Appendix B Food Safety Service Standards

1. Annual Action Plan

This gives details of the Food Safety activities which we plan to undertake in this coming year, the measures of performance (MOP) which will be achieved and the monitoring regime for the MOP. The detailed components are as follows:

a) We will undertake 455 routine inspections of food premises rated A to D, and an estimated 150 unrated premises to comply with the Food Standards Agency (FSA) Code of Practice. [MOP: Completion of our inspection program]

b) We will use alternative enforcement approaches to maintain contact with 75 E rated premises businesses, to recover our inspection programme at a faster pace than specified in the FSA Recovery Plan

c) We will operate the Food Hygiene Rating System across the Arun district linked to our inspection program and other visits. [MOP: All premises receiving an inspection, audit or monitoring visit will be rated under the Food Hygiene Rating System in accordance with the requirements of the FHRS brand standard].

d) We will participate in Sussex Local Sampling Programme and the national UK Health Security Agency (UKHSA) led sampling programmes where resources permit and to monitor the safety of food produced and sold in the Arun area. [MOP: Sampling plan delivered].

e) We will ensure we liaise with national Primary Authorities where they have been appointed for premises in our area [MOP: Clear liaison undertaken where appropriate].

f) We will develop training and information/education campaigns based on our local knowledge and consider contribution to those promoted nationally, as appropriate. [MOP: To be developed as appropriate].

g) We will enforce only where necessary and only in line with our Enforcement Policy. [MOP: All statutory action in line with the Enforcement Policy and monitored through our quality monitoring procedures].

h) We will produce an annual review of our performance and further intentions to secure food safety in the Arun district. [MOP: Annual Food Safety Plan produced].

2. General Complaints

We will deal with complaints by

a) Logging the receipt of the complaint; [MOP: Urgent complaints within one working day: periodic checks by Environmental Health Team Manager (EHTM) to monitor compliance) Note "Urgent" complaints are classed as Food Poisoning outbreaks and ‘Food Alert For Action’ Warnings].

b) Acknowledging the complaint and in appropriate circumstances send a "A Guide to our Services" leaflet; [MOP: periodic checks by EHTM to monitor compliance]

c) Responding to the complainant and where appropriate advising them on the legal position and possible outcomes; [MOP: immediately where there is serious and/or imminent risk, otherwise within 7 working days [MOP: periodic checks by EHTM to monitor compliance] NOTE: a response should consist of: a telephone contact, letter, email or SMS that covers the action to be taken, the timing of the next step by us, or complying with the request i.e. sending the information required.

d) Gathering evidence of the complaint where required in line with statutory requirements; [MOP: periodic checks by EHTM to verify action is taken in appropriate.]

e) Take action in accordance with the Council's Enforcement Policy and where required produce appropriate files and documents for legal opinion ; [MOP: action taken in accordance with Enforcement Policy and checked by EHTM. EHTM reviews prior to enforcement review panel, case notes to panel at least 5 working days in advance. Cases followed up at least monthly with case officer, until case completed or withdrawn].

f) In forming the complainant of progress with the complaint minimum is monthly intervals; [MOP: Periodic checks by EHTM that action is being taken in due time.]

g) Writing or telephoning complainants confirming when in our opinion the complaint is resolved and/or moved on to formal enforcement procedures; [MOP: Periodic checks by EHTM that action is being taken in due time.]

h) Reviewing all complaints which are still unresolved at the end of 3 months from receipt. [MOP: Review by EHT M and discussion at monthly catch ups. with case officer and agree action to be taken]

3. Food complaints

In addition to the above: -

a) If the complaint relates to food produced outside of the district, we will normally refer the complaint details to the Home/Originating/Primary Authority, the manufacturer/vendor/packer/wholesaler or retailer as appropriate, within 7 working days of receiving the complaint; [MOP: Home Primary Authority de tails kept current on EH Computer System by EHTO; Periodic checks by EHTM to check that appropriate action is being taken in due time.]

b) In the case of food produced within the district we will normally investigate and visit within 7 working days if appropriate. [MOP: Periodic checks by EHTM to check that appropriate action is being taken in due time.]

c) In the case of food complaints with national significance the case officer supported by E HTM and supported by wider team as necessary, will contact other agencies such as the Food Standards Agency (FSA) Department for Environment, Food and Rural Affairs (DEFRA),  Department of Health, or the Consultant in Communicable Disease Control (CCDC) as soon as possible and within not less than 2 working days. [MOP: EHTM to directly oversee activity and ensure actions and timeframes are appropriate]

We will not: 

a) Automatically submit the complaint to the Analyst or Manufacturer. Where food complaints are to be sent for analysis (either by a Public Analyst or the Manufacturer) they will be sent in a manner appropriate to ensure continuity of evidence.
b) Enter into negotiations regarding any compensation claims made by the complainant.
c) Investigate anonymous complaints unless there is a clear and imminent threat to public health, or where an officer is already aware of the issue raised
d) Investigate complaints about food produced outside the district. These will be referred to the relevant local authority in whose area the food originates.

