1. food and drink

CITY OF LONDON CORPORATION – DEPARTMENT OF MARKETS & CONSUMER PROTECTION
PORT HEALTH & PUBLIC PROTECTION SERVICE - FOOD SAFETY ENFORCEMENT PLAN 2012-13
Introduction
The food, catering and hospitality sectors make a significant contribution to City corporate life and to the wellbeing of
residents, workers and visitors.
At the City of London Corporation, the Food Safety Team is part of the Port Health & Public Protection Service (PH&PP) itself
part of the Department of Markets & Consumer Protection.
The proper regulation of food hygiene within food businesses remains an important national and local priority. The team
contributes directly to “…..the supports our communities” theme in our Community Strategy1, The City Together. Our main
goal to help ensure that food is hygienically prepared and safe to eat. Ensuring a safe, healthy and sustainable food chain is
also one of five national priorities for regulatory outcomes endorsed in November 2011 by an LBRO report2 on Priority
Regulatory Outcomes.
In performing our work, there is a need to strike a balance between support for businesses (especially smaller businesses) and
protecting consumers and others from fraudulent and illegal practices. The Business Plan 2009-12 target for the team was a
year-on-year increase in the number of ‘broadly compliant’3 food premises from 88.3% in 2007 to 95% by 2012. This was linked
to the London-wide ‘stretch’ objective of making all food businesses broadly compliant in ‘Olympic’ local authorities preGames and will be carried over into our new departmental Business Plan for 2012-2015.
Our initial focus for this year centres on Olympic preparations. The high profile of the Olympics magnifies potential negative
publicity received around standards of hygiene, safety and healthy food supplied leading up to and during the Games. We
will have additional plans in place to respond to situations that develop during the Games period but the strategy before this
remains a proactive approach to securing improvement. This is in line with strategic policy and plans developed for 2012 by
1 “The City Together Strategy: The Heart of a World Class City 2008 – 2014
www.cityoflondon.gov.uk/Corporation/LGNL_Services/Community_and_living/Community_advice/Community_strategy/community.htm
2 LBRO, 2011- A new approach to refreshing the national enforcement priorities for Local Authority Regulatory Services
3 Defined as scoring 10 or less in each of the Food Hygiene, Premises Structure and Confidence in Management categories of the Food Standards
Agency’s Inspection Rating Procedure
the Chartered Institute of Environmental Health (CIEH)4. and we will therefore continue with our work on food businesses that
are not yet properly compliant and there will be a final concentrated effort in the lead up to the Games to improve
compliance in these poorer performing food businesses. Some of this work will be funded by additional grant from the Food
Standard Agency (FSA) and the hope is that this will sustain compliance and thus create a more lasting legacy.
There are now 1758 “food businesses” registered with the City of London and with the London Port Health Authority as being
involved in the preparation, production, storage or sale of food. The majority of these are shops, bars, restaurants or other
types of catering establishments such as staff restaurants and corporate caterers. There are other temporary businesses
registered elsewhere that set up during various events and more of these may be planned in the run up to the Games.
This Food Service Enforcement Plan5 aims to ensure that our services remain targeted, proportionate, consistent and
transparent, and sets out the framework for the services delivery. It has been prepared as required by the FSA and in
accordance with their "Food Law Enforcement Service Planning Guidance". The format and content of the Plan provide the
basis upon which the City Corporation’s Food Safety Enforcement Service will be monitored and audited by the FSA.
4 CIEH, October 2010: Food Safety and Food Standards Management Strategy Olympics/Paralympics 2012
5 The scope of this plan does not include activities of the City of London on behalf of the Food Standards Agency at Smithfield Market or work of the
London Port Health Authority.
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1. Service Aims and Objectives
1.1 Aims
The Service Aim of PH&PP is “to create, develop and maintain a safe, fair and healthy
environment for the workers, residents and visitors of the City of London.”
1.2 Links to corporate
objectives and plans
As a part of PH&PP, the Food Safety Team aims to ensure that all food and drink that is
produced, stored, or sold by food businesses within the City of London is hygienically
prepared and safe to eat.
Links to our Departmental and Corporate Business plans and objectives and how we plan
for this service to play its part are given in the introduction above.
1.3 Objectives and plans
Our main objectives for the Food Safety Team are to:
Carry out regular inspections of City food businesses at a frequency determined by
national risk criteria and local intelligence;
Assist businesses in achieving legal compliance and good standards of food safety
management through the provision of targeted advice, support and training;
Investigate food poisoning outbreaks associated with City food businesses;
Investigate serious complaints about food purchased in the City and complaints about
City food premises;
Undertake an annual food sampling programme in liaison with other local authorities
and colleagues in the Health Protection Agency;
Take appropriate action in response to ‘food alerts’ issued by the FSA;
Take appropriate enforcement action for failures to meet legal standards.
