Audit feedback meeting: 14 January 2005

Mark Du Val, LACORS (Chair)
Charlotte Meller, LACORS
John Barnes, Food Standards Agency
John Questier, Food Standards Agency
Abi Adeyemi, Food Standards Agency (Secretariat)
Doug Bloomfield, APHA
Kirsty Dawes, APHA
Iain Pocknell, Crawley Borough Council
Mark Pledger, Dover District Council
Mark Holden, London Borough of Hillingdon
Ray Smith, London Borough of Hounslow
Martin Smith, Hull & Goole PHA
Jenny Davenport, Manchester City Council
Graham Slee, Mersey PHA
Chris Melville, North East Lincolnshire PHA
Lee Mansfield, North West Leicestershire District Council
David Jones, Portsmouth PHA
Neil Aston, Solihull MBC
Sandra Westacott, Southampton City Council
Martyn Jones, Suffolk Coastal PHA
Davina Gomersall, Tendring District Council
Geoff Smith, Uttlesford District Council

Apologies were received from Tony Fox (LACORS), Bristol PHA, Leeds City Council, River Tees PHA, Shepway District Council & PHA and Thurrock Council.

Mark Du Val welcomed everyone to the audit feedback meeting held jointly between LACORS and Food Standards Agency. The feedback at this meeting was invited from those local and port health authorities that had been selected for audits as part of the 2003/2004 focused audit programme of imported food controls. A summary of the customer satisfaction questionnaires received from the audited authorities was circulated.

Mark invited comments from the attendees, beginning with the positive experiences arising from the audit programme.

Food Standards Agency: John Questier said that the questionnaire feedback was very positive and felt that the audits had been both helpful to individual ports and in contributing to the wider remit of the Step Change year. John Barnes said that the constructive approach of the authorities had contributed to the process and the successful outcome in terms of demonstrating, and, where necessary, strengthening the levels of imported food controls in operation. John Barnes and John Questier explained that implementation of the audit action plans developed by the authorities was being followed up and that the good practice and useful documents identified during the programme will be placed on the Agency website from February 2005 during the re-assessments currently underway.

John Barnes said that the authorities had showed that they were open to change during the audits and also willing to defend the differing approaches that arose from a wide variation in scale of operation and demands.

APHA (Association of Port Health Authorities): Doug Bloomfield said that the feedback received by APHA was positive and the audited authorities felt fairly treated. The audits had challenged assumptions at all levels and raised the profile of port work. APHA were also pleased that the Agency had involved HM Customs & Excise, as the role of HMCE was an important factor in the process.

Hounslow: Appreciated the approach of the auditors, which was very fair and professional. The pre-visit questionnaire (PVQ) was helpful and helped the team to get a firmer grasp on what was required. The audit has made them more focused and the outcomes have been very positive.

Solihull: Agreed with the previous comments and found the audit report particularly useful. Everyone was involved in the process and more resources had been made available as a result of the audit.

Uttlesford: The Authority were pleased with the professionalism and helpful approach demonstrated by the auditors. The audit was a useful learning process that had assisted in ensuring that necessary changes were implemented.

Hull & Goole: Agreed with comments from other authorities. Found the auditors very professional. As a result of the audit they have upgraded their policies and procedures and the level of training of their officers.

North East Lincolnshire: Found the auditors polite and co-operative. Can now use the report as a basis to bid for additional resources.

Dover District Council: Struggling to find any positives for the Authority, other than the outcomes. As a result of the audit, a project plan has been developed and financial support received from the Agency has enabled a seconded officer to be deployed on imported food control work.

Crawley: A very positive experience. The Authority found the conduct of the audit excellent, transparent and 'fantastic' compared to audits carried out by other bodies. The PVQ had provided a useful focus and the action plan with target dates was particularly helpful in prioritising follow-up work.

North West Leicestershire: Found the audit a useful exercise. Auditors were experienced, polite and co-operative. Hope to use audit report to obtain additional resources.

London Borough of Hillingdon: Agreed with comments made by the other authorities. Found that an audit focusing on NPOAO (food of non-animal origin) was very useful. As a result, they now have a dedicated budget for NPOAO control work and have established a permanent team.

Manchester: Agreed with earlier comments from the other authorities.

Tendring: The Authority was quite happy with the audit process. The imported food control Service at the Port had now been contracted out to Felixstowe.

Mersey: Representative was not in post at the time of the audit and therefore couldn't comment. However, the follow-up discussions were very useful and they now have support for additional staff resources.

Southampton: Found the audit an enjoyable experience and were impressed with the auditors' skills. This was a learning exercise for all involved and the auditors were prepared to discuss differences of opinion with polite good humour - the authority didn't feel that they were involved in a 'point-scoring exercise'. The PVQ was very useful and the process has focused the authority on their procedures.

Portsmouth: Found the audit process to be a painless experience and very useful. The two auditors were professional and knowledgeable. The audit had raised the profile of imported food control work with senior managers and Members.

Suffolk Coastal: Audit was a very positive experience conducted professionally by the auditors. The auditors were happy to participate in a two-way interaction and provided encouragement where things were found to be good. The audit report was a fair reflection of the findings.

Food Standards Agency: John Barnes noted that where deficiencies had been found during the audit, these were understandable and would be remedied by implementation of the authorities' agreed action plans.

APHA: Kirsty Dawes noted that some legal grey areas needed further consideration. There were problems with authorisations and the answer may be an updated, centrally issued definitive list of relevant legislation. Local authorities had increasingly needed to use non-EHOs and further central guidance on their qualification and authorisation levels would be helpful.

• Action Point: LACORS and the Agency to explore the possibility of LACORS issuing a central list of relevant authorisations.

