1. Report on the Food Law
Enforcement Service
London Borough of Brent
24 June – 27 June 2003

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Foreword
Audits of local authorities’ food law enforcement services are part of the Food
Standards Agency’s arrangements to improve consumer protection and
confidence in relation to food. These arrangements recognise that the
enforcement of UK food law relating to food safety, hygiene, composition,
labelling, imported food and feeding stuffs is largely the responsibility of local
authorities. These local authority regulatory functions are principally delivered
through their Environmental Health and Trading Standards Services.
The attached audit report examines the Local Authority’s Food Law Enforcement
Service. The assessment includes the local arrangements in place for
inspections of food businesses and foodstuffs, sampling and analysis, internal
management, food safety promotion and educational activities. It should be
acknowledged that there will be considerable diversity in the way and manner in
which local authorities may provide their food enforcement services reflecting
local needs and priorities.
Agency audits assess local authorities’ conformance against the Food Law
Enforcement Standard “The Standard”, which was published by the Agency as
part of the Framework Agreement on Local Authority Food Law Enforcement and
is available on the Agency’s website at:www.food.gov.uk/enforcement.
The main aim of the audit scheme is to maintain and improve consumer
protection and confidence by ensuring that local authorities are providing an
effective food law enforcement service. The Scheme also provides the
opportunity to identify and disseminate good practice and provide information to
inform Agency policy on food safety.
The report contains some statistical data, for example on the number of food
premises inspections carried out. The Agency’s website contains enforcement
activity data for all UK local authorities and can be found at:
www.food.gov.uk/enforcement.
The report also contains an action plan, prepared by the Authority, to address the
audit findings.
For assistance, a glossary of technical terms used within the audit report can be
found at the Annex.

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CONTENTS
Page
1.0 Introduction 4
Reason for the Audit 4
Scope of the Audit 4
Background 5
2.0 Executive Summary 7
3.0 Audit Findings 8
3.1 Organisation and Management 8
3.2 Review and Updating of Documented Policies and
Procedures
11
3.3 Authorised Officers 12
3.4 Facilities and Equipment 14
3.5 Food and Feeding Stuffs Premises Inspections 15
3.6 Food, Feeding Stuffs and Food Premises Complaints 20
3.7 Home Authority Principle 21
3.8 Advice to Business 22
3.9 Food and Feeding Stuffs Premises Database 23
3.10 Food and Feeding Stuffs Inspection and Sampling 24
3.11 Control & Investigation of Outbreaks and Food Related
Infectious Disease
25
3.12 Food Safety Incidents 26
3.13 Enforcement 27
3.14 Records and Inspection Reports 31
3.15 Complaints About the Service 33
3.16 Liaison with Other Organisations 34
3.17 Internal Monitoring 35
3.18 Third Party or Peer Review 36
3.19 Food and Feeding Stuffs Safety and Standards Promotion 37
Action Plan for the London Borough of Brent 38
Annex: Glossary 42

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1. Introduction
1.1 This report records the results of the audit under the headings of the
Food Standards Agency Food Law Enforcement Standard and has
been made publicly available on the Agency’s website at
www.food.gov.uk/enforcement. Hard copies are available from the Food
Standards Agency’s Local Authority Enforcement Division at Aviation
House, 125 Kingsway, London WC2B 6NH, Tel: 020 7276 8434.
Reason for the Audit
1.2 The power to set standards, monitor and audit local authority food law
enforcement services was conferred on the Food Standards Agency by
the Food Standards Act 1999. The audit of the food service at the
London Borough of Brent was undertaken under section 12(4) of the
Act as part of the Food Standards Agency’s annual audit programme.
1.3 The Authority was included within the audit programme on the basis of
a low level of food standards inspections of high risk premises, as
indicated by 2001 monitoring information provided to the Agency under
section 13 of the Food Standards Act 1999. The London Borough of
Brent was subsequently named in a paper presented to the Food
Standards Agency's Board in February 2003. Further details of
monitoring statistics can be found at:www.food.gov.uk/enforcement.
Scope of the Audit
1.4 The audit covered the London Borough of Brent’s food hygiene, food
standards and feeding stuffs law enforcement service. The audit
specifically excluded the Authority’s food sampling activities in relation
to microbiological examination, compositional analysis and food
labelling as this activity had been subject to an audit by the Agency in
December 2002. The food sampling audit formed part of a focused audit
programme which specifically examined food sampling activities carried
out by 15 local authorities.
1.5 The on-site element of the audit took place on 24-27 June 2003 at the
Authority’s Food Safety Service Group offices at Brent House,
349-357 High Road, Wembley, London.
1.6 The audit assessed the Authority’s conformance against the Standard,
using audit protocols FSA/AP3/1 – FSA/AP21/1. The Standard was
adopted by the Food Standards Agency Board on 21 September 2000,
(amended March 2002), and forms part of the Agency’s Framework
Agreement with local authorities. The Framework Agreement and the
audit protocols can be found on the Agency’s website at:
www.food.gov.uk/enforcement.

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Background
1.7 Brent is one of London’s most diverse boroughs. It extends from Kilburn
and Park Royal in the south to Colindale in the north and Northwick
Park in the north-west. The Borough is highly developed and has an
overall population of 263,000 that is culturally and racially diverse. Five
neighbourhoods fall within the top 10% most deprived in the United
Kingdom. Unemployment is over 15% in some areas of the Borough
and overall is 40% above the national average. A comprehensive
programme is underway to regenerate the area. Brent is well located for
businesses with good road and rail links to Central London and contains
2 of London’s largest industrial estates.
1.8 Food hygiene, food standards and feeding stuffs enforcement was
carried out by officers of the Food Safety Service Group within the
Environmental Health Service Unit.
1.9 The Food Safety Service Group were also responsible for enforcement
and provision of advice and information on occupational health and
safety in food businesses, licensing of skin piercers and special
treatments and management of the infectious disease notification
system.
1.10 The Environmental Health offices were open from 09.00–17.00 Monday
to Thursday and 09.00-16.45 on Fridays. An emergency service
operated outside of normal hours. Specified staff, who were
Environmental Health Officers (EHOs), responded to requests and
where appropriate would refer food matters onto the Deputy Head of
Environmental Health or the Service Manager (Food Safety) for action.
1.11 The yearly return to the Food Standards Agency for 2002/2003 stated
that the Food Safety Service Group was responsible for enforcing food
hygiene legislation in 2,018 premises, of which 376 (19%) were
categorised as high risk (i.e. premises with either an A or B risk rating).
The average percentage of high risk premises for food hygiene for a
London borough is 16%. Food businesses were predominantly within
the catering (58%) and retail (34%) sectors, with 90 food manufacturers
and packers (4%). Food standards legislation was enforced in 1,987
premises of which 4 (0.2%) were categorised as high risk for food
standards, compared with a national average of 1% for London
boroughs.

