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TRADING STANDARDS SERVICE - BEST VALUE REVIEW

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TRADING STANDARDS SERVICE - BEST VALUE REVIEW Powered By Docstoc
					                                                                           CABINET

                                                                     29 March 2004

                                                                      ITEM NO:         .


               TRADING STANDARDS’ SERVICE PLAN 2004/2005
              Report by Steve Holland, Head of Trading Standards


 The purpose of this report is to advise and seek the views of Cabinet about the
 Trading Standards‟ Service Plan.


1.    INTRODUCTION

      The Local Government Act 2000 requires the County Council, amongst other
      things, to determine and establish a Policy Framework. The Policy
      Framework must incorporate a number of statutory plans and provides the
      County Council with the opportunity to include any other plans that it
      considers should be part of its Policy Framework. At its meeting on 25
      February 2002 the County Council incorporated the Trading Standards‟
      Service Plan within its policy framework. Details of, or any amendments to,
      plans within the policy framework are deemed to be Key Decisions which can
      only be taken by the full Council. Key Decisions are published in the
      Council‟s Forward Plan. The current Forward Plan provides for Cabinet‟s
      consideration of the Trading Standards‟ Service Plan at its meeting on 29th
      March.


2.    TRADING STANDARDS’ SERVICE PLAN

      The Trading Standards‟ Service Plan sets out the key actions that the Trading
      Standards Service proposes to take over the next year. These key actions
      are directly linked to the County Council‟s community strategy objectives in a
      clear and transparent way. In addition, specific and measurable targets
      against each of the key actions have been established.

      Annexed to the Trading Standards‟ Service Plan are:

             the Trading Standards‟ Enforcement Policy (Appendix E)
             the Food Law Enforcement Plan (Annex I)
             the Minor Sales: Major Consequences Plan (Annex II), and
             the Farm Enforcement Plan (Annex III).

      The Food Law Enforcement Plan is a statutory plan in its own right whilst the
      Minor Sales: Major Consequences Plan enables the County Council to
      discharge its statutory duty to consider its enforcement of the Children and
      Young Persons (Protection from Tobacco) Act 1991.
      The Trading Standards‟ Service Plan has been designed to fully address the
      requirements of the National Performance Framework for Trading Standards
      Services and to meet the County Council‟s local priorities.

3.    ACTIONS REQUIRED

      The views of Cabinet are sought in relation to the proposed Trading
      Standards‟ Service Plan prior to its consideration by full Council on 10th May.


4.    RECOMMENDATION

      It is recommended that Cabinet recommends that full Council adopts the
      Trading Standards‟ Service Plan and accompanying Appendix E and Annexes
      I, II and III.


5.    ALTERNATIVE OPTIONS

      No alternative options have been identified


6.    CONCLUSION

      This course of action has been recommended as the adoption of the Trading
      Standards‟ Service Plan and accompanying annexes will allow the Trading
      Standards Service to fully meet its obligations under the National
      Performance Framework and the County Council‟s local priorities.




Contact:    Steve Holland, Head of Trading Standards Tel: 01603 223429
            e-mail: steve.holland@norfolk.gov.uk

            Sophie Leney, Assistant Head of Trading Standards (Service
            Development Tel: 01603 224275
            e-mail: sophie.leney@norfolk.go.uk
               TRADING STANDARDS
                  SERVICE PLAN

                             2004/2005

Produced in accordance with the requirements of the National Performance
Framework for Trading Standards Services




         If you would like this report in large print, audio, Braille,
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                                         NORFOLK COUNTY COUNCIL
Name of Authority
Name of Chief Inspector of
                                         STEPHEN HOLLAND
Weights and Measures


Status of Plan                                                     Date


      Approved by Members (give approval date)


      Member Approval pending (give expected date for obtaining
       approval)                                                   10th May 2004
       (notify DTI when approval obtained)


                                537,234 HECTARES
Area


                                    GROSS EXPENDITURE FOR 2003/04 - £2,831,758
                                    Total Budget for 2004/05 - £2,838,710
Budget                              Gross Staffing Expenditure for 2003/04 - £2,176,115
                                    Budget Allocated for Staffing 2004/05 - £2,397,320



Contact Details

   Name              Sophie Leney
   Position          Assistant Head of Trading Standards (Service Development)
   E-Mail Address    sophie.leney@norfolk.gov.uk
   Address           Norfolk County Council Trading Standards Service,
                      County Hall, Martineau Lane, Norwich, Norfolk, NR1 2UD
CONTENTS


Part One: Context and Comparative Factors

A. The Trading Standards Service in the Community

      Introduction

1.    Core Responsibilities of the Trading Standards Service

2.    Community Objectives and Local Priorities

3.    Aims, Objectives and Strategic Thinking


B. Local Structure and Resources

4.    Local Authority Organisation, Accountability and Wider Links

5.    Accessibility


C. Assessing Community Expectations and Feedback

6.    Consumer Needs and Expectations

7.    Needs and Expectations of Local Business

8.    Awareness of Trading Standards

9.    Customer Care Strategy

10.   Demand for Specialist Services
Part Two: National and Local Priorities

D. Provisions For National and Local Priorities

Key Improvement Area:

1.    To Put Right Detrimental Trade Practices and Deter Rogue Traders

2.    To Reduce Risks Faced by Norfolk Citizens

3.    To Secure a Fair and Safe Trading Environment through Proactive Enforcement

4.    To Achieve Greater Community Engagement through Our Information, Advice and
      Education Services

5.    To Continue to Improve the Efficiency and Effectiveness of the Trading Standards
      Service



Part Three: Review: Assessment and Improvement

E. Quality Assessment and Review

1.    Quality Assessment and Review

2.    Variation from the 2003/04 Service Plan


Appendices

A:    Primary Legislation Enforced by the Trading Standards Service

B:    Norfolk County Council Local Priorities

C:    Organisation Chart of the Trading Standards Service

D:    Opera Community Research – Deprivation and Social Exclusion Survey – Analysis

E:    Enforcement Policy

F:    Customer Care Strategy


Annex I:     Food Law Enforcement Plan
Annex II:    Minor Sales: Major Consequences Plan

Annex III:   Farm Enforcement Plan
           PART ONE



A - THE TRADING STANDARDS SERVICE IN
    THE COMMUNITY



B - LOCAL STRUCTURE AND RESOURCES



C - ASSESSING COMMUNITY EXPECTATIONS
    AND FEEDBACK
A – THE TRADING STANDARDS SERVICE IN THE COMMUNITY


Introduction
All Trading Standards Services are responsible for a core of functions, including weights
and measures, consumer safety, advice and fair trading. Here in Norfolk we provide a full
range of services not only in line with these core activities but also in support of local
needs, through the pursuit of community objectives, which take into account the
geographic and demographic profile of our County. These local influences include:

(a)   Geography

         Norfolk is a large and predominantly rural county with an attractive environment
          including quiet villages and ancient market towns. Whilst it is a county with a
          strong agricultural base it also has a rich seafaring history and an industrial past.

         Much of the 322km of Norfolk‟s coastline is designated as Areas of Outstanding
          Natural Beauty. The Norfolk Broads, with over 200km of rivers, offers a unique
          and precious environment enriched with rare plants and wildlife.

(b)   Population

         Norfolk has a population of around 804,000, projected to increase to 844,700 by
          2011.

         The County covers a geographical area of 5,372 square kilometres and
          consequently has a very low population density – only 1.5 persons per hectare
          compared with an average of 3.8 in England and 46 in London.

         The County has three large centres of population, which account for 40% of the
          total population:
                  Norwich (194,930)
                  Great Yarmouth (69,275)
                  King‟s Lynn (39,475)

         There are a significant number of market towns (20 with a population in excess
          of 4000) that act as focal points for rural communities.

         25% of the population is aged 60 or over (as compared to the national average
          of 21%) with the number of persons of pensionable age projected to grow by
          around 42% between 1996 and 2021.

         Young people in Norfolk represent 23% of the population.
                Only 0.9% of the population comes from black and minority ethnic
                 communities.

(c)       Economy

             Norfolk has a diverse economy with no particularly dominant sector. Over 90%
              of firms employ less than 25 people. Firms employing over 200 people account
              for only 1% of the stock but provide almost half of the jobs. Total employment
              equates to 45% of total population.

             Business start-up rates in Norfolk are the lowest in the region but business
              survival rates are amongst the highest. This suggests that the economy will
              continue to grow for the foreseeable future. Unemployment is around 5% and
              this is higher in urban areas.

             The skills of the Norfolk workforce are below those of the UK as a whole and the
              proportion of people willing and able to become entrepreneurs and set up their
              own business is lower than that in the UK and the East of England.

             Norfolk has good communication links, particularly to continental Europe through
              the East Coast ports; and is served by an international airport. However, the
              County has poor East/West road and rail links.

         Norfolk is the largest tourist destination in the East of England.


(d)       Deprivation in Norfolk

         The average income for Norfolk is 12% less than the national average.

         There are pockets of real deprivation in both rural and urban areas.

         Many rural areas are suffering from declining services and poor access to transport.

         The highest areas of multiple deprivation (DTLR Indices of MD, 2000) are in urban
          wards. Out of 230 wards, Norfolk has 12 of the worst 10% nationally and 29 within
          the worst 20% nationally. It also has the 2 most deprived wards in the Eastern
          Region.


(e)       Funding

         The total expenditure on Trading Standards in Norfolk at £3,300 per thousand
          population, is slightly higher than the average for the nearest neighbour comparison
          group of £3,170 per thousand population, the range of this group being between
          £2,193 and £4,105 per thousand population.
1.        Core Responsibilities of the Trading Standards Service
The core responsibilities of the Service are given below:

     Enforcement                                                                      Is this in your
     Responsibility       DESCRIPTION                                                 remit?
                                                                                           (yes or no?)
     Weights and          Work relating to the accuracy of weighing and
     Measures             measuring equipment in use for official purposes and
                          ensuring quantity of goods is within tolerance.             YES
                          Verification services.
        Does your authority maintain local standards?                                        YES
         (Ref: Section 4 Weights and Measures Act 1985)
        Does your service hold Approved Body status?
     (Relates to the Non Automatic Weighing Instruments Directive and linked UK       YES
     Regulations)
                          Includes claims about prices, quality or description of
                          goods and services.
                                                                                              YES
     FAIR TRADING

                          Includes monitoring goods supplied to consumers and
     PRODUCT              checking that they are safe and correctly labelled.
                                                                                      YES
     SAFETY
                          Includes ensuring food is correctly described and
     FOOD                 labelled throughout the supply chain, and that applicable           YES
                          compositional standards are met.
     STANDARDS
      Is the above function shared with Environmental Health?                                YES

                          Includes monitoring licensing regime, ensuring
     CONSUMER             transactions, documentation and adverts comply.
                                                                                              YES
     CREDIT
     Animal Health        Includes movement licences, monitoring welfare during
                          transport and at markets
                                                                                              YES
     and W elfare
     Agricultural         Includes ensuring fertilisers and animal feeding stuffs
                          are of correct composition and labelled.
                                                                                              YES
     Standards
                          Ensuring certain products are not supplied to children:
     Age Restricted
                          for example tobacco, videos, butane lighter fuel,                   YES
     Sales                fireworks.
                          Includes supply of unroadworthy vehicles, overloaded
     Road Traffic         goods vehicles, weight restriction areas.
                                                                                              YES
                          Ensuring fireworks and other explosives are safely
     Explosives           stored on registered premises.                              NO
                          Ensuring petroleum is safely stored on licensed
                          premises.                                                   NO
     PETROLEUM
     Environmental        Includes energy labelling, packaging disposal and motor
                          fuel pollutants.
                                                                                              YES
     Legislation
                          List the main duties only

    Licensing
                          Performing Animals


                          Poisons


Additional Functions. List any additional main duties which fall to your service
(Do not include membership of enforcement forums and business partnerships as these fall into section 4 of
the plan): None
Specialist Services                                      1.2.1.1          Partners
List only the main services below. (Include
services such as calibration sevices, public analyst
and product testing, note any partners).
Metrology and Calibration Services
                                                            Local and National Calibration
       One stop calibration shop working                    Laboratories
    with partners to offer comprehensive
    calibration service
                                                            Test House
        New for 2004
     - length calibration service                           Scale Companies
     - development towards E2 Calibration
       Status.                                              Other Trading Standards Authorities

               Calibration services to other                            Weight Manufacturers and
                Trading Standards Authorities                             Suppliers


               Weighbridge Testing

Legal Services                                           None

                                                                                     Is this in your
Advice
                          DEFINITION                                                 remit?
Responsibility
                                                                                          (yes or no?)
Are you part of a Consumer Support Network?                           YES
                       Provision of advice to business through means
Business Advice                                                       YES
                       other than inspection and home authority.
                       Provision of advice and information to
Consumer Advice                                                       YES
                       consumers.
Indicate the level of consumer advice you provide. (mark Y for yes where appropriate)
(In terms of the Community Legal Services Quality Mark definitions)
                 Client
                           Local tax payers            Contract in area        No local connection
Level
Information
                              YES                   YES                      YES
Assisted
information                                         YES                      NO
                              YES
General Help
                              YES                   YES                      NO
General help plus
case work                     YES                   YES                      NO


The primary legislation that the Service enforces is listed in Appendix A.
2.    Community Objectives and Local Priorities
The overall aims and objectives of Norfolk County Council are represented by “Norfolk
Ambition”, the Community Strategy for Norfolk 2003-2023.

This new countywide strategy aims to develop, improve and sustain the social, economic
and environmental well being of Norfolk and Norfolk people. Among other things, this
means helping to shape a distinctive, sustainable and healthy environment and a vibrant
economy. It also means working with others to ensure a fair and just society and build a
county characterised by skilled workers supported by dynamic business leaders.

The Strategy focuses on the next twenty years, which will be a time of considerable
change. Much of this change will be very rapid, for example, changes in social and
economic circumstances mean that the nature and shape of our population is becoming
much more diverse in character. To help Norfolk continue to grow and prosper it is
recognised that we must work in partnership to plan collectively for the future and the
challenges and opportunities that change will bring.

The County Council has identified nine key themes to achieve this vision:

             Inclusive and Diverse
             Healthy and Well
             Safe
             Knowledgeable and Skilled
             Active and Engaged
             Environmentally Responsive
             Creative
             Economically Thriving
             Accessible and Well Housed


These themes, at least in part, fall within the remit of the Norfolk County Strategic
Partnership, though there is equally a shared responsibility within District Councils for
turning plans into action at a local level. The diagram overleaf shows the nine key themes
of this Community Strategy, three crosscutting issues and the four key features of effective
working for the Norfolk County Strategic Partnership.
Making Connections
                                                                               Aspirations &
                                                          Inclusiv             Achievement
                             Safe                           e&
                                                          Diverse




    Economi                                                                         Healthy
     c-ally                                                                           &
    Thriving                                                                         Well

                                       Citizenship



                          Leadership                Partnership
                                                                                        Knowled
Active &                                                                                g-eable
Engaged                                                                                    &
                                                                                         Skilled

                                     Sustainability


                                     Norfolk 2023                      Accessible
                                                                        and well-
               Creative                                                  housed

                                           Environ-
                                           mentally
                                          Responsive



                                     Rural/Urban Interplay

                                 RURAL/URBAN INTERPLAY
    Underpinning each of the above themes is a set of local priorities, which are listed in
    Appendix B. (The priorities that relate to the Trading Standards Service are highlighted
    in italics). Areas of Trading Standards work for the 2004/05 service year (key actions),
    which contribute to these priorities, are shown in Section D. Underpinning these
    objectives is the need to ensure that staff are equipped and supported to help give a
    better public service (Objective 40).
    3.      Aims, Objectives and Strategic Thinking
    The overall aim of the Trading Standards Service is to:

    Improve the quality of life of people in Norfolk when they are acting as consumers
    or businesses, through the provision of consumer protection and the enforcement
    of trading standards.

    In seeking to achieve this aim we have set out the following trading standards objectives,
    with links to local and national priorities also indicated.

                                                                                    NATIONAL
     LOCAL PRIORITY AREA              OBJECTIVE                                     PRIORITY

   SAFE                               To protect consumers and                Enforcement of a
   HEALTHY & WELL                      businesses from rogue traders           Fair & Safe Trading
   INCLUSIVE & DIVERSE                 through effective enforcement           Environment


   SAFE                               To put right consumer and business      Enforcement of a
                                        problems through effective              Fair & Safe Trading
                                        interventions and to help Norfolk       Environment
                                        citizens seek redress when it is
                                        appropriate


        SAFE                          To ensure Norfolk businesses are        Informed Successful
        ECONOMICALLY THRIVING          aware of their rights and legal         Businesses
        ACCESSIBLE & WELL              obligations and comply with them
         HOUSED                         through effective education, advice,
        ENVIRONMENTALLY                support and risk based inspection
         RESPONSIVE


        SAFE                          To ensure Norfolk citizens are aware    Informed Confident
        ACCESSIBLE & WELL              of their consumer rights through        Consumers
         HOUSED                         effective education, advice and
        KNOWLEDGEABLE &                support
         SKILLED
        INCLUSIVE & DIVERSE
        ACTIVE & ENGAGED


        INCLUSIVE & DIVERSE           To continuously develop the Trading Efficient, Effective &
        ACTIVE & ENGAGED               Standards Service so as to improve  Improving Trading
        ENVIRONMENTALLY                its effectiveness and efficiency    Standards Service
         RESPONSIVE
Whilst making the Service accessible to as wide a group of consumers and businesses as
possible, we will particularly direct our resources:

            at those consumers:
                   who are young, and can lack experience
                   of working age who live in the most deprived areas of the County
                   who are older, and may be vulnerable
                   who for reasons of disability or ethnicity, may experience
                    disadvantage

             at those businesses:
                    which are disproportionately burdened by red tape
                    which have the greatest impact on the economy of Norfolk
                    which cause the most detriment to the most vulnerable consumers

             where our legislative enforcement has the greatest impact on the
              environment.

Trading Standards is committed to creating a safer Norfolk by:

             tackling crime
             reducing risks, and
             achieving greater community engagement, ensuring that both consumers
              and businesses are aware of and benefit from compliance with the law.

In tackling crime, the service has a remit to “put things right” where it is found that traders
are not complying with trading standards legislation. The methods used range from an
advisory visit, through the use of new powers under the Enterprise Act, to the ultimate
sanction of prosecuting the most serious offenders.

To reduce risks faced by Norfolk citizens, the Service is working with other enforcement
agencies to:

             tackle the sale of age-restricted goods to young people via our Minor Sales:
              Major Consequences plan
             tackle bogus callers and rogue doorstep salesmen
             combat unsafe food, accommodation and consumer goods, such as
              inflatable swimming aids and second hand electrical equipment.

In order to engage the community and encourage greater “self-help”, the Service provides
a wide range of information, advice and support to both consumers and businesses.

Consumers can access information and advice via the County Council‟s Customer Service
Centre, our Superconsumer website, Council Information Centres and through the
Consumer Support Network.
Similarly businesses can access information and advice via the Customer Service Centre,
our Super Website and during proactive visits to business premises.

Further support for local and national businesses is provided in the form of metrological
calibration services.

The detail of how the Service will achieve its aim and objectives during 2004/05 is provided
by the key actions and targets listed in Section D, which also details how these areas of
work are linked to the National Performance Framework standards and the County Council
local priorities.

The aims and objectives take account of the following local and national drivers:

   (a)       The service requirements of customers:

             Consumers feel strongly that the Trading Standards Service should provide a
              higher level of service such that they get:

                  A clear assessment of their complaint's viability (what chance it has of
                   being successful)
                  A defined conclusion (successful or not)
                  Support by taking action on behalf of customers whose own complaints
                   have been ignored

             Businesses feel strongly that an enabling and educational role is the correct and
               ultimately more efficient stance for the Service

   (b)       The human geography and demography of the County (See Section A above)

   (c) The Government's White Paper "Modern Markets: Confident Consumers" which
       seeks to "put consumers at the heart of government". The White Paper proposes a
       wider role for Trading Standards Authorities including:

             provision of consumer education
             participation in the Consumer Advice Network
             development of codes of practice for local businesses
             enforcement of Enterprise Act Enforcement Orders (injunctions which require
              businesses to desist from detrimental trading practices)

         It also challenges traditional service delivery, emphasising the requirement for
         greater focus on the needs of consumers and businesses.
(d) The Audit Commission's "Measure for Measure" Report, which also highlighted
    weaknesses in traditional service delivery, including failure to:

    1.    assess consumer and business needs by consultation
    2.    assess risk and target resources effectively
    3.    operate adequate information systems to inform decisions and evaluate
         performance
    4.    develop a framework for continuous improvement.

(e) The Local Government Act 2000 that requires the Service to promote and improve
    the social, economic and environmental well being of Norfolk citizens. In order to
    maximise impact the Service must focus on areas where well-being is currently at
    it's lowest.

(f) The Food Standards Agency Framework Agreement on Local Authority Food Law
    Enforcement which provides the Agency with the opportunity to be proactive in
    setting and monitoring standards and auditing local authority food law enforcement
    activities in order to ensure they are effective and undertaken on a more consistent
    basis.

(g) The Best Value Performance Indicator for Environmental Health and Trading
    Standards (BVPI166). This is a composite performance indicator consisting of a
    checklist against which to judge the effectiveness of the Trading Standards Service.

(h) The National Performance Framework for Trading Standards Services which
    introduces performance standards for Trading Standards and aims to ensure that
    Trading Standards services throughout the UK are able to develop a modern
    service working towards national and local priorities in a coherent way.
B – LOCAL STRUCTURE AND RESOURCES


4.        Local Authority Organisation, Accountability and Wider Links
4.1       Local Authority Organisation

Norfolk County Council provides services through a number of directorates as detailed on
the Council Organisation Chart shown below.


                                                        Chief Executive




 Education              Social             Youth                 Finance               Special                Economic            Corporate
                       Services            Justice                                     Projects              Development          Resources




     Communications              Planning              Norfolk             Norfolk                Cultural                 Fire
                                    &                  Property            County                 Services
                              Transportation           Services            Services




          Democratic              Policy             Personnel              Trading                Law                 County
           Services                                                        Standards                                 Emergency
                                                                                                                      Planning




The Trading Standards Service is located within the Chief Executive‟s Department. The
Head of Trading Standards reports to the Director of Corporate Resources. The service is
delivered from two offices, County Hall in Norwich and St Margaret's House in King's Lynn.