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2. Background
2.1 Profile of the Local
Authority
The City of London Corporation is an unusually diverse organisation that supports and
promotes the City as the world’s pre-eminent financial centre and provides local
government and police services for the “Square Mile”.
We provide valued services to London and the nation as a whole including
management of Guildhall Art Gallery, the Barbican Centre, the Central Criminal Court
at the Old Bailey, 4,240 hectares of open space, three wholesale food markets and we
act as London’s Port Health Authority.
Our political and governance structures are not based on party politics and we use our
own private funds to finance the promotional work we do on behalf of the UK-based
financial and business services industry.
The City’s working population is in excess of 340,000 with people working in many
different business sectors but largely concentrated in finance, banking and the law.
There are reminders of the City’s past in the markets such as Smithfield and Leadenhall
but other industries have grown to service the needs of the businesses and people who
work in the City including the provision of food.
Increasingly other retail developments including food outlets are expanding in the City
and 2010 saw the opening of the large New Change shopping complex with an
increasingly diverse retail corridor being developed around it in Cheapside.
Hotel developments continue to expand and there is a thriving night-time economy
including world class venues such as the Barbican Centre and numerous bars and
restaurants.
The City has a small residential population currently around 8,000, evenly split between
male and female and which is predicted to rise to 12,300 by 2020.
The City is a popular destination for visitors, especially around St Paul’s Cathedral and
there are estimated to be over 10,000 visitors each day to the City.
London’s Competitive Place in the UK and Global Economies, produced by Oxford
Economics, highlights that the capital generates 21% of the UK's total GVA and made a
net contribution of £1.4 billion* in 2009-10 – the only positive figure among all other
regions of the country.
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2.2 Organisational Structure
2.3 Scope of the Feed and
Food Service
The Food Safety Team is located on the ‘commercial’ side of PH&PP and the team is
managed by a Food Safety Team Manager whose work is dedicated to food
enforcement and who reports to an Assistant Director (Public Protection).
The Food Safety Team is responsible for enforcing legal requirements relating to food
safety (standards and hygiene), occupational health & safety, statutory nuisances
(other than noise) arising from commercial food activities and the investigation of
infectious diseases that are related to food.
More details on the extent of this work are reported in the section below which looks
back on the work completed in 2011-12.
There are separate food enforcement activities in the Port Health side of the Service
and at Smithfield Market and these areas have their own separate plans.
The Feedstuffs enforcement function in the City is carried out by the Trading Standards
Team.
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2.4 Demands on the Feed and Food Service
Establishments profile: Registered food premises
Rating and Frequency of Food
Hygiene Inspections (under Food
Law Code)
Total
number
premises
2009-10
10
Total
number
premises
2010-11
6
Total number
premises
2011-12 (inc
Port)
27
Food Hygiene
inspections due
2012-13(inc
Port)
10
90
59
181
C rated =
Inspected 18 months
907
940
D rated =
Inspected 2 yearly
E rated =
Inspected ever 3 years
Unrated
243
A rated =
Inspected 6 monthly
B rated =
Inspected annually
Total
Approved food premises
Star
ratings
Number
premises
FHRS
Rating
Number
premises
0*
12 (11)
0
9
93
1*
53(78)
1
93
1083
702
2*
110(90)
2
58
214
200
119
3*
355(357)
3
196
208
254
279
101
4*
517(548)
4
345
50
36
88
2
5*
364(411)
5
798
Low Risk
273(267)
1508
1
1509
1858
1
(1)7
6
1027
Most premises rated as Low Risk under the old scores on the doors will be added to the FHRS so the numbers tally
7 This excludes, Smithfield Market where enforcement is overseen by the FSA.
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1684
(1762)*
*(201011)
14996
2.4 Demands on the Feed and Food
Service contd.
2.5 Regulation Policy
The service’s offices are located at Walbrook Wharf, 78-83 Upper Thames Street, London,
EC4R 3TD.
The office reception is open from 8am to 6pm each day but we only occasionally receive
callers (unless by pre-arranged appointment).
Access to the service is largely by telephone, e-mail, via the City Corporation’s web site and
the City Corporation’s Contact Centre or through our own proactive interventions on site.
Field enforcement officers normally work between the hours of 8am to 6pm.
In the event of an ‘out of hours’ emergency there is a duty officer system and senior
managers are all contactable via telephone.
Food safety information is displayed on the City Corporation’s website:
www.cityoflondon.gov.uk.