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1.12 The Authority’s monitoring returns made to the Agency for the four
quarters making up the financial year 2001/2002 indicated that the
Authority carried out:
Enforcement Activity No.
Food hygiene inspections 1,063
Food hygiene other visits 433
Formal food samples 411
Informal food samples 209
Food standards inspections 587
Food standards other visits 170

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2. Executive Summary
2.1 The Authority was able to demonstrate an effective food law
enforcement service with a good level of compliance with the Standard
overall. There was evidence of effective management and planning of
the Service and the Authority was adhering to its policies and
procedures.
2.2 Assessments of compliance with food hygiene requirements in general
premises, Approved Premises and in licensed butchers’ shops were
effectively carried out.
2.3 The database was up to date, well maintained and effectively used for
monitoring purposes. File records were generally well organised,
retrievable and contained relevant information.
2.4 The Authority’s Strengths:
Food Hygiene Inspections – The Authority was undertaking inspections
for food hygiene purposes in a structured and comprehensive manner
with detailed records. The standard inspection form encouraged a
detailed and systematic approach to inspections and helped to ensure
that appropriate records were maintained.
Assessment of Approved Premises and licensed butchers’ shops -
These assessments were carried out in a thorough manner and detailed
records had been maintained over a number of years. Standard
inspection and licensing assessment forms aided this process.
Database - The database was accurate, well maintained and effectively
utilised to assist in the delivery of the food safety service.
2.5 Key Areas for Improvement:
There were no key areas for improvement.

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3. Audit Findings
3.1 Organisation and Management
3.1.1 The Council’s political management structure comprised a Leader and
Cabinet form of executive together with a mayor who was elected
annually by Members of the Council. A revised Constitution had been
adopted in May 2003. In addition to Scrutiny and Overview Committees,
the Council had adopted a number of other Committees and sub-
committees relating to various Council functions. One Executive
Member was the portfolio holder for Environment and Planning.
3.1.2 The Authority had 5 Service Areas: the Corporate Centre, Education,
Arts and Libraries, Environmental Services, Housing and Social
Services. Food and feeding stuffs law enforcement was part of the
Environmental Health Service Unit of the Environmental Services
Directorate.
3.1.3 The corporate planning framework included the Directorate’s Strategic
Service Development Plan 2003-2006 based on the Council’s
Corporate Strategy 2002-2006 and the Council’s Best Value
Performance Plan. The Council had identified 5 corporate strategy
themes, namely:
• Supporting children and young people;
• Promoting quality of life and the green agenda;
• Regeneration and priority neighbourhoods;
• Tackling crime and community safety;
• Achieving service excellence.
3.1.4 The second, and the last of these, were directly supported by the Food
Safety Service.
3.1.5 The Best Value Performance Plan (BVPP) 2002/2003 contained
information about the services, details of performance in previous years,
and set out performance indicators for the forthcoming year. These
included, BVPI 166, the national best value performance indicator for
environmental health and trading standards. An Environmental Health
target of 90% had been set for 2002/2003.
3.1.6 A Best Value Performance Review was due to be completed in
December 2003 and was a cross cutting review across all 5 units of the
Environmental Services Directorate.

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3.1.7 The aim of the Food Safety Service, as detailed in the Service Plan for
Food Safety Enforcement 2003/2004, was to “work in partnership with
local people, other agencies and businesses to protect consumers
within the Borough by ensuring that all foods imported, produced,
stored, handled, distributed and consumed within the Borough on a
commercial basis, are safe, wholesome and meet compositional and
labelling requirements.”
3.1.8 Fourteen objectives had been set to meet the aim and these included:
• To achieve upper quartile performance for Best Value Performance
Indicator, BVPI 166;
• To achieve successful outcome in ‘public’ audits by statutory bodies;
• To achieve the Unit’s published Service Guarantees in response to
requests for service.
Figures provided in the Service Plan indicated the following past and
expected future performance levels for food hygiene and food
standards inspections:
2003/4 2002/3 2001/2 2000/1
Food hygiene inspections
% completed of those
planned
100%(e) 99% 89% 91%
Food standards inspections
% completed of those
planned
85%(e) 75% 78% 100%
(e) = estimated
3.1.9 The Service Plan had been approved by Members and was in line with
the Service Planning Guidance in the Framework Agreement on Local
Authority Food Law Enforcement.
3.1.10 Local performance indicators covering response times to complaints,
sampling rates and inspection rates had been set and were subject to
quarterly review by senior management and the Executive. These were
detailed in the Service Plan 2003/2004. Any variance in meeting the
plan was also addressed.

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3.1.11 The number of staff working on food law enforcement was provided in
the Service Plan 2003/2004 as follows:
Level of Food Law Enforcement
No. of
Staff
(FTE)*
Environmental Health Officer or
equivalent
6.0
Holder of the Ordinary Certificate in Food
Premises Inspection
0.8
Staff undertaking non-enforcement food
safety duties
4.0
Service Management 1.8
TOTAL 12.6
* Full Time Equivalent
3.1.12 The expenditure for food enforcement over the past 3 years was also
provided in the Plan. The figures excluded the cost of the support
services, accommodation, information technology and other non-
specific services provided within the Environmental Health Service. The
expenditure is shown below:
Area of Expenditure 2001/2
actual
(£’000)
2002/3
actual
(£’000)
2003/4
planned
(£’000)
Staffing 332 396 489
Sampling & analysis 14 17 16
Legal services 0 6 1
Supplies & services 25 32 13
Expenditure (total) 371 451 519
Income (total) 32 29 13
Total Budget 339 422 506
3.1.13 The auditors were advised that revenue growth bids had recently been
made and included 2 food safety issues, namely the provision of ‘an
Environmental Services One-Stop-Shop for Brent Businesses’ and to
deal with the ‘Revision of the Codes of Practice.’
3.1.14 The Authority was not aware of any premises that required feeding
stuffs enforcement visits at the time of the audit and only reactive work
was undertaken in this area.

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3.2 Review and Updating of Documented Policies and Procedures
General
3.2.1 The Authority had a document control system for internal policies and
procedures. Controlled policies and procedures were held on a central
drive for read only access by staff. New versions were drafted by the
Service Manager (Food Safety) and circulated for comment and
agreement prior to the version being logged onto the central drive. The
review dates were checked by the Service Manager (Food Safety) on a
regular basis and dates recorded in the ‘Food Managers Calendar.’ If
necessary, procedures would be amended whenever there were
changes to legislation or centrally issued guidance.
3.2.2 Documented procedures had been developed for all areas required by
the Standard. The procedure on investigating and prosecuting offences
was in draft format and currently out to consultation. A small number of
procedures required minor amendment or expansion.
3.2.3 Officers had access to all legislation, Codes of Practice and national
guidance necessary for food law enforcement.
Feeding Stuffs
3.2.4 Officers had access to feeding stuffs legislation and relevant official
guidance. The procedure on responding to service requests included
the investigation of complaints relating to pet food and animal feeding
stuffs. An inspection procedure was being developed but it was
understood that the Authority did not currently have any feeding stuffs
establishments.

