Health Protection Service Plan 2022-23

2.1 Aims and objectives

The Food Safety service aims to:

• assist the achievement of corporate objectives
• conduct its business in a consistent, fair, and transparent manner
• target the service in terms of risk to health and even-handedness, so serving to provide a ‘level playing field’ for local businesses; and
• satisfy consumer expectations of good standards in the district

It intends to achieve these aims by the following means:

• The use of robust performance and quality management to improve the quality of services
• The use of technology to improve efficiency and customer access to services by using, where  practicable, customer self-service and the contact centre
• Access to services can be made via the contact centre, website, telephone or e-mail in addition to traditional means; and
• Working with external and internal service areas partnerships

2.2 Links to corporate objectives and priorities

The Council has a comprehensive service improvement and performance management process. The Food Safety Service Plan feed into the following priority areas of the Council’s Corporate Plan 2021-2025.

• Improved Life Chances: Health, Social Care and Families, for example, robust implementation of the Food Standards Agency's E Coli O157 Guidance; implementation of the Health and Safety Executive’s National priorities, and implementation of Natasha’s Law/general allergen awareness raising
• Thriving Villages and Towns: Place shaping and Homes, for example, provision of food safety and health and safety training courses for local businesses/individuals; Daventry International Rail Freight Terminal Health, and Safety Forum
• Economic Development: Growth and Prosperity, for example, provision and development of Primary Authority, Business Support to local businesses and exploration of providing additional commercial services

Through a wealth of interventions including education/training, promotion, enforcement, audits/inspections, sampling, and consultation, Regulatory Services Health Protection aims to continually improve its services to assist the Council to achieve its corporate objectives.

3.1 Profile of the Local Authority: West Northants in Numbers

• £917m budget in 2021-22 including schools (£326.6m Net)
• 405,000 population
• 73,000 over 65s (21% increase in over 65s over next decade)
• 91,000 under 18s (2% increase in children aged 0-19 in next decade)
• 174,260 households
• 165 Town and Parish Councils
• 184 schools
• 1,707 Council buildings and assets
• 2,454km roads and carriageways
• £730.00 Median rent for a 2 bed
• £566.30 average wage

3.2 Executive Leadership

3.3 Place, Economy and Environment Directors

3.4 Regulatory Services Management

The following sections outline the principle demands on the Health Protection service.

4.1 Food Safety

As of 1 April 2022, West Northamptonshire Council has 3866 categorised local food businesses. The total number of food businesses has increased by 302 from the previous year. The risk category profile is as follows:

Intervention frequency is the minimum that the Council is required to carry out in accordance with the Food Standards Agency Food Law Code of Practice (England).

Food Hygiene Intervention Frequencies

• A at least every 6 months
• B at least every 12 months
• C at least every 18 months
• D at least every 24 months
• E Alternative enforcement strategy or interventions every three years

During the period from 1 April 2021 to 31 March 2022, 541 new food businesses were registered with the Council.

There are 24 approved premises that are approved to handle, prepare, or produce products of animal origin for which requirements are laid down in Regulation (EC) No 853/2004.

4.2 Occupational Health and Safety

As of 1 April 2022, there are 8601 businesses within the West Northamptonshire district, for which the Local Authority is the Health and Safety Enforcing Authority. These are broken down into the following main groups:

Many other local businesses/organisations are enforced by the Health and Safety Executive as laid out in the Health and Safety (Enforcing Authority) Regulations 1998: A-Z guide to allocation - HSE and LAs
Working together - HSE.

4.3 Cross-cutting Services

4.3.1 Primary Authority

West Northamptonshire Council hold 32 primary authority partnerships with a range of local and national businesses. The primary authority scheme allows a business to have one regulatory source of advice and guidance and the Council can assure the businesses documented procedures. Other local authorities must take account of advice that the Council has issued. It can issue advice on all aspects of Regulatory Services functions.

The following sections outline the scope of service delivery by Regulatory Services Health Protection.

5.1 Food Safety/Infectious Disease Control

The Food Standards Agency (FSA) principally directs the Food Safety service delivery through its Framework Agreement. The Service Head is Ruth Austen, Assistant Director Regulatory Services. The lead food safety officer is Ed Cooke, Environmental Health Manager: Health Improvement, [email protected]

All members within Regulatory Services Health Protection who have food safety responsibilities shall have ready access to Food Standards Agency information together with relevant legal encyclopaedias.

