Evaluation of Food Safety Management Systems based on HACCP

Audit programme summary report

Executive summary

This audit programme was developed following publication of the report of the Inquiry into the 2005 E. coli outbreak in South Wales that considered local authority food hygiene law enforcement systems; the local authority arrangements for evaluating and supporting food business compliance with food safety management systems (FSMS)/HACCP related requirements, their management and delivery.

There was widespread awareness of the Pennington Inquiry and about 75% of local authorities audited had already reviewed their service in light of the report recommendations, often across all the local authorities within regional liaison groups. Most of these had already implemented improvements and others were in the process of doing so.

A range of innovative and useful good practice relating to food safety management practice was identified and these are included at Annexe iv of this report. About a third of the local authorities had undergone FSMS related third party or peer review process within the preceding two years. These were implemented by internal audit, inter-authority audits, or consistency exercises within the food liaison groups, such as regional HACCP evaluation and business risk rating exercises.

There was reliable evidence and good quality documented records showing detailed and thorough assessments of FSMS at approximately 25% of the local authorities audited.

For the remainder, where effective assessments and action could not be fully evidenced, this appeared largely attributable to deficiencies in record keeping rather than officer competence. About 80% of audited local authorities received recommendations concerning their record keeping practices. These deficiencies ranged in significance from relatively minor and easily rectified amendments to improve data capture, to major gaps in the inspection and compliance records of food establishments, which obscured the actual standard of any interventions and follow-up actions undertaken. It should be noted that the audit necessarily encompassed compliance and local authority enforcement activities that had preceded publication of the inquiry findings (March 2009), however all Agency audit recommendations addressed local authority practices at the time of the audit.

Auditor ‘reality checks’ at food businesses and officer interviews indicated that front-line officers generally had good levels of HACCP understanding at about 85% of these local authorities, but the application of these competencies could not be verified satisfactorily from the HACCP assessment, compliance and enforcement records. Sufficiently detailed records were often not maintained because record keeping tended to be ‘by exception’. There was also a marked inconsistency in record keeping between individual officers within local authorities where the local procedures did not prescribe adequately the format and the level of detail required, and when the forms used were inappropriate or not fully completed.

There was evidence of good local authority representation at recent Agency HACCP refresher training, but it was not clear that this knowledge had been shared routinely through cascade training within local authorities. About 25% of local authorities had authorised one or more food law enforcement officers who appeared to lack recent training related to FSMS and/or did not currently meet the Food Law Code of Practice requirements for continuing professional development (CPD), although the officer training and CPD records maintained by about 50% of local authorities were incomplete.

While there was much anecdotal evidence of informal monitoring and documented evidence of quantitative monitoring, there were few records of qualitative monitoring and/or any corrective actions taken. More than 70% of local authorities received recommendations on deficiencies in their internal monitoring arrangements, which in many cases related specifically to the qualitative monitoring of FSMS/HACCP activities. Most of the issues identified by the Agency could have been identified and addressed through effective local internal monitoring.

Premises requiring approval under Regulation (EC) No. 853/2004 are generally higher risk due to inherent hazards arising from their food operations. About 65% of the local authorities could not provide evidence from their files that all establishments had been inspected and/or approved or re-approved in full accordance with the Food Law Code of Practice and relevant legislation. A similar proportion had not used appropriate aides-memoire or inspection forms for the type of establishments inspected, which were deficient in guiding officers against all the food specific legislative requirements for the process subject to approval. This was the main contributory factor in most of the inspection record keeping deficiencies, including the retention of information confirming key business operations and evidence to demonstrate that the more stringent HACCP evaluation requirements had been met.

All local authorities had an enforcement policy based on a graduated approach to non-serious contraventions, and when informal advice had failed to secure compliance with FSMS requirements. On the basis of their inspection records, almost half of local authorities appeared to have some establishments with no indication of formal enforcement action, although the compliance history and current inspection findings suggested this course of action had become necessary. In a minority of cases (less than 10% of the total), instances were identified where officers had recorded continuing food safety failures over successive inspections, some of which appeared to be of a serious nature, without evidence of appropriate enforcement follow-up. These cases were referred back to the local authorities during the audit for immediate attention.

local authorities were generally providing appropriate and effective reactive services when FSMS related complaints were received, in terms of thorough investigation and the use of well considered targeting of food sampling activity.

The audits highlighted the importance of local management and oversight in achieving and maintaining a satisfactory quality of officer inspections, including FSMS assessment, follow-up action and record keeping. There is an increasing trend in the appointment of non-specialist local authority managers with wider regulatory remits. Of the local authorities audited, the CPD records indicated that about 15% of lead officers responsible for the operational and managerial lead on food hygiene and safety matters had not received recent food related and/or FSMS/HACCP refresher training.

All issues identified during the individual local authority audits have been or are being addressed through the local authorities’ implementation of their agreed audit action plans. These are subject to Agency follow-up audits to review timely progress and verify necessary improvements in service delivery.