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3.3 Authorised Officers
3.3.1 The Authority had a documented procedure on “the authorising of
officers to exercise powers” and a clear scheme of delegation. Officers
were authorised to undertake duties under the Food Safety Act 1990
and associated Regulations. Authorisation was also conferred under the
European Communities Act 1972 in relation to specific regulations. The
Director of Environmental Services was authorised to exercise powers
contained in Brent’s constitution and he in turn had authorised each
post in the Food Safety Service Group to exercise specific powers. This
was further clarified in the Environmental Health Management Scheme
which named officers who were authorised to make specified
management decisions concerning functions within the Unit and also
placed limitations on the authorisations given to officers where
appropriate. Authorisations were based on externally set qualification
and competency requirements.
3.3.2 All field officers were operating in accordance with their authorisations,
qualifications, training and experience. However, the specialist food
officer, who was the Service Manager (Food Safety), was authorised to
detain and seize food and to serve emergency prohibition notices,
contrary to the requirements of Code of Practice 19: Qualifications and
Experience of Authorised Officers. Failure to meet these requirements
could leave the Authority open to legal challenge. It is understood that
the Authority had considered and was satisfied with the competency of
the officer and had included such authorisation to protect public health
but would rarely use the power in practice. There is provision in Code of
Practice 19 for equivalent qualifications to be considered by the Agency
and this approach was discussed at the time of the audit.
3.3.3 The Authority had appointed an officer with specialist knowledge to
have lead responsibility for food hygiene, food standards and feeding
stuffs legislation. This officer was not an Environmental Health Officer
(EHO) but was supported by 3 EHO team leaders who had specialist
food responsibilities and lead on allocated food hygiene, food standards
and feeding stuffs issues.
3.3.4 The Authority had drawn up a documented training programme and
there was a systematic process for identifying individual and group
training needs. Comprehensive individual training plans had also been
drawn up for any officers new to food work and these were
complemented by a new starter induction process and a checklist of
items required for officers new to the Authority.

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3.3.5 Records of qualifications and training were available for all officers and
these records demonstrated that sufficient update training was being
carried out. A file of course details was generally maintained and officer
training notes were kept and circulated to other officers for information.
Records of the duration, objectives and content of any relevant training
provided were not always available.
3.3.6 The Authority had achieved Investors in People accreditation and had
implemented the Council’s officer appraisals scheme. There was
evidence that food law enforcement officers had received update
training related to the Police and Criminal Evidence Act 1984. The
auditors were informed that a course on the Criminal Procedure and
Investigations Act 1996 was programmed in addition to a training
course to better familiarise officers with imported food controls.
Recommendations
3.3.7 The Authority should:
(i) Ensure that all officers are authorised in accordance with
their qualifications, training and experience, in line with Food
Safety Act Code of Practice No:19: Qualifications and
Experience of Authorised Officers. [The Standard – 5.3]
(ii) Ensure that training records include details of the duration,
objectives and content of all training provided.
[The Standard – 5.4]

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3.4 Facilities and Equipment
3.4.1 The Authority was providing the necessary equipment and facilities to
enable all activities associated with the Service to be carried out. The
Authority did not have feeding stuffs sampling equipment but had made
arrangements for the loan of sampling equipment from a neighbouring
authority when required.
3.4.2 The Authority had produced a documented procedure on the calibration
and maintenance of monitoring equipment. Records indicated that the
procedure was being implemented and that all equipment was within
calibration. The auditors were informed that checks before and after
enforcement action would be carried out if the situation arose, although
the procedure referred only to checks prior to formal food sampling and
after sampling had been completed. There was evidence that defective
equipment was being removed from service and this arrangement was
included in the procedure.
3.4.3 The computer software operated by the Authority was capable of
providing the information required by the Agency’s official monitoring
returns.
3.4.4 The Authority operated a system of restricted access levels, password
protection and mandatory fields for data entry aimed at minimising the
risk of corruption and loss of information held on the database. A
procedure dealing with database information and a user’s guide had
also been developed and implemented.
Recommendation
3.4.5 The Authority should:
Further develop the documented calibration and maintenance of
monitoring equipment procedure so that it includes checks before and
after enforcement action in accordance with Food Safety Act Code of
Practice No. 10: Enforcement of the Temperature Control
Requirements of the Food Hygiene Regulations. [The Standard – 6.2]

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3.5 Food and Feeding Stuffs Premises Inspections
Food Hygiene
3.5.1 The Authority’s yearly return to the Agency for 2003/2004 showed the
following profile for food hygiene premises:
Risk Category No. %*
A 29 2
B 348 18
C 916 48
D 233 12
E 294 15
F 74 4
Premises outside programme 22 1
TOTAL 1,916
*Figures rounded to the nearest percent
3.5.2 The Authority had set a 100% performance target for both high risk and
lower risk inspections that were due for the financial year, and
performance was monitored and reported to Members on a quarterly
basis.
3.5.3 A list of overdue inspections was run from the database as part of the
audit. This showed that no highest risk category A premises were due
for inspection at the time of the audit. Eighteen other premises (16
category B premises and 2 category C premises) were overdue.
3.5.4 The inspection histories for 10 general premises and 10 Approved
Premises were examined. With the exception of 1 general premises and
2 Approved Premises, all had been inspected at the correct frequencies
set out in Food Safety Act Code of Practice No.9: Food Hygiene
Inspections.
3.5.5 All premises examined had been inspected by officers with appropriate
levels of qualification, training and experience and the correct level of
authorisation.
3.5.6 A comprehensive standardised inspection form was used to record
business details and inspection findings for general food hygiene
inspections. Records indicated that officers’ assessments of compliance
with legally prescribed standards and risk assessment ratings were in
accordance with the relevant official guidance. Follow-up actions had
been taken when appropriate.