The City Corporation is committed to the principles of the Regulators’ Compliance Code, a
statutory code for all regulators8.
The PH&PP as part of the Department of Markets & Consumer Protection has a Policy
Statement on Enforcement approved by the Port Health & Environmental Services
Committee in June 20109 and this sets out our approach to enforcement.
8 www.bis.gov.uk
9 See http://217.154.230.218/NR/rdonlyres/208BFDEA-7C26-465C-A3CB-6C4413B18D3A/0/HS_EH_enforcepolicy.pdf
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3. Service Delivery
3.1 Interventions at Food and
Feeding stuff establishments
Single-tier local authorities like the City of London can opt to base our planned
programme of food intervention work around the Food Hygiene risks rating scheme
made under the FSA’S Food Law Code of Practice.
For the vast majority of food businesses in the City, there is considerable overlap
between aspects of Food Hygiene and Food Standards making simultaneous inspections
in most case the best option, assisting both businesses, through minimising disruption and
limiting multiple visits, and allowing our Service more resources to deal with the poorer
performing businesses.
For a number of years we have also considered appropriate Health & Safety
interventions during some food inspections and we believe this work remains in line with
the recommendations in Lord Young’s report10. The work was also in line with the joint
statement from Health & Safety Executive (HSE), FSA and LG Regualtion11 in February
2011. The regulatory landscape has since altered further and this was subject of a
Committee Report in January 2012. The plan for 2012-13 is to consider targeted, risk–
based approach to interventions: Newly registered premises are entered onto our PH&PP database and our FSA-based
target is to inspect and risk rate them within 28 days of opening.
New food businesses once opened, will receive a comprehensive Food Hygiene and
Food Standards intervention to assess their compliance with the relevant legislation
and they will be consequently risk-rated so as to trigger future inspections at
appropriate intervals for each. An appropriate H&S intervention will be considered at
the same time and a rating assigned to them as an assessment of our confidence in
10 www.number10.gov.uk/wp-content/uploads/402906_CommonSense_acc.pdf
11 FSA, HSE, LG Regulation Joint statement – “Combining Health and Safety and Food Safety inspections”- February 2011
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their continued compliance.
Food businesses in the lower two tiers12 (Zero and One Star) will receive a full
inspection before the Olympics and will be considered for appropriately targeted,
more intensive follow up, if they have not improved. The programme is scheduled to
be accelerated further in the immediate build up to the Olympics subject to further
funding (FSA grant).
Food businesses due a Food Hygiene inspection and which are rated as ‘broadly
compliant’ will receive an inspection in line with FSA guidance
Food businesses visited or inspected for Food Hygiene interventions will also be
simultaneously inspected for Food Standards if such an inspection is due any time this
year or if it is overdue.
The City Corporation plans to migrate from the London Scores on the Doors Scheme
to the new national Food Hygiene Rating Scheme (FHRS). The FHRS will help to ensure
that the public continue to be able to determine how well a business performs in
relation to food safety. With the eventual adoption of one scheme in England and
Wales it will also make rating easier to compare.
Other interventions will continue. These are classed as those that are not an audit or
inspection. They include sampling visits, visits to check compliance after complaints
and revisits to check progress on implementing remedial action following an
inspection. These are seen as a very important part of the service, especially in poor
performing businesses, as they help to ensure a regulatory presence is maintained. We
believe that this helps to ensure that standards are improved where required, or at
least maintained. This programme is further enhanced in the build up to the Olympics
and the following migration to the FHRS.
All team members are encouraged to identify new premises and report details to our
Data Management Team to ensure our database is kept up to date. This program is
also being enhanced following our planned migration to the FSA Food Hygiene Rating
Scheme
12 London Scores on the Doors www.scoresonthedoors.org.uk
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Intelligence on new premises is also acquired from other City departments and
colleagues in other teams (e.g. Licensing, Trading Standards, Planning, Building
Control), as well as formally through new food business registrations.
Full details of our work planned for 2012-2013 are set out below.
3.2 Feed and Food Complaints
3.3 Home Authority Principle and
Primary Authority Scheme
3.4 Advice to Business
The Food Safety Team will continue to respond to all complaints but decisions on the
depth of investigations will be made according to whether:- food is suspected as causing food poisoning or does not satisfy food safety
requirements;
- the City of London Corporation has enforcement responsibility; and
- It is suspected that there could be a significant breach of the law.
Views and information received from the FSA and Home / Primary Authorities will also
be taken into account when determining the extent and direction of any
investigation.
The team manager and officers make an assessment of the complaint to determine
the most appropriate follow up action and previous intelligence and compliance
history are both considered.