4. Food Alerts and Trade Withdrawals

We will ensure that we have a system which responds appropriately to Food Alerts issued by the Food Standards Agency or the Consultant in Public Health Medicine (CPHM). This will include:

a) Adequate arrangements for the receipt of warnings usually via e mail including procedures for cover in the event of leave, illness etc. [MOP: periodic checks by EHTM]

b) Food Alert for Action (Response to be made as soon as possible following receipt. Response to include (as per FSA instruction):

  • Email, letter or telephone call to premises which are open;
  • Officers to be notified and visits to be made if appropriate on day of receipt with outstanding premises by following day;
  • Other relevant premises to be notified by other means e.g. phone;
  • Information dissemination via media and or our website.

c) Food Alert for Information (FAFI) as per FSA instruction

d) Where necessary, liaison will take place with Trading Standards via the Sussex Food Liaison Group reps. They will confirm what action is to be taken (if any), where the Food Alert relates to a Trading Standards matter.

e) Phone calls or visits, if required, will commence on the working day the notification is made. [MOP: We will aim to reach all targeted premises within 2 working days for urgent cases and within 7 working days for less urgent cases].

f) We will facilitate Trade Withdrawals of suspect food in a similar manner to official Food Alerts as above.

g) We will not always action Food Alerts where the risk to public health and/or the type of product involved has limited significance within Arun District

5. Outbreaks of food poisoning

a) A Food Poisoning Outbreak (defined by the CCDC) will be investigated ideally immediately but within a maximum of 72 hours (includes weekends/holidays), according to the UKHSA KSS outbreak incident control plan.[MOP: EH system to monitor response time to initial complaint]

b) Investigations will be conducted in liaison with, and under the guidance of, the CCDC and in accordance with our procedures and the UKHSA PHE KSS outbreak incident control plan. At close of outbreak, a full debriefing report be prepared

c) We will: 

a) Contact UKHSA immediately on receipt of information pointing to a possible food poisoning issue and take instruction. A specific decision will be made on establishment (or not) of outbreak control team and clarity of roles and responsibilities. Decision recorded and conveyed to EHTM.
b) Be part of any outbreak control team and/or review team.
c) Attempt within 2 working days to discuss the situation with suspected cases and contacts and give them advice regarding the need to visit their own General Practitioner.
d) Liaise with other local authorities within 2 working days of the notification.
e) Visit and carry out an investigation where premises are identified in this area, ideally on the day of notification and not less than the next working day.
f) Take samples of food and other evidence as required and arrange for their delivery to the appropriate laboratory for examination.
g) Advise proprietors of the legal position and in particular give specific instructions as to the hygiene requirements for food handlers and the arrangements which are needed for exclusion from work.
h) Send out questionnaires, when instructed by the CCDC, as part of the investigation.
i) Liaise with Public Health laboratory, as necessary.
j) Contact those who have been involved in the case, at the conclusion of our investigation, and inform them of the outcome.
k) Act in accordance with the Council's Enforcement Policy and where required produce the appropriate files and documents for legal opinion [MOP: At close of outbreak, a debriefing report be prepared]

d) We will not

a) Become involved in claims for compensation.
b) Investigate outbreaks originating from the home unless advised to do so by the CCDC.

6. Sampling

We will, subject to available resources: -

a) Carry out all statutory sampling as defined in Food Legislation & Code of Practice.

b) Participate in UKHSA sampling programme as agreed by Sussex Food Liaison Group.

c) Review sampling requirements for Approved premises. [MOP: Contribution to Sussex and UKHSA Sampling programmes delivered]

7. Risk Interventions

a) We will draw up an annual programme at the beginning of the financial year based on the current risk scores for food premises. This programme will form the annual list of food premises risk interventions as based on the FL CoP weighting criteria. [MOP: data extracted by the end of first week of April and list compiled]

b) Food officers will:
a. Check the premises file record on the EH database.
b. Assess previous risk score and individual rating criteria.
c. Assess any relevant complaints, information on layout and management systems etc.
d. Discuss any contentious issues with the previous case officer or EHTM
e. Ensure all equipment, notices, inspection pro forma and report forms are available for the intervention.
f. Visit the premises, identify, and interview the proprietor, where available.
g. Carry out the risk intervention in accordance with the "Programmed Food Hygiene Risk Interventions" procedure note.
h. Give an immediate record of intervention, Food Hygiene Rating unless in need of second opinion, and agree an action plan at the conclusion of the audit. A copy will be provided to the business.
i. Confirm any legal requirements, the rating outcome and recommendations in writing within 7 working days.
j. Where contentious matters are identified, consider whether further visits/action is necessary by discussion and peer /team review, record the agreement and inform the business as required.
[MOP: Checks carried out monthly and quarterly by EHTM to ensure the above service standards are being achieved and where they are not to take corrective action to secure compliance]

8. Planning Applications

We will: 

a) Provide comments, where required, within the deadline provided by the Planning Department.

b) Undertake a review of relevant planning applications to ensure applicants are informed to their statutory duties as far as is possible.

We will not normally:

a) Contact the applicant or their agent directly to discuss the application. If such contact does occur and written confirmation of discussions/decisions is required this should be logged on the EH database system and dealt with as above, with a copy to the Planning Officer

9. Information and advice to businesses

a) Initial enquiries concerning the standards for new or existing premises will be logged as service requests and dealt with as above.

b) Matters that can be dealt with within 30 minutes will be prioritised for response according to risk and will not attract a fee.

c) Matters that require more than 30 minutes, require a visit to a business or relate to a request for an advisory inspection will attract the published fee for advisory inspection /advice.

d) Advisory visits are a discretionary function and a paid for service and will only be carried out as follows:

i) Where a request has been registered and the published fee paid in advance. Note requests and payment can be made via the online portal.
ii) Will only be made where the existing owner/proprietor has given their consent for the visit, or has directly made the request
iii) FHRS will not be awarded following advisory visits
iv) Officers do not have discretion to classify a routine inspection as an advisory visit
v) Any requirements will be confirmed in writing within 14 working days of the site visit.

9. Premises Licence applications

We will: 

a) Provide comments if required, within statutory deadlines

b) Undertake reviews of relevant premises licence applications to ensure applicants are informed of their statutory duties as far as possible.