An organisation chart of the Trading Standards Service is attached at Appendix C.
4.2   Accountability

The Council has 84 elected Members. The Conservatives took control in June 2001.
They hold 47 council seats, Labour 26 and Liberal Democrats 11. The structure of the
Council is shown in the diagram below:


              Joint
          Committees
          (with District
           Councils)
                                     FULL COUNCIL


                                                                      Standards
                                                                      Committee
                                     All 84 Members
          Regulatory                                                Personnel
          Committees                                                Committee




                       CABINET                                         OVERVIEW
                      10 Members                                          &
                                                                       SCRUTINY




                         Service
                       Development
                        Committee

                                                       Cabinet             5 Review
                                                       Scrutiny             Panels
                                                      Committee




The Head of Trading Standards reports to the Fire and Community Protection Review
Panel, which can review and scrutinise any decisions made or action taken. The Trading
Standards Service Plan and the complementary Food Law Enforcement Plan (FLEP -
Annex I) form part of the policy framework of Norfolk County Council. They must therefore
be approved by the full Council, having been prepared by the Cabinet.
4.3     Partnerships

The Trading Standards Service has developed partnerships with a number of agencies in
order to deliver its services more effectively. These are listed below:



PARTNER                                      ACTIVITY
Information and Advice
 Citizens Advice Bureaux
 BBC Radio Norfolk                          Delivery of the Service Level Agreement
                                             between CABx and Trading Standards
 Norfolk County Council Education
   (Basic Skills Unit)                       Consumer Support Network
 Norfolk County Council Youth and           Development Plan which includes
   Community Service                         provision of information and advice in the
 Norwich City Council Advice &              community via information points and
   Information Services                      consumer champions
 Age Concern Norwich
                                             Continued development of
 Age Concern Norfolk
                                             Superconsumer – a project to ensure
 Mancroft Advice Project                    consumer information and advice is
 Norwich City Council                       accessible electronically
 South Norfolk District Council
 Norfolk County Council Cultural
                                             Development of Superconsumer
   Services
 CitA (aka NACAB)                           Development of SLA between CABx and
                                             NCC (including Trading Standards)
     Community Legal Service Partnership    Information and Advice Service
                                             development
     Norfolk County Council Social          Provision of information and advice to
      Services                               elderly and vulnerable people
     Norwich & Norfolk Voluntary Services   Development and promotion of joined-up
                                             working between the County Council and
                                             the Voluntary Sector, including Compact
                                             implementation and development
     Waveney and Norfolk Business Link
     The Norfolk Chamber of Commerce
     The Norfolk Prince's Trust
                                             Provision of business information, advice
     Norwich Enterprise Agency Trust        and services
     Women's Employment, Enterprise and
      Training Unit
     Redundancy Advice Network
     The Office of Fair Trading
                                             Dissemination of consumer and business
     The Department for Environment,        information
      Food and Rural Affairs
                  Partner                                   Activity
                                             Cross referrals and joint enforcement
        Inspection/Enforcement
                                                       and in particular
   District Council Environmental Health
                 Departments                 Development of SUPER - a project to
   District Council Planning Departments    ensure all regulatory information and
   District Council Building Control        advice is accessible electronically
    Departments
   Other Trading Standards Departments      Operation of the Home Authority Principle
   District Council Environmental Health
    Departments
   The Food Standards Agency                Food, animal welfare and animal by-
   The Department for Environment,          products matters
    Food and Rural Affairs
   The Meat Hygiene Service
   The Police                               Serious fraud, Underage sales of alcohol,
                                             Computer forensics, Unroadworthy
                                             vehicles, Photographic evidence and
                                             PNC checks
   Vehicle Examiners                        Unroadworthy vehicles
   The Benefits Agency
   Customs and Excise                       Market trading exercises
   The Inland Revenue
   The Office of Fair Trading               Consumer Credit exchange of information
   The Federation Against Copyright
    Theft and the Federation Against
    Software Theft
                                             Counterfeiting enforcement
   British Phonographic Institute
   The International Federation of Spirit
    Producers UK
   Norfolk Health & Safety Working          Consumer/home safety
    Group
   Norfolk Alliance Against Tobacco         Underage sales of tobacco
   National Newsagent Federation            Promotion of project and trader seminars
4.4.   Membership of Enforcement Forums

       The Service participates in a variety of forums to facilitate the exchange of
       information, ensure consistency of approach and assimilate best practice. The
       main ones are listed below:


                       Forum                                     Purpose


          Norfolk County Council Crime and       To develop partnership working in
           Disorder Reduction Strategy, in         each of the seven district council
           partnership with:                       areas in order to tackle crime and
                                                   disorder in Norfolk
              Breckland District Council
              Broadland District Council
              Great Yarmouth Borough
               Council
              Borough Council of King‟s Lynn
               and West Norfolk
              North Norfolk District Council
              Norwich City Council
              South Norfolk Council
              Norfolk Constabulary and Police
               Authority


          Norfolk Enforcement Liaison Group,     Norfolk based inter agency forum
           incorporating:                          sharing information and participating
                                                   in joint operational activities
              Police
              Customs & Excise
              Benefits Agency
              Health and Safety Executive
              Vehicle Inspectorate
              Inland Revenue
              DVLA


          Government Agencies Intelligence         Regional inter agency forum bringing
           Network                                   together public sector enforcement
                                                     agencies from both central and local
                                                     government, to share intelligence
                 Forum                                 Purpose


   East of England Trading Standards      A partnership between ten local
    Authorities (EETSA)                     authority Trading Standards
                                            Services. Representing the
                                            eastern region as part of the
                                            LACORS liaison structure, it aims
                                            to enhance Trading Standards
                                            Services within the region by
                                            sharing best practice, sharing
                                            resources and providing mutual
                                            support


   Norfolk Food Liaison Group,            The formal liaison group set up in
    including:                              accordance with Food Safety Act
                                            Codes of Practice which require
        Seven Norfolk Environmental        local liaison arrangements between
         Health Services                    food authorities
        Meat Hygiene Service
        Public Analyst
        Public Health Laboratory
         Service (PHLS)


   National Poultry Products Sector       A forum comprising local
    Group                                   authorities responsible for
                                            enforcing Food Standards for
                                            poultry products. Its aims include
                                            sharing information and agreeing a
                                            common enforcement approach to
                                            this manufacturing sector


   DEFRA Regional Liaison Group           Monthly liaison forum, led by
                                            DEFRA in order to facilitate
                                            common enforcement and
                                            information sharing on a range of
                                            issues
                        Forum                                       Purpose


         DEFRA Animal Welfare Liaison               Quarterly regional forum led by the
          Group                                       Divisional Veterinary Manager for
                                                      the Counties of Norfolk, Suffolk and
                                                      Cambridgeshire to agree on local
                                                      arrangements and targets for
                                                      welfare issues


         National Measurement Partnership           A partnership network linking
          (Working Party)                             scientific, industrial and
                                                      governmental organisations as a
                                                      mechanism for promoting better
                                                      measurement practice, supporting
                                                      competitiveness and regulatory
                                                      compliance



4.5   Membership of Business Forums/Business Partnerships

             During 2004/05 the Service plans to work in partnership with Business Link
      and other agencies to develop an initiative on how we can best help businesses to
      comply with trading standards. We will also continue to play an active role in
      existing forums, examples of which include:

             The Federation of Small Businesses
             National Association of Estate Agents
             Society of Valuers and Auctioneers
             Norfolk and Norwich Licensed Vituallers Association
5.     Accessibility


Methods of Access        Level of Availability


(a) Personal Callers        Both the County Hall and St Margaret‟s House offices are
    at Trading               open to the public:
    Standards’ offices
                                       8.45am to 5.30pm Monday to Thursday
                                       8.45am to 4.35pm on Friday
                                             Trading Standards‟ staff, qualified to give
                             consumer advice, are always available at each site and
                             offer a drop-in service


(b)   By Telephone          The Norfolk County Council Customer Service Centre,
                             launched in October 2003, fields all Trading Standards
                             frontline telephone calls, fulfilling those that require only
                             basic information or assisted information and referring all
                             other enquiries to the appropriate Trading Standards‟
                             enforcement team
                            It is operational during normal office hours (see above)


(c)   Answerphone           An automated out-of-hours service directs customers to
                             alternative service provision, such as the Super and
                             Superconsumer websites and informs them of the opening
                             hours


(d)   e-mail                There are two dedicated e-mail addresses for:
                               >       consumers and businesses
                               >       administrative contacts


(e)   Websites              Trading Standards has a dedicated internet site which
                             includes contact details
                            The Trading Standards Service internet site can be
                             accessed via the Norfolk County Council internet site
                            Two internet-based databases, one for regulatory
                             information and advice for businesses (Super) and one for
                             consumer information and advice (Superconsumer) are
                             available on-line
                           Superconsumer is advertised as available on all Norfolk
                            County Council Library computers for public use




(f)   By Post/Fax          The County Hall address appears on all our information
                            resources


(g)   Via Information    There are Consumer Support Network (CSN) Information
      Points              Points in Gorleston Library; Age Concern, Norwich; The
                          Forum, Norwich; and in the foyers of County Hall and St
                          Margaret‟s House


(h) Via Council          The County Council is working in partnership with District
    Information           Councils to relaunch and open a number of Council
    Centres               Information Centres (CICs) in market towns. All CIC staff
                          are provided with training to give frontline Trading
                          Standards‟ information and assisted information and to refer
                          other enquiries to the appropriate Trading Standards‟
                          enforcement team via the NCC Customer Service Centre
                         The Council Information Centres hold a selection of our
                          information sources and it is envisaged that most of the
                          current CSN Information Points will be incorporated into the
                          Council Information Centres


(i) Via Consumer         The Consumer Support Network has provided training and
    Champions             resources to a number of people to allow them to act as
                          consumer champions within their own communities
                         For example a butcher in Hevingham has been trained so
                          as to be able to give basic consumer information and, if
                          necessary, to direct his customers to the best organisation
                          to receive further help. Trading Standards has provided him
                          with a computer so that he and his customers can access
                          our Superconsumer website along with other online County
                          Council resources
(j) Methods of          All guidance material produced by Norfolk Trading Standards
    Access for Those     invites people to request the following alternative options:
    with Special         >          large print
    Needs                >          audio
                         >          Braille
                         >          languages other than English
                          The Council offers interpretation and translation facilities
                           with immediate access, via INTRAN.
                          Minicom facilities are available in the Norfolk County
                           Council Customer Service Centre
             C – ASSESSING COMMUNITY EXPECTATIONS

                                       AND FEEDBACK


6.    Consumer Needs And Expectations
6.1   Reactive Assessment Of Consumer Needs

6.1.1 Consumer Complaint Analysis

      Norfolk Trading Standards records all consumer complaints in accordance with the
      Office of Fair Trading (OFT) Categorisation System. During 2003 we recorded the
      following results for trading practice and goods/services categorisation.


      Trading Practices                % of Total   Goods/Services                       % of Total
                                       Complaints                                        Complaints

      1.    Defective Goods/Services      50%       1.    House Fittings & Appliances       30%
      2.    Selling Techniques            33%       2.    Personal Goods/Services           17%
      3.    Non-Delivery/Delay             7%       3.    Transport                         14%
      4.    Faults Not Put Right           3%       4.    Leisure                           14%
      5.    Prices and Pricing             3%       5.    Other Services                    13%
      6.    Health and Safety              2%       6.    Other Household Requirements      12%



6.1.2 Feedback from Other Agencies

      During 2003/04 the service consulted on the draft Trading Standards Service Plan
      2004/05, seeking the views of a diverse audience which included consumer groups,
      businesses, other enforcement agencies and staff. Feedback from this consultation
      was broadly supportive of the plan both in terms of our strategic aim and objectives
      and our plans (key actions) for 2004/05.

      Where possible we have sought to ensure that this feedback was taken into account
      in this plan. Specific comments (and action taken as a result) are listed below:

      (1)      “There is no mention of those who suffer from disability – they seem to be a
               separate category and should not be included with the elderly”

               ”for consumers would it be appropriate to consider those from minority ethnic
               groups"

               Action - Strategic objectives clarified.
     (2)       “suggest including use of CAB as partner agencies to delivery Key Actions in
               Section 4”.

               Action – this was already reflected via CAB membership of the Consumer
                             Support Network (CSN) in Key Action 4, however we have
               supported this
                             further through the additional Key Target in Key Action 15.

    (3)        “alcohol should be added to the example list of underage products”.

               Action – Alcohol has been added to the list of products in Key Action 4
               (Underage Sales).


6.1.3 Analysis of Make Up of Community

     For a brief overview of the demography of the County, please see Section A.


6.2 Proactive Assessment of Consumer Needs

6.2.1 User Surveys

              Consumer satisfaction surveys are carried out every quarter and comprise at
               least 5% of the contacts for that period. This proactive survey is conducted
               on a random basis incorporating all sections of the service that have direct
               contact with consumers. During 2003 the mean return rate from consumers
               was 44% of the 518 consumers surveyed over the whole year. The survey
               questions are based on the Community Legal Service (CLS) Quality Mark,
               with other additional questions added to target specific service issues. The
               surveys also include a measure of ethnicity, disability, gender and age.

              Currently (up to 31st December 2003) the average satisfaction rate for these
               surveys is 97%, which represents an increase on 2002 when the rate was
               approximately 96%.

              Consumers‟ comments provided as part of these surveys include:

                    I was very grateful of your help and I am certain that without your
                     involvement I would not have received any payment at all. I received
                     £92.76. Very grateful, thank you for all you did. (April 2003)

                    “You are a very useful service and funds could very well be redirected
                     from less useful services to yourselves”. (September 2003)

                    “I have contacted you twice this year to find that you couldn‟t actually
                     do anything more than advise on letter writing which I could do
perfectly well myself”. (September 2003).
                   “I have great difficulty getting though to the correct number. I was
                   given 3-4 different numbers before I got the correct one. I think the
                   number should be in the front of the Telephone Directory with other
                   important numbers.” (April 2003).

                  “On certain issues it would be more effective if you explain more
                   clearly.” (September 2003)


6.2.2 Consultation with Non Users

     (a)   The Citizens‟ Panel

                  The Norfolk-wide Citizens‟ Panel was established in September 1999.
                   It consists of 7000 members with 1000 members based in each of the
                   District Council areas. The first Citizens‟ Panel Questionnaire was
                   sent out to panel members during November 1999.

                  Two questions concerning the Trading Standards Service were
                   included. The first on how Consumer Advice Services should develop
                   in the future and the second on the prioritisation of the Service.

                  Nine out of ten respondents agreed that Consumer Advice Services
                   should both provide customers with a clear assessment of their
                   complaint ie. what chance it has of being successful (93%) and
                   support complainants by taking action on behalf of customers whose
                   own complaints have been ignored (92%). A majority (53%), though
                   much smaller than above, also agreed that the Consumer Advice
                   should be available via regular surgeries at local community centres
                   and village halls.

                  When asked to prioritise the work of the Trading Standards Service,
                   very few respondents were prepared to class any of the aspects of
                   work put before them as a low priority. In fact, a majority of
                   respondents believed every one of the aspects was a high priority.
                   Top of the list of priorities, however, was product safety – investigating
                   the safety of all consumer goods (79%). A little way behind this came
                   ensuring animal welfare (70%), fair trading activities (69%), such as
                   ensuring legally required information about goods is accurate and
                   displayed where appropriate, food contents and labelling (67%), and
                   regulating finance and credit organisations (65%).

                  A second citizens‟ panel questionnaire was sent out in July 2002 this
                   time focussing on awareness of consumer rights and faulty
                   goods/services.
                Panel members tended to guess correctly when considering their
                 consumer rights. The majority were incorrect, however, regarding
                 their consumer rights when purchasing goods by mail order or over
                 the internet.

                Views were more confused about faulty goods and services overall,
                 with the majority incorrectly stating that shops have the right to try and
                 repair faulty goods before offering a refund.


(b)      Readers‟ Panel

         During 2003 we recognised that, due to the recent changes in consumer
         legislation, our range of “Your Guide to..” consumer leaflets required
         updating.

         We asked the Readers‟ Panel to consider and review the new leaflets before
         going to print. The Readers‟ Panel is made up of volunteers, comprising four
         groups with twenty-one people on each. The content of the new leaflets was
         provided in the form of word documents, with the old style leaflet also sent
         out to accompany the new text. The purpose of this was so that we could
         obtain comments on the design, style and artwork of the leaflets.


     Feedback

         We received a very good response to our questionnaires from the Readers‟
         Panel, with 111 returned out of the 140 sent out, nearly 79% of the
         volunteers responding.

         A full report of all comments made is available however we have provided a
         summary of the main issues that were highlighted by the panel below, along
         with action taken in terms of revisions to the leaflets.

     Artwork & Design

         11% of the panel stated that the front cover was dated and far too simplistic.

         “The sample of the old leaflet has a very old-fashioned look and something
         more up to date, especially on the front cover, would help to make it look
         more „pickupable‟ and 21st Century.”

         “The design cover of the „old publications‟ is not very appropriate for the
         young who are the ones most likely to find the information useful.”

         All the front covers have been redesigned so as to be more eye-catching to
         consumers, whatever their age, and to modernise the general style of the
         leaflets.
   Advertising

       Nearly 6% of the panel commented on the fact that our leaflets needed to be
       advertised locally.

       “I had no idea leaflets like these existed. Do you promote them at all?”

       “I was not aware of the existence of the current leaflet and wonder how
       people get to know about it and where they can obtain it.”

       Due to the above responses, leaflets will be promoted throughout the county
       via the Consumer Support Network, being made available to other statutory
       and voluntary agencies. The leaflets will also be made available in all
       Council Information Centres, as well as via the Superconsumer and Trading
       Standards‟ websites.

   General

       16% of the group made comments in relation to general changes (including
       language) that they felt should be made to the leaflets.

       “Would like details of approximate cost of starting legal action”.

       “0844 number should indicate what call rate is e.g. local rate, national rate,
       premium.”

       “The word “trader” is confusing. Some may confuse it to mean, “market
       trader”. What about “company”, “retailer” or “retail company”.

       “The word “onus” not commonly known”.

       Unfortunately, we are unable to provide details of all the costings for
       instigating legal action, as there are many differing fees to be paid,
       depending on the amount being claimed. However, we do provide leaflets to
       consumers in relation to County Court fees if this is requested or appropriate.

       The new Customer Service Centre telephone number indicates, on the
       leaflet, that the cost of a call is at a local rate, the word “trader” has been
       replaced by “business” and “onus” has been removed from the publications.


   Sample Letters

       There was mixed feedback in relation to the sample letters.

       Positive

       “Template letters and checklist – excellent”.
      “An excellent idea to give “letter” examples. They are so easy to follow”.

      Negative

      “Instead of saying, „choose the point below that applies and cross out the
      others‟ – it should read „choose the point below that applies and include it in
      your letter‟”

      “It would be better to include the template letters in the booklet itself to avoid
      them becoming separated”.

      The sample letters have been revised to make the appropriate instructions
      clearer to the general consumer. Unfortunately, it is not economically
      possible to attach the letters to the leaflets at this stage.


(c)   Community Research

         In 1999, a consumer consultation exercise was undertaken. The key
              findings of which were:

                  The need for help and assistance with Trading Standards issues
                   is most acute with young people and those in disadvantaged
                   areas. However, use of the enquiry line is skewed towards an
                   older, more affluent section of the population. Use of the
                   service is deriving from word of mouth. Targeted promotion of
                   the service is therefore a priority, with a particular focus on
                   young people and deprived areas.

                  Consumers feel strongly that a higher level of service is required
                   and should be available for everyone. Consumers want a
                   service where they get:

                     a clear assessment of their enquiry‟s viability
                     hand-holding where this is productive
                     importantly, a defined conclusion (successful or not).

            During 2001 a consultation exercise was conducted to examine both
             the supply and demand sides of the local economies in examples of
             the 20 most deprived wards in Norfolk. The research was targeted at
             those residents that, it was felt, represent those people with the
             greatest need:

                  young teenagers who are starting to purchase for themselves;
                  low income families;
                  independent older people still purchasing for themselves.
          The key message from the consultation was that Trading Standards
           should adopt the role of “expert friend” to show ways to access the
           best value choices. The stance and tone adopted by Trading
           Standards is critically important.

          Specific recommendations (as detailed in Appendix D) have directly
           influenced the manner in which we deliver our services. This is both
           in terms of policy and specific plans, with those for 2004/05 detailed in
           Section D to this service plan. However, actual links are provided
           below:

               OPERA Recommendation                 2004/5 Key Action Reference
                  reference number(s)                        Number(s)
           1,2,3,4,5,6,7,8,15,18,19,20,21          15
           9,25                                    16
           9,17                                    Under review
           10,11,12                                15, 16
           16                                      15, 19
           13,14                                   1
           22                                      15, 7
           23                                      8
           24                                      9, 15
           26                                      4, 9, 15


(d)   Best Value

          The Audit Commission inspected the Best Value Review of Trading
           Standards in November 2001 and made the following comments
           concerning how best to take forward the needs of consumers:

                  improve customer access to the service generally, especially for
                   disadvantaged groups;
                  physical access to the consumer advice service is not good.

          Since the Best Value Review we have taken steps to improve
           accessibility of our service. Key Actions 14 & 15 in Section D to this
           Service Plan take this forward in 2004/05.
7.    Needs and Expectations of Local Business
      Sectorally, the Norfolk economy is made up of a wide range of activities, with no
      particularly dominant sector. Despite steady job losses, manufacturing remains a
      very significant employer (along with public administration). Norfolk County Council‟s
      Shaping the Future Strategy identified the following nine business sectors as having a
      key role to play in the economic prosperity of the County:

          Agriculture and Food Processing
          Boat Building
          Business and Financial Services
          Creative Industries
          Energy
          Engineering and Electronics
          Health and Life Services
          Information and Communications Technologies
          Tourism

       The economy is dominated by Small and Medium Sized Enterprises – especially
       micro-businesses. Over 90% of firms employ less than 25 people, but this provides
       only 25% of total employment in businesses. Larger firms (over 200 employees)
       account for only 1% of the stock but provide almost half the jobs.

7.1    Reactive Assessment of Local Business Needs

7.1.1 Analysis of Business Requests

             The type and nature of business requests to the service are not recorded in
              as detailed a format as consumer complaints. However the following
              breakdown of requests received during 2003 provides a useful assessment
              of business needs during that period:

                   Total number of requests – 2285
                   Request breakdown by premises type:


                          Premises Type                    % of Requests
                 Retailers (non food)                          30%
                 Agriculture/Hunting/Forestry                  14%
                 Other Businesses                              14%
                 Food Retailers/Catering                       11%
                 Service Industry                              10%
                 Food Manufacturers                            10%
                 Non Food Manufacturers                         7%
                 Packers/Importers/Wholesale                    4%
7.1.2 Analysis of the Demands of Home Authority Work

            The Trading Standards Service remains strongly committed to the Home
             Authority Principle and has a good reputation for the service it provides in
             this area. Increasingly the support offered to Home Authority Businesses is
             as much to do with the wider economy and a level playing field as it is about
             protecting consumers. However this work is no less important when set
             against the need to support business infrastructure within the county,
             highlighted by the importance of larger firms in providing employment.

            The extent of Home Authority demand can be measured in terms of:

                  the number of Home Authority businesses – 78
                  the number of Home Authority requests for advice – 102
                  the number of Home Authority referrals/complaints – 324

             N.B. These figures are for 2003 and whilst they do not represent a large
             number compared to all premises/requests/complaints, they generally
             represent high level detailed enquiries, which can be very time consuming.

            The breakdown below details the proportion of requests by business type
             and broadly reflects the fact that the biggest demand has historically been
             from food manufacturers. This is not surprising given the rural and
             agricultural base of the County.