The assessment of complaints investigated will also be tempered by an enhanced
response during the Olympics.
Feed complaints are investigated by Trading Standards. None were received in 201112. Several supermarket chains have now registered as feed premises as certain waste
foods are now being recycled into the feed chain.
PH&PP have actively sought appropriate Primary Authority partners for Food Safety,
Health & Safety and Trading Standards. Two have been engaged for Health & Safety
and one for Trading Standards and it is anticipated that a Food Safety- related
Primary Authority Partnership will be signed with a national restaurant chain in early
2012.
Food safety advice to businesses is an integral part of our service and forms a
significant part of our discussions with food business operators at various times
including at the design stage for new premises or refurbishments and during
inspections and following other service requests.
Not all food businesses consult directly prior to carrying out works. New developments
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3.5 Feed and Food Sampling
3.6 Control and Investigation of
Outbreaks and Food Related
Infectious Disease
3.7 Feed/Food Safety Incidents
and their associated permissioning processes in the City can be complex and we
endeavour to engage with them through Planning, Building Control and Licensing in
order to advise and influence on food hygiene and health & safety in new
developments and refurbishments believing this to be the best time to secure
sustainable improvements through adequate investment.
The service strives to be an active contributor to national and regional sampling
programs and the sampling program is developed with our neighbours in the SE
London Food Group and through the pan-London Food Co-ordinating Group.
The group also takes advice and guidance from the Health Protection Agency and
the Public Analysts and a sampling plan is devised that considers the co-ordinated
programs as well as locally important issues.
Samples are submitted to the Food Examiner or Analyst as necessary for the selected
projects or in response to specific complaints and we have a contingency fund for this
work with the Public Analyst.
The City Corporation is in the North East and North Central Health Protection Unit
(HPU)’s area and operates with the HPU to investigate outbreaks and selected
notifications.
In April 2010, Health Protection legislation in England was updated. The revised
measures are contained within the amended Public Health (Control of Disease) Act
1984 and accompanying Regulations and local authorities have new powers and
duties to prevent and control risks to human health from infection or contamination,
including by chemicals and radiation.
The new legislation adopts an all hazards approach, and, in addition to the specified
list of infectious diseases, there is a requirement to notify cases of other infections or
contamination which could present a significant risk to human health.
The service has arrangements in place to ensure that it is able to respond to Food
Alerts issued by the FSA.
Warnings are received electronically and all urgent Food Hazard Warnings receive
immediate attention and action where necessary with staff able to be co-opted from
other teams if necessary.
Outside office hours, an emergency duty rota is available through the Out of Hours
Service and if necessary members of the service’s management team.
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3.8 Liaison with Other
Organisations
3.9 Feed and Food Safety and
Standards promotional work, and
other non-official controls
interventions
The City Corporation is a member of the SE London Sector Food Group and is in the
North East and North Central London Health Protection Unit’s area, and our
representatives regularly attend meetings with the Directors of Public Health as well as
hosting the London Food Coordinating Group meetings.
We are also members of the SE London Quadrant for health & safety and the AllLondon Boroughs’ Health & Safety Liaison Group.
For a number of years we have maintained links with the LBRO (now the Better
Regulation Delivery Office) being involved in their Retail Enforcement Pilot Project and
our Assistant Director is a member of their World Class Local Authority Reference Panel
and we regularly contribute to improvement and development work for local
authority regulatory services.
The Food Safety Team members have been involved in work with our Licensing
colleagues and the City of London Police on the Safer City Partnership’s Safety Thirst
initiative and in specific work dealing with Illegal Street Trading.
The intention in 2012-13 is to focus our work around food premises that are not
‘broadly compliant’.
However, the promotion of Food Hygiene and good practice in the prevention of
food allergenic reactions remains important
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4. Resources
4.1 Financial Allocation
In 2009-10 expenditure was £525,939.85 and in 2010-11 the overall level of
expenditure involved in providing the Food Service was £461,600. In 2011-12 the
expenditure planned for the year is £508,016
Legal provision for enforcement action is part-funded locally from the Team’s
budget and part centrally through the Comptroller & City Solicitor’s department,
with counsel engaged for all prosecutions
4.2 Staffing Allocation
There is a Food Safety Manager managing the team.
There are seven other Environmental Health Officers (EHOs) within the team.
Two of these EHOs were on maternity leave during 2011-12. One returned to work
in January 2012; the other has resigned her post in February 2012. Posts were fully
covered by agency staff on temporary contracts.
The team reports to an Assistant Director (Public Protection).