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3.5.7 For all premises examined, officers left either a standard hand written
inspection report on site or sent a follow-up letter detailing legal
requirements and recommendations as soon as possible and within 4
weeks of completion of the inspection. A recent procedural change
required a hand written report of the inspection to be issued to the
proprietor in all cases with a follow-up letter where appropriate.
3.5.8 The Authority had approved 34 premises under product specific
legislation. All premises had been appropriately notified to the Agency.
A complete review of Approved Premises had been identified and
progressed as an area for action in the Service Plan for 2002/2003 and
specific products highlighted for further action in the current Plan.
3.5.9 Specific inspection forms were used for the inspection of Approved
Premises and these helped in ensuring a comprehensive assessment of
compliance of premises and systems to legally prescribed standards.
Recent inspections had all been carried out under the correct
legislation.
3.5.10 Approval documents were maintained on file for all premises. Six out of
12 documents did not record the approved activities and 8 did not detail
the products approved. Seven documents did not include the
requirement to notify the local authority of any changes. The auditors
were advised that the files examined mainly related to premises that
had been approved prior to the review. Details of production volumes
and types of activities were included on the inspection forms for existing
premises. Approval documentation had subsequently been revised and
documentation relating to premises approved after the review did
contain the relevant information.
3.5.11 An inspection report or letter relating to the last 3 inspections was held
on file for all premises.
3.5.12 Ten files relating to the licensing of butchers’ shops were examined.
The Authority had used a standard application form and a
comprehensive checklist for assessments. Butchers’ shop licensing
assessments were clearly documented and officers appeared to be
assessing compliance of food businesses with the Regulations and
related official guidance. There was evidence that the Authority was
sending out reminders at an early stage and chasing up applicants
before expiry of licenses. In 3 cases, the application had not been
determined within 28 days of receipt. There was evidence that 2
businesses had been trading without a licence although the Authority
was taking action on these.

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3.5.13 The standard licence format issued by the Authority contained all
relevant details and was in line with the official guidance. Where a
licence had been refused, the notice of determination clearly laid out the
reasons why and the options available to the applicant.
3.5.14 The Authority had developed a documented procedure for food hygiene
inspections, this was entitled ‘policy and procedure for food safety and
standards inspections’ and included an addendum inspection protocol
for contractors. Procedures covering butchers' shop licensing and
approval of product specific premises had also been developed. Whilst
follow-up actions including improvement notices, emergency prohibition
and inspection, detention and seizure of food were covered in the
procedure for food safety and standards inspections, some further
development was needed to outline the process to be followed by
officers. A useful and simple aide memoire had also been developed
which summarised current inspection issues including food hazard
warning information that officers took on inspections.
3.5.15 A draft policy and procedure on investigating and prosecuting offences
had been developed and was being circulated for comment at the time
of the audit.
Food Standards
3.5.16 A breakdown of premises subject to food standards inspection was also
detailed in the Authority’s yearly return to the Agency for 2003/2004 as
follows:
Risk Category No. %*
High 0 0
Medium 581 31
Low 1,309 69
Premises outside the programme 0 0
TOTAL 1,890
*Figures rounded to the nearest percent
3.5.17 The Service Plan estimated the expected performance to be 85%
completed of those food standards inspections planned for 2003/2004.

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3.5.18 The Authority’s previous yearly return for 2002/2003 had indicated that
there were 4 premises assessed as high risk for food standards. The
auditors were advised that implementation of an historical unitisation
policy had broken some premises down into units that may not have
been appropriate in all cases. This policy had now changed and the
Service Manager (Food Safety) was systematically checking the
database to assess unitisation in accordance with the revised policy.
3.5.19 The risk assessment history for 1 large scale importer that had
previously been high risk was examined. In the past, this had been
treated as 3 units and 3 inspections had been carried out as part of the
inspection programme. This premises was now entered as 1 unit on the
database and a recent risk assessment appeared to have appropriately
assessed the premises as medium risk. A software programme to
identify historical risk assessments from the database was not available
at the time of the audit, but file records for general premises checked
during the course of the audit did not appear to indicate that any of
these premises should have been assessed as high risk.
3.5.20 A list of overdue inspections was run from the database as part of the
audit. This confirmed that no high risk inspections were overdue.
Seventeen medium risk and 5 low risk premises were overdue.
3.5.21 The inspection histories for 10 food premises were examined. Five of
the premises had not been inspected at the correct frequency. Five
premises appeared to have been correctly risk assessed but there was
insufficient information on the file to determine the other 5 cases.
3.5.22 Premises had been inspected by officers with the correct authorisation.
A report of inspection had been sent or left on site in all but 1 of the
most recent inspections and a follow-up letter had been sent in 2 cases,
in accordance with the Authority’s policy.
3.5.23 There was evidence that officers were assessing compliance of
manufacturers and importers premises and systems in accordance with
legally prescribed standards. It was not, however, possible to verify that
an adequate assessment of food standards in non-manufacturing
premises had been carried out as the record forms only recorded limited
information about what had been inspected for food standards
purposes. This had been recognised by the Authority and a revised
inspection form had recently been introduced which expanded on the
food standards issues relevant to non-manufacturing premises. There
was evidence that a comprehensive assessment of these premises was
now being carried out.

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3.5.24 The procedure for food standards inspections was detailed in the
documented ‘policy and procedure for food safety and standards
inspections’. This incorporated the revised inspection form dealing with
food standards in retailers and caterers and an inspection protocol/aide
memoire for officers carrying out inspections of manufacturing
premises.
Feeding Stuffs
3.5.25 The auditors were advised that no premises requiring inspection under
feeding stuffs legislation had been identified by the Authority in its area.
The Authority did not have a procedure that specifically dealt with the
inspection of feeding stuffs establishments, although it was understood
that there were plans to develop one.
Recommendations
3.5.26 The Authority should:
(i) Ensure that food hygiene and food standards inspections are
carried out at a frequency which is not less than that required
by the relevant Food Safety Act Codes of Practice.
[The Standard – 7.1]
(ii) Expand the inspection procedure to detail the procedures for
the range of follow-up actions that reflects current practice
and relevant official guidance. [The Standard – 7.4]
(iii) Implement the investigating and prosecuting offences
procedure. [The Standard – 7.4]

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3.6 Food, Feeding Stuffs and Food Premises Complaints
General
3.6.1 The Authority had implemented a policy and procedures for dealing with
the investigation of complaints about food and feeding stuffs and on
responding to Service Requests. The Service Plan for 2003/2004 set
out an objective for the Unit to achieve published ‘Service Guarantees’
in responding to requests for service. This included a rapid response to
specified incidents, including those of imminent and significant public
health risk within 24 hours, and all other service requests to be
responded to within 3 working days.
Food Hygiene
3.6.2 The records of 10 food hygiene and food premises complaints received
by the Authority were examined. In all cases, appropriate investigations
had been carried out. Eight had been responded to within the
Authority’s target response time and there was evidence that the results
of investigations had been confirmed with complainants. All files
showed that complete data had been recorded about the complaint.
Food Standards
3.6.3 The records of 10 food standards complaints received by the Authority
were examined. Appropriate investigations had been carried out and
complaints had been responded to within the Authority’s target
response time. Results of investigations had been confirmed with
complainants and all files showed that complete data had been
recorded about the complaint. In 1 case concerning aflatoxin in ground
nutmeg, the Food Standards Agency had been contacted and a product
withdrawal initiated.
Feeding Stuffs
3.6.4 No complaints had been made to the Authority about feeding stuffs in
the 2 years preceding the audit.