                                                          Percentage of Home
                                                          Authority Requests
             HOME AUTHORITY BUSINESS TYPE
                  Food Manufacturers                              45%
                  Large Retailers                                 30%
                  Non-Food Manufacturers                          8%
                  Packers/Importers/Wholesalers                   8%
                  All Other Business Activities                   9%

7.1.3 Assessment of Business Needs Arising from New Legislation

     The following areas have been identified as likely to have a degree of impact on
     businesses during 2004/05. Each area has also been assessed as to the likely
     input required from this service, in order to support businesses in their attempts to
     implement new legislative requirements.
                                Impact on Business           Trading Standards Input Required
 New/Proposed Legislative
      Requirements                                   Inspection/                             Mail
                                                                   Seminars    Media/
                                Significant   Some    Sampling                            Shots/Web
                                                                    /Talks    Marketing
                                                     and Advice                              Info
Food Standards
New Meat Product
                                                                               
Regulations
New Chocolate Product
                                                        
Regulations
New Allergen Labelling
                                                                                              
Regulations
New rules on Traceability                               
Consumer Law
New Consumer Goods
                                                                                             
Regulations
Consumer Protection
(Distance Selling)                                                                            
Regulations
The Enterprise Act                                                                            
Consumer Safety
New Firework (Safety)
Amendment Regulations                                               
2004
New General Product Safety
                                                                                              
Regulations
Animal Health and
Agriculture
New Animal By Product
                                                                                             
Regulations
The Horse Passport
                                                        
Regulations 2003/2004
New Feedingstuff & Fertiliser
                                                        
Regulations
Consumer Credit
New Advertising Regulations,
Early Settlement Regulations,                                                               
Agreement Regulations
Metrology
Extended Weighing Machine
                                                                                              
Requirements (NAWI)
Ongoing Implementation of
                                                        
Metrication Requirements
Review of Part IV and Part V
Weights & Measures Act (and                                                                  
Regulations)
Pricing
Revised Code of Practice for
                                                                                               
Traders on Price Indications
7.1.4 Analysis of Inspections

      (a)   Quantitative Findings

                  In all there were 7904 enforcement visits made to Norfolk Businesses
                   during 2003.
                  These visits were made for a number of reasons, for example:

                          as a result of a consumer complaint
                          as part of a specific project
                          following a request from a business
                          as part of the risk based inspection programme
                          following receipt of hazard information/intelligence

                  Activities at the premises inspected are listed below along with
                   respective figures for areas found to require attention:


                                 Activity                  Number and       Number and %
                                                             % of All              of
                                                             Checks         infringements
                                                                                 found

                          Checks on Fair Trading
                                                            3898 (36%)            1553 (58%)
                           Issues


                          Ensuring Safety of
                           Consumer Goods and               2205 (20%)             206 (8%)
                           Underage Sales


                          Checks on Food and
                                                            1652 (15%)            325 (12%)
                           Agricultural Standards


                          Inspecting and Verifying
                           Weights and Measures             1238 (12%)             234 (9%)
                           Equipment


                          Protecting Animal Health
                                                            1128 (11%)            340 (13%)
                           and the Food Chain


                          Auditing Control Systems                          Information Not
                                                             643 (6%)
                           and Staff Training                                   Available
(b)   Qualitative Feedback from Staff

           Inspection staff were asked to consider the following three questions:

                  What are the most common areas where businesses state that
                   we do well in meeting their needs?

                  What are the most common areas where businesses state they
                   need improved service from Trading Standards?

                  What are your recommendations for delivering this need to
                   businesses?

      In response to these questions, staff made the following comments:

           Things we do well:

                  Our information fact sheets generally and specifically our
                   underage sales pack.
                  Good, impartial advice service.
                  Our inspection programme, raising the service profile.
                  Prompt response to queries.

           Common business needs:

                  More/specialist advice on:
                         - pricing
                         - safety
                         - food

                  Better access to the service, eg. by phone or by the internet.
                  More preprinted fact sheets.
                  “Frequently asked questions” literature

           Ways we could improve/deliver on business needs:

                  Increased marketing of the service.
                  Focussing also on the “level playing field” by tackling
                   infringements by bigger companies, and by itinerant traders.
                  Adopting other methods of routine contact e.g. email, letter,
                   short visits etc.
7.1.5 Business Profile

                      Description                                             Number
Businesses
                     This brings consistency to statistics between       28,167
registered for       authorities. Give most recent figures.
business rates
Home Authority
                     Following LACOTS Home Authority principle
Firms: formal        guidance. Give estimate at end March 2004.
                                                                              0
agreements
Home Authority       Number of traders you recognised as being based in
Firms: informal      your area and about which you will take enquiries.      78
recognition          Give estimate for end March 2004.
Enquiries received Include figures from other enforcement agencies.
concerning your      Exclude consumer complaints and enquiries and
                     requests for business advice. Give estimate for end
                                                                            237
Home Authority
firms.               March 2004.
*Risk Assessment: assessment of risk a business poses to consumers and competitors to
determine frequency of inspection visits and appropriate enforcement
High                 Follow LACOTS guidance on premises risk                 47
                      assessment (revised and issued early 2002). Give
Medium                figures from your database for year end for the                   1523
                      number of businesses based, or with physical
Low                   premises, in your local authority area. This can                 10,902
                      include internet sites where the supplier is based in
No inspectable risk   your area, stalls and other mobile traders as well as             7,648
                      fixed premises.

*Note: this risk assessment profile is subject to review following the issue of the new
       LACORS Risk Model. Full implementation of the model is anticipated by the end of
       March 2004.
7.2 Proactive Assessment of Local Business Needs

7.2.1 User Surveys

           The Trading Standards Service regularly surveys business customers to
            assess their level of satisfaction with the services it provides. Satisfaction
            Surveys are sent out quarterly to a random selection of those who have had
            contact with the Service.

           Business satisfaction surveys are carried out in two ways:

                 Businesses which request information or advice are surveyed in the
                  same way as consumers i.e. every quarter and at least a 5% random
                  sample of traders who have made requests. The questions are based
                  on the Community Legal Service (CLS) Quality Mark, with other
                  additional questions added to target specific service issues. Race,
                  gender, age and disability monitoring is also included.

                 Businesses which received proactive visits by enforcement staff are
                  surveyed independently for satisfaction with our enforcement
                  practices. This is also carried out every quarter and at least a 5%
                  random sample is selected. The surveys also include a measure of
                  ethnicity, disability, gender and age.

                  The mean return rate for both surveys is approximately 39%.

            Currently (up to December 2003) the mean satisfaction rate is 97%, which is
            identical to that of the same surveys carried out in 2002.

        Business comments include:

                 “The visit was carried out very professionally and very polite”. (June
                  2003.)

                 Very helpful, plain speaking, gave good advice that we acted on. Too
                  many times, consumers bully the company. Your advice was clear
                  and gave us the direction to resolve the matter. Thank you.
                  (February 2003)

                 “I had a simple question that with a bit of research, on your part, could
                  have been resolved. I was sent out different literature giving generic
                  information that I already knew about”. (June 2003)

                 “Told that I would be contacted within 3 days this is no good if you
                  require an immediate answer”. (October 2003)
        The Metrology Service delivers commercial calibration services to customers
         across Europe. Clients of the service have high accuracy calibration needs. A
         programme of proactive postal surveys of these customers is carried out
         quarterly to ascertain their perception of the service received and their future
         needs. Approximately 40% of Norfolk Calibration customers are surveyed over
         the year by randomly selecting 10% every quarter.

         Currently (up to December 2003) the satisfaction rate is 100% of customers
         surveyed. This maintains the same excellent satisfaction rate during the 2002
         service year. The return rate is 72%.

         Comments by these customers include:

                  “The service we received from the team was excellent. We have used
                   the services before and there has been an improvement, which was
                   made more impressive by the fact that previous experiences had been
                   more than satisfactory”. (August 2003)

                  “This service has had a consistently high level of service during the life
                   of the contract between ourselves”. (December 2003)

                  “I do not believe that your services are as well known to local trade as
                   it could be”. (August 2003).



7.2.2 General Business Surveys/Consultation

           Two major consultation exercises involving business clients have been
            conducted by Trading Standards in recent years. The research objectives of
            the first, conducted in 1999, were:

                  to understand customer expectations of the Trading Standards
                   Service
                  to assess the Service‟s actual performance against current
                   expectations
                  to recommend how the Service should be evolved in order to improve
                   service quality.

        The survey involved:

                  Four discussion groups with

                   -   Home Authority businesses
                   -   Tourism and leisure businesses
                   -   Farmers
                   -   New businesses
        a random selection of Norfolk businesses
        a random selection of businesses who had contacted Trading
          Standards with a business enquiry in the previous year.

   The key findings of the business survey were:

        There are specific areas of business where a lack of understanding of
          the role of Trading Standards is acute:

          -   farmers
          -   start-up businesses.

         Home Authority businesses represent a very distinct group; they are
          well aware of the service Trading Standards provides and are very
          pleased with the relationship they enjoy.

         All businesses felt strongly that an enabling and educational role was
          the correct and ultimately more efficient stance for the Service.

         The idea of a single contact number for businesses is by far the most
          important service development for this group, and should be
          prioritised.

         The development of a mediation service would appear to be a positive
          step.

   The second consultation exercise was conducted in 2001 and was designed
    to examine both the supply and demand sides of the local economies in
    examples of the 20 most deprived wards in Norfolk.

   As already referred to in Section 6.2.2 above, the key message from the
    consultation was that Trading Standards should adopt the role of “expert
    supporter” to show traders ways to protect their business and to achieve the
    balance of rights and responsibilities.
8.   Awareness of Trading Standards

        Local awareness of Trading Standards has historically only been measured
         in general terms.

        The Citizens‟ Panel questionnaire sent out in November/December 2001
         revealed that 5% of respondents had contacted the Trading Standards
         Service during the last 12 months.

        This appears to be broadly in line with a DTi consumer knowledge survey
         conducted at the end of 2000. This established that, amongst the small
         minority of complainants who do take further action when their problem is not
         resolved by the product seller or service provider, just 4% get in touch with
         their local Trading Standards Department.

        The qualitative consultation exercise conducted by Trading Standards in
         2001 revealed that, in general, awareness of Trading Standards was low.

        Specifically:

             older people tend to rely on long-trusted sources for information, such
              as Citizens Advice Bureaux (CABx) and do not have an extensive
              knowledge of Trading Standards.
             amongst low-income families there is a general awareness of Trading
              Standards but not of its role. CABx tend to be relied on for advice.
             teenagers have little knowledge of Trading Standards and rely on their
              parents to take action to protect consumer rights.
             for businesses, there is confusion between the role of Trading
              Standards and that of Environmental Health.

        However the more recent Citizens‟ Panel questionnaire, sent out in July
         2002, indicated an awareness level of the Trading Standards Service of 80%.
         This is higher than the result of a recent national survey, conducted by the
         Department of Trade and Industry (DTi), which put the overall awareness of
         Trading Standards at 72%.

        Despite this apparent high awareness of Trading Standards amongst Norfolk
         citizens, a significant number of respondents to our satisfaction surveys
         comment about their lack of awareness, examples being:

         “I had great difficulty getting through to the correct no; I was given 3-4
         different no before I got the correct one. I think the number should be in the
         front of the Telephone Directory with other important no and did get good
         advice finally. Thank you”. (April 2003)

         ”Does everyone know you are there?” (Sept 2003)
            During 2003/04 a cross party member/officer group scrutinised the work of
             Trading Standards. Its remit was to recommend innovative ways to ensure
             that all the people of Norfolk understood the value of the service delivered by
             Trading Standards. This work will be taken forward through the development
             of our Marketing and Publicity Strategy (Key Action 19, Section D)


9.     Customer Care Strategy
       For the 2004/05 service year, Trading Standards is to adopt a comprehensive
       Customer Care Strategy (and supporting action plan) which is appended to this
       service plan as Appendix F. The strategy is designed to promote active
       engagement with all our customers and stakeholders across the Trading Standards
       Service so that we become more responsive to our customers‟ needs.

10.    Demand for Specialist Services
10.1   Calibration and Metrology Services

       During 2003/04 income generated from calibration and verification services is
       projected to increase by 27% and 14% respectively. The success of the unit in
       terms of generating calibration income has offset, so some extent, the trend of
       falling verifications income, as self-verification become more widespread. However
       it is recognised that marketing strategies must be rigorous to ensure continued
       growth and this is reflected by the Key actions and targets set out in Section D of
       this Service Plan. During 2003/04 the number of staff within the Unit was increased
       to 5 FTE, in order to accommodate the increase in demand.


10.2   Legal Services

       In order to ensure high levels of consumer protection it is vital that the Trading
       Standards Service has an effective criminal prosecution service. It can be argued
       that any trading standards advice will be ignored by those traders wishing to comply
       with the law if no action is taken against those who choose to breach it.

       The Trading Standards Service operates a Legal Process Unit, which takes all the
       Service's prosecutions before the courts. Trading Standards is a specialised area
       of law and this has been found to be a very successful and cost-effective means of
       securing convictions. In addition, insights gained in court have allowed the Legal
       Process Unit to provide on-going training to Enforcement Staff in terms of
       investigative techniques.
  PART TWO



 D – PROVISIONS FOR
NATIONAL AND LOCAL
      PRIORITIES
D - PROVISIONS FOR NATIONAL AND LOCAL PRIORTIES


The following Section sets out the key improvement areas for the Trading Standards
Service during 2004/05, working towards the national priorities listed below:



NO               KEY IMPROVEMENT AREA                          NATIONAL PRIORITY


      TO PUT RIGHT DETRIMENTAL TRADE                      Enforcement of a Fair and Safe
 1
      PRACTICES AND DETER ROGUE TRADERS.                  Trading Environment


      TO REDUCE RISKS FACED BY NORFOLK                    Enforcement of a Fair and Safe
 2
      CITIZENS                                            Trading Environment

                                                          Enforcement of a Fair and Safe
      TO SECURE A FAIR AND SAFE TRADING                   Trading Environment
 3    ENVIRONMENT THROUGH PROACTIVE                       Efficient, Effective and
      ENFORCEMENT                                         Improving Trading Standards
                                                          Service
                                                          Informed Confident Consumers
      TO ACHIEVE GREATER COMMUNITY                        Informed Successful
      ENGAGEMENT THROUGH OUR                              Businesses
 4
      INFORMATION, ADVICE AND EDUCATION
      SERVICES                                            Efficient, Effective and
                                                          Improving Trading Standards
                                                          Service

      TO CONTINUE TO IMPROVE THE EFFICIENCY Efficient, Effective and
 5    AND EFFECTIVENESS OF THE TRADING      Improving Trading Standards
      STANDARDS SERVICE                     Service



Each key improvement area links directly to the national standards and to the County
Council‟s local priorities. Each has associated key actions and targets for improvement
during 2004/05.
This section also provides for the implementation of specific plans where these are
required as part of additional framework responsibilities, namely:

        Key Action No. 11 - The Food Law Enforcement Plan

        Key Action No. 4 - The Enforcement of Age Restricted Sales via our Minor Sales:
                            Major Consequences Plan

        Key Action No. 11 - The Farm Enforcement Plan

Each of these specific plans includes key actions and targets of its own, to take forward
those parts of the service. All three plans are annexed to this service plan such that:

      Annex I - Food Law Enforcement Plan (FLEP)
      Annex II - Minor Sales: Major Consequences Plan (MSMCP)
      Annex III - Farm Enforcement Plan (FEP)


This section also makes reference to several other policies, plans and strategies which
underpin the following Key Actions:

        Key Action No. 2 - Enforcement Policy (see Appendix E)
        Key Action No. 16 - Consumer and Business Education Programme
        Key Action No. 17 - Customer Care Strategy
                             (see Appendix F)
        Key Action No. 17 - Benchmarking Strategy
        Key Action No. 18 - Intelligence Strategy
        Key Action No. 19 - Marketing/Publicity Strategy
        Key Action No.21 - Health, Safety & Welfare Plan
        Key Action No. 22 - Learning and Development Plan

The most significant of these are appended to this Service Plan as indicated above.
KEY IMPROVEMENT AREA NO. 1:
     TO PUT RIGHT DETRIMENTAL TRADE PRACTICES AND DETER
     ROGUE TRADERS

Working towards the following National Standards and local priorities of Norfolk
County Council:

National Standards

ENFORCEMENT OF A FAIR AND SAFE TRADING ENVIRONMENT
14a    Principles of good enforcement that meet the requirements of the Enforcement
       Concordat and take into account the Code of Crown Prosecutors.
14e    Targeting traders or business sectors which are known to give rise to high level of
       problems.
14f    Tackling practices which target the vulnerable and socially excluded.
14g    Arrangements through Trading Standards regional coordinators and/or which other
       enforcement agencies (including central government agencies) to target rogue
       traders and unsafe or misdescribed goods to avoid duplication.


Local Priorities of Norfolk County Council


SAFE
(10)   Strengthen our contribution towards reducing crime and disorder, and take steps to
       make local communities safer.
(12)   Helping young people resist drug misuse and work with people with drug problems
       to overcome them and live healthy crime-free lives.
(15)   Ensure consumers and businesses are exposed to less trading malpractice through
       the provision of information and advice, interventions and formal investigations.
                                                                                                                         Link to
                                                                    Key Targets                                         Priority/
                                                                                                                        Standard
KEY ACTION

1. Respond to all               (a) At least 90% of detrimental trade practices put right.
   consumer complaints          (b) All fair trading referrals not requiring intervention closed out within 3 working
   and business enquiries           days.
   putting right at least 90%
   of detrimental trade         (c) 80% of fair trading referrals requiring intervention closed out within 10           15   14a
   practices where these            working days.
   occur.                       (d) 100% of fair trading referrals closed out within 40 working days (unless there
                                    are wholly exceptional circumstances such as the initiation of a formal
                                    investigation)

2. Carry out proactive          (a) The following investigation work carried out:
   investigation work in the        Underage sales             - 86 staff days
   following areas:                 Bogus callers etc          - 36 staff days
    Underage sales                 Unroadworthy vehicles      - 24 staff days
    Bogus callers, rogue           Persistent offenders       - 24 staff days                                               14a
                                                                                                                        10
       doorstep sellers and         Complaint led              - 300 staff days                                              14e
                                                                                                                        12
       other Trade                                                                                                           14f
                                (b) 90 Formal Investigations undertaken                                                 15
       Descriptions Act                                                                                                      14g
       offenders                (c) A successful conviction achieved in at least 87.5% of prosecutions.
    Unroadworthy
                                (d) Enforcement Policy (see Appendix E) reviewed on an annual basis
       vehicles
    Persistent offenders.
3. Make effective use of new     (a) Intervention Policy implemented and monitored.
   powers involving                                                                                                  14a
                                 (b) Enforcement Orders used as a new tool in responding to consumer
   Enforcement Orders to                                                                                        10   14e
                                     complaints.
   tackle persistent offenders                                                                                  15   14f
   of trading law.               (c) Persistent offenders of trading law targeted, based on intelligence.            14g
                                 (d) The percentage of traders prosecuted for trading offences who do not re-
                                     offend within two years to equal 90% or better.
KEY IMPROVEMENT AREA NO. 2:
     TO REDUCE RISKS FACED BY NORFOLK CITIZENS

Working towards the following National Standards and local priorities of Norfolk
County Council:

National Standards

ENFORCEMENT OF A FAIR AND SAFE TRADING ENVIRONMENT
14a    Principles of good enforcement that meet the requirements of the Enforcement
       Concordat and take into account the Code of Crown Prosecutors.
14c    A programme of enforcement activity that is informed and linked to recognised risk
       assessment analysis, and which reflects appropriate levels of enforcement.
14e    Targeting traders or business sectors which are known to give rise to high level of
       problems.
14f    Tackling practices which target the vulnerable and socially excluded.
14g    Arrangements through Trading Standards regional coordinators and/or which other
       enforcement agencies, (including central government agencies) to target rogue
       traders and unsafe or misdescribed goods to avoid duplication.



Local Priorities of Norfolk County Council


SAFE
(10)   Strengthen our contribution towards reducing crime and disorder, and take steps to
       make local communities safer.
(12)   Helping young people resist drug misuse and work with people with drug problems
       to overcome them and live healthy crime-free lives.
(14)   Reduce the frequency and impact of fires and deal with fires and respond to other
       emergencies promptly and efficiently
(15)   Ensure consumers and businesses are exposed to less trading malpractice through
       the provision of information and advice, interventions and formal investigations.
1.2.1.2
Healthy and Well
(5)    Support older people to live at home wherever possible and to lead independent,
       fulfilling and safe lives.
Inclusive and Diverse
(3)   Maximise the positive impact of all services on disadvantaged and excluded people.
                                                                                                                    Link to
                                                                 Key Targets                                       Priority/
Key Action                                                                                                         Standard

4. Reduce the incidence of    (a) Contribute to the work of the seven Crime & Disorder Reduction Partnerships
   anti-social behaviour by       as appropriate.
   tackling the under-age                                                                                               14a
                              (b) Minor Sales: Major Consequences Plan (see Annex II) implemented by
   sale of items such as                                                                                           10   14c
                                  31st March 2004
   alcohol, tobacco,                                                                                               12   14e
   solvents, fireworks and    (e) Work under the Minor Sales: Major Consequences Plan (see Annex II)               15   14f
   videos, via our Minor          delivered and further developed by 31st March 2005.                                   14g
   Sales: Major
   Consequences Plan.

                                                                                                                        14a
5. Reduce crime and the       (a) Establish a multi-agency initiative to tackle bogus callers and rogue doorstep   10   14c
   fear of crime amongst          sellers.                                                                          5   14e
   older people by tackling
                                                                                                                   15   14f
   bogus callers and rogue
                                                                                                                        14g
   doorstep sellers.

6. Combat unsafe food,        (a) Establish a multi-agency enforcement group – Norsafe                                  14a
   accommodation and                                                                                               10   14c
                              (b) Establish a partnership with the principle further education institutions in     14   14e
   consumer goods.                Norfolk with a view to the development of a “safe student accommodation”         15   14f
                                  registration scheme                                                                   14g
KEY IMPROVEMENT AREA NO. 3:
     TO SECURE A FAIR AND SAFE TRADING ENVIRONMENT THROUGH
     PROACTIVE ENFORCEMENT
Working towards the following National Standards and local priorities of Norfolk County
Council:

National Standards

ENFORCEMENT OF A FAIR AND SAFE TRADING ENVIRONMENT
14a Principles of good enforcement that meet the requirement of the Enforcement Concordat
    and take into account the Code of Crown Prosecutors.
14b The operation of the Home Authority principle in accordance with LACORS guidance
    including responding to queries from other authorities.
14c A programme of enforcement activity that is informed and linked to recognised risk
    assessment analysis, and which reflects appropriate levels of enforcement.
14d Enforcement arrangements for e-businesses/e-commerce.
14g Arrangements through Trading Standards regional coordinators and/or with other
    enforcement agencies, (including central government agencies) to target rogue traders and
    unsafe or misdescribed goods to avoid duplication.
14h The inspection of metrological equipment and goods based on risk assessment.
    Verification of equipment and arrangements for joined up working on legal metrology issues.
EFFICIENT, EFFECTIVE AND IMPROVING TRADING STANDARDS SERVICE
15h Evaluating and improved joined up working and coordinated activities for enforcement,
     advice and information sharing.
15i  Plans for responding to emergencies effectively.

Local Priorities of Norfolk County Council



Safe
(15) Ensure consumers and businesses are exposed to less trading malpractice through the
     provision of information and advice, interventions and formal investigations.
(14) Reduce the frequency and impact of fires and deal with fires and respond to other
     emergencies promptly and efficiently.

Economically Thriving
(35) Promote Norfolk as a good place for business.
(32) Help businesses to develop in Norfolk and improve travel, transport and IT links.

Environmentally Responsive
(25) Reduce waste and improve recycling.
(26)   Protect and sustain the environment.

Accessible & Well-Housed
(39) Improve electronic access to services and information.
Underpinning our work to deliver these high priorities is the need to:
(40) Ensure staff are equipped and supported to help give a better public service.
                                                                                                                Link to
                                                                Key Targets                                    Priority/
                                                                                                               Standard
Key Action

7. Implement an effective    (a) All high risk businesses inspected at least once a year. (100% of total)
    business inspection      (b) Medium risk businesses receive an inspection and/or alternative enforcement
    programme, based on          action once every two years. (50% of total)
    risk.                                                                                                      15   14a
                             (c) Low risk businesses receive an inspection and/or alternative enforcement      35   14c
                                 action once every four years. (25% of total)                                  32   14d
                             (d) A premises data collection and updating system implemented to inform the
                                 inspection programme.
                             (e) Establish an inspection programme of virtual business premises.