Posts
FTE
1x Food Safety Team Manager
7 x EHO posts
1 x AD Commercial
1.0
6.6
0.25
We have a Data Management Team that manages the Northgate M3 backoffice system for PH&PP, adding new premises, registrations and reporting/data
extraction. Time spent on Food and Feed Control is not recorded separately from
their other, departmental-wide work.
4.3 Staff Development Plan
Staff development is managed through the City Corporation’s Performance &
Development Framework appraisal scheme
Specific assessments are used such as the HSE’s Regulator’s Development Needs
Analysis (RDNA) tool and CPD requirements for Food Officers and generally for
EHO members of CIEH and IOSH etc., are taken into account. This year we will
introduce the LBRO’s more general RDNA tool which now covers food work.
The main targets for training are on the delivery of our Service Plan and the
Page 13 of 27
development of staff competencies that can best achieve this.
Value for money is considered and the best results have been achieved by
engaging external trainers to deliver specific courses.
Training records are kept for all staff.
5. Quality Assessment
5.1 Quality assessment and internal
monitoring
Monitoring is by way of: The City Corporation’s Performance & Development Framework appraisal
scheme links individual officer’s work to this plan and the overall aims of the
organisation. These require preparation, a meeting, a six monthly follow-up and an
end of year review. [12 days work]
The workload monitoring process ties in with appraisal objectives and regular oneto-one meetings are held with officers to monitor how objectives are proceeding.
These also consider enforcement action and interaction with individual food
businesses. As a signatory to the national Food Hygiene Rating Scheme, we have
further monitoring and consistency obligations but aside from an initial training
period these are not thought to be any more onerous than those for the previous
London Scores on Doors Scheme [24 days]
There are separate procedures for monitoring enforcement decisions,
investigations and formal notices this time is incorporated in the above tables
Regular (6 weekly) team meetings [16 days]
The Food Service contributes to the local Food Sector and H&S Quadrant work
that reviews the arrangements that are in place to meet our service obligations. [6
days Food, 2.5 days H&S]
The Food Service has received accreditation under ISO 9001 but this is to be
reviewed during the year.
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6. Review
6.1 Review against the Service Plan
for 2011-12
See the Service Work Plan below
6.2 Identification of any Variation
from the Service Plan
See the Service Work Plan below
6.3 Areas of Improvement
See Service Development below
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Service Work Plan
1. Food Hygiene inspections
Risk based targeted interventions, including use of alternative controls and enforcement for compliance with Food
Hygiene legislation. Target 90% of food premises due and any overdue for intervention: New Premises to receive a full inspection within 28 days of registration(or opening)
Category A, B and C (not broadly compliant) premises to receive a full inspection.
Food Hygiene Inspections
Rating and Frequency
Due
2012-13
Done
2011-12
Done
2010-11
Done
2009-10
Predicted commitment (per
inspection, not including follow up)
A rated = Inspected 6
monthly
10
23
20
12
7 days
B rated = Inspected
annually
93
81
77
70
46.5 days
C rated = Inspected 18
months
702
640
704
608
250 days
D rated = Inspected 2
yearly
E rated = Inspected ever 3
years
Unrated
Totals
119
67
114
65
22.5 days
101
96
96
112
15 days
2
1027
2
909
1011
867
341days
(1)13
13 The premises, Smithfield Market, is approved as a cutting plant and is enforced directly by the FSA but with the City Corporation still expected to
carry out interventions in relation to other food and related operations in the market.
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2. Food Standards interventions
Continue action plan as agreed with our Port Health & Environmental Services Committee for 2010-11 with all high risk
premises rated and all others including any overdue inspections being picked up when the relevant Food Hygiene
intervention is due thus eventually removing any backlog by 31 March 2012
Food Standards
Due
Done
Done
Done
Predicted commitment
14
Inspections
2012-13
2011-12
2010-11
2009-10
Rating and Frequency
A= Annually
0
0
0
1
B = Two yearly
58
18
80
57
C = Five yearly
27
292
443
376
Unrated
17
0
0
77
111
523
545
Outstanding
Total
298
14 Based upon the number of inspections completed up to the end of January 2011
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10 days
3. Health and safety in food premises
Risk based intervention/Inspections; focus on the highest risks and identified local and national issues of concern15.
Health and Safety
inspections
Accidents
LOLER/PUWER reports
Due
2012-13
Done
2011-12
Done
2010-11
Done
2009-10
Predicted commitment
NB see note16
89
355
291
Uncertain following
changes to work patterns17
Uncertain18
95
104
155
50 hours work19
<5
3
2
5
4. To receive and investigate appropriately all requests for service, food incidents and complaints about food and
food premises.