5.1.1 Food Premises: Hygiene Inspections

West Northamptonshire Council follows the priority rating system identified in the FSA Food Law Code of Practice (England).

Interventions consist of questioning the food business operator and employees to discover their knowledge of food hazards and ability to control them. In addition to assessing relevant documentation, officers will also physically inspect the food premises, including food items, and observe food handling practices and procedures.

The following table shows the number of food hygiene inspections/interventions carried out during 1 April 2021 to 31 March 2022.

The following table shows the inspection profile for the year beginning 1 April 2022 to 31 March 2023 (Including the backlog of inspections pre-1 April 2022)

Data from the previous year has been included in the above table indicating the positive impact that Regulatory Services Health Protection has had on the backlog of inspections caused by the COVID pandemic response requirements.

Category A premises are those that pose the highest risk; this may be because of the nature of the activities and/or poor operating conditions. The minimum intervention frequency for the different categories of premises is given above. Food businesses receive interventions more than this where required. The Council uses proprietary software (NEC M3/Assure Public Protection) for logging and tracking all interventions.

Revisions in the Code of Practice enable Local Authorities to deal with low-risk premises (Category E) by means other than an inspection. Health Protection utilises alternative inspection strategies, such as the use of self-assessment questionnaires, to deal with these premises throughout the year.

Revisits are made to food premises where there are food safety matters not broadly complying with Food Law identified during a primary visit.

Hygiene improvement notices will be issued if work detailed on a previous intervention report has not been completed or if there are serious concerns about food safety during a primary visit. The legal notices assist to ensure that improvements are made within a reasonable timescale.

Hygiene emergency prohibition notices are used where there is an imminent risk to health. This would normally lead to immediate closure of the premises. Reasons for taking this action could include the discovery of pest infestations, the absence of water, or very poor control of food hazards and/or cleaning.

The business may decide to voluntarily close in these circumstances; officers would support that approach. A prosecution would be considered against the business involved if deemed appropriate in accordance with the Council’s Enforcement Policy.

The outcome of routine food hygiene inspections will be displayed on the Food Standards Agency (FSA) Food Hygiene Rating website and window stickers issued to food business operators in accordance with the National FSA Food Hygiene Rating scheme.

The COVID-19 Pandemic response has had a significant adverse impact on the Council’s ability to carry out the food safety service throughout recent years. As with many other Council’s, food safety officer capacity was redeployed to respond effectively to the pandemic. The FSA recognised this and has provided direction to Local Food Authorities throughout; essentially leading to the focus on the very highest risk food safety interventions whilst deferring planned interventions. The FSA Board agreed a Local Authority Recovery Roadmap which provides direction on re-starting the regulatory delivery system in line with the Food Law Code of Practice for the highest risk establishments while providing greater flexibility for lower
risk establishments.

The Recovery Roadmap takes account of the following points:

• Numbers of ‘new’ food businesses have significantly increased and, although some may never have started trading and others will have ceased trading, the risks associated with them remain largely unknown
• Some existing businesses may have changed hands while others may start up to capitalise on potential additional trade from staycations etc. this year
• Existing businesses will gradually be re-opening, many after prolonged closure, as restrictions on businesses in the hospitality sector on eating onsite are lifted, while others will continue to diversify activities to adapt to ongoing changes in the market.
• The highest risk establishments – which represent a relatively small proportion of the total number of establishments – may have missed one, two or, in a very small number of cases, three planned interventions
• Local Authority resources have been – and in many cases still are – diverted during the pandemic to activities related to reducing the spread of COVID-19
• Local Authorities are anecdotally reporting that significant resource is currently being used for non-statutory, but important, wider government priorities such as export certification
• Local Authorities are also anecdotally reporting that in some cases hygiene standards have reduced since the onset of the pandemic.

The following table illustrates the FSA expectations and timescales included within the Recovery Roadmap.

The FSA have declared that a new delivery model will be ready for implementation in 2023/24.

The Lead Food Officer shall ensure that all FSA expectations are met and exceeded if resources allow.

5.1.2 Support to Businesses

The Council shall provide appropriate and competent advice/support, through a variety of different means, to local businesses and residents, within its resource constraints. Much of the advice is made available through the Council website. Some charged discretionary enhanced support services are offered and it is the Regulatory Services Health Protection intention to expand those services.