8. Improve standards of      (a) “How am I Trading?” Scheme launched
   fair trading though the   (b) 1000 businesses signed up to the “How am I Trading?” Scheme.
   introduction of a fair
   trading scheme and by     (c) Revised Home Authority Strategy implemented by 1st April 2004.                15   14a
   helping Norfolk based     (d) Home Authority Strategy operated successfully throughout the year.            35   14b
   businesses to comply                                                                                        32   14c
   with trading law,         (e) Product pricing monitoring project undertaken.
   protecting them from
   unfair competition.
                                                                                                                   Link to
                                                                  Key Targets                                     Priority/
                                                                                                                  Standard
Key Action

9. Participate in national,    (a) Participate in appropriate local/regional/national liaison groups, including
   regional and local              EETSA.
   project initiatives,        (b) Review of our partnership arrangements to ensure that they continue to
   working with our                                                                                               15
                                   provide the best means of service delivery or information sharing by 31st           14c
   partners to target                                                                                             35
                                   March 2005.                                                                         14d
   enforcement and raise                                                                                          32
   awareness.                  (c) Participate in the ICPEN 2005 project.                                              14g
                                                                                                                  25
                                                                                                                       15h
                               (d) Establish common ground with other agencies on packaging waste                 26
                                   reduction.
                               (e) Tackle the issue of heavy vehicles travelling on unsuitable roads in the
                                   County to improve environmental sustainability.

10. Protect consumers from     (a) Plans for inspection and/or sampling activities devised by 1st April 2004.
    dangerous consumer         (b) Work in partnership with Norfolk Police and Fire Service on the sale and
    goods such as electrical       storage of fireworks.
    products, fireworks and
    toys, through a rigorous   (c) Project relating to the safety of inflatable swimming aids undertaken.         15   14c
    testing programme.                                                                                            35   14g
                               (d) Project relating to the safety of secondhand electrical products undertaken.
                                                                                                                  14   15i
                               (e) Planned activities delivered and reported on by 31st March 2005.
                               (f) Fundamental review of our emergency response to consumer safety issues
                                   conducted (to bring our procedures in line with our Food Hazard response)
                                   by 1st October 2004.
                                                                                                              Link to
                                                                   Key Targets                               Priority/
                                                                                                             Standard
KEY ACTION

11. Ensure safety in the food   (a) Food Law Enforcement Plan (see Annex I) implemented by 1st April 2004.
                                                                                                                  14a
    chain by implementing a     (b) Food Law Enforcement Plan (see Annex I) delivered by 31st March 2005.    15   14c
    dedicated programme of
                                (c) Farm Enforcement Plan (see Annex III) implemented by 1st April 2004.     14   14g
    checks on food quality
                                                                                                             40   15h
    and standards of Animal     (d) Farm Enforcement Plan (see Annex III) delivered by 31st March 2005.           15i
    Health and Welfare.


12. Increase our capacity to    (a) All Norfolk County Council Weighing and Measuring equipment kept in
     meet the demand from           calibration at all times.
     businesses, local
                                (b) Metrology calibration income exceeds £41,000.
     authorities and other
     agencies for our           (c) UKAS accreditation for Gravimetric calibration achieved.
     metrological and           (d) Temperature calibration services established.                            32
     technical services.                                                                                     35   14h
                                (e) Client base extended by 10%.                                             39
                                (f) At least two new partnership/alliances developed.
                                (g) Our metrology services website upgraded.
                                (h) Strategy concerning the implementation of the Measuring Instruments
                                    Directive (MID) developed by 31st May 2004.
13. Improve the targeting of   (a) Strategy implemented and delivered by 31st March 2005 to inspect weighing
    our checks on the              and measuring equipment, including:
                                                                                                                    14a
    accuracy of weighing
                                     50% of oil meters                                                        15   14c
    and measuring
                                     Weighbridges (100% public 35% private)                                        14h
    equipment, based on
    risk.                            15% of LPG meters
                                     10% of NAWI medical scales
KEY IMPROVEMENT AREA NO. 4:
     TO ACHIEVE GREATER COMMUNITY ENGAGEMENT THROUGH
     OUR INFORMATION, ADVICE AND EDUCATION SERVICES

Working towards the following National Standards and local priorities of Norfolk
County Council:

National Standards

INFORMED CONFIDENT CONSUMERS
12a   Providing quality advice and information using modern technology and appropriate
      media.
12b   Informing consumers to enable them to deal with new or difficult trading activity.
12c   Creating confidence in e commerce issues.
12d   Developing and delivering proactive education programmes to vulnerable groups.
12e   Joined up working through trading standards regional coordinators or with other
      organisations, to improve service delivery through increased coverage, improved
      efficiency and so on.
12f   Participation in your local Consumer Support Network.
12g   Improved accessibility and availability of the service to local consumers, including
      actions to identify gaps in the service and reach non-users.

INFORMED SUCCESSFUL BUSINESSES
13a   Providing quality advice and information, using modern technology and appropriate
      media.
13b   Developing and delivering a proactive education programme for business.
13c   Working with business to improve compliance and minimise non-compliance and
      failure.
13d   Participation in local business partnerships, forums and local business link.
13e   Joined-up working through Trading Standards regional coordinators or with other
      organisations, to improve service delivery through increased coverage, improved
      efficiency and so on.
13f   Exploiting existing links between business, local authorities and government
      agencies to give information and advice.
13g   Improved accessibility and availability of the service to local business including
      action to identify gaps in the service and reach non-users.
National Standards continued

EFFICIENT, EFFECTIVE AND IMPROVING TRADING STANDARDS SERVICE
15g    Maximising efficiency through use of IT and other modern technology.

Local Priorities of Norfolk County Council


Safe
(15)   Ensure consumers and businesses are exposed to less trading malpractice through
       the provision of information and advice, interventions and formal investigations.



Accessible & Well-Housed
(39)   Improve electronic access to services and information.


Economically Thriving
(32)   Help businesses to develop in Norfolk and improve travel, transport and IT links.


Knowledgeable & Skilled
(19)   Increase opportunities to learn throughout life.


Inclusive & Diverse
(3)    Maximise the positive impact of all service on disadvantaged and excluded people.


Active & Engaged
(22)   Support capacity building in the voluntary and community sectors.

Underpinning our work to deliver these high priorities is the need to:
(40)   Ensure staff are equipped and supported to help give a better public service.
                                                                                                                  Link to
                                                                 Key Targets                                     Priority/
                                                                                                                 Standard
KEY ACTION

14. Increase the capacity of   (a) The conditions within the Trading Standards/CSC Service Level
     our consumer and              Agreement are met.                                                                 12a
     business information                                                                                        15
                               (b) At least 20,000 consumers and 3,000 businesses receive quality Trading             12b
     and advice services.                                                                                        39
                                   Standards information and advice.                                                  12g
                                                                                                                 32
                                                                                                                      13a
                               (c) All consumer complaints that require frontline information and/or assisted    19
                                                                                                                      13c
                                   information are fulfilled by the CSC.                                          3
                                                                                                                      13g
                                                                                                                 40
                               (d) Corporate Customer Care and Information Standards are met by 1st October           15g
                                   2004.


15. Improve the access to      (a) The effectiveness of the Consumer Support Network is increased by including        12a
     and availability of our       all district councils and 4 more key voluntary organisations.                      12b
     consumer and business                                                                                            12c
                               (b) Consumer Champions Initiative extended.
     information and advice                                                                                      15   12e
     services.                 (c) Approximately 20 hours training per year provided to the Consumer             22   12f
                                   Champions volunteer training scheme.                                           3   12g
                               (d) Referral protocols between CABx and Trading Standards developed,              39   13a
                                   monitored and reviewed.                                                       19   13c
                                                                                                                 32   13d
                               (e) CSN Information points established at all Council Information Centres.
                                                                                                                 40   13e
                               (f) Working in partnership with Business Link and other agencies, develop an           13f
                                   initiative on how we can best help businesses to comply with trading               13g
                                   standards                                                                          15g
                                                                                                                Link to
                                                                 Key Targets                                   Priority/
                                                                                                               Standard
KEY ACTION
Improve the access to and      (g) Increased usage of our Consumer and Business websites.
availability of our consumer
and business information       (h) All information resources, including Superconsumer, Super and the TS NCC
and advice services.               Internet to be reviewed and continuously updated as required.
continued                      (i) Super and Superconsumer to be integrated into the NCC Website, as per the   As above
                                   web/infobase corporate project.
                               (j) TS NCC Internet developed to allow online transactions and publication of
                                   statutory notices, as per web/infobase corporate project.

                                                                                                                    12a
16. Establish a sustainable    (a) Consumer and Business Education Programme implemented by 31st                    12b
    consumer and business          March 2004.                                                                      12d
                                                                                                               15
    education programme,                                                                                            12e
                               (b) Consumer and Business Education Programme delivered by 31st March           19
    targeting vulnerable                                                                                            12g
                                   2005.                                                                        3
    groups and key trade                                                                                            13a
                               (c) Participate in appropriate events such as The Royal Norfolk Show.           22
    sectors.                                                                                                        13b
                                                                                                               32
                                                                                                                    13c
                                                                                                                    13e
                                                                                                                    13g
KEY IMPROVEMENT AREA NO. 5:
     TO CONTINUE TO IMPROVE THE EFFICIENCY AND EFFECTIVENESS OF
     THE TRADING STANDARDS SERVICE

Working towards the following National Standards and local priorities of Norfolk County
Council:

National Standards

EFFICIENT, EFFECTIVE AND IMPROVING TRADING STANDARDS SERVICE
2a     Trading Standards should have a role in a range of cross cutting objectives.
2b     Objectives should build on the promotion of economic well being and quality of life in the
       community.
3a     Key aims and objectives will relate to policies on national and local priorities as set out in
       Part Two of the Plan. Strategic plan will need to focus on building on the existing gaps in
       the medium terms (2-3 years from April 2002).
3b     Best Value principles should apply to every aspect of service delivery.
8a     Make a full assessment of consumer need based on current intelligence.
8b     Consultation and user surveys should be employed to assess community needs and
       expectations.
9a     Make a full assessment of the help your local business community wants and needs, based
       on current intelligence.
9b     Consultation and user surveys should be used to assess business needs and expectations.
10a    Awareness surveys should be considered as a means of assessment.
12g/   Improved accessibility and availability of the service to local consumers and businesses,
13g    including action to identify gaps in the service and reach non-users.
12h/   Measuring the use and effectiveness of education, advice and information services.
13h
12i/   Encouraging participation in consultation processes.
13i
15a    Communicating and raising the profile of the service and the Plan to those responsible for
       delivering it, to Council Members and to those who will use the service.
15b    Ensuring that Officers within the service know which parts of the plan they are responsible
       for and how their performance against the plan will be measured.
15c    Consulting users on developing the service.
15d    Dealing with complaints about the service.
National Standards continued
15e    Developing and training staff to ensure that they have the skills required to deliver the
       service.
15f    Developing all aspects of the service from delivery to internal procedures to reflect current
       recognised good practice.
15j    Allocating resources appropriately.
15k    Ensuring formal reporting procedures are carried out in an efficient and timely manner.
16a    Monitoring of progress against the Service Delivery Plan.
16b    Review of policies and procedures in the plan to
             - Assess effectiveness
             - Identify areas of work needing improvement and take remedial action
             - Identify problems that need to be addressed in future plans.
             - Assess successes.
             - Ensure examples of good practice have been taken up and/or disseminated.
             - Inform future planning.
16c    Use of external accreditation, self and peer assessment models to help appraise the
       service.
16d    Comparison of outcomes with other Trading Standards services with similar business
       profiles etc.
16e    User surveys to assess satisfaction.
16f    Consultation of stakeholders to assess effectiveness.
16g/   Monitoring the quality and consistency of advice and performance.
16h

Local Priorities for Norfolk County Council
Inclusive & Diverse
(2)    Work to achieve equality of opportunity.
(3)    Maximise the positive impact of all services on disadvantaged and excluded people.

Active & Engaged
(23)   Increase the involvement of people who have not traditionally been listened to.
(24) Increase the involvement of Norfolk residents in the design, delivery and evaluation of public
   services.
Environmentally Responsive
(25)   Reduce waste and improve recycling.
Under pinning work to deliver these high priorities is the need to:
(40)   Ensure staff are equipped and supported to help give a better public service.
                                                                                                                 Link to
                                                                 Key Targets                                    Priority/
                                                                                                                Standard
Key Action
                                                                                                                      8a
17. Improve our service by     (a) Customer Care Strategy and Action Plan (see Appendix F) developed by               8b
    acting on the feedback         1st April 2004.                                                                    9a
    of our customers and                                                                                              9b
                               (b) Customer Care Strategy and Action Plan (see Appendix F) delivered by
    constantly comparing                                                                                             10a
                                   31st March 2005.
    ourselves with the best.                                                                                         12g
                               (c) Consultation feedback used to modify service provided.                            12h
                               (d) 93% of customers rate our services as satisfactory or better.                     12i
                                                                                                                     13g
                               (e) Benchmarking Strategy developed by 31st March 2005.                          23
                                                                                                                     13h
                                                                                                                24
                               (f) 100% score achieved against the national performance indicator for Trading        13i
                                   Standards. (BVPI 166).                                                            15c
                                                                                                                     15d
                                                                                                                     15f
                                                                                                                     16d
                                                                                                                     16e
                                                                                                                     16f
                                                                                                                     16g
                                                                                                                     16h

18. Target our resources at    (a) Intelligence Strategy developed by 1st April 2004.                                 8a
    those businesses                                                                                                  9a
                               (b) Intelligence Strategy delivered by 31st March 2005.                           3
    causing the most                                                                                                 12g
    problems.                  (c) Intelligence used to modify service provided.                                     13g
19. Raise awareness of our      (a)   Marketing/Publicity Strategy devised by 31st March 2005.        10a
                                                                                                  3
    service so that all those                                                                         12g
                                (b) Increase in number of customers using the service.           23
    who need it actually use                                                                          13g
                                                                                                 24
    it.                                                                                               15a
                                                                                                                   Link to
                                                                  Key Targets                                     Priority/
                                                                                                                  Standard
Key Action
                                                                                                                  40   15a
20. Improve our internal        (a)   All staff have an understanding of the Trading Standards Service Plan and        15b
    communications,                   their role within it.                                                            15j
    including our appraisal     (b) Staff guide to the Trading Standards Service Plan published via the Trading
    processes.                      Standards Homepage.
                                (c) Personal Work Accounts system implemented for all operational staff.

21. Implement corporate         (a) Service representation on key corporate projects ensures customer and
    standards and initiatives       service needs are met.
    in relation to:             (b) Corporate complaints and compliments process adopted as an integral part
    Complaints &                   of our Customer Care Strategy.
       Compliments
    Health, Safety &           (c) Health, Safety & Welfare Plan delivered.
       Welfare                  (d) Chief Executive‟s Department Equal Opportunities Plan delivered.
    Equal Opportunities
                                (e) Corporate standards in relation to equal opportunities, sustainability,
    Sustainability                                                                                               40
                                    accessibility, information, customer care and purchasing performance are           15d
    Accessibility                                                                                                 2
                                    met as per the specific corporate targets.                                         15k
    Freedom of                                                                                                   25
       Information              (f) Filing system for both electronic and paper based documents developed and
    Data Protection                implemented which meets the requirements of the Service, the Freedom of
    Information Security           Information Act and the Data Protection Act.
    Business Continuity        (g) ICT developments explored to facilitate remote working and real time
    Customer Care                  updating of databases.
    e-Services
    Purchasing
       Performance.
                                                                                                             Link to
                                                                    Key Targets                             Priority/
                                                                                                            Standard
Key Action

22. Deliver the Learning and      (a)     Learning and Development Plan in place by 31st May 2004.
    Development Plan,             (b) Learning and Development Plan delivered by 31st March 2005.                15e
    including the                                                                                           40
                                  (c) IiP status maintained.                                                     16c
    implementation of
    internal peer review.         (d) Competency and Peer Review System implemented.


23. Continue to deliver quality   (a) Accreditation maintained against the following standards:
    services, through external
                                         BS EN ISO 9001:2000
    accreditation of our
                                         UKAS ISO 17025:2000                                                    15f
    management systems.
                                         CLS Quality Mark.                                                 40   16b
                                  (b) Internal auditing programme in place by 1st April 2004.                    16c

                                  (c) Internal auditing programme delivered by 31st March 2005.
                                  (d) Quality Management Review conducted and action plan implemented.

24. Monitor our performance (a)   Performance monitoring against key actions and targets reported 4 times        15k
    against the Trading           a year.                                                                   40   16a
    Standards Service Plan. (b) Trading Standards Service Plan delivered by 31st March 2005.                     16b
 PART THREE




E - QUALITY ASSESSMENT

     AND REVIEW
E – QUALITY ASSESSMENT AND REVIEW



1       Quality Assessment and Review

1.1     Provisions to review the work of the service against the Trading Standards
        Service Plan and standards.

1.1.1   Monitor progress against plan


       Service performance monitoring. Once the Trading Standards‟ Service Plan, and
        the supporting Food Law Enforcement, Minor Sales: Major Consequences and
        Farm Enforcement Plans, have been approved, the Trading Standards Service‟s
        key actions and targets are translated into team and individual targets and agreed
        at staff appraisals.

        Individual performance is monitored by Team Managers on an ongoing basis, with a
        formal mid term review held six months through the service year. Team
        performance is monitored on a monthly basis by each Assistant Head of Trading
        Standards.

        A performance monitoring report, compiled by each Assistant Head of Trading
        Standards, is presented to the Departmental Management Team four times per
        year. Performance is reviewed, any variations from the plan are identified and
        remedial action is put into effect.


       Performance monitoring by Members. Progress against the Trading Standards‟
        Service Plan is reported to the Fire & Community Protection Review Panel on a
        biannual basis, following the departmental performance reviews.



       Communication of performance monitoring. Progress is communicated to all
        Trading Standards staff via the Service‟s bimonthly internal bulletin “Trading Post”.


1.1.2    Review policies and procedures in plan:
         to assess effectiveness
         to assess successes
         to ensure examples of good practice have been taken up and/or
          disseminated

       9001:2000 management system review. Our 9001:2000 accredited management
        system incorporates a comprehensive review process. All policies and procedures
are audited by internal auditors (who are trained as Lead Assessors and who attend
departmental refresher training) as part of the annual audit programme.
    Any failure to meet requirements, or opportunity to improve the requirements,
    highlighted during internal audits are addressed via the quality improvements and
    auditing procedure. In addition, where opportunities to improve are identified other
    than during internal audits, these are also handled via this procedure.

    Improvements to the management system are communicated to all staff as they are
    implemented.

    The management system is reviewed by the Extended Departmental Management
    Team on an annual basis. The review includes the results of both internal and
    external quality audits; examination of records concerning non-conforming service
    and the effectiveness of corrective and preventative actions which have taken
    place; review of formal complaints about the Service and the corrective and
    preventative actions arising from them: and a review of the effectiveness of changes
    to the system as a result of the previous management review meeting.

   Service Plan review. Specific procedures in the management system relate to
    service designs & plans and policy formulation, deployment & review.

    Service plans are required before the commencement of the delivery of service and
    outline the performance objectives which are planned to be achieved in delivering
    the service. The Trading Standards‟ Service Plan is reviewed on an annual basis
    as are all other major service plans including the Food Law Enforcement Plan. A
    service planning guide has been introduced to ensure that drivers such as customer
    needs, the National Performance Framework priorities & legal requirements and
    other issues such as resources, health & safety and sustainability are taken into
    consideration during the service planning process.

    In November 2003, a Service Plan summary was distributed to a number of
    stakeholders including consumer groups, businesses, other enforcement agencies
    and staff and their comments have been used to refine this service plan.

    Planned inspection, enforcement and sampling activities (or projects) are
    documented prior to commencement, outlining the performance objectives which
    are planned to be achieved in delivering the project. A project template is used to
    ensure that projects meet legal requirements and have regard to official and
    professional guidance and standards.

    This year, Project Managers will be asked to present project reports to the
    Departmental Management Team on completion of the project so that the results
    can be assessed, further actions can be agreed and outcomes can be disseminated
    both within the Service and externally as appropriate.

   Policy review. All policies are reviewed on an annual basis although more frequent
    reviews are undertaken where it is appropriate to do so. Reviews may be required
    where corporate or Service priorities change, where new legislation is enacted, or
    where customer feedback suggests amendments. Again, any amendments to
    policies are communicated to all staff as they are implemented.
1.1.3        Use of external accreditation, self and peer assessment models to appraise
             service

            The Trading Standards Service holds a number of awards, standards and quality
            marks as listed below:

    In what year will/was the Trading Standards service part
                                                                         2000/2001
    of a Best Value review by your authority?
    Indicate if you have received, or are working towards,                       Working
                                                                  Received
    any of the following:                                                        towards
         Charter Mark
            Investors in People                                    1999
            OFT excellence award (scheme under review)
            Beacon Status (what topic)
                                                                   2000
            CLS Quality Mark
                                                                 Full 2001
                                                                   1994
                                                                 9002:2000
            ISO 9000
                                                                   2003
                                                                 9001:2000
    Do you use the EFQM ® model? (yes or no?)                              YES
    Do you have a service level agreement with the Office
                                                                         YES
    of Fair Trading? (Yes or no?)
    Others: (list below)                    Brief description
                                            For Mass at OIML Class F1, F2, M1 and
                                            M2 uncertainties
                                            For Non-Automatic Weighing Machines up
    UKAS Accreditation for Metrological     to 2060kg on site (analytic balances to
    Services                                platform machines)
                                            For Non-Automatic Weighing Machines up
                                            to 2060kg in the laboratory (simple
                                            machines such as spring balances)

           9001:2000 accreditation. As already outlined under Standard 16b above, our
            9001:2000 accredited management system incorporates a comprehensive review
            process with an annual internal audit programme. In addition the Service is audited
            by the certification body twice a year.

           Peer Reviews. In 2003/04 we participated with other East of England Trading
            Standards Authorities (EETSA) in the peer review process developed by EETSA in
            relation to food law enforcement. We were audited by Hertfordshire & Luton
            Trading Standards and in turn audited Peterborough Trading Standards. We have
            found the experience a valuable one and are currently restructuring the
            management of our food law enforcement in response to the lessons learnt.
        We welcome the proposed DTi/LACORS peer review process based on the EFQM
        excellence model and are keen to implement it.

       Self-Assessment. Regardless of the timing of the introduction of the peer review
        process we intend to conduct a self-assessment of the Service using the EFQM
        excellence model in the forthcoming service year.


1.1.4   Comparison of outcomes with similar Trading Standards Services

       We recognise that comparing ourselves with other similar Trading Standards
        Services and learning from the best practice demonstrated in other authorities is an
        invaluable way to improve our own service delivery and to ensure consistency of
        enforcement. We are working with other East of England Trading Standards
        Authorities (EETSA) with a view to formalising benchmarking in the region, using
        the Tri-Nations Good Practice Guides. We will develop our Benchmarking Strategy
        during the 2004/05 service year


1.1.5   User surveys to assess satisfaction

       We have a well-established system for surveying our customers, both consumers
        and businesses. Surveys are conducted every quarter and encompass at least 5%
        of consumer and business contacts for that period. We survey customers who have
        received one or more of the following services:
             Consumer information and advice delivered by the corporate Customer
              Service Centre and/or our Fair Trading Teams
             Business information, advice and support
             Business inspection
             Metrological services

       For consumer and business information surveys, the criteria for the categorisation
        of questions and responses is based on the Community Legal Service (CLS)
        Quality Mark, although additional, targeted questions are also used. The majority of
        surveys also include a measure of ethnicity, disability, gender and age.

       Individual survey responses (both positive and negative) are fed back to officers
        and their team managers to either confirm that they are delivering a quality service
        to the customer‟s satisfaction or to allow them to modify their service delivery to
        improve customer satisfaction.