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3.7 Home Authority Principle
3.7.1 The Authority recognised the value of the Home Authority Principle in
securing and improving food hygiene and food standards practices. The
Authority acted formally for 1 local business and informally for a large
number of others in the Borough. The auditors were advised that a
review of food businesses with decision making bases in their area had
been carried out several years ago and another similar exercise was
planned.
3.7.2 There was clear evidence on the files that officers had liaised where
appropriate with Home and Originating authorities.

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3.8 Advice to Business
3.8.1 The Authority had been providing advice during the course of visits and
inspections and in response to specific enquiries. A dedicated call
centre had been set up to deal with Environmental Health issues and
requests were logged on the database and responded to within the
Authority’s Service Guarantees framework. The Authority was also
carrying out a range of other activities aimed at helping businesses,
which included the following:
• Production of a range of food hygiene and food standards leaflets
on specific topics, for example, guidance for the preparation and
storage of cold ready to eat foods and general requirements and
guidance on quantitative ingredient declaration;
• Training courses in food hygiene including courses in languages
other than English;
• Production of advisory letters aimed at specific businesses;
• Awareness seminars on specific topics;
• Distribution of information packs to planning applicants proposing to
set up a food business and others on request;
• Participation in a local business partnership.
3.8.2 A business support service was under development to form greater
links with local food businesses and to assist them in complying with
legal requirements. A Revenue growth bid had also been made for
2004-2005/2006-2007 to set up and run an Environmental Services
One-Stop-Shop for Brent businesses, to provide advice and support to
businesses on a range of legislation enforced by Regulatory Services.

23. - 23 -
3.9 Food and Feeding Stuffs Premises Database
3.9.1 The Authority had established a database of the food businesses in the
Borough. This was used for recording food hygiene, food standards and
any feeding stuffs data. It was evident that extensive measures had
been taken to ensure that the database was comprehensive.
3.9.2 Ten food premises were selected at random from a local business
directory. All were on the database and included in the food hygiene
and food standards inspection programmes.
3.9.3 A documented procedure on database information had been developed
which set out the measures taken to ensure that the system was
routinely updated and cross-referenced with other sources of data. This
was supported by a Database Users’ Guide Supplement for the Food
Safety Service.
3.9.4 Reasonable security measures were in place to prevent access and
amendment of data by unauthorised persons.

24. - 24 -
3.10 Food and Feeding Stuffs Inspection and Sampling
General
3.10.1 The Authority had been subject to an audit by the Agency in December
2002 regarding its food sampling activity and this area was therefore
not included in the scope of this audit.
Feeding stuffs
3.10.2 At the time of the audit no planned feeding stuffs sampling had been
undertaken. The auditors were informed that there were no feeding
stuffs manufacturers or wholesalers in the Borough.

25. - 25 -
3.11 Control and Investigation of Outbreaks and Food Related
Infectious Disease
3.11.1 The Authority had a documented Infectious Disease Outbreak Control
Plan. This had been drawn up by Brent and Harrow Health Authority in
conjunction with local authorities in accordance with national guidelines.
The Plan was due to be revised shortly to take account of structural
changes within the Health Authority.
3.11.2 The Authority had developed a documented policy on the Control of
Infectious Diseases and documented procedures on the investigation of
cases and outbreaks of food poisoning and the processing of infectious
disease notifications.
3.11.3 The investigation records relating to 3 outbreaks and 8 notifications of
food related infectious disease were examined. In general, records of
the investigations carried out were insufficient to determine if
appropriate action had been taken.
Recommendation
3.11.4 The Authority should:
Ensure that investigations of outbreaks and individual notifications of
food related infectious disease are carried out in accordance with its
documented procedures and that complete records are maintained for
at least 6 years. [The Standard – 13.2 and 13.3]

26. - 26 -
3.12 Food Safety Incidents
3.12.1 The Authority had a computer system capable of receiving food hazard
warnings (FHWs) and a documented procedure that set out the process
for responding to and initiating FHWs.
3.12.2 The Service’s responses to a sample of FHWs that had been issued by
the Agency were examined. From the records checked it was clear that
appropriate action had been taken. This had included officer monitoring
visits, information letters and local press releases.
3.12.3 One food safety problem with wider significance had been identified
locally by the Authority and proper notification had been made to the
Agency.

27. - 27 -
3.13 Enforcement
General
3.13.1 The auditors were informed that the Authority had adopted the
Enforcement Concordat in 2000. This is a Home Office and Local
Government Association scheme that sets out the principles of good
enforcement practice, based on the following criteria:
• Standards of service and performance;
• Openness and clarity;
• Helpfulness;
• Effective complaints procedures;
• Proportionality of enforcement actions;
• Consistency.
3.13.2 The Authority had developed a generic Environmental Health Unit
Enforcement Policy which had received Member approval in July 2002.
The Policy had been published on the Council’s website and hard
copies were available to members of the public and businesses on
request. There was evidence that the Enforcement Policy had been
supplied to a legal advisor representing a food proprietor when
requested.
3.13.3 A draft policy and procedure on investigating and prosecuting offences
had been produced to complement the Unit’s Enforcement Policy. The
purpose of the document was to act as a reference for officers and as a
standard against which managers should audit officers’ decisions on
whether or not to prosecute.
3.13.4 The Authority had also developed additional documents that were
entitled ‘Enforcement Policies’. These related to specific food service
activities and included an Enforcement Policy on Control of Infectious
Disease, an Enforcement Policy on responding to Service Requests
and an Enforcement Policy on Butchers’ Licensing. These policy
documents were intended to complement the Environmental Health
Enforcement Policy but had not been submitted for Member approval or
made publicly available, as required by the Standard. The documents
generally contained guidance and procedural information, although the
latter in particular set out significant policy decisions on butchers’ shop
licence refusals, premises trading without a licence and licensed
premises found not meeting licence conditions.
3.13.5 Regulatory services within the Environmental Services Directorate
operated an Enforcement Forum which met to discuss enforcement
issues.

