Health Protection Service Plan 2024-25

2.1 Aims and objectives

The Health Protection 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
• 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
• 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 Health Protection Service Plan feeds into the following priority areas of the Council’s Corporate Plan.

• Improved Life Chances: Health, Social Care & Families 
  • 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 & Towns: Place shaping & Homes 
  • provision of food safety and health & safety training courses for local businesses/individuals; Health, Safety and Wellbeing Forum
• Economic Development: Growth & Prosperity 
  • 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.

2.3 Links to Live Your Best Life ambitions

Since Integrated Care Northamptonshire launched its Live Your Best Life Strategy, Regulatory Services Health Protection have endeavoured to ensure that they play a key role in the collaborative approach to deliver better outcomes for the people of Northamptonshire through the set of 10 ‘Live Your Best Life’ ambitions. 

In addition to engagement with the Northampton and Daventry/South Northants Health & Wellbeing Forums, and various Local Area Partnerships, one associated workflow for the Health Protection team is to collaboratively support the numerous Community Larders across West Northamptonshire.

3.1 About West Northamptonshire Council

West Northamptonshire Council is the single unitary council responsible for providing a range of public services to residents and businesses in the areas of Daventry, Northampton and South Northamptonshire.

It has replaced Daventry District Council, Northampton Borough Council and South Northamptonshire Council, and now delivers all the services which were previously provided by these councils. 

These services include:

• collection of your household waste
• maintenance of parks and open spaces
• street cleaning
• environmental health
• planning services

West Northamptonshire Council also delivers many of the services which were provided by Northamptonshire County Council, including Education, Highways, Adult Social Care and Libraries.

Through one council, we are transforming these services for the better, and delivering them in a more joined-up and cost-effective way.

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 2024, West Northamptonshire Council has 3604 categorised local food businesses. 

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

There are 664 unrated premises. Unrated food premises are those that have not received a visit (official control) by a food inspector following receipt of the food business registration. 

All food business registrations are, nevertheless, triaged upon receipt to ensure that visits are based on risk and inspections prioritised accordingly.

During the period from 1 April 2023 to 31 March 2024, 579 new food businesses were registered with the Council.

There are 20 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 2024, 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 Is HSE the correct enforcing authority for you?

4.3 Business Development

The Business Development Team was established during 2023 to provide and develop charged-for discre-tionary Regulatory Services. 

The services currently include:

• Pest Control
• Primary Authority
• Training (online and taught)
• Undertaking re-rating food hygiene inspections
• Attestation certificates

The team is looking to expand the services delivered across Regulatory Service, including Health Protection to contribute to the income generation. 

This will include the promotion of the services during routine in-spection and investigation work and could include:

• Sale of business resources such as Safer Food Better Business packs
• Advertise online and taught training
• Bespoke business advice
• New business registration advice, coaching and mentoring
• Sampling (swimming pool)
• Export of Products not of Animal Origin sampling and certification
• Charging for Sports Ground Safety Certificate review and special certificates
• Expanding the pest control service
• Review of some current paid for services:
  • Private water supply sampling
  • Attestation certificates

4.3.1 Primary Authority

West Northamptonshire Council hold 33 active legal primary authority partnerships with a range of local and national businesses as illustrated below. The primary authority scheme allows a business to have one regulatory source of charged-for advice/guidance and the Council can assure the businesses documented procedures. 

Other local authorities must take account of advice that the Council has issued, and the Council can block enforcement action proposed by other local authorities if the primary authority partner has not followed the published advice. It can issue advice on all aspects of Regulatory Services functions.

• Avara Foods Ltd
• Avon Cosmetics Limited
• Barchester Healthcare Homes Ltd
• Blue Skies Holdings Limited
• Butchers Petcare Limited
• Butterflies Healthcare Ltd
• Carlsberg UK Limited
• Central Foods Ltd
• Childminding UK
• City Plumbing Supplies Holdings Limited
• CoffeeSafe
• DKL-Marketing Ltd
• Euro Food Brands Ltd
• Faccenda Foods Ltd
• Flogas Britain Ltd
• Hallmark Care Homes Group Holdings Ltd
• Highbourne Group Limited
• Houghton Hams Limited
• MA Assist Ltd
• Maclaren UK Limited
• Pepkor UK Retail Limited
• Poundland Limited x2
• QHotels Limited
• Radisson Hotels UK LTD
• Secure Living Limited
• The British Pepper & Spice Co Ltd x2
• Travis Perkins Plc x2
• Trends UK Ltd
• Weddel. Swift Distribution Ltd
• Wickes

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 Sally Burns, Director of Public Health and Regulatory Services. 