Food safety/hygiene advice shall be routinely given as part of an intervention and is complimented using mail shots, national/local campaigns and promotional activities when required. Advice is also given out upon request when food business registration may well not be required, for example, pop-up food outlets.

5.1.3 Food Sampling

Food sampling is an integral part of the food hygiene intervention process.

Microbiological food sampling is carried out to meet 4 main objectives:

• To determine the current state of food safety in the West Northamptonshire Area as part of a structured sampling programme
• To improve the effectiveness of food hygiene interventions
• To investigate suspect cases of food poisoning where a link with a local business or food is suspected; and
• To investigate complaints about food

The Council’s food sampling plan shall link with the European Commission and the United Kingdom Health Security Agency (UKHSA) Regional sampling plan as well as taking account of local/County trends and needs.

Number of microbiological samples taken

5.1.4 Infectious Disease Control

General Practitioners across the Area report suspected cases of food poisoning to the Consultant for Communicable Disease Control (CCDC) at UKHSA. The local medical microbiological laboratories also advise the CCDC of positive results for food poisoning and food/water related illness. In turn, Regulatory Services Health Protection are advised so that they can carry out investigations to discover the source of
infection.

Documented procedures are available for the management of the investigations of outbreaks of food borne infectious disease. The procedures were developed and are regularly reviewed with the CCDC and other Regional Local Authorities.

Number of individual investigated cases (informal and formally notified)

5.1.5 Food Safety Incidents

The Food Standards Agency declares National food safety incidents from time to time and notifies food authorities of these by means of a ‘Food Alert’ procedure. Some notifications require directed action, whereas others are for information only. The Council ensures that all directed action is carried out.

Number of National Food Alerts received

5.1.6 Liaison with other Organisations

The Council is a member of the Northamptonshire Food Liaison Group. The group aims to:

• Act as a forum to provide consistency of enforcement
• Act as a facilitator for benchmarking activities; and
• Provide exercises to facilitate consistency.

Other links include:

• United Kingdom Health Security Agency (East Midlands)
• Building and Development Control Service (regarding any development within the district)
• Care Quality Commission (regarding residential care home)
• Office for Standards in Education (regarding school and nursery provision)
• Police and Fire Authority (regarding licensing matters); and
• Local and national area forums, such as the Primary Authority Regulatory Group and the Local Authority Food Hygiene Rating Scheme user group

5.1.7 Promotion and Education

Regulatory Services Health Protection will contribute to the National ‘Food Safety Week’. Activities are based around raising public awareness of food safety and hygiene issues.

As a registered training centre, the Council offers a range of both taught and e-learning food safety courses.

Regulatory Services will aim to maximise the use of social media platforms and enhanced used of the Council’s website to promote and educate on food safety matters.

5.2 Occupational Health and Safety

The Health and Safety Executive continues to encourage Local Authorities to focus the attention of their interventions on the National Priority Areas as set out in its document LAC 67-2 (Revision 11) - Setting Local Authority Priorities and Targeting Interventions (hse.gov.uk).

5.2.1 Occupational Health and Safety Interventions

Regulatory Services Health Protection has committed to engage in the following priority areas during 2022/23.

Warehousing and workplace transport: To ensure that health, safety, and welfare is effectively managed at local workplaces where warehousing and/or workplace transport is identified as poorly managed. That shall be done through targeted interventions, including focussed inspection/audit, and raising awareness through education/advice. Regulatory Services Health Protection will facilitate workplace transport focussed Health, Safety and Wellbeing forums.

Gas safety in commercial catering premises: To ensure proper installation, maintenance, and inspection by a competent Gas Safe registered engineer to ensure that staff and customers at commercial catering premises are protected from exposure to carbon monoxide gas. That shall be done through a range of
interventions to raise awareness, with local duty holders, of the risks of exposure to carbon monoxide in commercial kitchens from badly installed or faulty appliances; poor ventilation resulting in lack of make-up air to support combustion; and/or inadequate extraction systems.

Electrical safety in hospitality settings: To ensure that any electrical equipment which has the potential to cause injury is maintained in a safe condition. That shall be done through raising awareness to improve standards of compliance. Duty holders shall be reminded to ensure both the fixed installation and electrical appliances are inspected by a competent person at appropriate intervals.

