) Training
Committee, and APA Educational Trust group.
• Member of the ‘Made in Lancashire’ steering group
• Organiser of the Lancashire ‘Curry Club’ for food additives
Resource allocation for these activities is estimated to be between 0.5
and 1 FTE.
3.9 Food and Feedingstuffs Safety and Standards Promotion
The Food Service is committed to raising public and business
awareness of consumer protection issues.
Projects targeted at achieving this have been identified as follows:
• Develop and implement a plan to increase the promotion of the
benefits of the existing “Made in Lancashire” scheme to increase the
membership from the current 50 members. Consider the impact on
workload and the benefits to the Food Service/Businesses/ and
Consumers of having such a scheme.
• Evaluate the feasibility of, and, if so, plan for, the further
development of the ‘Curry Club’ (re: colourings in food) into a
comprehensive TS ‘trader scheme’, embracing all trading standards
activities, using curry club members as the pilot study. The intention
will be to extend the scheme to other trade sectors and areas (e.g.
allergens) if successful. Project team will assess the justification for
having such schemes, the objectives being achieved, and the
structure and resources needed to achieve them. This project links
to the ‘Made in Lancashire’ scheme.
• Develop and implement a plan for a comprehensive approach to the
implementation of the meat product regulations at high, medium and
low risk premises. For example, consider developing business
seminars, one-to-one advisory visits, trader leaflets, etc.
In addition, the following activities are planned or will continue to be
provided as required:
• Attendance and display stand at the Royal Lancashire Agriculture
• Maintenance of a website were consumers and businesses can
continue to access information on the latest developments in food
and feedingstuffs matters
• Presentations to schools and local interest groups
• Joint promotions with local Environmental Health Departments
• Guided tours of the Food Control Laboratory (e.g. Environmental
Health Officers, Elected Members, etc)
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4.1 Financial allocation
The officers engaged in food law enforcement activities may also
undertake other duties and the costs of the Food Service are contained
within the total approved budget for the Trading Standards and County
Analyst and Scientific Adviser’s Services.
The estimated joint costs for food law enforcement are as follows:
Budget Heading 2003/4 2004/5
Employees 785,886 780,000
Premises 47,590 (see note 2) 49,000
Transport 30,882 28,000
Supplies and Services 150,564 158,000
Central Support Costs 184,229 202,000
Total 1,199,151 1,217,000
Note 1: Costs include provision of specialist inspection team and Public Analyst Laboratory
Note 2: Central Support Costs include an element for premises costs
Legal Services: all legal work is carried out within the Food Service,
including court advocacy, except in contested cases, where it is normal
practice to instruct counsel. It is the policy of the Service to seek
recovery of all legal costs, including investigation expenses, from
defendants when a conviction is secured. The sum of £20,000 is held
in reserve in the event of substantial legal costs being either incurred
and irrecoverable, or awarded against the Authority.
4.2 Staffing allocation
The Food Service has the following staff engaged on food law
enforcement and related matters:
6 (FTE) Trading Standards Officers holding the Diploma in Trading
Standards or its antecedents. All Trading Standards Officers within the
Quality Section hold lead auditor qualifications in order to undertake
inspections of high-risk premises or those with documented assurance
systems in place.
NOTE: One TSO has been seconded onto a Review of Quality
Systems within the department during 2003/4
4(FTE) Fair Trading Officers (Enforcement) holding or studying for the
Diploma in Consumer Affairs, including the Food & Agriculture paper,
or the Certificate of Competence.
1.5 (FTE) Technical/Admin Support staff.
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2.8 Scientific Officers (FTE) undertaking Food Business Inspections. All
have BSc. (Hons), B.S. Lead Assessor Certificate and have the
Diploma in Consumer Affairs Certificate of Competence, or its
7.6 (FTE) analytical staff undertake food and agricultural materials
analysis and examination. Staff are educated up to degree level (in a
relevant science subject) together with Chartership status.
1 (FTE) member of Administrative Services Section
In addition, responsibility for food law enforcement, including
complaints, at specified business premises is allocated to suitably
qualified non-specialist officers in either the Metrology or Fair Trading
& Safety sections.
4.4 Staff development plan
The highly specialised nature of food law enforcement and the
evolution of legislation presents a continual requirement for ongoing
staff development. It is the policy of the Food Service to ensure the
continued development and training of staff in keeping with both the
County Council’s corporate ‘Performance and Development Appraisal’
scheme and with the requirements of relevant codes of practice.