28. - 28 -
3.13.6 The following formal enforcement actions were taken by the Authority in
the 2 years preceding the audit:
• 89 improvement notices served on 53 premises;
• 17 emergency prohibitions;
• 2 voluntary closures;
• 1 formal caution;
• 10 seizures and detentions;
• 5 voluntary surrenders.
3.13.7 A sample of 10 improvement notices served on 5 premises was
examined. All notices had been served by a correctly authorised officer
who had witnessed the contraventions and had been served on the
proprietor. The reasons for the contravention were specified, clearly
worded and the works required were specified, clear and easily
understood.
3.13.8 Two notices that related to lack of adequate training for food handlers
and 1 on hazard analysis were not in accordance with LACORS
guidance on the service of improvement notices. The notices did not
contain sufficient evidence of the officers’ opinion on why there was a
contravention and detail on the required action. Two notices did not
accurately detail the regulation contravened.
3.13.9 All notices gave an indication that works of equivalent effect could be
carried out and all included details about the right of appeal. All notices
gave details of the local Magistrates Court and the time period for
appeal. There was evidence of proper service in all cases. A timely
check had not been undertaken on 3 notices and in 3 cases an
extension of time had not been confirmed in writing with the proprietor.
3.13.10 The records of 10 emergency prohibitions were examined. All
emergency prohibition notices had been signed by the correctly
authorised officer and had been appropriately carried out in accordance
with the Authority’s Enforcement Policy. Whilst the auditors were
advised that monitoring visits would be carried out, records of
monitoring visits were not generally kept, including those that should be
made immediately prior to the hearing.
3.13.11 One voluntary closure was examined and this had been appropriately
carried out. It was confirmed in writing with the proprietor and the
premises had been visited to check on closure.
3.13.12 The formal caution had been authorised by an appropriate officer. There
was evidence that the Enforcement Policy had been considered and
that the action taken had been in line with the Policy.

29. - 29 -
3.13.13 Four files relating to voluntary surrender were examined. In 3 cases,
where receipts were available, they were appropriately worded and had
been signed by the person surrendering the food. The other case
followed a detention and a letter sent to the proprietor had been
countersigned to indicate acceptance of the voluntary surrender. There
was evidence that food had been correctly disposed of.
3.13.14 Files relating to 4 detentions and 1 seizure were examined. One
detention related to illegally smuggled milk powder and a detention
notice had been served under the Products of Animal Origin (Third
Country Imports)(England) Regulations 2002. One detention notice had
been served by an officer who had been authorised by the Authority but
not in accordance with Food Safety Act Code of Practice No.19:
Qualifications and Experience of Authorised Officers. All other notices
had been served by correctly authorised officers. Notices clearly
specified the foods to be detained and a withdrawal notice had been
served where appropriate. Satisfactory arrangements had been made to
ensure the security of the food.
3.13.15 The seizure had been carried out in full accordance with Food Safety
Act Code of Practice No.4: Inspection, Detention and Seizure of
Suspect Food.

30. - 30 -
Recommendations
3.13.16 The Authority should:
(i) Ensure that any additional, complimentary Enforcement
Policies are approved by Members and made publicly
available. [The Standard – 15.1]
(ii) Ensure that improvement notices are prepared and followed
up in accordance with the relevant Food Safety Act Codes of
Practice and centrally issued guidance.
[The Standard – 15.2]
(iii) Ensure that officers who serve detention and seizure notices
are appropriately authorized in accordance with Food Safety
Act Codes of Practice 4 and 19. [The Standard – 15.3]
(iv) Ensure that records of monitoring visits for emergency
prohibitions and detentions are maintained.
[The Standard – 16.1]

31. - 31 -
3.14 Records and Inspection Reports
General
3.14.1 The Authority’s records were generally well ordered, retrievable and had
been kept for the 6 years required by the Standard. The paper file
records were consistent with the information held on the electronic
database.
Food Hygiene
3.14.2 File records for general premises, Approved Premises and licensed
butchers’ shops were comprehensive and easily retrievable. The
standardised formats for recording details of food hygiene inspections of
general premises, licensing assessments of butchers’ shops and
Approved Premises were particularly clear and appropriately detailed.
3.14.3 Records for 10 premises where food hygiene inspections had been
carried out were examined. Full records were maintained on the size
and scale of the business, type of food activity, information on hygiene
training and an assessment of the businesses’ hazard analysis
systems.
3.14.4 Ten records relating to butchers’ shop licensing were examined and
contained details on the licensing assessment.
3.14.5 Records relating to 10 Approved Premises were examined. Relevant
approval information was maintained except for details on any
emergency withdrawal plan.
3.14.6 A report of inspection or a follow-up letter was issued following each
food hygiene inspection. Some details required by Food Safety Act
Code of Practice No.9: Food Hygiene Inspections had not been
included in the standard report form. The type of premises, officer
designation and specific legislation were not included although the latter
had been recorded in 2 cases.
3.14.7 Follow-up letters were clear and the work required was easily
understandable, indicated appropriate timescales and legal and
advisory matters were clearly distinguished. Two of the 5 follow-up
letters examined did not contain full legislative references.
3.14.8 Detailed records of food complaints and complaints about food
premises were maintained on premises files.

32. - 32 -
Food Standards
3.14.9 Database and file records of food standards inspections of
manufacturers were retrievable and detailed. Historical records of food
standards inspections of retailers and caterers were generally limited.
However, the inspection form had been revised and expanded to
include appropriate food standards matters, and comprehensive records
of recent inspections were now being maintained.
3.14.10 Reports following inspections of manufacturers were retained and
contained appropriate information in line with official guidance.
However, reports of food standards inspections of retailers and caterers
were not routinely available and where they existed they were usually
combined with a food hygiene inspection report and were incomplete.
Recommendations
3.14.11 The Authority should:
(i) Ensure that complete records are maintained for food
premises including Approved Premises.
[The Standard – 16.1]
(ii) Ensure that all relevant details are recorded on inspection
reports in accordance with Food Safety Act Codes of Practice
No.8 & No.9. [The Standard – 16.1]

33. - 33 -
3.15 Complaints about the Service
3.15.1 The Authority had a documented corporate procedure for dealing with
complaints against the Service.
3.15.2 A Council leaflet entitled ‘How to Complain about Brent Council’ had
been produced and provided the public with a summary of the process.
This was available from public reception points.
3.15.3 Two complaints had been made against the food law enforcement
Service over the 2 years preceding the audit. Both of these had
received investigations and responses in accordance with the corporate
procedure. Details had been properly forwarded to the appropriate
officer in the Council who collated such complaints.

34. - 34 -
3.16 Liaison with Other Organisations
3.16.1 Appropriate liaison arrangements were in place with neighbouring
enforcement authorities and other bodies aimed at facilitating consistent
enforcement. This was principally through the Authority’s regular
attendance at meetings of the following organisations:
• North West London Food Liaison Group;
• Three Valleys Water;
• Thames Water;
• Representation on Local Authorities Co-ordinators of Regulatory
Services (LACORS) Focus Groups on labelling and standards;
• North West London Health Protection Agency;
• Brent & Harrow Trading Standards Service;
• Brent Council’s Planning Service.