       Survey results are analysed and reported to the Departmental Management Team
        on a quarterly basis. Where suggestions for service improvements are
        recommended, they are considered and adopted, if appropriate, across the Service
        on an ongoing basis.
1.1.6    Consultation with stakeholders to assess effectiveness

       All our customer satisfaction surveys ask for suggestions on how we could improve
        the service we provide. In addition we have undertaken two major surveys of
        consumers and businesses in the last five years (as detailed in Section C) and
        much of the intelligence gained from them is still informing our thinking on the
        manner in which we deliver our services.

       A cross-party Member/Officer group was established in early 2003 to scrutinise the
        Trading Standards Service as a whole. Members engaged with a broad cross-
        section of staff in an effort to develop innovative ways to ensure that the people of
        Norfolk understand the value of the service delivered by Trading Standards. This
        work is to be used to inform the development of our Marketing/Publicity Strategy in
        2004/05.


1.1.7    Monitoring the quality and consistency of advice and performance

       As already outlined under Standard 16b above, our 9001:2000 accredited
        management system incorporates a comprehensive review process with an annual
        internal audit programme.

       We have established induction, appraisal and learning & development systems.
        Individual performance is monitored by Team Managers on an ongoing basis, with a
        formal appraisal/mid term review held every six months. Team Managers are
        responsible for quality auditing their staff to ensure the provision of advice and other
        service delivery matches established policies, procedures and protocols. Last year
        a formal monitoring procedure was introduced to improve the quality of the
        recording on our FLARE database of services delivered.

       2003 saw the introduction of an internal peer review process, which we intend to
        fully implement this year. The process is specifically designed to promote
        compliance with the Service‟s standards and policies and good practice in respect
        of the delivery of services. It involves officers accompanying one another in a
        series of work situations and documenting their assessment of performance. In the
        first instance this process will be used to assess the effectiveness of training
        provided to enforcement staff.

       The corporate Customer Service Centre delivers frontline information and assisted
        information on behalf of the service and has done so since its launch in October
        2003. In order to ensure the quality and consistency of the assisted information
        provided by the Customer Service Agents, we have developed a Service Level
        Agreement, which documents the policies, procedures and protocols to be followed.
        Compliance is monitored on a monthly basis.
1.2   Customer Care Strategy

      The Customer Care Strategy (see Appendix F), which is to be introduced at the
      beginning of the 2004/05 service year, adopts a comprehensive approach to the
      assessment of customer needs, expectations and satisfaction. It will allow us to
      assess the use and effectiveness of the service we provide and allow us to develop
      all aspects of the service to better meet our customers‟ needs.


2     Variations from the 2003/04 Service Plan

2.1   The Service Plan for the 2003/04 service year contained a comprehensive list of
      key actions and targets which identified those key areas of work to be taken forward
      during that service year. Whilst the majority of objectives were delivered as
      planned, in some cases variation from the original plan was necessary. These
      areas of variation are listed below:

      Area of variation                  Reason for variation
       To extend membership of           All District Councils were invited to join the
         the Consumer Support              CSN in March 2003. Information exchange
         Network (CSN) to include all      has been effective but to date only two
         District Councils (DC‟s)          District Councils have a nominated officer.
                                           Consideration is being given as to how to
                                           achieve more active membership and this
                                           area of work has therefore been carried
                                           forward to the 2004/05 service year. (See
                                           Key Action 15)
       To implement referral             This is still work in progress and is to be
        protocols between Citizens         carried forward into 2004/05. (See Key
        Advice Bureaux and Trading         Action 15)
        Standards
       To set up CSN Information         The County Council is now working with
        Points in Wroxham and              District Councils to open new Council
        Fakenham                           Information Centres. These will include
                                           CSN information points, including those
                                           centres based in Wroxham and Fakenham
                                           (See Key Action 15)
         To participate in National      Although we carry out a number of actions
          Safety Week                      relating to safety as part of our routine work,
                                           including firework inspections and toy and
                                           electrical goods safety checks, specific
                                           participation in National Safety Week was
                                           not undertaken due to lack of resources.
                                           During 2004/05 this campaign will be
                                           carried out on a more specific project basis.
                                           (See Key Action 10)
Area of variation                    Reason for variation
 To sign up 1000 businesses          Implementation of the scheme has been
   to a Fair Trading Scheme            deferred to 2004/05 due to other priorities.
                                       (See Key Action 8)
   To provide PAT testing            Following a review, we have secured
    services in-house                  efficiency savings through the employment
                                       of a contractor to fulfil this need
   To achieve targeted               This work has not been targeted in line with
    proactive investigations and       our expectations. As a result of
    project work in key areas          intelligence, investigations into
                                       counterfeiting have overshadowed other
                                       planned areas. This position is currently
                                       under review with a view to ensuring a more
                                       balanced approach during 2004/05
   20,000 consumers to access  The number of consumer complaints
    Trading Standards via the          recorded by the CSC is projected to be
    Customer Service Centre            15,200 this year. This is an increase over
                                       the 2002/03 figure but not as high an
                                       increase as anticipated given the improved
                                       access to the service. The projected
                                       number of telephone calls received per
                                       annum on the 0844 800 8013 number is
                                       27,000 so a review is to take place to
                                       establish why there is such a variation
                                       between the two. The overall 20,000 target
                                       has not been increased for the 2004/05
                                       service year.
   60% of consumer                   Currently 55% are handled by the CSC. A
    complaints/business                new Service Level Agreement (SLA) now
    enquiries to be fulfilled by the   provides for a different target, focusing on
    Customer Service Centre            the CSC dealing with all those enquiries
                                       that require only basic information and
                                       assisted information. The SLA also
                                       ensures that enquiries requiring further
                                       action are passed through to the correct
                                       enforcement team.
                                     Appendix A

           Primary Legislation enforced by the Trading Standards Service

Accommodation Agencies Act 1953
Administration of Justice Acts 1970 & 1985
Agriculture Act 1970
Agriculture (Miscellaneous Provisions) Act 1968
Agricultural Produce (Grading and Marking) Acts 1928-1931
Animal Health Acts 1981 & 2002
Animal Health and Welfare Act 1984

Business Names Act 1985

Children & Young Persons Act 1933
Children & Young Persons (Protection from Tobacco) Act 1991
Companies Act 1985
Consumer Credit Act 1974
Consumer Protection Act 1987
Copyright Designs and Patents Act 1988
Courts and Legal Services Act 1990
Crossbows Act 1987

Development of Tourism Act 1969

Education Reform Act 1988
Energy Act 1976 (S.1(4))
Energy Conservation Act 1981
Enterprise Act 2002
Environmental Protection Act 1990
Estate Agents Act 1979
European Communities Act 1972 (S.2)

Fair Trading Act 1973
Farm & Garden Chemicals Act 1967
Food & Environment Protection Act 1985
Food Safety Act 1990
Forgery & Counterfeiting Act 1981

Hallmarking Act 1973
Health & Safety at Work Act 1974

Insurance Brokers (Registration) Act 1977

Medicines Acts 1968-1971
Merchant Shipping Act 1995
Mock Auctions Act 1961
Motor Cycle Noise Act 1987

Nurses Agencies Act 1957

Performing Animals (Regulation) Act 1925
Poisons Act 1972
Prices Acts 1974 & 1975
Property Misdescriptions Act 1991
Protection from Harrassment Act 1997
Protection of Animals Acts 1911
Protection of Animals (Amendment) Act 1954
Protection of Animals (Amendment) Act 2000
Registered Designs Act 1949


Road Traffic Act 1988 (S.17, 18 & 75)
Road Traffic Act 1991 (S.16)
Road Traffic Offenders Act 1988

Slaughter of Poultry Act 1967
Solicitors Act 1964

Telecommunications Act 1984
Theft Acts 1968 & 1978
Timeshare Act 1992
Tobacco Advertising & Promotion Act 2002
Trade Descriptions Act 1968
Trade Marks Act 1994
Trading Representations (Disabled Persons) Acts 1958-1972
Trading Stamps Act 1964

Unsolicited Goods & Services Acts 1971-1975

Video Recordings Act 1984

Welfare of Animals at Slaughter Act 1991
Weights and Measures Acts 1976-1985
                                 APPENDIX B


             NORFOLK COUNTY COUNCIL LOCAL PRIORITIES

Inclusive & Diverse

  1    Build vibrant, confident and cohesive communities, promoting the value of
       diversity


  2    WORK TO ACHIEVE EQUALITY OF OPPORTUNITY

  3    Maximise the positive impact of all services on disadvantaged and excluded
       people



Healthy & Well

  4    Protect children from abuse, support families and keep them together
       wherever possible

  5    Support older people to live at home wherever possible and to lead
       independent, fulfilling and safe lives

  6    Support people with mental health problems to lead independent, fulfilling
       and safe lives

  7    Support people with learning difficulties to lead independent, fulfilling and
       safe lives

  8    Support people with physical impairment to lead independent fulfilling and
       safe lives

  9    Develop preventative and open access services, including services to
       support informal carers



Safe

  10   Strengthen our contribution towards reducing crime and disorder, and take
       steps to make local communities safer

  11   Strengthen our contribution to road safety in Norfolk and help to reduce
       deaths and injuries on our roads

  12   Helping young people resist drug misuse and work with people with drug
       problems to overcome them and live healthy crime-free lives
  13   Working with young people and their families to overcome the causes of
       offending behaviour to prevent re-offending



  14   Reduce the frequency and impact of fires and deal with fires and respond to
       other emergencies promptly and efficiently

  15   Ensure consumers and businesses are exposed to less trading malpractice
       through the provision of information and advice, interventions and formal
       investigations



Knowledgeable & Skilled

  16   Continue to improve educational attainment and aim to help all children reach
       their full potential

  17   Increase access to early years education and childcare

  18   Improve the suitability of school buildings


  19   INCREASE OPPORTUNITIES TO LEARN THROUGHOUT LIFE



Active & Engaged

  20   Increase Norfolk people‟s trust in democratic processes

  21   Engage young people as active citizens


  22   SUPPORT CAPACITY BUILDING IN THE VOLUNTARY AND COMMUNITY
       SECTORS

  23   Increase the involvement of people who have not traditionally been listened
       to

  24   Increase the involvement of Norfolk residents in the design, delivery and
       evaluation of public services



Environmentally Responsive


  25   REDUCE WASTE AND IMPROVE RECYCLING


  26   PROTECT AND SUSTAIN THE ENVIRONMENT
  27    Leading to reduce climate change



Creative

  28    Maximise opportunities to access cultural and heritage resources

  29    Support the self development needs of people and communities

  30       Look after and develop cultural and heritage resources




Economically Thriving

  31    Reduce deprivation in both rural and urban areas

  32    Help businesses to develop in Norfolk, and improve travel, transport and IT
        links

  33    Maintain a strategic and co-ordinated approach to the development of the
        Norfolk economy

  34    Improve the competitiveness and levels of employment in key sectors


  35    PROMOTE NORFOLK AS A GOOD PLACE FOR BUSINESS

  36    Seek to address skills and accessibility issues which constrain individuals
        from fulfilling their potential in the labour market




Accessible & Well-Housed

  37    Better travel and transport around and into Norfolk

  38    Land use planning and accessibility for new housing


  39    IMPROVE ELECTRONIC ACCESS TO SERVICES AND INFORMATION

Underpinning our work to deliver these high priorities is the need to:
  40    Ensure staff are equipped and supported to help give a better public service.
                                     Appendix D


                      Opera Community Research -
            Deprivation and Social Exclusion Survey - Analysis
Norfolk County Council Trading Standards Service is aiming to maximise the impact of
Trading Standards on social and economic well being in Norfolk. The hypothesis is
that, if effort is concentrated on population sub-groups and geographical locations
where well being is known to be low, then the Service will achieve a potentially greater
payback through sheer numbers of disadvantaged people reached.

Research was conducted earlier this year by Opera Community Research to examine
both the supply and demand sides of the local economies in examples of the 20 most
deprived wards in Norfolk. The research was targeted at those residents that, it is felt,
represent those people with the greatest need:
      Young teenagers who are starting to purchase for themselves
      Low income families
      The independent elderly still purchasing for themselves.

The purpose of this report is to summarise the findings of the research and to state how
Trading Standards intends to develop or is already developing its service in response to
it.

1. Consumer Mindsets

   Consumers‟ purchasing behaviour is strikingly similar to that of peers with more
   disposable income. All the big name high street stores are used regularly except by
   some elderly respondents with mobility problems. The differences lie in how people
   manage their money and why they make their choices, particularly for borrowing.
   They believe they are in control, but know their choices are limited.

       Trading Standards should adopt the role of “expert friend” to show ways to
       access the best value choices. The stance and tone adopted by Trading
       Standards is critically important.

2. Business Mindsets

       Businesses are defensive income replacers who tend to operate remotely from
       local infrastructure unless exchanging crime information. They are very wary of
       authority but they can see the benefit of widening their contact on a supportive
       business community basis.

       Trading Standards should adopt the role of “expert supporter” to show
       ways to protect their business and to achieve the balance of rights and
       responsibilities. Again, the stance and tone adopted by Trading Standards
       is critically important.
3. Trading Standards Communication with the Independent Elderly

  When shopping, convenience overrides best value for money. Habit and loyalty to
  specific outlets are also ingrained. The elderly tend to rely on long-trusted sources
  for information, such as CABx, and do not have an extensive knowledge of Trading
  Standards.

  No. Research Recommendation                    Service Response
  1   Run training sessions for staff employed    The provision of an Internet-based
      at trusted and frequented institutions     consumer information resource for use
      and organisations such as Day Centres,     by specialist and non-specialist
      Age Concern and GP surgeries               advisors across the Consumer Support
                                                 Network
                                                  The provision of training on
                                                 consumer advice including the use of
                                                 this resource for non-specialist staff and
                                                 volunteers in a range of agencies, such
                                                 as post-offices, health outlets and
                                                 businesses to provide first stop
                                                 information to consumers
  2    Locate simple, plain English leaflets and  The review and revision of all
       posters at places where the elderly visit consumer advice resources provided by
       – above all local post offices but also   the Trading Standards Service so as to
       Day Centres, Age Concern, GP              be more user-friendly and compliant
       surgeries, CABx, City Hall, churches,     with accessibility guidelines.
       village halls and through the local paper  The provision of self-help leaflets in
       or Council distributed leaflets such as   accessible locations such as post
       the Citizen                               offices, shops and health centres with
                                                 support from the staff who can signpost
                                                 to these resources and give basic help
                                                 in their use
                                                  The development of an Internet-
                                                 based Consumer Information database
                                                 aimed directly at consumers which will
                                                 allow information to be made available
                                                 on screen or printed out on a self-serve
                                                 basis
                                                  The proposed development and
                                                 implementation of 20 pilot consumer
                                                 information points. The points are to
                                                 consist of, at the most basic level,
                                                 attractive points at which it is easy to
                                                 access a range of up-to-date, well-
                                                 presented leaflets and, at the most
                                                 advanced level, information points
                                                 accommodating a range of leaflets, a
                                                 telephone with direct links to
                                                 information agencies and self-serve
                                                 computer access to information).
No. Research Recommendation                              Service Response
2                                                        The points are to be situated in the
cont.                                                    most deprived wards in the County, in
                                                         those areas where there is currently no
                                                         provision for consumer or other legal
                                                         information. They are to be situated at
                                                         easily accessible community locations,
                                                         such as post offices, village shops,
                                                         community centres, health settings and
                                                         libraries. Staff in these locations will be
                                                         primed to signpost to the information
                                                         point, understand the content and
                                                         purpose of the materials on display and
                                                         will be prepared to assist in publicising,
                                                         maintaining the appearance and
                                                         maintaining the functionality of the
                                                         resource. The information points will
                                                         include content relevant to meeting the
                                                         needs of the local community. There
                                                         would also be the flexibility to include
                                                         up-to-the-minute information on
                                                         particular issues as they become
                                                         relevant to the community and to
                                                         support particular campaigns.
                                                          The weekly Consumer Advice
                                                         column in the Eastern Daily Press and
                                                         the Lynn News

3       Make visiting Trading Standards as                         The development of the Consumer
        easy as “Going up the Citizens' Advice”* Support Network whose initial
        by working in partnership with CABx                       membership is the Trading Standards
                                                                  Service and the 13 CABx in Norfolk.
                                                                   The provision of an Internet-based
                                                                  consumer information resource for use
                                                                  by specialist and non-specialist
                                                                  advisors across the network
                                                                   The provision of further training on
                                                                  consumer advice to CAB advisors
                                                                  including on the use of this resource
                                                                   The improvement of ICT provision in
                                                                  CABx to allow the effective exchange of
                                                                  information and client referral between
                                                                  agencies
                                                                   The implementation of effective
                                                                  referral protocols between Trading
        * A direct quote from an elderly respondent demonstrating
        how comfortable she was with the service provided by her  Standards and CABx
        local CAB.
  No. Research Recommendation                                      Service Response
                                                                    A programme of seminars, meetings
                                                                      and events on key issues such as
                                                                      changes in consumer and business
                                                                      legislation and the sharing of best
                                                                      practice for Consumer Support
                                                                      Network agencies

  4    Make visiting Trading Standards as                             A programme of outreach consumer
       easy as “Going up the Citizens' Advice”*                        advice surgeries targeted at the 20
       by conducting outreach consumer                                 most deprived wards in the County
       advice surgeries at Community Centres,
       CABx and other familiar venues
       * A direct quote from an elderly respondent demonstrating
       how comfortable she was with the service provided by her
       local CAB.




4. Trading Standards Communication with Families

  Pride, choice, convenience and ease of shopping are paramount. Families are
  prepared to travel for price and variety and will look for good value alternatives if
  certain shopping trips are seen as inconvenient (eg, the mother of 5 who shops at
  Tesco via the Internet). There is a general awareness of Trading Standards but not
  of its role. CABx tend to be relied on for advice.

  No. Research Recommendation                                      Service Response
  5   Produce leaflets to keep at home                              See Point 2

  6    Locate leaflets and posters at places                          See Point 2
       where families visit – above all local
       post offices but also CABx, City Hall,
       town and village halls, local shops,
       large supermarkets and through the
       local paper

  7    Conduct outreach consumer advice                               See Point 4
       surgeries at supermarkets, mums and
       toddlers groups and other regularly
       frequented locations

  8    Appear on radio and television,                                Weekly Consumer Advice slots on
       particularly on “Watchdog” type                                 Radio Norfolk
       programme, in partnership with other                           Regular appearances on Consumer
       Consumer Support Network members                                programmes on local television
                                                                       Communication strategy -
                                                                       responses to local and national
                                                                       issues
5. Trading Standards Communication with Teenagers

  Peer pressure overrides choice and price. Teenagers purchase independently but
  often rely on parents to take action to protect consumer rights. There is little
  knowledge of Trading Standards.

  No. Research Recommendation                    Service Response
  9   Develop and possibly deliver                The development of consumer
      “citizenship” programmes in partnership    education within the schools‟
      with schools PSE curriculum                curriculum, working with the County
                                                 Council‟s Education Department, Youth
                                                 & Community Services and local
                                                 agencies relevant to young people
  10   Produce carefully written leaflets         The development of consumer
       targeted at teenagers (language, layout, education resources on consumer
       style, colour, graphics, text and         issues relevant to young people,
       illustrations) circulated through schools working with the Youth & Community
       and located at leisure centres and        Services to ensure suitability
       shops which are frequented
                                                  The development of an Internet-
                                                 based Consumer Information database
                                                 aimed directly at consumers which will
                                                 allow information to be made available
                                                 on screen or printed out on a self-serve
                                                 basis
  11   Conduct outreach consumer advice           See Point 4
       surgeries at schools
  12   Have an input into industry training days  Proposed work with the County
       and Young Enterprise as part of the       Council‟s Education Department and
       curriculum                                City College


6. Implications for Trading Standards on Consumer Rights

  Respondents have a good basic understanding of their consumer rights – they are
  all well aware that they can return goods that are faulty or not as stated within a
  certain time limit. However, they are less clear regarding specifics such as buying
  second hand goods, goods that are out of guarantee, sale goods and being refused
  a refund or replacement

  No. Research Recommendation                    Service Response
  13 Provide a coach/mentor role in helping       The development of the Compliance
      consumers develop their understanding      Team (Civil Law) such that our civil law
      of consumer rights                         specialists develop a broader range of
                                                 intervention techniques in order to put
                                                 right trading practices which have
                                                 caused detriment to consumers
  No. Research Recommendation                      Service Response
  14 Provide a supporter role in developing         See Point 13
      consumer assertiveness

  15   Disseminate information on consumer            See Point 2
       rights in plain English format to keep at
       home

  16   Make accessing Trading Standards             The development of co-ordinated
       much easier and more visible                advertising of Consumer Support
                                                   Network services
                                                    Participation in National Consumer
                                                   Week
                                                    Banner advertising of our Advice
                                                   Line telephone number in the local
                                                   papers



7. Implications for Trading Standards on Credit and Finance

  Consumers believe they make effective decisions within their means. They believe
  they are in control of their finances, know their own limits, live by these and survive.
  Choices are driven by affordable payments per week – consumers trade off
  convenience and affordability for paying more in total because they know there is no
  other choice.
  There is little in depth knowledge of credit and finance (eg, APR). There is a
  general wariness of high street banks and, in particular credit cards. Respondents
  feel they would be losing control of their finances if they ventured into credit card
  transactions. They think short-term rather than long-term. Lenders such as the
  Provident are sometimes seen as the “easy” option because the fairly low weekly
  repayments are affordable and convenient in that they are collected at home. There
  is also the personal touch of the often “friendly” person who comes to offer and
  collect the money. However some respondents are unhappy with the amount of
  interest they have to pay, especially if they feel this was not adequately explained at
  the time of the loan.

  No. Research Recommendation                      Service Response
  17 At a strategic level, develop cheaper          Liaison with Norwich City Council
      access to borrowing through Credit           and Warwickshire County Council
      Unions, by acting as an advocate and         Trading Standards, both of whom have
      promoting the benefits                       experience of establishing credit unions

  18   At a strategic level, ensure lenders such    Proposed work with financial
       as the Provident give all appropriate       institutions in developing the provision
       information at the right time, in           of product information
       partnership with other Consumer
       Support Network members
  No. Research Recommendation                     Service Response
  19 Provide credit and finance leaflets &         See Point 2
      posters and outreach advice surgeries        Participation in National Consumer
                                                  Week 2001, the theme of which was
                                                  debt

  20   Ensure the tone and style of support          See Point 2
       given gives credit to the consumers for
       successes in controlling their finances
       and gives encouragement to consumers
       to build on what they are achieving
       already

  21   Give consumers first and foremost the         See Point 18
       information they are looking for –
       information on a range of finance
       sources that fit their mindset, most
       notably in terms of weekly affordability
       (as opposed to APR or final pay back
       amount)



8. Implications for Trading Standards on Businesses

  Local businesses survive through offering posi
  tive customer relations, by providing a personal service and by developing an on-
  going rapport with regular customers. This is seen to be of primary importance in
  gaining and maintaining business.

  There is confusion between the role of Trading Standards and that of Environmental
  Health. There is a wariness regarding “inspection” by outside bodies and some
  businesses feel a little helpless in these situations. Nevertheless, businesses are
  eager to work in partnership with Trading Standards, enabling information to flow
  both ways and achieving clarity regarding the rights of both consumers and
  businesses.