Identify and follow the most appropriate enforcement response in accordance with this plan our procedures and
our enforcement policy
Complaints & Service
N/K
375
364
355
44 days
Requests
(10/12)
15 This work will develop in 2012-13 as more guidance is published following the Löfstedt Review of health & safety
16 Following a report to the City Corporation’s Port Health & Environmental Services Committee in January 2012, health & safety interventions will
continue in new food premises and we will also continue to complete health & safety interventions where problems are discovered during other work.
Full health & safety inspections have however all but ceased following revised HSE guidance See www.hse.gov.uk/lau/lacs/67-2.htm
17 Previously based upon 1 Hour per inspection when combined with Food Hygiene; new premises likely to be similar, more serious reactive
interventions will take longer
18 There are changes to both RIDDOR notifications and to HSE investigative criteria meaning that fewer incidents are likely to be reported and less
investigated. See www.hse.gov.uk/lau/lacs/22-13.htm for details on incident selection criteria
19 If no major investigative work is required following a serious accident etc.
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5. Follow up enforcement action in food premises.
Identify and follow the most appropriate enforcement response in accordance with this plan our procedures and our
enforcement policy
Estimated
Done
Done
Done
Predicted commitment
2012-13
2011-12
2010-11
2009-10
Letters with legal
requirements
664
930
835
Inc. in Inspection Time
quoted above.
Numbers of HIN’s
19
27
35
3-5 days
HSW Notices
Not Known
2
1
1
Negligible
Voluntary Closures
Not Known
2
3
1
2 days per case
Emergency Prohibitions
Not Known
2
1
0
3 days per case
Legal Proceedings
Not Known
1
3
1
21 days per case
Page 19 of 27
Service Work Plan: Activity
6. Devise and deliver a sampling program. An
annual commitment for the Food Safety
Team selected from national and local
sampling initiatives developed through
recommendations from the London Food
Coordinating Group and work in the SE
London Food Group.
The level of work to fit within our allotted
(free) allocation of samples from HPA and
our sampling budget for those consigned
to the Public Analyst (see above).
7.
2011-12
Review
Completed as planned
Sampling Plan devised and
delivered
Sample allocation from HPA
completed
Spend with Public Analyst......
Studies 42 & 45 most beneficial
(check)
2012-13
Work Planned/Activity
Q1 & 2 will focus on Olympic
delivery program (separate
sample focus)
Planned to concentrate on
Study 42 &45 issues (check)
Olympic monies available to
boost/assist sampling work20
and all based on, National, London
Food Co-ordinating Group and
local SE London Sector Food Group
devised projects with actual
projects selected where they are
of most relevance to the City.
Q1 & 2 will focus on a specific
Increase our presence with Food Businesses The level of activity in premises
not broadly compliant
Olympic delivery program
that are not currently broadly compliant
increased.
with continued focus on non
Reinforcing our intervention strategy with
A number of formal
compliant businesses. This will
additional follow ups; revisits and coaching
investigations will roll over into
be funded by separate grant
as deemed necessary to improve
2012-13 where proceedings are
application from the FSA.
performance.
planned or reported for
We will use the “Safe Food, Better Business”
approval.
100 premises [~5-10 Hours]
model where this is appropriate.
Formal enforcement action is not precluded
140 days
and this will be informed by our Policy
Statement on Enforcement.
20 Currently there is a general London Boroughs’ [ALEHM] bid in with the FSA which includes funding for sampling work
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Service Work Plan: Activity
8. Special Events and Street Trading; Olympic
preparation and reputational risk
Agree a policy on outside events.
Catering at outdoor events is a high risk
activity whether at an established venue or
market or at a temporary or mobile
function. Potentially large numbers of
people, frequent use of temporary staff, the
temporary nature of the accommodation
and high-risk products for sale place specific
pressure on food safety management.
Sampling surveys have indicated that
outdoor events are vulnerable to food
safety problems.
Devise a system for gathering intelligence
on these events in advance.
Gather information and comment to the
relevant duty holders
Visits sites as necessary with follow-up action
taken as necessary
Contribute to the auditing of caterers on
the Remembrancer’s approved list.
21
2011-12
Review
2012-13
Work Planned/Activity
No formal policy agreed.
ASAG21 formed in 2011, PH&PP
are represented. There is much
improved coordination and
communication for larger
special events that feed into the
ASAG process
Other smaller events and issues
around trading outside are not
so readily quantifiable; many
events are not planned or not
notified to the City Corporation.
Legislation for the City of London
on street trading is currently
passing through Parliament
Injunctive action proved
successful against one particular
company but is costly and
unwieldy.