A training needs analysis is carried out for all Food Service staff on an
annual basis. The minimum requirement for update training of 10
hours continual professional development specified in Code of Practice
19 will be provided in conjunction with the North of England Trading
Standards group and other training providers, for all authorised officers
in the Service. Further specialised training when identified will be
provided either via external courses or in house using external
All analysts are required to undergo formal training and to satisfy
analytical quality assurance requirements prior to being approved for
any work within the laboratory. Results may only be submitted by
analysts approved for each relevant technique.
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5 Quality Assessment
5.1 Quality Assessment
The fundamental role of quality assurance and assessment of food law
enforcement service delivery is recognised by the Food Service The
monitoring of service delivery against defined performance indicators is a key
requirement of the Food Standards Agency.
The Food Service is committed to quality management of all its functions and
continuously develops its quality systems to encompass all key control
elements of the food enforcement service, in keeping with legislative,
technological and scientific requirements driven by modernisation of the
Part of the Food Service is already accredited to EN ISO 9001:2000 and
subject to regular assessment by BSI. The remaining part is seeking
accreditation in 2004/5. Internal audits and Management Reviews are carried
out to ensure continuing compliance with the requirements of the standard.
The Public Analyst laboratory meets the requirements specified by the Official
Control of Foodstuffs Directive (89/397/EEC) and the Additional Measures
concerning the Official Control of Foodstuffs Directive (93/99/EEC) to be an
Official Food Control Laboratory for food analysis and food examination. It is
accredited by the United Kingdom Accreditation Service (UKAS) to the
European Standard ISO EN 17025:2000.
The laboratory takes part in regular comprehensive proficiency testing
schemes operated by FAPAS, FEPAS, LEAP, Campden and Chorleywood
and the Laboratory of the Government Chemist, as part of its commitment to
the demonstration of ongoing competency.
The Food Service is working towards the achievement of the Investors in
People Standard and periodically uses the EFQM (European Foundation for
Quality Management) Excellence Model to assess performance
In 2004/5 a focused audit on ‘monitoring’ provisions of the Food Service will
be undertaken by the FSA. This is scheduled to last 2 days.
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6.1 Review against the Service Plan
Review is achieved by –
• Regular team briefings/meetings to inform officers of progress
against plan and discuss recovery actions where a shortfall is
• Progress report to Senior Management Team by responsible
• Quarterly review of performance against plan
• Quarterly reports to Food Standards Agency
• Progress reports to Assistant Director
• Progress reports to O&S Steering Group as required
6.2 Identification of any variation from the Service Plan
100% of high-risk premises were inspected as targeted for 2003/4.
69% of medium-risk premises were inspected as targeted for 2003/4. A
shortfall against target was anticipated at a 6 monthly review of
inspection levels when only 38% of medium risk inspections had been
achieved. Interrogation of the Flare database revealed the shortfall was
in the Licensed Restaurant/Café, Pub/Bar, Hotel/Guest House and
Licensed Club groups of premises. The shortfall was due to a shortage
of staff in one particular team (Metrology) and a number of non-food
projects for this team were dropped to provide extra resources to direct
towards visits of those groups of premises. However, a further loss of
another member of staff in that same team later in the year resulted in
a continuing shortfall at the following quarterly review. The Quality
Team was then directed towards visiting the licensed restaurant group
of premises; utilising appointment visits to achieve the greatest
Targets for food and labelling samples from food businesses have
been exceeded because of the need to provide additional advice and
education to meat processing businesses as a result of two major and
complex changes in legislation.
The target for the milk sampling has been exceeded because of an
unforeseen need to carry out follow up samples as part of the
enforcement and advice given to traders. The planned figure for 2004/5
has been increased to accommodate this.
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6.3 Areas of improvement
• Thematic review on Protecting the Consumer completed and a
project on a review of food enforcement carried out
• Outcome was that present working arrangements were the best, but
recognition that improvements can be made
• Following improvements identified:
o Modification of Flare database of premises and
inspections planned by improving links, data inputting,
management and information retrieval
o Introduction of LACORS risk-rating scheme in full
o Re-distribution of visits to optimise the effectiveness of
inspections and improve use of resources
o Special projects have been identified and are included in
this plan (see section 3)
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