35. - 35 -
3.17 Internal Monitoring
3.17.1 The Authority had developed documented procedures on monitoring
service quality and a procedure for the collection of performance
monitoring data that dealt with quantitative issues.
3.17.2 Useful quantitative management reports were produced from the
database on a monthly, quarterly and annual basis in accordance with
the procedure. These provided monitoring information on areas such as
officer caseloads, complaints received and actioned and overdue
inspections. There was evidence that this data was being effectively
utilised. Quarterly reports were prepared and submitted to Members on
internal performance indicators including the percentage of food safety
inspections carried out of those due.
3.17.3 Monitoring of service quality was principally undertaken by the Service
Manager in conjunction with the Team Leaders. An annual audit
programme was drawn up and included accompanied inspections, post
inspection exercises, monitoring of notices and service requests.
3.17.4 Other qualitative monitoring included:
• Occasional consistency exercises;
• Regular team meetings;
• Individual review meetings as part of the appraisal scheme;
• Prior approval of notices, prosecutions and formal cautions;
• Customer satisfaction questionnaires which were carried out
centrally as part of the Chartermark initiative;
• Participation in a local business partnership;
• Review of customer complaints.
3.17.5 There was evidence on files that internal monitoring was taking place.

36. - 36 -
3.18 Third Party or Peer Review
3.18.1 The Authority had participated in an inter authority audit exercise in May
2000 and there was evidence that issues raised in the subsequent audit
report had been addressed. These had been tackled in a systematic
way through the development of an action plan.
3.18.2 A third party audit was carried out in 2001 of the ‘management
arrangements for ensuring probity in inspection, licensing and
enforcement services within the London Borough of Brent.’ The audit
included food inspections and it was clear that recommendations had
been implemented.
3.18.3 A focused audit of the food sampling activity had been carried out by
the Food Standards Agency during December 2002 and an agreed
action plan had been developed.
3.18.4 The Authority had also gained accreditation for Investors in People and
a Chartermark.

37. - 37 -
3.19 Food and Feeding Stuffs Safety and Standards Promotion
3.19.1 The Authority was involved in a number of activities aimed at promoting
food safety. These included:
• Participation in National Food Safety Week which included displays
at 2 venues in the Borough for the 2003 campaign;
• Work with local and national media including input into Council
magazines;
• Advisory information and links on the Environmental Health website;
• Provision of advisory leaflets in English and other local community
languages;
• Consultation with community groups and the local business
partnership on specific topics;
• Talks to schools and interested bodies on request.
3.19.2 No specific budget was available for promotional work but monies were
agreed for each project and came from any underspend from the
previous year. Records of promotional work were maintained.
Auditors: Sally Hayden
Andy Bowles
Bill Parkinson
Food Standards Agency
Local Authority Enforcement Division

38. - 38 -
Action Plan for the London Borough of Brent
Audit date: 24 – 27 June 2003
IMPROVEMENTS PLANNED BY (DATE) TO ADDRESS (RECOMMENDATION INCLUDING
STANDARD PARAGRAPH)
COMMENTS
1. To contact the FSA to seek
derogation on Code Of
Practice No.19 on qualification
for remaining member of staff.
30/09/03 3.3.7(i) Ensure that all officers are authorised in
accordance with their qualifications, training and
experience, in line with Food Safety Act Code of
Practice No.19: Qualifications and Experience of
Authorised Officers. [The Standard – 5.3]
Brent has taken the policy decision to
authorise this member of staff based on
qualification and experience, but takes on
board issue of COP19.
2. Keep all course details with
training evaluation forms.
Completed 3.3.7(ii) Ensure that training records include details
of the duration, objectives and content of all training
provided. [The Standard – 5.4]
3. Include calibration checks
on thermometers prior to and
following enforcement action
e.g. service of notices
regarding temperature control.
Completed 3.4.5 Further develop the documented calibration
and maintenance of monitoring equipment
procedure so that it includes checks before and
after enforcement action in accordance with Food
Safety Act Code of Practice No. 10: Enforcement of
the Temperature Control Requirements of the Food
Hygiene Regulations. [The Standard – 6.2]
4. Review inspections overdue
at the end of each month.
Contract out inspections
where feasible to do so.
Completed 3.5.26(i) Ensure that food hygiene and food
standards inspections are carried out at a
frequency which is not less than that required by
the relevant Food Safety Act Codes of Practice.
[The Standard – 7.1]
Our policy is to give priority to enforcement
over inspections, but we will ensure that the
inspection programme is managed to reduce
the number of overdue high-risk inspections.

39. - 39 -
5. To expand inspection
procedure to include voluntary
surrender, closure and
prohibition orders.
30/09/03 3.5.26(ii) Expand the inspection procedure to detail
the procedures for the range of follow up actions
that reflects current practice and relevant official
guidance. [The Standard – 7.4]
6. Implement the Investigation
and Prosecuting Offences
Procedure.
31/10/03 3.5.26(iii) Implement the investigating and
prosecuting offences procedure.
[The Standard – 7.4]
Currently circulating for comments
7. To include investigations of
outbreaks and notifications as
part of the audit process.
30/09/03 3.11.4 Ensure that investigations of outbreaks and
individual notifications of food related infectious
disease are carried out in accordance with its
documented procedures and that complete records
are maintained for at least 6 years.
[The Standard – 13.2 and 13.3]
8. To review all policies and
differentiate between
operational guidance and
policy issues. Where policy
issues to get member
approval and publicise.
31/12/03 3.13.16(i) Ensure that any additional,
complimentary Enforcement Policies are approved
by Members and made publicly available.
[The Standard – 15.1]
To review all policies by 31/10/03.
Schedule for Member approval by 31/12/03
any with policy issues.
9. LACORS guidance issued
to all managers for checking of
improvement notices served.
Training to be given where
required.
Completed 3.13.16(ii) Ensure that improvement notices are
prepared and followed up in accordance with the
relevant Food Safety Act Codes of Practice and
centrally issued guidance. [The Standard – 15.2]
Guidance already issued. All notices are
check for compliance with guidance.
A developed report was already in operation
which flags up expiration of notices so that
officers can make a timely check on
compliance.
Training to be arranged where required.
10. To contact the FSA to
seek derogation on Code Of
Practice No. 19 on
qualification for remaining
member of staff.
30/09/03 3.13.16(iii) Ensure that officers who serve detention
and seizure notices are appropriately authorized in
accordance with Food Safety Act Codes of Practice
4 and 19. [The Standard – 15.3]
Brent has taken the policy decision to
authorise this member of staff based on
qualification and experience, but takes on
board issue of Code Of Practice No.19.