Large scale public gatherings, including inflatable amusement devices: To ensure that health, safety, and welfare is effectively managed during large local public events. That shall be done through active engagement with the West and North Northamptonshire Event Safety Partnership and facilitating
Safety Advisory Groups as necessary.

5.2.2 Support to Businesses

The Council shall provide appropriate and competent advice/support, through a variety of different means, to local businesses and residents, within its resource constraints. Much of the advice is made available through the Council website. Some charged discretionary enhanced support services are offered.

Occupational health, safety and welfare advice shall be routinely given as part of an intervention and is complimented using mail shots, national/local campaigns and promotional activities when required.

5.2.3 Complaints about health, safety, and welfare at work

It is the Authority’s intention to investigate all complaints concerning health, safety, and welfare at work.

These complaints are commonly about the following matters:

• Equipment at work is not safe (guarding missing or electrical problems)
• Workplace is not safe because of defective floors or blocked fire exits
• Unsafe systems of work – employees are being required to carry out particular jobs or processes which they feel are unsafe, for example, use of chemicals, manual handling
• Inadequate protective clothing provided
• Welfare facilities not kept clean or in good repair

Additionally, members of the public contact the service to complain about conditions they have experienced while visiting shops, restaurants and leisure premises in the district.

Regulatory Services Health Protection shall assess and respond, where necessary, to consultations under the Licensing Act 2003.

5.2.4 Investigation of Reportable Accidents/Incidents

Employers have a duty to report certain categories of accidents. Accidents can be reported directly to the Council or to the Health and Safety Executive’s online reporting system.

It is the aim of Regulatory Services Health Protection to investigate all reported major accidents in line with guidance issued by the Health and Safety Executive. The purposes of the investigation are to both ensure legal compliance and to make sure that steps have been taken to prevent similar accidents or incidents occurring wherever possible.

Number of reported accidents/incidents

5.2.5 Liaison with other Organisations

Regulatory Services Health Protection is an active member of the Northamptonshire Health and Safety Liaison Group. The group aims to:

• act as a forum to provide consistency of enforcement
• act as a facilitator for benchmarking activities
• provide ‘standardisation’ exercises to facilitate consistency; and
• provide competent training at reasonable costs for members.

It also liaises with the Police, Fire Service, St Johns Ambulance, EMAS, and a range of other partners, to ensure that the major events happening in the district have safety planning very much at their heart. This is a particularly important role as many thousands of people could be placed at risk when event activities are not effectively controlled.

5.2.6 Promotion and Education

In addition to the activities outlined in section 5.2.1 above, as a registered training centre, the Council offers a range of both taught and e-learning health and safety courses.

Regulatory Services will aim to maximise the use of social media platforms and enhanced used of the Council’s website to promote and educate on occupational health and safety matters.

6.1 Resources

6.2 Staffing Allocation

(Senior) Environmental Health Officers have holistic responsibilities for food safety, occupational health and safety, and health improvement. This approach facilitates a broad approach to the protection of the health of the public within the district.

Much of Regulatory Services Health Protection consists of Environmental Health Practitioners and is complimented by Specialist Officers and Regulatory Support Officers. All Environmental Health Officers possess a BSc or MSc in Environmental Health, and many are Chartered Practitioners or working towards
this.

As of 1 April 2022, the Council has 15.34 Full Time Equivalent (FTE) to provide the services outlined in this service plan (detailed below). Unexpected demands on the service, such as vacancies, complex legal cases or the requirement to ensure virulent organisms (for example, Escherichia coli O157) are adequately controlled, have illustrated that lesser-risk interventions may well suffer. Services will be re-prioritised to high-risk based interventions accordingly. 

6.3 Enforcement Policies

An enforcement policy (the Policy) is in place to cover all environmental health functions. It sets out the general principles and approach that the Council will follow when considering enforcement action.

The policy takes account of the Regulators’ Code (the Code) published by the Better Regulation Delivery Office of the Department for Business, Innovation and Skills. The Code is underpinned by the statutory principles of good regulation, which states that regulatory activities should be carried out in a way, which is transparent, accountable, proportionate, and consistent and should be targeted only at cases in which action is needed.

6.4 Staff Development Plan

Every year development discussions shall be held with all members of staff and in light of the service plan objectives, action plans are drawn up for each individual. Action plans detail the training and development needs of the individual to meet service requirements.