The lead food safety officer is Ed Cooke, Head of Health Protection and Business Support, [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 and the Council’s Legal Services.

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 total number of food hygiene interventions (planned and reactive) carried out during 1 April 2023 to 31 March 2024, broken down by the intervention types.

The following table shows the inspection profile for the year beginning 1 April 2024 to 31 March 2025 (Including the backlog of inspections pre-1 April 2024).

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 various 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. The Management Information Systems (MIS) have yet to be aggregated from legacy Council’s, however the Council has an ongoing project to aggregate the MISs which may have an adverse effect on achieving targets until it is completed.

The latest version of the Food Law Code of Practice enables Local Authorities to deal with lower-risk premises (Category D and E) by means other than ‘official controls’ such as a full on-site inspection. Many establishments rated category D can alternate between either an intervention that is an official control and an intervention that is not an official control of which there are a range of options. 

Local intelligence will be used to focus interventions on category D premises. Establishments rated category E can be subject to an Alternative Enforcement Strategy such as the use of self-assessment questionnaires. 

Health Protection intends to utilise the flexibility contained within the Food Law Code of Practice to ensure that as many of the premises as possible in this cohort are contacted to ascertain whether there have been any significant changes/to assess compliance (which would then act as intelligence to determine whether a physical inspection is needed).

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 or prohibition of a process. 

Reasons for taking this action could include the discovery of an active pest infestation, the absence of water, or extremely 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 Council is amongst many other Local Authorities across England who have a significant backlog of routine inspections (circa. 1400) created throughout the COVID-19 Pandemic, particularly Category D and E premises that were not included in the FSA Recovery Roadmap. 

The Council is being actively supported/monitored by the Food Standards Agency Strategy and Regulatory Compliance Division. A 3-year comprehensive plan, developed by the Council Officers was presented to the FSA Regulatory Compliance Division and accepted. 

The plan includes the following aspects aimed at reducing the backlog:

Triage of all new food business registrations 

There is a comprehensive triage process in place for new businesses, which provides the Council with de-tailed information about the business. Each food registration receives an automatic email containing a tri-aging form and general information regarding food safety/hygiene, Safer Food Better Business (SFBB) Safety Management System and allergens links. 

After receiving a response from the Food Business Opera-tor (FBO), a competent officer will review the food registration and triage forms. Following this, a second email will be sent with bespoke information relevant to the specific scale and nature of the business, such as cake bakers SFBB, etc. If the FBO does not reply to the email, a phone call or a follow-up email will be made to chase it up. A visit will be carried out if there is still no reply. 

Also, an onsite inspection will be performed for low-risk businesses that require the Food Hygiene Rating Scheme sticker, such as those attending events.

Workshops (non-official control) for compliant D-rated premises 

There are a substantial number of outstanding Category D Inspections, so an alternative approach using the flexibility within the Food Law Code of Practice was duly considered. The FSA have been presented with, and positively fed back, to a workshop-based proposal for non-official control of complaint D-rated premises. 

Council Officers outlined that during the initial phone call or email exchange with the FBO, they would carefully review the data stored in the respective Management Information System since the last inspection regarding changes in risk factors, layout, ownership details, and similar aspects. That will help you determine if the FBO is eligible to attend the workshop. 

Attendees at the workshop will receive an interactive presentation based on the local top ten food hygiene issues, a specific presentation on a local prosecution and opportunity for Questions/Answer. 

E-rated premises

The FSA questioned officers' proposal: ‘To allow focus on the backlog of Category D interventions …outstanding Category E interventions …. shall only be routinely rated when they are subject to complaint, or a notable change is brought to our attention. This approach will be reviewed on a 6-monthly basis and amended when the backlog of Category D interventions is under control.’ 

Nevertheless, officer agreed that they should consider using Regulatory Support Officers to gather information about E-rated businesses as part of its alternative enforcement strategy for now. 

Inability to carry out all initial inspections with the specified period

The Council is unable to carry out the initial inspection within 28 days as required by the Food Law Code of Practice due to the outstanding backlog of inspections; however, FSA/Council officers have agreed that they would drip-feed them into the inspection programme.

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

5.1.2 Support to Businesses

In line with the aims of the Business Development team, the Council shall provide appropriate and competent advice/support, through a variety of different means, to local businesses and residents, within its resource constraints.