The landscape of street trading
has evolved with many more
public spaces now used to host
temporary food events and with
mobile stalls at New Change
and New Street Square’s regular
markets.
We have established contacts
with the organisers of these
Formal policy with workable
protocol for rogue traders is
still required.
With no specific new
legislation there will be a
potential problem with
enforcement at the Olympics;
this needs to be recognised
so we can deal effectively
(quickly) with rogue food
traders.
At present we are only able
to prosecute for street
trading; there is no power to
remove or seize equipment.
“Pop up” style vendors now
receive public acclaim in
parts of London and
contribute to a vibrant street
scene. Properly vetted these
vendors add value to the
street scene.
The next round of audits of
approved Guildhall caterers
will be completed.
ASAG-Augmented Safety Advisory Group for the City of London and partners
Page 21 of 27
Service Work Plan: Activity
2011-12
Review
9. Continue to develop the programme to
consolidate procedures and protocols to
improve consistency of inspection,
enforcement, advice, accuracy and
consistency of record keeping and
procedures.
Consider the future accreditation and
development of our ISO:9001 quality system
Develop further work to improve
consistency and effectiveness with
reference to the FSA Framework
Agreement, Health Protection Agency
Protocols and good practice.
Individual officers will be given specific
process related work as part of their
Performance & Development Framework
objectives.
events.
The first round of audits of
prospective Guildhall caterers
was completed.
To continue to work on
developing workable consistent
processes and procedures.
PH&PP have examined various
commercially available systems;
none have been felt suitable to
cover the broad range of
procedures across PH&PP
Work has focused on specific
issues developed by other
PH&PP service commitments
including the Olympics.
Capacity building and training
of staff has been considered in
the event of a serious food
incident/crisis/infection affecting
public health.
The City plans to adopt the
UKFSS22 system for recording
food and feed samples. This is a
database that can be used by
22 UKFSS- UK Food Surveillance Scheme See www.food.gov.uk/enforcement/monitoring/fss
Page 22 of 27
2012-13
Work Planned/Activity
Develop our services content
for the revised City
Corporation website; work
continues into 2012 with a
launch end Q1.
Procedures and protocols are
required for the FHRS system
and will be developed Q4
2011-12 and Q1 2012-13
Procedures and protocols are
required for the development
of the UKFSS sampling system.
Further training and exercises
are planned to enhance
training and capacity
building for food/infectious
disease investigation
(preparedness)
The legal proceedings work is
underway managed by the
AD (PH&PP).
Service Work Plan: Activity
2011-12
Review
10. Increase awareness and effectiveness of
pest control management in food
businesses. Training was completed in
January 2011 for field officers on insect
activity and pest management building on
the previous year’s rodent control. The
closures of food premises have all related
at least in part to a failure to control pests.
Westminster-Aiming High initiative24 - will
this result in improvements in the City?
Small food businesses and their
understanding of what is required
Pest Control companies and their
standard contracts - will eradication
contracts work better and will there be
sign up by the pest control companies to
them?
all local authorities and
laboratories (the HPA23 and
Public Analyst)
UKFSS work will commence late
Q4 2011-12.
There has been no formal review
of the ISO: 9001 quality system.
Lack of understanding and
commitment to pest control
management and active pest
problems continue to result in
more formal action.
A more co-ordinated approach on pest control is still not
formulated.
Evaluation of pest activity
(anecdotal) indicates an
increase in rodent and insect
activity.
Enforcement work has
increased even when pest
control companies engaged
before our intervention.
2012-13
Work Planned/Activity
Olympic work in Q1 will
include pest control advice
No further planned
commitment until after the
Olympics.
The hypothesis remains that
food businesses and pest
controllers consistently fail to
coordinate their pest control
activities properly/effectively.
23 Health Protection Agency has a food water and environmental reference laboratory at Colindale which provides the City with microbiological
services
www.hpa.org.uk/ProductsServices/InfectiousDiseases/RegionalMicrobiologyNetwork/FoodWaterEnvironmentalMicrobiologyServices/FWEColindale/
24 An initiative to make pest control companies and their client food businesses take a more proactive approach to pest control management.
Page 23 of 27
Service Work Plan: Activity
11. Evaluate our commitment to food hygiene
training events.
We believe they can help improve poor
performance with better trained food
handlers supporting businesses to meet
their legal requirements, especially in
relation to effective Food Safety
Management Systems
12. We will continue to support the London
Scores on the Doors scheme whilst the
commitment remains in London or until
there is a change in policy or the law which
requires adoption of the FSA’s national
Food Hygiene Rating Scheme (FHRS).