  No. Research Recommendation                     Service Response
  22 Provide direct mailed information packs,      The review and revision of all
      tailored to particular business types       business advice resources provided by
                                                  the Trading Standards Service so as to
                                                  be more user-friendly and compliant
                                                  with accessibility guidelines
                                                   The provision of business
                                                  information resources & services,
                                                  highlighted to businesses during
                                                  Generic & Specialist Inspections
  23   Provide a coach/mentor role in              The implementation of the “How Am
       increasing knowledge of rights and         I Trading?” Scheme
       responsibilities
No. Research Recommendation                    Service Response
24 Develop a modern “partnership” based         The development of the Local
    profile with businesses                    Business Partnership

25   Offer a supportive stance through local    Delivery of business seminars
     meeting, discussing common issues          Delivery of business surgeries with
                                               the Chamber of Commerce
26   Link with local District councils and      The development of the Local
     other government agencies in the          Business Partnership
     delivery of services                       The development of the Local
                                               Strategic Partnerships
                                                The development of the Generic
                                               Inspection programme so as to deliver
                                               a one-visit inspection to businesses
                                               covering compliance with regulations
                                               enforced by both County and District
                                               councils (pilot scheme to be trialed in
                                               Norwich)
                                                The development of an Internet-
                                               based Regulatory Information database
                                               aimed directly at businesses which will
                                               allow information to be made available
                                               on screen or printed out on a self-serve
                                               basis
                                                The provision of an Internet-based
                                               business information resource for use
                                               by specialist and non-specialist
                                               business advisors across the
                                               partnership
                                    Appendix E


         Norfolk County Council Trading Standards
                    Enforcement Policy


CONTENTS

1. Introduction

2. Approval

3. Scope

4. Access to Policy

5. General Principles

6. Formal Action

7. Determination of Formal Action

8. Forfeiture

9. Assets

10. Compensation

11. Company Directors

12. Guidance

13. Partnership Working

14. Review



APPENDICES

Appendix 1 – Enforcement Concordat
Appendix 2 – Code for Crown Prosecutors
Appendix 3 – Home Office Guidance – Cautions
Appendix 4 – Other Relevant Codes/Best Practice
Appendix 5 – Guidance Notes for Officers
1.    Introduction


1.1    Effective enforcement of Trading Standards legislation is essential to protect the
       health, safety and economic interests of businesses, residents and visitors to the
       County of Norfolk. The purpose of this policy is to provide guidance on the
       general principles which the service will apply when carrying out statutory duties.

2.    Approval


2.1 This policy was approved at a full meeting of the Norfolk County Council on 10 th
    May 2004.

3.    Scope


3.1 This policy applies to the enforcement activities undertaken by the Trading
    Standards Service. For the purpose of this document „enforcement‟ includes
    action carried out in the exercise of, or against the background of, statutory
    enforcement powers. This is not limited to formal enforcement action such as
    prosecution or issue of notices and would include the inspection of premises for
    the purpose of checking compliance with regulations and the provision of advice to
    aid compliance.

4.    Access To Policy


4.1 This policy is available on the Norfolk County Council Trading Standards Website:
    tradingstandards.norfolk.gov.uk

      And at the Service‟s offices at:
       Norfolk Trading Standards, County Hall, Martineau Lane, Norwich, NR1 2UD
       Norfolk Trading Standards, St Margaret‟s House, Kings Lynn, Norfolk, PE30 5DL


      Or by telephone on 0844 800 8013 or by email on
      tradingstandards@norfolk.gov.uk


4.2 On request the document can be made available on tape, in braille, large type or
    in a language other than English.



5.    General Principles

5.1 The service recognises the need for and has adopted the Enforcement Concordat
    (Appendix 1). Wherever appropriate the service will seek to actively work with
    Norfolk businesses in accordance with the concordat.
5.2 It is the general policy of the service to work with business to achieve compliance
    with Trading Standards legislation.


5.3 The service is a public authority for the purposes of the Human Rights Act 1998.
    Wherever appropriate all staff will apply the principles of the Act and the European
    Convention on Human Rights. This policy accords with the principles of the Act
    and the Convention.

5.4 In all instances where it is appropriate officers conducting inspections shall provide
    a written summary of that visit (including areas of non-compliance) and if
    requested further written advice.

5.5 In all instances where it is appropriate officers shall ensure that particular needs
    are met in respect of interpretation facilities for non-English speakers.


6.    Formal Action

6.1 Whilst recognising the need to work within the Enforcement Concordat the service
    also recognises that elements of trade and individuals will operate outside the law
    (both intentionally and unintentionally) to the detriment of consumers or society
    generally.

6.2 The service retains the right to take formal action against such elements in the
    following circumstances:

      1. Where there is a risk to public health or safety.

      2. Fraudulent, deceptive or deliberately misleading trading practices.

      3. A deliberate or persistent failure to comply with advice, warnings or legal
         requirements.

      4. The sale or provision of age restricted products to underage persons

      5. Animal cruelty, unnecessary suffering caused by a wilful or negligent act,
         neglect of livestock or any other matters concerning animal welfare.

      6. Any act likely to affect animal health or disease prevention measures.

      7. For serious matters where there has been recklessness or negligence.

      8. Obstruction of an officer in the execution of their duties.

      9. Assault, including verbal assault, of an officer.

6.3    For the purposes of this document „formal action‟ means:

      Prosecution, Formal Caution, Informal Caution, Seizure, Suspension, Forfeiture,
      Enterprise Act Proceedings, Written or Verbal advice or warning, or any other
      criminal or civil proceedings, applied either separately or in any appropriate
      combination.
7. Determination Of Formal Action

7.1 Where investigating officers consider a matter merits any action before a tribunal
    or the issue of a caution, having regard to any guidance issued in the attached
    appendices, they will submit a report to an appropriate senior officer, independent
    of the investigation, who will decide what, if any, action is most appropriate. That
    officer shall consider each case on its own merits and shall have regard to:

     1. The nature, seriousness and extent of any alleged contravention

     2. This policy

     3. The Code for Crown Prosecutors (Appendix 2)

     4. Home Office guidance on the issue of Cautions (Appendix 3)

     5. Any statutory requirements

     6. Any other relevant guidance or Codes of best practice for example Food Safety
        Act Code 2 (Legal Matters) (Appendix 4)

     7. Consumer interests in particular:

        a) the expectations of any complainant or victim
        b) whether it is expedient for the promotion or protection of the interests of the
           inhabitants of the County of Norfolk

7.2 Where investigating officers do not consider such action to be appropriate they
    may dispose of the matter by some other means as identified in point 6.3 above, if
    necessary after consultation with their team manager.


8.   Forfeiture

8.1 Where an accused has not agreed to voluntarily surrender any infringing goods
    then, on successful conclusion of legal proceedings, forfeiture will be applied for.
    This does not preclude the service taking forfeiture proceedings in their own right
    in appropriate circumstances.


9.   Assets

9.1 Where appropriate Norfolk Trading Standards, working in partnership as
    necessary, will seek to recover the assets of convicted offenders under the
    Proceeds of Crime Act 2002.

10. Compensation
10.1 Where a victim has suffered a quantifiable loss, on successful conclusion of legal
     proceedings, compensation will be applied for.


11. Directors

11.1 On the conviction of a Director connected with the management of a company
     the Prosecutor will, in appropriate cases, draw to the Courts attention their powers
     to make a Disqualification Order under the Company Directors Disqualification Act
     1986.


12. Guidance

12.1 Further guidance for officers may be issued from time to time (Appendix 5). This
     guidance will relate to specific pieces or sets of legislation and be appended to
     this policy. It is emphasised that this is guidance only on suggested ways officers
     should deal with particular incidents. At all times officers are empowered to deal
     with infringements using their discretion within the overall parameters of this
     policy.


13.   Partnership Working

13.1 In certain circumstances it may be necessary or desirable for more than one
     enforcement agency to participate in an investigation. In such circumstances
     Trading Standards will seek to engage all appropriate partners in the enquiry
     either before commencement or at the earliest opportunity. Where one agency
     leads in a multi-agency investigation that lead agency will be identified and
     agreed at the outset by all involved. The lead agency will be responsible for
     ensuring the effective management and control of the investigation.

13.2 Where appropriate and in the interests of justice Norfolk Trading Standards will
     agree at an early stage which agency will conduct legal proceedings where
     offences fall within the jurisdiction of several agencies or in different geographical
     areas.


14.   Review

14.1 This policy shall be reviewed:

      a) on the passing of any significant new legislation
      b) annually
                                      Appendix F


               Draft Trading Standards Customer Care Policy

Trading Standards customers are those who might reasonably expect to receive
services from or be regulated by the Trading Standards Service. They include among
others, the citizens and businesses of Norfolk, other organisations which provide
services, other parts of the council and any person who is temporarily a resident of
Norfolk.

The resources made available to Trading Standards will be used in the best possible
way to satisfy the needs of its customers. The service will be provided at all times fairly
to all. We will be polite, courteous and timely when dealing with our customers. We will
communicate effectively and with understanding of our customers needs.

Trading Standards will listen to and acknowledge the expressions of our customer‟s
wishes and desires. We will also actively consult and involve them appropriately about
the aspects of trading standards which concern them. We will use this information to
balance these wishes and desires against the resources we have available in order to
deliver the best possible service to all our customers. We will monitor and review our
performance in order to guide improvements to our customers.

Trading Standards will seek to be at the forefront in following corporate customer care
policies and initiatives. We will respond in an appropriate and timely manner to all
expressions of dissatisfaction made by our customers and where possible, will seek to
satisfy their reasonable expectations.
  th
15 January 2004
Trading Standards Customer Care Strategy


Active Listening

      Improving service delivery through ensuring that officers are excellent at
      recognising and listening to customers’ expressions of need.

Through a programme of training build on and improve officers’ skills to:
      ● Recognise and listen to customers’ expressions of need.

      ● Make the process of listening an integrated part of all service delivery.

           Training required here could be delivered in house through team talks.
            CTD do offer some courses in this subject we would need to research
            their ability to deliver this training, costs and user feedback.

Ensure the service provides a wide range of options for customers to express their
needs.
             Via the TS web pages
             Dedicated line to CSC (for the whole Council)
             Visit Reports
             Complaints and Service Requests
             Consider using reply post cards in letters etc to obtain customer views
              about topical issues



Active Enquiry

      Improving service delivery by ensuring that officers interacting with
      customers actively obtain the fullest picture of all a customer’s needs
      before trying to satisfy them.

Through a programme of training build on and improve officers‟ skills to:

      ●   Ensure customers‟ needs are sought where these have not been stated
      ●   Understand customers‟ needs
      ●   Ensure ambiguous customer needs are clarified / confirmed
      ●   Obtain the customer‟s perception of service delivery as it is delivered

           See note in Active Listening above

Continue to survey customers who have received service delivery

           Customer Surveys to continue
               Visit Surveys        - Targeted surveys by visit type
                                     - Review questionnaire format. Ensure issues
                                       raised by comments are covered by
                                       questions
                    Complaint Surveys – Specific to CSC fulfilled calls
                                       - Specific to Escalated work
                                       - Redesign the LSC question format

           Spot surveys of customers on topical issues – suggest pre-paid post
            cards
           Explore the use of our web sites
           Explore the expectations of customers in respect of our web usefulness /
            user friendliness etc

Communicate with customers who appear not to use the service to find out why.

           Explore if these people are non-users. Are they using our web sites?
           Explore how we can engage non users – suggest telephone surveys and
            written surveys



Active Response

      Improve service delivery by delivering, where possible, what the customer
      wants.

Through a programme of informing, training and mentoring of officers who interact with
customers to:

      ● Ensure that reasonable customer needs are delivered by the service.
      ● Know „how far they can go‟ when seeking to satisfy a customer need.
           See first note of active listening above

      ● Ensure good communication skills including plain English are used with
        customers.
           Use corporate guides on intranet.
           Monitor and guide officers’ letter writing and telephone communication
            skills.

Service Development Manager (SDM) to continue service complaint management role.
           SDM to ensure that corporate policies on complaints are fully met.



Active Balancing

      Improve service delivery by ensuring that service delivery desires are
      balanced against the service delivery needs of all customers.

By the establishment and implementation of sound policies and policy guidelines which
balance the needs of all customers and:

      ● Ensure that innovative service delivery does not marginalize customers.
      ● Ensure that fairness for all is the foundation of all service delivery.
Through the proper training of those who implement policies to ensure that:
       ● The proper needs of customers are not compromised by unreasonable
         service demands.

           Provide well-researched and communicated policies which give clear
            indications of what we can and cannot do / what we do and do not do
           Provide guidance on dealing with demanding customers


Ensure that service planning includes an accessibility / fairness „audit‟

           Service Development Unit (SDU) to audit service delivery plans for
            accessibility and fairness.



Active Communication

       Improve customer satisfaction through appropriate awareness raising of the
       service‟s aims, achievements, costs, abilities and constraints.
SDU to ensure that timely and efficient means of collecting feedback are in place.

           SDU to ensure that Flare can record all service delivery customer
            feedback
           SDM to ensure that feedback is monitored, analysed and summarised to
            service managers
           SDM to monitor and report to DMT on results of feedback and
            improvement opportunities. Suggest quarterly.

SDU leads on the creation of a „Guide to the services offered by Trading Standards‟

           Produce guide to assist in the promotion of the service and explain in
            succinct terms what the department does and does not do

Improve the web page information on TS services.

       ● Create an information zone on the web pages to outline our approach to
         enforcement, what we expect of traders at a visit.

       ● Create feedback zone on the service web page where summaries of feedback
         can be viewed and commented on by customers

           Create feedback zone on the TS web page
           Put links to feedback zone on Super and Superconsumer
           Put details of consultation on Corporate Communication site including
            outcomes

       ● Create Customer feedback zone on TS Homepage so that officers can see
         current issues and performance.

           SDM puts feedback reports on Homepage
Active Change

      Improve service delivery through challenging the way we achieve it and
      implementing changes which will improve customer satisfaction.
SDM to produce a Customer Care Strategy Implementation Plan to ensure the
Customer Care Strategy is implemented throughout the service.

      ● SDM to act as „Customer Champion‟
          With Team Managers, form Customer Care Group to review customer
           care issues and identify to DMT recommendations to resolve customer
           care issues, identify problem areas / barriers to improvement / strategies
           to overcome issues. Suggest monthly initially.
          Research ways that optimum customer care is acknowledged by team /
           by individual efforts.
          Ensure that corporate customer care initiatives are implemented by TS.
          Ensure the role of the CSC does not compromise our customer
           satisfaction.

      ● Service Managers to take ownership for change in the way their services are
        delivered as a result of customer feedback reports.

          Customer Care to be part of Team Meeting agendas

      ● SDM to audit and report to DMT improvement implementation by service
      delivery
        teams.

          Internal audit program to ensure that improvements are being
           implemented
          Identify key measures of improvement in service plans and ensure these
           are included in service plan monitoring

      ● SDM reports on service improvement through customer feedback in review of
        the management system.
       ANNEX I




FOOD LAW ENFORCEMENT PLAN

        2004/2005
   NORFOLK COUNTY COUNCIL
  TRADING STANDARDS SERVICE

 FOOD LAW ENFORCEMENT PLAN
          2004/2005


Produced in accordance with the requirements of the
  Food Standards Agency Framework Agreement




 If you would like this report in large print, audio, Braille,
     alternative format or in a different language please
  contact our Customer Service Centre on 0844 8008013
                and we will do our best to help
                                   CONTENTS


                                                               Section


Service Aims and Objectives                                      1



Background                                                       2


      Profile of Norfolk                                         2.1

      Organisational Structure                                   2.2

      Scope of the Service                                       2.3

      Demands on the Food Enforcement Service                    2.4

      Enforcement Policy                                         2.5


      Service Delivery                                           3


      Food and Feedingstuffs Premises Inspections                3.1

      Food and Feedingstuffs Complaints                          3.2

      Home Authority Principle                                   3.3

      Advice to Businesses                                       3.4

      Food and Feedingstuffs Inspection and Sampling             3.5

      Control and Investigation of Outbreaks of Food Related
                                                                 3.6
      Infectious Disease

      Food Safety Incidents                                      3.7

      Liaison with Other Organisations                           3.8

      Food and Feedingstuffs Safety and Standards Promotion      3.9
                               CONTENTS Continued 2



                                                       Section


Resources                                                 4


      Finance Allocation                                 4.1

      Staffing Allocation                                4.2

      Staff Development Plan                             4.3


Quality Assessment                                        5



Review                                                    6


      Review against the Food Law Enforcement Plan       6.1

      Identification of any variation from the Plan      6.2

      Areas of Improvement                               6.3


Key Actions and Targets                                   7




Appendices

      County Council Structure                        Appendix A

      Food Chain Inspection Programme                 Appendix B

      Food Law Policy                                 Appendix C

      Project Plans                                   Appendix D

      Inspection Policy and Guidelines                Appendix E
                          CONTENTS Continued 3



                                                   Section

Enforcement Policy                                Appendix F

Enforcement Concordat                             Appendix G

Guidance Notes for Inspections (Food Standards)   Appendix H

Guidance Notes for Inspections (Feedingstuffs)    Appendix I

Home Authority Strategy                           Appendix J

Public Analyst Contract                           Appendix K

Norfolk Food Liaison Group                        Appendix L

Food Law Competencies Schedule 2004/2005          Appendix M

EETSA Inter-Authority Audit Scheme for Food Law
                                                  Appendix N
Enforcement
                                                                            Page 1 of 19




1.    Service Aims and Objectives

1.1   Aims and Objectives of the Trading Standards Service


1.1.1 Norfolk Trading Standards aims to improve the quality of life of people in Norfolk
      when they are acting as consumers or businesses, through the provision of
      consumer protection and the enforcement of trading standards.


1.1.2 The service works to the Objectives of the County Council which are set out in
      the Trading Standards Service Plan (TSSP). The TSSP also recognises the
      National Performance Framework priorities as set out by the Department of
      Trade and Industry Performance Standards for Trading Standards. In particular
      the Service has a major role to play in the following areas:


             ·    Informed Confident Consumers
             ·    Informed Successful Businesses
             ·    Enforcement of a Fair and Safe Trading Environment
             .    Efficient, Effective and Improving Trading Standards Service


      The Key Actions and Targets within the TSSP take forward proposals for all
      aspects of the Service during the 2004/2005 service year. The Food Law
      Enforcement Plan is one of a number of plans specifically identified, which also
      require dedicated key actions and targets in addition to those within the TSSP.
      These additional key actions and targets are detailed in section 7 to this plan.
                                                                            Page 2 of 19



2.    Background

2.1   Profile of Norfolk


2.1.1 Norfolk is a geographically large county spanning some 537,234 hectares. It
      remains a mainly rural county with much of the land set aside to the primary
      production of foods such as cereals and vegetables.


2.1.2 Norfolk has a population of around 804,000, projected to increase to 844,700 by
      2011.


2.2   Organisational Structure


2.2.1 Norfolk Trading Standards Service is part of the County Council‟s Chief
      Executive's Department which also includes services such as Economic
      Development, Emergency Planning, Legal Services and Corporate Personnel.
      The Head of Trading Standards reports to the Director of Corporate Resources
      who in turn, reports to the Chief Executive. The Head of Trading Standards is
      responsible for the referral of policies and procedures to the Fire & Community
      Protection Review Panel. Matters which require a County Council decision are
      referred via the Cabinet for members to consider.


2.2.2 The food standards service can be seen to fit in with the overall County Council
      structure at Appendix A, which also details those officers with a specialist
      responsibility for food standards and feedingstuffs.
                                                                            Page 3 of 19


2.3 Scope of the Service


2.3.1 Norfolk Trading Standards delivers a range of food enforcement services which
      include controls on animal feedingstuffs. Specific functions of this work include:


          ·   programmed inspections
          ·    resolution of complaints
          ·   food and agriculture sampling
          ·   home authority responsibilities
          ·   advice, information and support for businesses
          ·   food promotion activities
          ·   enforcement activities
          .   food hazard warnings
          .   working in partnership
          .   public awareness campaigns


2.3.2 The delivery of the food enforcement service is mainly the responsibility of
      operational teams based in the East and the West of the County. The service is
      delivered alongside other similar services, for example the inspection of
      weighing and measuring equipment.


2.3.3 Currently the delivery of the food enforcement service is carried out exclusively
      by officers employed by the County Council. Analytical services are subject to a
      contract with the Public Analyst for Norfolk, Lincoln, Sutton and Wood Ltd, based
      in Norwich.
                                                                           Page 4 of 19


2.4   Demands on the Food Enforcement Service


2.4.1 There are a number of large food manufacturers in Norfolk, together with some
      large food packers that are contracted to provide fresh vegetables to the main
      supermarket chains. There are also a number of smaller businesses which
      include butchers, bakers and sandwich manufacturers. Retailers now tend to be
      concentrated into fewer large multiple outlets. There are a number of caterers
      which include restaurants, hotels and guest houses. The profile of food
      premises that are liable to food law enforcement visits is to be found in the Food
      Chain Inspection Programme at Appendix B.


2.4.2 Manufacturers and processors in Norfolk having specialist or complex processes
      are also identified in the Food Chain Inspection Programme. Some of these
      companies also come within the remit of the Home Authority Principle, and are
      listed at Appendix J.


2.4.3 Workload can be broadly divided between proactive work, for example
      inspections/ and sampling; and reactive work, such as responding to complaints,
      requests for advice from traders and dealing with other incidents as they occur.
      Complaints made about food standards are dealt with in accordance with the
      Customer Requests Procedures and Work Instruction „‟Food and Feedingstuffs
      Complaints”.


2.4.4 The service is delivered in the main by operational teams based in Norwich and
      King‟s Lynn. A Customer Service Centre intended to handle all initial enquiries
      is based at County Hall, Norwich where calls are received via a local rate
      helpline. All services are available from 08.45 to 17.30, Monday to Thursday
      and from 08.45 to 16.35 on Friday.
                                                                            Page 5 of 19

2.5   Enforcement Policy

2.5.1 Norfolk Trading Standards has an established Enforcement Policy (Appendix F)
      which includes the enforcement of food law. The County Council has signed up
      to the Enforcement Concordat (Appendix G) and the Trading Standards Service
      fully subscribes to its principles.


3.    Service Delivery

3.1   Food and Feedingstuffs Premises Inspections


3.1.1 Food and Feedingstuffs premises inspections are planned in accordance with
      the Food Law Policy (Appendix C). Details of the type and number of premises,
      together with a programme of inspection are to be found in the Food Chain
      Inspection Programme and in Project Plans (Appendix D).


3.1.2 Food and Feedingstuffs inspections will be carried out by suitably qualified and
      experienced officers. Some inspections, which include the collection of data
      soley for the purpose of updating records and identifying potential non-
      compliance with legislation will be delivered by Fair Trading Inspection Officers
      as part of the overall inspection programme for the Trading Standards Service.
      This inspection programme is subject to a robust referral system detailed in the
      Inspection Policy Guidelines (Appendix E) where food law enforcement officers
      carry out all follow up action.


3.1.3 Food Standards Inspections are carried out in accordance with the relevant
      Codes of Practice and Operating Procedure „Enforcement Visits to Businesses‟.
      In addition officers are able to consult detailed guidance notes for both Food
      Standards Inspections (Appendix H) and Feedingstuffs Inspections (Appendix I).


3.1.4 The frequency of planned inspections to relevant premises will be determined in
      accordance with risk. The risk assessment scheme in use by officers during an
      inspection is the LACORS model.
                                                                              Page 6 of 19


3.1.5 Targeted inspection, revisits and other visits will be carried out in addition to
       programmed risk based inspection. Details of these activities are given in the
       Food Chain Inspection Programme and estimated resources required for food
       and feedingstuffs inspection are 1.75 FTE and 0.7 FTE respectively.


3.1.6 Key actions and targets for inspection work during 2004/2005 are detailed within
       the Trading Standards Service Plan.


3.2    Food and Feedingstuffs Complaints


3.2.1 Food and feedingstuffs complaints are dealt with in accordance with the
       Customer Requests Procedures and with work instruction “Food and
       Feedingstuffs Complaints”.


3.2.2 The Food Law Policy details the priority criteria for samples taken as a result of
       consumer complaints as the number one priority for the service.


3.2.3 Current levels of complaints are:


          ·    food            - 200
          ·    agriculture     - 30


       It is estimated that to investigate and conclude this level of complaints
       approximately 0.5FTE and 0.05 FTE respectively are required.