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

5.1.3 Complaints about food, food hygiene/safety

It is the Authority’s intention to consider all complaints concerning food, food hygiene/safety. These complaints are commonly about the following matters:

• foreign objects in food, such as wood, metal, insects, mould
• unhygienic food premises and their staff
• unsafe food safety practices such as provision of undercooked food, lack of protective clothing and lack of hand washing

5.1.4 Food and Water Sampling

Food sampling is an integral part of the food hygiene intervention process. We also lead on the sampling and enforcement of Private Water Supplies.

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

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

5.1.5 Infectious Disease Control

General Practitioners across the Area report suspected cases of food poisoning to the United Kingdom Health Security Agency. The local medical microbiological laboratories also advise the UKHSA 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 and prevent further potential disease spread.

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 UKHSA and other Regional Local Authorities.

5.1.6 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.

5.1.7 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 
• 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 homes)
• Office for Standards in Education (regarding school and nursery provision)
• Police and Fire Authority (regarding licensing matters)
• Local and national area forums, such as the Primary Authority Regulatory Group and the Local Authority Food Hygiene Rating Scheme user group

5.1.8 Food Safety 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 setting priorities and targeting interventions. 

5.2.1 Occupational Health and Safety Interventions

Regulatory Services Health Protection has committed to engage in the following priority areas during 2024/25.

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 focused inspection/audit, and raising awareness through education/advice.

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.

Safety at Sports Grounds: to ensure the safety of the public attending designated sports grounds and those grounds with regulated grandstands. Regulatory Services Health Protection will advise, monitor, review and enforce as necessary the terms and conditions specified in safety certificates, engage with partner agencies (including participation in Safety Advisory Groups), and follow direction from the Sports Ground Safety Authority to ensure the sports ground operators are meeting their responsibilities.

Cellar Safety: To ensure that health, safety, and welfare is effectively managed in cellars, principally of food businesses. Duty holders shall be remined and made aware of hazards including slips, trips, falls, carbon dioxide and radon.

Planned Preventative Maintenance of Coffee Machines: To ensure that safety of coffee machines is effectively managed. Duty holders shall be reminded and made aware that coffee machines work under extreme pressure and if not checked regularly can become a lethal weapon.

5.2.2 Support to Businesses

In line with the aims of the Business Development team, the Council shall provide appropriate and competent advice/support, through a variety of different means, to local businesses and residents, within its resource constraints.

Occupational health, safety and welfare advice shall be routinely offered 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 consider 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 jobs or processes which they feel are unsafe such as 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 and planning consultations.

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.

5.2.5 Liaison with other Organisations

Regulatory Services Health Protection is an active member of the Northamptonshire Health & 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
• provide competent training at reasonable costs for members

It also liaises with the Police, Fire Service, St Johns Ambulance, East Midlands Ambulance Service, 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 vital role as many thousands of people could be placed at risk when event activities are not effectively controlled.

5.2.6 Health & Safety Promotion and Education

In addition to the points stated in 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

All officers shall be duly authorised in accordance with the delegated authority laid out in the Council’s Constitution. (Senior) Environmental Health Officers have holistic responsibilities for food safety, occupational health & 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 2024, the Council has a base budget for 17.28 Full Time Equivalent (FTE) to provide the services outlined in this service plan (detailed below). The capacity shall be uniformly split between Food Safety/Infectious Disease Control and Occupational Health and Safety. 

Unexpected demands on the service, such as vacancies, complex legal cases, or the requirement to ensure virulent organisms (e.g. 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. Permission to recruit to any vacancies opened throughout the year shall be made to the Council’s Approval to Recruit - Budget Control process.

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.

Regulatory Services will encourage and support individual officer professional development (including apprenticeships) to facilitate the ‘grow your own’ approach and help ensure an experienced and competent workforce.

Staff will cascade training received, as appropriate, to increase the knowledge base of colleagues.

Staff will carry out Continued Professional Development to help maintain their competence.

6.5 Quality Assessments

Documented procedures are being harmonised to ensure that the services provided by the Health Protection team are consistent and subject to continual improvement.

Published service standards are monitored on a regular basis.

6.6 Review against service objectives

This service plan pulls together significant information about the Council’s Food Safety service activities.

Health Protection team performance indicators, as shown below, shall be reviewed monthly through one 2 ones with the Service Managers and through the Regulatory Services Managers team meetings.