Food law enforcement plan

Resources

4.1 Financial Allocation and ‘Efficiency Savings’

Expenditure on food law enforcement is identified within the CIPFA best value accounting framework.

The movement in the budget over the last seven years is shown below, divided between food safety, food standards and communicable disease control:

Food safety	2014-15 (£,000)	2015-16 (£,000)	2016-17 (£,000)	2017-18 (£,000)	2018-19 (£,000)	2019-20 (£,000)	2020-21 (£,000)	2021-22 (£,000)
Total budget	481	502	472	462	465	462	527	556
Increase/decrease (£,000) on previous year	-36	+21	-30	-10	3	-3	+65	+29
%age increase/decrease on previous year	-7.0%	-4.4%	-6.0%	-2.1%	+0.6%	-0.6%	+14.1%	+5.5%
Real terms increase/ decrease year on year (adding 3% for inflation)	-10%	+1.4%	-9.0%	-5.1%	-2.4%	-3.6%	+11.1%	+2.5%

 

Food standards	2014-15 (£,000)	2015-16 (£,000)	2016-17 (£,000)	2017-18 (£,000)	2018-19 (£,000)	2019-20 (£,000)	2020-21 (£,000)	2021-22 (£,000)
Total budget	129	129	135	204	210	197	216	227
Increase/decrease (£,000) on previous year	-25	+0	+6	+69	+6	-13	+19	+11
%age increase/decrease on previous year	-16.2%	0%	+4.7%	+51.1%	+2.9%	-6.2%	+9.6%	+5.1%
Real terms increase/ decrease year on year (adding 3% for inflation)	-19.2%	-3.0%	+1.7%	+48.1%	-0.1%	-9.2%	+6.6%	+2.1%

 

Communicable Disease control	2014-15 (£,000)	2015-16 (£,000)	2016-17 (£,000)	2017-18 (£,000)	2018-19 (£,000)	2019-20 (£,000)	2020-21 (£,000)	2021-22 (£,000)
Total budget	35	36	37	56	64	56	57	58
Increase/decrease (£,000) on previous year	-20	+1	+1	+19	+8	-8	+1	+1
%age increase/decrease on previous year	-36.4%	+2.8%	+2.8%	+51.4%	+14.3%	-12.5%	+1.8%	+1.8%
Real terms increase/ decrease year on year (adding 3% for inflation)	-39.4%	-0.2%	+0.2%	-48.4%	+11.3	-15.5%	-1.2%	-1.2%

 

The marked increase in 2017-18 was as a result of reassigning the whole of the Food Team resources and therefore salary budget to food safety and standards enforcement (and away from communicable disease control), with a significant component of the Health and Safety Team budget reflected for the first time against Communicable Disease Control. Further changes have arisen from a review of the percentage breakdown of officer time resulting in some realignment of staffing costs to more accurately reflect service/work activities.

The following table shows how the proportion of expenditure on central support costs has risen relative to the total budget for these food-related services has increased over this 6 year period, rising from 22.8% of the total service costs in 2016-17 to 24.2% as at 1st April 2022.

Expenditure	2016-17	2017-18	2018-19	2019-20	2020-21	2022-23
Total budget for food-related services	£643,830	£722,000	£738,310	£800,000	£818,360	£840,340
Central support and internal recharges (uncontrolled)	£147,020	£147,390	£158,970	£111,500	£209,220	£203,930
%age of total budget made up from central support and internal recharges (uncontrolled)	22.8%	20.4%	21.5%	13.9%	25.5%	24.2%

 

The budget provision includes various allocations for non-fixed costs, with some of the more pertinent indicated below:

• Staffing (includes all salary related costs):£632,560
• Travel (includes Mileage, pool cars, hire cars and diesel):£8,480
• Subsistence (includes Other travel related expenditure):£250
• Furniture and equipment (includes Purchase of furniture and equipment, equipment maintenance costs (incl. calibration), mobile phones: £2,750
• IT (includes Purchase of equipment and internal IT recharges):£31,200
• Legal services (includes Internal recharge for Legal Services):£10,190
• Food sampling (excl. drinking waters) (includes Cost of purchasing food samples, and the budget for having samples ‘analysed’ by the Public) Analyst and/or subject to ‘examination’ by a food examiner (when not covered as part of the Authority’s laboratory allocation) :£9,970

As with all other local authorities across Wales (and the UK as a whole) the Authority has had to contend with significant cuts in its Revenue Support Grant (RSG) in recent years, as a result of Government austerity measures, and has increasingly had to identify ways of delivering ‘efficiency savings’. Food law enforcement services have not been protected from these cuts. In practice, the required efficiency savings have been managed through a range of measures designed to reduce expenditure and to maximise income generation, where possible.

To date expenditure across the Service has been reduced by:

• The reduction Public Protection Manager positions (reduced from 4 to 2).
• Changes in the arrangements for providing a guaranteed out of hours service for Public Protection, with a significant reduction in expenditure.
• Cutting out the ‘contingency budget’ for the employment of food hygiene contractors.
• Cutting out the overtime budget for food premises inspections.
• Permitting officers to ‘buy more leave’ where this can be accommodated.
•  Pursuing more cost effective database solutions (for Public Protection as a whole). Subsequent to a new software provider (Tascomi) being engaged.
• Reducing expenditure on equipment maintenance, by identifying more competitive solutions for equipment calibration and by officers washing their own protective clothing.
• Adhering to officer ‘guidelines to reduce stationery, printing and postage costs’. In particular through greater use of electronic communications. During 2015-16, an electronic communication strategy was prepared for use across the Section, having regard to the Council’s Channel Access Strategy and results of a business survey, to increase the emphasis given to providing information and advice electronically, utilising the Council’s website and e-mail in particular. This work is ongoing.
• Adhering to officer ‘guidelines to reduce mileage expenditure.
• Use of in-house electronic inspection proformas to capture information on businesses electronically. While this has required a significant investment of time, to develop the proformas; for officers to become practised and proficient in their use; and, to generate comprehensive electronic records on each business, this investment should result in longer term efficiencies as the information gathered provides a starting point for subsequent inspections.

In addition, income has been secured through:

• Promoting and carrying out revisits for rescoring under the national Food Hygiene Rating Scheme.
• Entering into Primary Authority arrangements, as outlined under 3.4 above.
• Applying for a range of grants to support food law enforcement activities.

The Authority as a whole will continue to face further reductions in its RSG for the years ahead. However, there are no proposals to reduce the budget for food law enforcement during 2022-23, while the service remains committed to reducing expenditure where it is possible to do so.

Also, while continuing to pursue the cost reduction strategies covered above, the Service will continue to recover any costs associated with:

• advisory visits and related consultancy-type activities.
• food export certificates.
• Primary Authority partnership arrangements.

4.2 Staffing Allocation

The following staff were employed on food law enforcement during 2021-22

Food Law Enforcement – Officers

PP Manager (Health and Consumer Protection)

• Minimum qualifications:  BSc(Hons)/MSc Degree in Environmental Health or Diploma in Trading Standards, or antecedents
• Maximum Full time equivalent officers (FTEs), with some fluctuations through the year: 0.05

Environmental Health Officers (includes Port Health officer time)

• Minimum qualifications: BSc(Hons)/MSc Degree in Environmental Health
• Maximum Full time equivalent officers (FTEs), with some fluctuations through the year: 6.9

Trading Standards Officers

• Minimum qualifications: Diploma in Trading Standards, or antecedents
• Maximum Full time equivalent officers (FTEs), with some fluctuations through the year: 1

Food Safety/Standards Officers (includes Port Health Officer time)