3.2.4 In addition to reactive complaints work, information and advice will be made
       available to consumers. This is achieved through the provision of advice and
       information in paper form, via the Customer Service Centre or the Internet
       (www.superconsumer.com).


3.2.5 Key actions and targets for complaint work during 2004/2005 are detailed within
       the Trading Standards Service Plan.
                                                                             Page 7 of 19


3.3   Home Authority Principle


3.3.1 The Home Authority Strategy (Appendix J) gives details of the way in which the
      service supports the LACORS Home Authority Principle.


3.3.2 Currently, the service has an active Home Authority relationship with 42 food
      businesses and 5 feedingstuffs manufacturers. In addition there are 33 further
      „food chain‟ businesses for which the service is either originating authority or
      Home Authority (within the LACORS definition) but where the latter group is
      made up of companies with whom less contact is required. A summary of these
      companies along with the relevant contact officer details is provided by the
      Home Authority List (Appendix J).


3.3.3 It is estimated that the Home Authority Strategy will require 1.2 FTE (food) and
      0.2 FTE (feedingstuffs). This excludes resources required for inspection and
      promotional activities which are dealt with elsewhere.


3.3.4 Key actions and targets for Home Authority work during 2004/2005 are detailed
      within the Trading Standards Service Plan.


3.4   Advice to Businesses


3.4.1 The Service works with businesses to help them comply with the law and to
      encourage the use of best practice. This is achieved through a range of
      activities including:
             ·   Advice given during the course of inspections and other visits.

             ·   The provision of advice and information in paper form or via the
                 internet.
             ·   Through responding to queries.
                                                                            Page 8 of 19


3.4.2 It is estimated that in excess of 150 food business enquiries (excluding Home
      Authority Businesses) will be made to the Authority during the year 2004/2005
      which will require resources of 0.25 FTE. The likely demand for feedingstuffs
      advice from non Home Authority businesses will be relatively small,
      approximately 30 enquiries, requiring 0.05 FTE.


3.4.3 Key actions and targets for business advice during 2004/2005 are detailed within
      the Trading Standards Service Plan.


3.5   Food and Feedingstuffs Inspection and Sampling


3.5.1 The Service will target its proactive food and feedingstuffs sampling towards
      products/ingredients from companies that manufacture, are based in, or import
      into Norfolk. Sampling plans will be formulated in accordance with the Food Law
      Policy and the „Sampling‟ procedure. Details are given in Project Plans.


3.5.2 The Service‟s sampling programme will also include relevant regional sampling
      through the EETSA (East of England Trading Standards Authorities) group of
      authorities.


3.5.3 All sampling undertaken by officers will be in accordance with all relevant
      legislation and all formal food samples will be taken in accordance with the Food
      Standards Agency Code of Practice No.7: Sampling and Analysis.


3.5.4 Samples will be procured in accordance with the „Sampling‟ procedure and work
      instructions “Food Safety Act 1998 Samples” and “Agriculture Samples”.


3.5.5 The Service aims to sample at a level which is sufficient to meet the sampling
      priorities of the Authority. The sampling budget for the year 2004/2005 will be
      approximately £40,000 of which £30,000 relates to food sampling and £10,000
      to Agriculture sampling. Staffing resources in relation to this are estimated at 0.8
      FTE and 0.5 FTE respectively.
                                                                            Page 9 of 19
3.5.6 Samples will be analysed and/or examined by the Service‟s nominated Public
       Analyst Laboratory in accordance with the procedures laid down in the Food
       Safety (Sampling and Qualifications) Regulations 1990 and the Food Standards
       Agency Code of Practice No.7: Sampling and Analysis.


3.5.7 The Public Analyst appointed by the Authority is the subject of a Contract
       (Appendix K) which is reviewed annually.


3.5.8 Key actions and targets for Food and Agriculture sampling are detailed in
       Section 7 of this plan.


3.6    Control and Investigation of Outbreaks of Food Related
                       Infectious Disease

3.6.1 Food poisoning notifications do not usually fall within the responsibility of the
       Trading Standards Service.


3.6.2 However, should the service become aware of any incident of food poisoning or
       infectious disease, the facts will be reported to the appropriate authority in
       accordance with Work Instructions, „Food and Feedingstuffs Complaints‟ and
       „Food Hazards‟.


3.7    Food Safety Incidents


3.7.1 On receipt of any food hazard warning, the Trading Standards Service will
       respond as appropriate and in accordance with the relevant statutory Code of
       Practice issued under the Food Safety Act 1990 and Work Instruction „Food
       Hazards‟.
                                                                             Page 10 of 19


3.7.2 In most cases, food hazard warnings state that the Environmental Health
      Departments should respond. Instances where the Trading Standards Service
      has had to take action are few and have only required a small number of staff
      hours to resolve. However it is becoming an increasing demand in terms of the
      need to consider each hazard in detail in terms of any need for a response. It is
      estimated that, for the coming service year, 0.05 FTE will be required for the
      work.

3.7.3 In cases where the Service receives reports of chemical contamination of food
      and there is a subsequent threat to human health, it will liase with the
      appropriate local Environmental Health Department, with a view to taking over
      responsibility of the case, or for undertaking a joint investigation, as the situation
      demands.


3.7.4 Key actions and targets for Food Safety Incidents are detailed in Section 7 of
      this plan.


3.8   Liaison with Other Organisations


3.8.1 The Service works with a wide range of organisations in varying degrees of
      formality in carrying out it‟s food law enforcement function. These include
      LACORS, EETSA, Health Authority Services, Environmental Health
      Departments, the Food Standards Agency and others.

3.8.2 The Service maintains a strong regional commitment to EETSA and, via
      quarterly meetings and a regional intranet, aims to ensure that local food and
      feedingstuffs enforcement activity is consistent with neighbouring authorities.


3.8.3 The Service also ensures co-ordination with Environmental Health Departments
      through the Norfolk Food Liaison Group (Appendix L) set up to co-ordinate
      activities as per the Food Standards Agency Code of Practice No.1:
      Responsibilities for Enforcement of the Food Safety Act 1990.


3.8.4 The estimated total resources to be allocated to liaison work during the year are
      40 officer days (FTE of 0.2).
                                                                            Page 11 of 19


3.8.5 Key actions and targets for liaison work are detailed in Section 7 of this plan.


3.9    Food and Feedingstuffs Safety and Standards Promotion


3.9.1 Food Standards promotional work for the year will be linked to events attended
       by the Service, to any relevant prosecutions, to information provided through the
       SuperUK and Superconsumer websites and to leaflets/information displayed at
       points throughout the County. Such promotional work will also include regular
       press releases, locally, regionally and nationally.


3.9.2 Attendance at promotional events by the Service will be assessed considering
       the likely impact of the event, and the client groups and number of potential
       people who will be subject to the event. Previous events include seminars on
       GM foods, Beef labelling, Farmers Markets and West Norfolk Food Fortnight.


3.9.3 The estimated total resources to be allocated to promotional work during the
       year are 10 officer days. (FTE of 0.05 officers).


3.9.4 Key actions and targets for Food Standards promotion activities are detailed in
       section 7 of this plan.


4.     Resources
4.1    Finance Allocation


4.1.1 The total budget for the Trading Standards Service (subject to County Council
       ratification) for 2004/2005 is estimated to be £2,674,070.
                                                                           Page 12 of 19


4.1.2 A breakdown of the Trading Standards budget is reproduced below:



                                      Outturn        Forecast Outturn           Estimate
                                      2002/03            2003/04                2004/05

                                    £1,926,312           £2,163,227            £2,201,600
               Staffing
                                    (£155,586)           (£174,722)            (£177,821)


      Sampling Budget (Food
                                      £56,456              £41,500              £41,500
      & Agriculture Analysis)

          Subsistence/Car
                                     £104,290             £119,000              £140,000
          Allowances and
                                     (£8,423)             (£9,611)              (£11,307)
             Travelling


4.1.3 The relative amounts allocated to food law enforcement are given in brackets
       and are based on the staff allocation breakdown given in paragraph 4.2.2.


4.1.4 The Service continues to invest in modern ICT systems. Access to the Internet,
      to the FLARE database and to other information systems is seen as a vital
      resource for operational staff. All food law enforcement officers have been
      issued with mobile telephones and it is hoped that in time officers will be able to
      have better access to ICT via laptop computers whilst out in the field. The
      current budget for ICT forms part of the overall budget in terms of purchasing
      and leasing costs. This combined with costs associated with equipment
      amounts to an investment of approximately £2,000 in relation to food law
      enforcement.


4.1.5 Currently no set amount is set aside for legal costs with specific regard to food
      law. However a general legal cost header is allocated to the budget, the
      forecast amount for 2004/2005 being £15,800.
                                                                           Page 13 of 19


4.2   Staffing Allocation


4.2.1 For operational purposes, the service is divided into four key teams:

             ·   The Customer Service Centre (Front Line Services provided by
                 Norfolk County Coucil)
             ·   Fair Trading Teams
             ·   A Farm Enforcement Team
             ·   An Investigation Team


      The Fair Trading Teams undertake the majority of food law enforcement
      although the Customer Service Centre, Farm Enforcement and Investigation
      teams deal with a degree of „gateway‟ consumer/business advice, feedingstuffs
      and „high level‟ investigation work respectively.


4.2.2 The Fair Trading Teams inspect any premises supplying goods or services
      where there is a reference to quantity, quality, description or price. The range of
      duties given to the teams is therefore very wide. Whilst there is no dedicated
      „food team‟, food law enforcement officers have been identified within each of
      the geographical units to carry out this work.

      The Farm Enforcement Team operates county wide from its base in Norwich.
      This team also undertakes a wide range of activities including animal health,
      Feedingstuffs and fertilisers enforcement. The following breakdown of staff
      allocation is an assessment of staff resources from each team:

            Food Law Enforcement          = 4.8 FTE

            Feedingstuffs Enforcement = 1.5 FTE

            Total                         = 6.3 FTE
                                                                           Page 14 of 19

      Note – These figures reflect the following key functions within each area:

              Complaint Handling

              Business Advice

              Home Authority Work

              Inspections

              Sampling

              Liaison Work

              Formal Investigations

              Food and Feedingstuffs Hazard Response

              Promotional Activities



4.2.3 The staff profile reflecting the proposed time allocated to food law enforcement is
      also contained within the Food Law Competencies Schedule (Appendix M)
      which also identifies the qualifications, skills and knowledge requirements for the
      various levels of food law enforcement.


4.3   Staff Development Plan

4.3.1 The current structure allows the service to focus on the needs of both specialist
      food law enforcement officers and other staff in terms of their training and
      continuous professional development (CPD).

4.3.2 The current training structure is reflected in the Training and Development
      procedure and the Learning and Development Plan. The „Qualifications,
      Competency and Training of Enforcement and Advice Officers‟ work instruction
      also provides links via the Training Procedure to the ongoing development of
      staff.


4.3.3 Key actions and targets for staff development are detailed within the Trading
      Standards Service Plan.


                                                                           Page 15 of 19
5.    Quality Assessment

5.1   Quality Assessment


5.1.1 Food Law Enforcement is subject to the established Quality Improvements and
      Auditing Procedure which applies to the whole of the Trading Standards Service.



5.1.2 Norfolk Trading Standards is accredited to ISO 9001:2000 and is therefore
      subject to a rolling external audit programme, the next audits being scheduled
      for April and October 2004.


5.1.3 In 2003/04 the EETSA Inter-Authority Audit scheme for food law enforcement
      was implemented (Appendix N). The scheme is intended to allow individual food
      authorities to review their system against the FSA Standard and their own
      documented plans and procedures, using a robust audit system acceptable to
      the FSA and which focuses on promulgating best practice amongst EETSA
      members. The scheme recognises, and is consistent with, the aims of the FSA
      Audit Scheme as documented in Chapter 5 of the Framework Agreement. Audits
      are carried out over a 3-year rolling programme.


5.1.4 The service was also successful in achieving the Investor in People award in
      November 1999.



5.1.5 Key actions and targets for Quality Assessment are detailed in Section 7 to this
      plan.
                                                                              Page 16 of 19

6     Review

6.1   Review against the Food Law Enforcement Plan


6.1.1 This Plan is subject to the ongoing monitoring and review of the Service;
      specifically work instruction „Food Law Enforcement Plan‟. The review will
      include information on the year‟s performance against the plan and in particular
      the specified performance targets/outcomes.

6.1.2 Key actions and targets for review of the Food Law Enforcement Plan are
      detailed in Section 7 to this plan.

6.2   Identification of any variation from the Plan


6.2.1 The review will look for areas where there has been variation in performance
      and identify reasons for that variation.


6.2.2 Where alternative activities have taken place which have achieved the same
      objectives, these will be identified within the review.




6.3   Areas of Improvement


6.3.1 Although recent improvements have already been made to the food enforcement
      service, it is anticipated that the introduction of this food law enforcement plan
      will result in the identification of further opportunities to improve current
      procedures and practices.

6.3.2 Any areas for service development which come out of the review and/or quality
      or other assessments will be taken into account within the provisions of Work
      Instruction „The Food Law Enforcement Plan‟.
                                                                                                                   Page 17 of 20

SECTION 7.    FOOD LAW ENFORCEMENT PLAN 2004/2005 SUMMARY OF KEY ACTIONS AND TARGETS


     National         Food Law Enforcement Plan – Key            Food Law Enforcement Plan – Key             Local Priorities
   Performance                   Actions                                    Targets
                                                                      st
Framework Priority                                           (By 31 March 2005 unless otherwise stated)



                      1 Initiate and Implement the Food          Food Sampling Plan in place at 1st
                        Sampling Plan                             April 2004

                                                                 By 31st March 2005 Food Sampling
                                                                  Plan completed


                      2 Initiate and Implement the                    Feedingstuffs and fertiliser
                        Feedingstuffs and Fertilisers                  sampling plan in place at 1st April
                                                                                                                 SAFE
Enforcement of a        Sampling Plan                                  2004
                                                                                                              Objective 15
Fair & Safe Trading
                                                                                                              Objective 14
Environment                                                           By 31st March 2005 feedingstuffs       Objective 40
                                                                       and fertiliser sampling plan
                                                                       completed


                      3 Ensure an effective response to            Food Hazard procedure in place
                        emergency incidents in relation to        and followed
                        the food chain
                                                                    Out of hours emergency response
                                                                  system reviewed by 31st March 2005
                                                                                                                     Page 18 of 19

SECTION 7.      FOOD LAW ENFORCEMENT PLAN 2003/2004 SUMMARY OF KEY ACTIONS AND TARGETS


National               Food Law Enforcement Plan – Key             Food Law Enforcement Plan – Key             Local Priorities
Performance                       Actions                                     Targets
                                                                      st
Framework Priority                                             (By 31 March 2005 unless otherwise stated)


                       4.   Devise and deliver an                     Food chain education/promotion
                            education/promotion programme            programme devised by 31st May
Informed                    for food chain businesses via            2004
Successful                  seminars, briefings, promotional
Businesses                  events and other communication            Food chain education/promotion
                            channels                                 programme delivered by 31st
                                                                     March 2005.

                                                                                                            Economically thriving
                       5.   Work with the public, private,          Participate in all appropriate
                                                                                                                Objective 35
                            business community and                   local/regional/national liaison
                                                                                                                Objective 32
                            voluntary sectors to ensure that         groups
                            food standards initiatives and
                                                                                                            Active and Engaged
                            services support each other and         Contribute to the EETSA regional
                                                                                                                     22
Efficient, Effective        work together                            enforcement and food chain
and Improving                                                        sampling plan as appropriate
Trading Standards
Service                                                             Participate in the Norfolk Food
                                                                     Liaison Group


                       6.   Improve targeting of food chain           22% of samples found to be
                            sampling                                  unsatisfactory on analysis.
                                                                                                                     Page 19 of 19


     National          Food Law Enforcement Plan – Key             Food Law Enforcement Plan – Key             Local Priorities
   Performance                    Actions                                     Targets
                                                                      st
Framework Priority                                             (By 31 March 2005 unless otherwise stated)



                       7.   Deliver the annual learning and          Learning and Development plan
                            development plan in relation to          delivered by March 31st March
                            food standards                           2005.
                                                                     By 30th June 2004 food hygiene
                                                                     competencies reviewed
                                                                     By 31st March 2005 basic and
                                                                     update training for food hygiene
                                                                     delivered as required
Efficient, Effective
and Improving                                                                                               Underpinning our work
Trading Standards                                                                                                Objective 40
Service
                       8.   Implement Food Standards               Competency and Peer review
                            Competency and Peer review              system in place by 30th September
                            system                                  2004.


                       9.   Continue to deliver the EETSA          By 31st March 2005 carry out a
                            Inter-Authority Audit Scheme for        Quality Assessment of activities
                            Food Law Enforcement (Year 2).          against the Food Standards Agency
                                                                    Framework Agreement Standards
10. Review the delivery of the Food      By 31st March 2005 carry out formal
    Law Enforcement Plan                  review of the Food Law Enforcement
    2004/2005 against the                 Plan for 2004/2005, identifying any
    requirements of the Food              variation from the plan and
    Standards Agency Framework            recommending areas of
    Agreement                             improvement
                                         Performance Monitoring against key
                                          actions and targets to be reported on
                                          a quarterly basis
            ANNEX II



MINOR SALES: MAJOR CONSEQUENCES PLAN
               2004/2005
        NORFOLK COUNTY COUNCIL TRADING STANDARDS SERVICE



       MINOR SALES: MAJOR CONSEQUENCES
                      Enforcement of Age Restricted Sales Plan


A plan to reduce the incidence of underage sales of proscribed goods in Norfolk and reduce
                  the level of associated anti-social and criminal behaviour

1.    Service Aim and Objectives

1.1   Norfolk Trading Standards aims to improve the quality of life of people in Norfolk
      when they are acting as consumers or businesses, through the provision of
      consumer protection and the enforcement of trading standards

1.2   Our 5 key objectives are:

      Objective 1. To protect consumers and businesses from rogue traders through effective
                   enforcement.

      Objective 2. To put right consumer and business problems through efficient
                   interventions and to help Norfolk citizens seek redress where it is
                   appropriate.

      Objective 3. To ensure Norfolk businesses are aware of their rights and legal
                   obligations and comply with them through effective education, advice,
                   support and risk based inspection.

      Objective 4. To ensure Norfolk citizens are aware of their consumer rights through
                   effective education, advice and support.

      Objective 5. To continuously develop the Trading Standards Service so as to
                   improve its effectiveness and efficiency.

      The Minor Sales: Major Consequences Plan is one of a number specifically identified which
      require dedicated key actions and targets in addition to those within the Trading Standards
      Service Plan. These additional key actions and targets contribute towards meeting the
      Service Aim and Objectives.
                                                                                       Page 2 of 10


2.    Introduction

      Legislation to prevent the sale of proscribed goods to underage children is well established.
      Ongoing development also addresses emerging issues and the Government‟s drive to
      tackle anti-social behaviour and the development of an Alcohol Strategy has provided a
      focus for the Service‟s activities.

      Norfolk County Council Trading Standards recognises that effective enforcement of the
      legislation requires a multi-agency approach. During 2003/04 a Home Office funded
      initiative enabled the Service to develop a robust framework addressing the many facets of
      an effective enforcement strategy including the development of educational resources,
      advice, information and support for both consumers and traders. The 2004/05 service year
      will see the continued development of this work and the mainstreaming of the many
      activities, procedures and processes into the core work of the Service.

3.    Scope of the Service

3.1   Norfolk County Council Trading Standards delivers the enforcement of a range of legislation
      covering „underage sales‟. This is accomplished by:

                    Programmed inspections
                    The resolution of complaints
                    The provision of advice, information and support for businesses
                    An intelligence led „test purchasing‟ programme
                    Enforcement activity
                    Publicity and promotional activities
                    Multi-agency and partnership working
                    Working with community groups and other voluntary agencies/organisations

3.2   The delivery of the service is the responsibility of Fair Trading and Investigation Teams
      based in the east and west of the county. The teams work within agreed procedures and
      protocols including those that cover the sharing of information and the recruitment of young
      persons for test purchase programmes.

3.3   The service can be accessed through the Norfolk County Council Customer Service Centre,
      the Internet based services, email, facsimile, letter or by personal call.

4.    Statement of Policy

      To reduce the incidence of underage sales in Norfolk through the effective enforcement of
      relevant legislation in partnership with key organisations, agencies, businesses and the
      community. The Trading Standards Service fully subscribes to the principles of the
      Enforcement Concordat in carrying out its duties.
                                                                                         Page 3 of 10


5.     Service Delivery

5.1    Intelligence-led enforcement

5.1.1. In making best use of the available resources, enforcement programmes will be planned
       using relevant information and intelligence held by the service including that supplied by
       partner organisations. Analysis of the data will be used to determine „hotspots‟ and to target
       identified problems. This method will also enable improved partnership working, identifying
       those agencies/organisations that are best placed to put right any non-compliance with
       legislation or unfair trading practice.

       The sharing of information and intelligence and the improved flow of this shared resource
       will be achieved by the implementation of an information sharing protocol with all involved
       partners. Policy and procedures will be established for gathering and sharing information
       used to formulate intelligence for tasking officers.

5.1.2. The sharing of information will promote joint working and other collaborative enforcement,
       increasing the effectiveness of activity undertaken by individual organisations/agencies.

5.2.   The night-time economy

5.2.1. The consumption of alcohol and subsequent anti-social and other criminal behaviour is of
       increasing concern to the government, enforcement agencies, licensees and the wider
       community. Enforcement activity in the past has concentrated on daytime outlets but there
       is increasing concern about the levels of consumption at premises open in the evenings
       until the early hours (public houses, nightclubs and other clubs).

5.2.2. During 2004/05 a number of multi-agency interventions will be undertaken, led by Norfolk
       Police. Activity will be targeted at known „problem‟ premises identified through the analysis
       of information/data. The Trading Standards Service will take part in these interventions and
       where necessary, will take enforcement action.

5.2.3. The multi-agency interventions will be used to promote and publicise the Minor Sales: Major
       Consequences Plan, particularly the NO ID – NO SALE campaign which emphasises the
       Proof of Age Schemes.

       All multi-agency interventions will be well planned work programmes having defined
       objectives and outcomes.

5.3.   Test Purchase programmes

5.3.1. One element of an effective enforcement strategy is to carry out a test purchase programme
       targeted at known problem premises. The programme for 2004/05 will concentrate on the
       sale of alcohol, solvents (including lighter fuel) tobacco and cigarettes, fireworks and knives
       unless subsequent intelligence directs this activity to other products.
                                                                                          Page 4 of 10


5.3.2. The test purchasing of alcohol at „off licence‟ premises will be undertaken by Norfolk County
       Council Trading Standards Service and that at „on licence‟ premises, by the Police.

5.3.3. The recruitment, selection and utilisation of young persons for test purchasing will only be in
       accordance with the protocols and systematic procedures adopted by the Service and
       developed in line with the strict guidelines laid down by the Home Office and other
       organisations. These protocols and procedures are maintained in the Service‟s Quality
       Management System and are thus subject to rigorous internal and external audit.

       An Officer leading a test procedure programme can only do so if a Criminal Records Bureau
       check has been carried out. Officers assisting, who form the core team carrying out this
       work will also be required to have a Criminal Records Bureau check carried out.

5.4.   Proof of Age Schemes

5.4.1. The Trading Standards Service does not promote any specific proof of age scheme but
       supports those schemes that conform to the PASS Scheme criteria. A photo driving licence
       or a valid passport can also be used as „proof of age‟.

5.4.2. An annual programme to promote the use of Proof of Age cards will be implemented,
       alongside trader awareness initiatives. The trader information pack contains references to
       the Proof of Age Schemes and also includes a NO ID – NO SALE poster.