2011-12
Review
Following a concerted effort by the FSA in
2011 to lobby all Local Authorities to adopt
a single national scheme in England and
Wales, the City has determined, with many
other London Boroughs, that we will now
adopt the FHRS. This will now launch prior
to the Olympics
2012-13
Work Planned/Activity
We have not secured the
No further specific work
necessary uptake to sustain the
planned in Q1 & 2.
4 courses we planned
Businesses will be directed to
An alternative form of delivery
other providers
was considered with an
alternative supplier but this was
not progressed because of
concerns about loss of potential
income generation.
The City and Port Health food
We consider the rating scheme
services will adopt the FHRS at
in London has been a success,
the start of Q1. All ratings will
contributing to the improvement
be listed under the new
in standards in businesses in our
scheme criteria from 1st April
area. This is supported by
evidence from FSA.
2012.
The Scores on Doors scheme will Migration preparation work
be replaced by the FSA’s Food
commenced in Q4 of 2011-12
Hygiene Rating Scheme [FHRS]
following a formal agreement
See 13- for more details on this
with the FSA. This agreement
national scheme.
released additional funds
Hygiene rating schemes provide
that enabled the financing of
consumers with published readily
the migration exercise.
accessible information about
There is a potential for
hygiene standards in food
confusion between schemes
premises operating in the City
and location of information
and beyond.
but there will be increased
Support for the Your London site
publicity for the national
ceased in Q2 2011. Information
scheme in the build up to the
25 Scores on the Doors is operated by Transparency Data http://www.scoresonthedoors.org.uk/
Page 24 of 27
Service Work Plan: Activity
2011-12
Review
was published on the Scores on
the Doors website from Q3. This
website was in turn acquired by
the FSA in late 201125.
13. Further Olympic works funded by FSA
This work was not considered in the original
plan for 2011-12 but work has developed in
the latter part of the 2011-12 year so it has
been included on the review of the year
and the plan for Q1 and Q2 of 2012-13.
Plans for a coordinated London
Olympic food project were
developed between ALEHM and
the FSA between November
2011 and January 2012
The Food Team prepared a bid
for FSA funding for work in the
City.
14. Work with the Data Management Team to
carry out a database ‘clean-up’ of food
premises.
Data management remains an important
priority.
2012-13
Work Planned/Activity
Olympics. With the
acquisition of Transparency
Data by FSA there is a direct
connection between
websites.
Delivery ALEHM Olympic
Project
Complete FHRS migration
and associated work.
Work started on improvements in 2009-10 and continues as we
develop procedures that
encompass the needs of all the
(various) users of the PH&PP
database.
In Q4 of 2011-12 we secured
funding from the FSA as part of
migration to the new FHRS to
further improve data entries to
the standard prescribed.
Page 25 of 27
Further development work is
envisaged with Data
Management now the
responsibility of an AD who
also manages regulatory
service teams.
Service Work Plan: Activity
15. Develop options for encouraging
businesses to provide Healthy Eating
Choices including setting up a Healthy
Eating Award for businesses that can
demonstrate good standards of Food
Hygiene and include healthy options on
their menu
16. Develop the Primary Authority Programme
with potential partner organisations.
2011-12
Review
2012-13
Work Planned/Activity
An application for further
funding to contribute to the
London wide Health Catering
Commitments Campaign was
applied for but rejected.
On-going
Work is on-going with a national
restaurant chain and it is
anticipated that a Primary
Authority Partnership Agreement
will e signed early in 2012-2013
On-going
Page 26 of 27
Food Safety Enforcement Targets - Key Performance Indicators [KPI’s]
To reduce average Food Hygiene compliance score below 15.026
[NEH1]
NI 184 (ex) Increase ‘Broadly Compliant’27 food premises from
91.3%28 to 95%
[NEH2]
75% food businesses inspected will receive a report/letter detailing
the outcome of their inspection within 5 working days and the
remainder within 10 working days. This will accord with standards
within the FHRS system
All authorised Food Safety staff to receive/complete the necessary
professional development with:-
13.55 (Q3)
(91.36%)
100%
Completed
at least 10 hours CPD on Food Safety tailored to delivery of this
Enforcement Plan; and
To complete their RDNA assessment.
26 Business Plan ‘Key Performance Indicator’
27 Judged as such by using Criteria 5, 6 and 7 - Food Hygiene Compliance, Structural Compliance and Confidence in Management – from Annex 5 of
Food Law Code of Practice- Scores >30 for these criteria combined are deemed non broadly compliant
27 LACORS – Local Authority Co-ordinators of Regulatory Services www.lacors.gov.uk
28 Based upon data up to the end of the third quarter.
Page 27 of 27