• Minimum qualifications: Higher Certificate in Food Premises Inspection plus Certificate of Competence in Food and Agricultural Standards or equivalent )
• Maximum Full time equivalent officers (FTEs), with some fluctuations through the year: 1.6

Food Law Enforcement – Support Staff

Performance Collator

• Minimum qualifications: Not stipulated
• Maximum Full time equivalent officers (FTEs), with some fluctuations through the year: 0.6

Technical Clerks

• Minimum qualifications: Not stipulated
• Maximum Full time equivalent officers (FTEs), with some fluctuations through the year: 1

Summary of impact of Covid-19 on Food team Staffing

2 officers were fully seconded to the Test trace Protect Contact Tracing Service (TTP) from June 2020, and these secondments will continue until at least 30 June 2022, when a more regional approach to

management of vulnerable cases and contacts will be initiated. A further officer and the Lead Officer for Food Safety were partly seconded whilst also still providing oversight of the Food service. This partial secondment continued up to the end of March 2022.
In addition to secondments out of the Food Team to work on the Covid-19 Response, an experienced Area Food Safety Officer left the team in May 2021 and the Lead Trading Standards Officer (Food Standards) left the Authority in September 2021. Another officer went on Maternity Leave in 2021.

Whilst an officer from the team was able to step up into the Lead Officer (Food Standards) role, this created an additional vacancy in the team. Fortunately it was possible to recruit an Environmental Health Officer and Area Food Safety Officer to the Team in the autumn of 2021. However one of the newly appointed officers was seconded to another team in Public Protection on 1 April 2022, due to staff shortages.
In addition, a further Environmental Health Officer is due to retire from the team in June 2022

Also in line with other areas, the Food team was significantly affected by family bereavements, personal illness and serious family illnesses in 2021 and 2022, which resulted in a number of long term absences from the Team.
These issues have had a limiting effect on the pace at which the Food Standards Agency LA Recovery Plan has been implemented, and will be able to be implemented in 2022-23

4.3 Staff Development Plan

Annual training priorities are agreed for every member of staff, as part of the annual performance review process. Records of these performance reviews and training identified are maintained.
The Authority takes advantage of opportunities for low cost training offered by the Food Standards Agency and CIEH (Cymru) where it is available, although there was a marked decline in courses offered in recent years. Many courses only allow one or two delegates to attend, although there are some self-guided training courses available on the FSA website . In addition, training may be provided in-house, using the resources available through the Authority’s Training and Development Section, or by contracting external trainers in appropriate cases. Where additional training is required staff will be sent on courses/seminars run externally. Team meetings are also used as an opportunity to provide training.

During 2021-22, officers within the Food Safety and Standards Team benefited from a range of formal training opportunities. These courses included:

• The FSA Funded one newly appointed officer to attend the University of Birmingham Food Standards Endorsement of the Higher Certificate in Food Control
• Privately purchased ABC online training and webinars, accessible in real time or subsequently which allowed officers to manage time spent training more efficiently and flexibly. In house FSA National Consistency Exercise
• Imported Food training for officers of the Food team, both in relation to controls at ports and at inland premises,
• FSA Hypersensitivity training,

Further opportunities for knowledge sharing are pursued in relation to approved premises inspections by undertaking joint visits.
While prioritising training to meet key business/service needs the Authority will seek to ensure that each officer receives the minimum level of technical and professional training, necessary to satisfy the Food Safety Act Code of Practice, and Continual Professional Development requirements required to maintain professional status.

A training budget of approximately £5746 is available to the Section as a whole for 2022-23. As from 2019 the CPD required by the Code of Practice doubled from 10 to 20 hours, placing increased demands on the service in this area through increased Continual Professional Development requirements and the need to update existing policies and procedures surrounding authorisations and competencies. The Department also takes advantage of regular Food Standards Agency funding which is provided for officers to attend training courses and events, in addition to subscribing to an online professional Food Law Training service, to assist and ensure that officers undertake the necessary training to meet the Code of Practice Training obligations.