5.4.3. The Trading Standards Service will also encourage and promote the use of a „Refusals Log‟
       by traders to provide evidence that proof of age is being sought and sales refused in
       appropriate circumstances.

5.5    Education Programmes

5.5.1 Businesses

5.5.1.1.   Trader Information Packs and relevant leaflets will be distributed by request and where
           appropriate, when an inspection visit to a business is undertaken. A selective mailing to
           3,000 businesses was undertaken in 2003/04

5.5.1.2.   During 2004/05 a number of business seminars will be run to complete the programme
           begun in 2003/04. The seminars are focussed on the sale of alcohol, solvents and
           knives and the associated anti-social behaviour but the content is relevant to all
           proscribed products.

5.5.1.3.   Publicity will also be used to raise trader awareness about specific issues and this will
           include the reporting of enforcement action outcomes.
                                                                                        Page 5 of 10


5.5.2. Young Persons

5.5.2.1.   The Trading Standards Service Underage Sales Pack and leaflet will be distributed to
           young persons through partner agencies and organisations including schools.

5.5.2.2.   All volunteers who partake in test purchasing programmes will receive a training
           package primarily designed to equip them with the knowledge and skill to undertake the
           task. These opportunities also promote active citizenship in young people whose
           participation is recognised and evidenced through the provision of a certificate, which
           can be attached to a CV.

5.6.   Publicity and media campaigns

5.6.1. The Trading Standards Service will produce a number of articles to raise awareness through
       the press, radio or television.

5.6.2. Where appropriate, enforcement action will be reported through local media outlets.

5.6.3. Multi-agency work will be actively promoted and reported, including regional or national
       coverage where relevant.

5.6.4. Support and publicity will be sought for new initiatives launched during 2004/05. Where
       possible local members or community representatives will be requested to support or attend
       relevant activities.

5.7.   Community Involvement

5.7.1. Where possible, the Trading Standards Service will participate in or support community
       based projects that develop resources to assist in underage sales activities.

5.7.2. The Trading Standards Service will promote underage sales work through presentations at
       community group meetings.

5.7.3. Where resources allow, the service will undertake to tackle specific problems identified by a
       community group regarding underage sales. A community group will need to provide
       sufficient evidence of a credible nature in support of the request before the Service will
       undertake any activity.

5.7.4. The Service may also agree to participate in other local projects if relevant to underage
       sales activities.
                                                                                       Page 6 of 10


5.8.   Training and Development

5.8.1. Through ongoing training and development the „pool‟ of officers able to take on enforcement
       work of underage sales legislation, will be increased during 2004/05.

5.8.2. Of particular importance is the need to separate the roles within the recruitment of
       volunteers to undertake test purchasing. The officer undertaking the selection process will
       not be involved in the training of those selected or any test purchasing programmes they are
       involved in.

5.9.   Tackling Anti-social Behaviour

5.9.1. The link between anti-social behaviour and the consumption of alcohol or solvent abuse is
       established.

       This plan is designed to prevent the upstream supply of a number of restricted products to
       underage persons and thus reduce the level of anti-social behaviour associated with the use
       of these products.

5.9.2. This plan will contribute to the objectives of the Crime and Disorder Reduction partnerships
       particularly those arising from the governments Alcohol Strategy and Anti-social Behaviour
       Strategy.
                                                                                                                Page 7 of 10
                     MINOR SALES – MAJOR CONSEQUENCES PLAN 2004/2005
                           SUMMARY OF KEY ACTIONS AND TARGETS
                                                                                      National
                                  Key Targets (By 31st March 2005 unless
        Key Actions                                                                 Performance         Local Priorities
                                            otherwise stated)
                                                                                 Framework Priority
1.   To increase the uptake of        Distribute the services‟ „Young
     PASS accredited Proof of          Persons Information pack to Year 10
     Age schemes such as               and above students throughout
     Citizencard, Portman and          Norfolk.
     Connexions cards through         Increase the number of cards issued
     promotional and                   by 25% over the previous end of
     educational activities.           service year figure.
2.   Provide young people with        Distribute the services‟ „Young
     information and advice            persons Information pack to Year 10       Informed Confident
     about underage sales and          and above students throughout             Consumers
     the consequences of               Norfolk.
     obtaining restricted goods                                                                             Safe
     illegally.                                                                                          Objective 10
3.   Complete two recruitment         Recruit a minimum of 4 test                                       Objective 12
     programmes to identify a          purchasers from each programme to                                 Objective 15
     cohort of volunteer test          assist in current enforcement activity.
     purchasers using the
     Service‟s established                                                                             Active & Engaged
     systematic procedures.                                                                               Objective 22
4.   Implement a programme of         Achieve 86 staff days of underage
     test purchasing based on          sales enforcement.
     intelligence received and
     the analysis of crime data
                                                                                 Enforcement of a
     from identified reliable
                                                                                 Fair and Safe
     sources.
                                                                                 Trading Environment
5.   Respond to complaints            Respond to complaints in accordance
     received about alleged            with the Intervention Protocol.
     supply of proscribed goods
     to underage persons.
                                                                                                                 Page 8 of 10

                                                                                       National
                                   Key Targets (By 31st March 2005 unless
         Key Actions                                                                 Performance         Local Priorities
                                             otherwise stated)
                                                                                  Framework Priority
6.   Provide a balanced                Participate in a minimum of 2 night-
     approach to the                    time economy, multi-agency
     enforcement of underage            enforcement operations.
     sales through the inclusion
     of activity outside normal
     retail opening hours.
7.   Work with the public,             Participate in the Crime & Disorder
     private, business                  Reduction partnerships.
     community and voluntary           Participate in and work closely with                                 Safe
     sectors to ensure the              the Consumer Support Network (CSN)        Informed Successful
     effective enforcement of                                                                             Objective 10
                                        partners.                                 Businesses
                                                                                                          Objective 12
     underage sales legislation.       Participate in the Norfolk Alliance
                                                                                                          Objective 15
                                        Against Tobacco group contributing        Enforcement of a
                                        resources where appropriate.              Fair and Safe
                                       Participate in the Local Strategic        Trading Environment   Active & Engaged
                                        Partnerships.
                                                                                                           Objective 22
                                       Draw up and implement a
                                        Memorandum of Understanding with
                                        Norfolk Fire Service regarding the sale
                                        and storage of fireworks enforcement
                                        activity.
8.   Implement the Information         Utilise information and intelligence
     and Intelligence sharing           gathered to direct enforcement, advice
     protocol.                          and awareness activities.
                                                                                                                 Page 9 of 10

                                                                                      National
                                     Key Targets (By 31st March 2005 unless
          Key Actions                                                               Performance          Local Priorities
                                               otherwise stated)
                                                                                 Framework Priority
9.    Provide traders with advice,       Complete the series of planned
      information and support to          business seminars arising from the
      prevent underage sales              Minor Sales: Major Consequences
      and consequent anti-social          project.
      behaviour.                         Distribute the Minor Sales: Major
                                          Consequences information pack and
                                          leaflets and provide advice during
                                          routine inspection visits. Total number
                                          of packs distributed to exceed 1000                                Safe
                                          per annum.
                                                                                                          Objective 10
                                         To include information and advice
                                                                                                          Objective 12
                                          about underage sales legislation and    Informed Successful
                                                                                                          Objective 15
                                          other relevant information on           Businesses
                                          www.superuk.com.
                                         To provide information and advice                             Active & Engaged
                                          using the news media where
                                                                                                           Objective 22
                                          appropriate including the prosecution
                                          of offenders and other formal action
                                          taken. Achieve 10 pro-active contacts
                                          with the media.
10.   Continue to promote the            Reduce the level of „successful‟ sales
      NO ID-NO SALE campaign              from test purchasing programmes to
      to help reduce the number           less than 10%.
      of underage sales.
                                                                                                                  Page 10 of 10

                                                                                        National
                                    Key Targets (By 31st March 2005 unless
          Key Actions                                                                 Performance          Local Priorities
                                              otherwise stated)
                                                                                   Framework Priority
11.   Distribute the Minor Sales:       Provide the toolkit to the seven Crime
      Major Consequences                 and Disorder Reduction partnerships
      toolkit for tackling anti-         in Norfolk.
      social behaviour and other        Provide the toolkit to Trading
      criminal activity.                 Standards authorities when
                                         requested.
12.   Seek funding from the             To secure sufficient funding to sustain
      seven Crime and Disorder           the current levels of activity as a
      Reduction partnerships in          minimum.
      Norfolk to continue the
      Minor Sales: Major                                                           Efficient, Effective
                                                                                                          Underpinning Our
      Consequences initiative                                                      and Improving
                                                                                                               Work
      contributing to the                                                          Trading Standards
                                                                                                            Objective 40
      reduction of anti-social                                                     Service
      behaviour.
13.   Train and develop staff to        Train a minimum of four Fair Trading
      carry out and assist with          team members by October 2004 to
      the test purchasing                the level of lead officer.
      programme
14.   Report on the level of            Produce report for the Fire &
      activity in relation to the        Community Protection Review panel
      sale of tobacco and                by the end of April 2004.
      cigarettes enforcement in
      2003/04.
        ANNEX III




FARM ENFORCEMENT PLAN 2004/2005
 NORFOLK COUNTY COUNCIL

TRADING STANDARDS SERVICE

 FARM ENFORCEMENT PLAN

                     2004/2005


     If you would like this report in large print, audio, Braille,
 alternative format or in a different language please contact our
   Customer Service Centre on 0845 7 444466 and we will do
                          our best to help
                                          CONTENTS



                                                                  Sections

Background                                                           1


Structure and Aims of the Service                                    2


Service Delivery                                                     3


Finance                                                              4


Enforcement Policy                                                   5


Key Actions and Targets                                              6




Appendices


On Farm Inspections Checklist                                        A

Cleansing, Disinfecting and Planning for Visits to Agricultural
                                                                     B
Premises

Enforcement Policy – Animal Health & Welfare Issues                  C


Enforcement Policy – Agriculture                                     D


Standard Letters                                                     E
                                                                                                   Page 1 of 10

1. BACKGROUND


In the 2004/2005 service year, the Department of the Environment, Food and Rural Affairs
(DEFRA) will be introducing a framework agreement for the Animal Health and Welfare
function. This authority has been part of a pilot trialing the agreement and elements of it have
already been introduced.

The key aspects can be stated as follows:

   1. Service delivery principles which include:
        High level organisational information
        Specific Objectives
        Specific Profiles

   2. Risk analysis of agricultural type premises

   3. Activities carried out

   4. Management information (data capture of enforcement work)

   5. Finance


1.1 Breakdown of Agriculture Premises Types within Norfolk (where known)

As part of the agreement, the profile of the Animal Health and Welfare function has been carried out and this can
be stated as follows:

  Total number of Business Premises:                                                 See below

  Number of premises currently risked as:
  High-Risk
  Medium-Risk
                                                                                     See below
  Low-Risk
  No Inspectable-Risk:


  Total number of Premises registered as livestock keepers:                          See below

  Number of keepers – Mixed Species:                                                 Not Known

  Number of keepers – Single Species:
  Cattle
  Sheep/Goats
                                                                                     Not Known
  Pigs
  Deer


A census carried out in 2003/2004 has given the Department a better understanding of the livestock keepers in the
county. A risk assessment of the premises will be completed by the end of March 2004.


                                                                                                      Page 2 of 10

  Number of Markets (all types):                                                     1 per week
  (Number of Market operating days):
    Number of Collecting Centres (all types):                                           1 per week
    (Number of Collecting Centre operating days):

    Number of Abattoirs (all types, including OTMS):                                    16
                                                                                        (red and white meat)

    Number of Knackers/Hunt Kennels:                                                    8

    Number of Ports/Airports:                                                           4

    Number of Commercial Hauliers:                                                      12

    Data Capture System used:                                                           FLARE


1.2 Profile of Norfolk

    Norfolk is a large county (537,000 hectares) with a population of around 804,000

    25% of the population is aged 60 or over (as compared to the national average of 21%)

    Only 0.39% of the population comes from Black and minority ethnic communities

    The county has three large centres of population

        Norwich     (194,930)
        Gt Yarmouth (69,275)
        King‟s Lynn (39, 475)

    There are a significant number of market towns (20 with a population in excess of 4000) that act as focal
     points for rural communities

    There are pockets of both urban and rural deprivation with areas of Great Yarmouth, King‟s Lynn and Norwich
     amongst the 10% most deprived areas in the country

    There are 29,000 businesses, over 60% of which are small (employing 5 or fewer people)

    It remains a predominantly rural county, with a significant number of people employed in the agriculture sector

    The skills base is low and earnings are below the national average
                                                                                      Page 3 of 10

2. STRUCTURE AND AIMS OF THE SERVICE

The primary aim of the Farm Enforcement team is to:

        Ensure high levels of animal health and welfare
        Enforce the Agriculture Act in relation to feedingstuffs and fertilisers

The principal legislation enforced can be listed as follows:

Acts
         Agriculture Act 1970
         Animal Health Act 1981
         Protection of Animals Act 1911
         Agriculture (Miscellaneous Provisions) Act 1968
         Animal Health Act 2002


Secondary Legislation

         Anthrax Order 1991
         Animal By-Products Regulations 2003
         Animal Gatherings Order 2003 - as amended
         Cattle Identification Regulations 1988
         Disease Control (Interim Measures) (England) (No.2) Order 2003 – as amended
         Feeding Stuffs (Establishments and Intermediaries) Regulations 1999
         Feeding Stuffs Regulations 2000
         Fertilisers Regulations 1991
         Markets, Sales and Lairs Order 1925 – (Temporarily Revoked)
         Pigs (Records, Identification and Movement) Order 2003
         Rabies (Control) Order 1974
         Sheep and Goats Identification and Movement (Interim Measures) (England) (No.2)
         Order 2002 - as amended
         Specified Risk Materials Order 1997 – as amended
         Sheep Scab Order 1977
         Swine Fever Order 1963
         Transport of Animals (Cleansing and Disinfection) England (No.3) Order 2003
         Welfare of Animals (Transport) Order 1997
         Welfare of Animals at Markets Order 1990
         Welfare of Horses at Markets (and Other Places of Sale) Order 1990


The following outlines some of the most important enforcement areas under the above
legislation (Source: LACORS document - Animal Health and Welfare LA Roles on Farms):

I.       Responsibilities for the enforcement of separation, staining, storage, record keeping,
         prohibition of sale, or use for food purposes, of SRM in all premises not licensed under
         the Fresh Meat (Hygiene and Inspection) Regulations 1995. In addition to farms, this
         includes slaughterhouses, unlicensed cutting premises, collection centres, rendering
         plants, knackers yards, hunt kennels, veterinary and medical laboratories and other
         premises which might use SRM eg. tennis racquet manufacturers and includes control
         while in transit. (The Specified Risk Material (SRM) Regulations 1997 (Food Safety Act)
         and The Specified Risk Material Order 1997 as amended by the TSE Regulations 2002
         (Animal Health Act)).
                                                                                        Page 4 of 10


II.       False certification or declarations, regarding meat, meat products, carcases or animals,
          in relating to BSE, country and place of origin, and animal identifications (Trade
          Descriptions Act 1968, Cattle Identification Regulations 1988, Fresh Meat (Beef
          Controls) (No.2) Regulations 1996).

III.      Breach of any disease restriction notice or requirements such as TB, Brucellosis, Foot
          and Mouth, Swine Fever.

IV.       Illegal animal imports and illegal landings of rabies susceptible animals whether
          intentional or accidental.

V.        Failure to keep records as required by any Order.

VI.       Illegal feeding of waste food or inappropriate carcase disposal (Animal By-Products
          Regulations 2003).

VII.      Transit of unfit animals, causing unnecessary suffering in transport and transporting
          animals not fit for the intended journey.

VIII.     Other breaches of the transit regulations, including journey times, vehicle standards and
          provisions regarding rest and feeding.

IX.       Exposure of unfit animals for sale and other breaches of the markets legislation, likely to
          involve unnecessary suffering.

X.        Failure to treat scab-affected sheep, movement of scab affected sheep, clearance of
          common land, seizure of unauthorised sheep (Sheep Scab Order 1997).



The number of officers currently employed to carry out the farm enforcement functions is:


      Team Manager                                                               1 FTE
      Principal Enforcement Officer                                              1 FTE
      Farm Enforcement Officers                                                  8 FTEs
      Licensing Officers (Temporary)                                             2.5 FTEs
                                                                                     Page 5 of 10
3. SERVICE DELIVERY

The proposals for service delivery are detailed in Section 6 (Key Actions and Targets). These
include requirements which flow from the DEFRA Framework Agreement and also the
Framework Agreement for Food Law Enforcement, which details procedures and policies for
feedingstuffs enforcement in the following areas:

     Inspection
     Home Authority Work
     Sampling
     Promotion
     Complaints
     Advice to Businesses
     Liaison Arrangements

Increasingly the key actions of the Farm Enforcement Team contribute to wider controls on
primary food production. It is recognised that improved liaison arrangements between
agencies in enforcing such controls are vital in order to achieve confidence in the food chain.
Principal areas of concern include:

     Animal by-products (meat fraud)
     Veterinary residues (banned medicines)
     Feedingstuffs (undesirable substances)

There also needs to be a closer working relationship with the various teams in the Service
itself. Policies and procedures will therefore be introduced so there is a rigorous and robust
approach in service delivery thus ensuring the health and welfare of animals and creating a
confidence level where Norfolk consumers do not have concerns about the food they eat.

Estimates for the associated resources required are given below:

FARM ENFORCEMENT TEAM AVAILABLE STAFF DAYS: 1487.5 (8.5 FTEs)

Review in process with DEFRA, due for completion in mid March 2004.

The requirements for activities will be communicated to individual staff by way of goal setting in
their annual appraisal. This is supported by guidance/checklists, an example being the “On
Farm Inspection” Checklist (see Appendix A) and guidance on cleansing and disinfection (see
Appendix B).

4. FINANCE

The sampling budget allocated for feedingstuffs and fertilisers analysis is £10,000. This
equates to approximately 90 samples. This area of work links directly to the Food Law
Enforcement Plan (FLEP), which provides for the production of a detailed Feedingstuffs and
Fertiliser Sampling Plan. (Awaiting input from FSA and all sampling data 2003/2004, due for
production in April 2004).

Ongoing costs for the team relate to the procurement of personal protective equipment and
disinfectant. This will come directly out of the Operating Equipment budget.
                                                                                   Page 6 of 10

Welfare inspections which lead to investigations require a large input from Local Veterinary
Inspectors. The cost of such inspections can be quite high so £5,000 has been made available
for this. Additionally it may be necessary for an expert to look at animal carcases, bones etc.,
and this needs to be accounted for in the said monies.


5. ENFORCEMENT POLICY

To ensure consistency with investigations of animal health and agriculture matters, policies
specific to said investigations have been produced. These are as stated in Appendices C and
D.

In addition standard letters have been agreed on repeat offences (see attached Appendix E).

Furthermore service level agreements have been agreed with particular Local Veterinary
Inspectors (LVI‟s) to provide assistance on welfare cases. The Service Level Agreement is
currently under review and will be part of the plan when the LVI‟s have signed up to it.
                                                                                                                           Page 7 of 10
Section 6: Farm Enforcement Plan 2004/2005 – Summary of Key Actions and Targets

    National
  Performance     Farm Enforcement Team                         Farm Enforcement Team
                                                                     Key Targets                             Priorities
   Framework      Key Actions                           (By 31st March 2005 unless otherwise stated)
     Priority

                  1 Farm Enforcement Team to resolve     10% of referrals closed out within 1
                    complaints/business enquiries and     working day of referral from Team
                    put right detrimental practices       Manager/Duty Officer to Actioning
                                                          Officer
                                                         30% of referrals closed out within 5
                                                          working days of referral from Team
INFORMED                                                  Manager /Duty Officer to Actioning
CONFIDENT                                                 Officer                                              Safe
CONSUMERS                                                50% of referrals closed out within 20             Objective 15
                                                          working days of referral from Team
                                                          Manager/Duty Officer to Actioning
                                                          Officer
                                                         100% of referrals except those where
                                                          an IF has been raised or a sample is
                                                          required closed out within 40 working
                                                          days

                  2 Achieve a risk based inspection        Review in process with DEFRA –             Economically Thriving
                    and sampling programme                  completion by Mid March 2004
                                                                                                           Objective 31
ENFORCEMENT                                                                                                Objective 34
OF A FAIR AND                                              85% of inspections found to be correct         Objective 33
SAFE TRADING                                                or corrected on first visit
ENVIRONMENT
                                                                                                               Safe
                                                                                                            Objective 15
   National
 Performance    Farm Enforcement Team                         Farm Enforcement Team
                                                                   Key Targets                             Priorities
  Framework     Key Actions                           (By 31st March 2005 unless otherwise stated)
    Priority


                3 Investigations                         See 2                                              Safe
                                                                                                          Objective 15
                                                                                                          Objective 10

                                                                                                             Safe
ENFORCEMENT     4 Conduct AMLS Follow-up Work            See 2
OF A FAIR AND                                                                                             Objective 15
SAFE TRADING                                                                                              Objective 10
ENVIRONMENT
                5 DEFRA Framework Agreement              Deliver/Embrace the Framework                      Safe
                  (New)                                   Agreement                                       Objective 15


                6 Biosecurity (New)                      100% of all farm inspections deliver               Safe
                                                          biosecurity advice                              Objective 15


EFFICIENT       7 Joint Working with other Agencies      Plan visits where possible with
EFFECTIVE AND     (New)                                   appropriate agencies
IMPROVING                                                                                            Economically Thriving
TRADING                                                                                                  Objective 15
STANDARDS
SERVICE
                                                                                                                        Page 9 of 10

   National
 Performance    Farm Enforcement Team                        Farm Enforcement Team
                                                                  Key Targets                             Priorities
  Framework     Key Actions                          (By 31st March 2005 unless otherwise stated)
    Priority

                8 New Feed Hygiene Legislation          Prepare farming community by way of
INFORMED          (New)                                  inspection and advice
                                                                                                    Economically Thriving
SUCCESSFUL
BUSINESSES                                                                                               Objective 15




                9 Ammonium Nitrate Safety               Aim for 100% inspection
ENFORCEMENT       Regulations (New)
OF A FAIR AND                                                                                               Safe
SAFE TRADING                                                                                             Objective 15
ENVIRONMENT



EFFICIENT       10 Review the delivery of the Farm    Carry out formal review of the Farm
EFFECTIVE AND      Enforcement Plan 2004/2005          Enforcement Plan identifying any
IMPROVING          against the requirements of the     variation from the plan and                          Safe
TRADING            DEFRA Framework Agreement           recommending areas of improvement                 Objective 15
STANDARDS                                             Performance monitoring against key
SERVICE                                                actions and targets to be reported 4
                                                       times a year
                                                                                Page 10 of 10


                                                                   SUPPORTING DOCUMENT


FARM ENFORCEMENT TEAM


New Key Drivers 2004/05

1) Deliver DEFRA Framework Agreement in its entirety by appropriate Service Delivery and
   effective partnership with SVS.

     Key Action 5

2) Customer satisfaction surveys indicate that farmers view our own biosecurity with suspicion.
   Biosecurity is key to disease control so 100% of all inspections must deliver effective
   advice.

     Key Action 6

3) Joint working with other agencies is key to an effective enforcement regime. Customer
   Satisfaction Surveys indicate that this is an issue.

     Key Action 7

4) Proposed new Feed Hygiene Legislation will require the farming community to change their
   working practices.

     Key Action 8

5)   Ammonium Nitrate Safety Regulations are a new duty for Local Authorities. In view of the
     potential risks all imports will be inspected.

     Key Action 9

				
DOCUMENT INFO