40. - 40 -
11. Monitoring visits on
Emergency Prohibition
Notice’s to be recorded on
database.
Completed 3.13.16(iv) Ensure that records of monitoring visits
for emergency prohibitions and detentions are
maintained. [The Standard – 16.1]
Visits were being carried out in accordance
with Code Of Practice No.6: Prohibition
Procedures but not being recorded, this has
now been addressed.
12. Review procedures at
case reviews and audit
records to ensure compliance.
To develop synopsis for all
approved premises and to
ensure that LA’s role in
withdrawal plan is detailed.
Completed 3.14.11(i) Ensure that complete records are
maintained for food premises including Approved
Premises. [The Standard – 16.1]
Reviews of the approval system and food
standards inspections at caterers and
retailers had demonstrated the need to
develop these areas. These have now been
in place for some time.
13. Inclusion of time of
inspection, legislative details ,
officer designation and type of
premises to be included on
inspection report left on site.
31/12/03 3.14.11(ii) Ensure that all relevant details are
recorded on inspection reports in accordance with
Food Safety Act Codes of Practice No.8 & No.9.
[The Standard – 16.1]
When next print run for pre-printed forms all
detail will be included.

41. - 41 -

42. - 42 -
ANNEX
Glossary
Agricultural Analyst A person, holding the prescribed qualifications, who is
formally appointed by a local authority to analyse feeding
stuffs samples.
Approved premises Food manufacturing premises that has been approved by the
local authority, within the context of specific legislation, and
issued a unique identification code relevant in national and/or
international trade.
Authorised officer A suitably qualified officer who is authorised by the local
authority to act on its behalf in, for example, the enforcement
of legislation.
Best Value A Government policy which seeks to improve local
government performance in the delivery of services to local
communities – from education and care for the elderly
through to environmental health and road maintenance. Best
Value aims to ensure that the cost and quality of these
services are of a level acceptable to local people by:
• increasing the role of local people in deciding the priorities
for local government services
• improving the way authorities manage and review their
business
• building on the experience and expertise of staff.
Border Inspection Post Point of entry into the UK from non-EU countries for products
of animal origin.
Codes of Practice Government Codes of Practice issued under Section 40 of the
Food Safety Act 1990 as guidance to local authorities on the
enforcement of food legislation.
County Council A local authority whose geographical area corresponds to the
county and whose responsibilities include food standards and
feeding stuffs enforcement.
District Council A local authority of a smaller geographic area and situated
within a County Council whose responsibilities include food
hygiene enforcement.
Enforcement Concordat Government guidance setting out principles and procedures
of good enforcement which local authorities may adopt.
Developed in consultation with businesses, local and central
government, consumer groups and other interested parties. It
sets out what businesses and others being regulated can
expect from enforcement officers.
Environmental Health Officer
(EHO)
Officer employed by the local authority to enforce food safety
legislation.

43. - 43 -
Feeding stuffs Term used in legislation on feed mixes for farm animals and
pet food.
Food Examiner A person holding the prescribed qualifications who
undertakes microbiological analysis on behalf of the local
authority.
Food Hazard Warnings This is a system operated by the Food Standards Agency to
alert the public and local authorities to national or regional
problems concerning the safety of food.
Food hygiene The legal requirements covering the safety and
wholesomeness of food.
Food standards The legal requirements covering the quality, composition,
labelling, presentation and advertising of food, and materials
in contact with food.
Framework Agreement The Framework Agreement consists of:
• Food Law Enforcement Standard
• Service Planning Guidance
• Monitoring Scheme
• Audit Scheme
The Standard and the Service Planning Guidance set out
the Agency’s expectations on the planning and delivery of
food law enforcement.
The Monitoring Scheme requires local authorities to submit
quarterly returns to the Agency on their food enforcement
activities i.e. numbers of inspections, samples and
prosecutions.
Under the Audit Scheme the Food Standards Agency will be
conducting audits of the food law enforcement services of
local authorities against the criteria set out in the Standard.
Full Time Equivalents (FTE) A figure which represents that part of an individual officer’s
time available to a particular role or set of duties. It reflects
the fact that individuals may work part-time, or may have
other responsibilities within the organisation not related to
food enforcement.
HACCP Hazard Analysis Critical Control Point – a food safety
management system used within food businesses to identify
points in the production process where it is critical for food
safety that the control measure is carried out correctly,
thereby eliminating or reducing the hazard to a safe level.
Home Authority An authority where the relevant decision making base of an
enterprise is located and which has taken on the responsibility
of advising that business on food safety/food standards
issues. Acts as the central contact point for other enforcing
authorities’ enquiries with regard to that company’s food
related policies and procedures.

44. - 44 -
Improvement notice A notice served by an Authorised Officer of the local authority
under Section 10 of the Food Safety Act 1990, requiring the
proprietor of a food business to carry out suitable works to
ensure that the business complies with the requirements of
food hygiene or food processing legislation.
Inter Authority Auditing A system whereby local authorities might audit each others’
food law enforcement services against an agreed quality
standard.
Member forum A local authority forum at which Council Members discuss
and make decisions on food law enforcement services.
Metropolitan Authority A local authority normally associated with a large urban
conurbation in which the County and District Council functions
are combined.
Minded to notice A notice served by an Authorised Officer of the local authority
under the Deregulation (Improvement and Enforcement
Procedures) (Food Safety Act 1990) Order 1996. This notice
is served prior to an ‘improvement notice’ and gives food
business proprietors a specified period to make either a
written or oral representation to the enforcement authority
about the enforcement action. A repeal to the above Order
means that from 10 April 2001 ‘minded to notices’ no longer
need to be issued prior to the issue of an ‘improvement
notice’.
OCD returns Returns on local food law enforcement activities required to
be made to the European Union under the Official Control of
Foodstuffs Directive.
Originating Authority An authority in whose area a business produces or packages
goods or services and for which the Authority acts as a
central contact point for other enforcing authorities’ enquiries
in relation to the those products
Port Health Authority A local authority within whose boundaries there is a point of
entry into the UK for imported foods.
Public Analyst An officer, holding the prescribed qualifications, who is
formally appointed by the local authority to carry out chemical
analysis of food samples.
Risk rating A system that rates food premises according to risk and
determines how frequently those premises should be
inspected. For example, high risk premises should be
inspected at least every 6 months.
Service Plan A document produced by a local authority setting out their
plans on providing and delivering a food service to the local
community.

45. - 45 -
Trading Standards The Department within a local authority which carries out,
amongst other responsibilities, the enforcement of food
standards and feeding stuffs legislation.
Trading Standards Officer
(TSO)
Officer employed by the local authority who, amongst other
responsibilities, may enforce food standards and feeding
stuffs legislation.
Unitary Authority A local authority in which the County and District Council
functions are combined, examples being Metropolitan
District/Borough Councils, and London Boroughs. A Unitary
Authority’s responsibilities will include food hygiene, food
standards and feeding stuffs enforcement.