APHA: It was also important that authorities with low levels of import activity that had not been audited yet should benefit from the experience of those that had. Kirsty was receiving enquiries from these authorities and had begun to explore ways in which information and assistance could be disseminated.

Suffolk Coastal: Found that a lot of time and effort were spent in preparing for the audit, but overall the audit had been a positive experience and there were no negatives to report.

Portsmouth: No negative comments regarding the audit process.

Southampton: Felt that more detail of evidence could have been included in the report. Although detailed feedback was provided on-site, it was difficult to remember the factual details underpinning some issues by the time the draft report was issued and when factual corrections were invited.

There were also some disagreements between the authority's legal services and the Agency's regarding due processes that had not been resolved.

FSA: John Barnes explained that the Agency's general approach in these circumstances was to point out any variations in opinion between the authority's and the Agency's legal advisors and to recommend that authorities seek further advice from their own legal services. This approach was reflected in the published reports, which would contain a factual description of the two points of view and a recommendation that the authority's approach should be reviewed. No further action would generally be taken by the Agency as these issues were ultimately matters that only the Courts could decide.

Tendring: Found the process time consuming, but otherwise no negatives to report.

Manchester: The Authority was not happy that the Agency had access to HMCE ('CHIEF') data, which they had been unable to obtain. The Authority was 'put on the spot' during the audit, particularly as the figures did not reflect their knowledge of actual trade.

FSA: John Barnes said that the Agency felt it vitally important that import trade statistics held by HMCE should be used during audits and made available to assist local authorities. The audits had been a learning experience for all involved and only through this process had it become evident that there were issues regarding the interpretation and reliability of these statistics. This data was now provided to local authorities and discussions were being held with HMCE regarding the availability of data and further areas of cooperation.

London Borough of Hillingdon: The only major negative impact arising from the audit was the loss of a member of staff as a direct consequence. However, the authority accepted that their recruitment vetting procedures had needed to be tightened.

North West Leicestershire: The Authority did not have a Member present at the audit, which would have been to their advantage. It was felt, therefore, that the Agency should do more to encourage Member participation in the audit process.

Crawley: The date of audit had not been negotiable despite difficult circumstances for the Authority, although it was accepted that the Agency probably needed to audit due to the Step Change pressures. Had experienced problems in getting their Members to attend the audit meeting. The budget has been cut and Members were unsure whether any more funds would be available - imported food control is not a local vote winner.

FSA: John Questier explained that the Agency was fully aware of the Authority's concerns regarding the availability of key personnel on the proposed audit date. The Agency normally seeks to agree an audit date that is acceptable to the authority concerned, however, it was important that the import controls at Gatwick airport were covered by the programme and the auditors were prepared to 'make the best' of, and to adapt the process, to whatever circumstances and staff were available at that time.

Dover: The Authority stated that the CHIEF data used by the Agency was inaccurate and that the Agency had a wrong assumption about the nature of Channel Tunnel controls. Although the Authority accepted the problems identified, it felt that the audit report did not reflect that the underlying problems of a lack of resources and the consequential lack of motivation.

FSA: John Barnes felt that this was not an appropriate forum for discussing problems with specific authorities, but in general terms, resources issues were a matter for individual local authorities. John Barnes further mentioned that the Agency had subsequently met with the appropriate Dover Member and that the Authority had applied for and received Agency funding made available to all local authorities for the purpose of enhanced surveillance and sampling checks.

John Questier explained the Agency's general approach to resource issues in terms of audit and published reports. It is difficult for auditors to determine objectively whether food law enforcement services are adequately funded in the absence of a sufficiently detailed local enforcement programme, including estimated resource needs and appropriately disaggregated budget figures. These details are always requested as part of the audit process and all relevant information provided by authorities is factually detailed in the published reports.

North East Lincolnshire: The Authority felt that they had been disadvantaged because the local Trading Standards Service had been unwilling to participate in the audit. The Authority had nothing negative to say about the process itself.

Hull & Goole: Found the process of producing policies and procedures time consuming, but were satisfied with the audit process.

Uttlesford: The Authority had no dedicated officer to do the work and therefore found preparation for the audit to be time consuming. The audit had highlighted problems with local issues that could not be easily or quickly changed.

Solihull: No major negatives, but found that the time allocated at the planning stage for the on-site audit was over estimated because the Agency had not appreciated the limited scale of activities. However, this had been adjusted appropriately by the auditors on site.

London Borough of Hounslow: The Authority found the audit process stressful due to the fact that they have a very small and busy team.

Dover suggested that smaller local authorities should join with a neighbouring authority to create a joint port authority especially where there are limited resources.

The group were informed that monitoring returns for imported food at ports and airports are to be reviewed and revised in due course.

It was pointed out that proformas and procedures were already on the Agency website to assist local authorities. Mark Du Val thought that local liaison groups could be used to promote port health authorities and it was noted that many regional groups have already started sharing information.

The Agency mentioned that funding for imported food work may continue next year.

Manchester pointed out the difficulties encountered while using a commercially available database for imported food work. APHA are to raise the issue of IT problems at their meeting in Liverpool later this year.

• Agency Action Point: Issue of problems encountered with software to be raised by Monitoring Branch at next meeting with the software provider.

It was suggested that APHA could assist the Agency�s Imported Food Division in the development of a report database that would be beneficial to all ports. It was mentioned that a volunteer was required from a port authority to test the food sampling database.

• Agency Action Point: Agency to request a volunteer from port authorities to test the food sampling database and to chase up requests for GRAIL (Guidance and Regulatory Advice on Imports Legislation database).

The Agency confirmed that the European Union regulation for consolidation of imported food would soon be replaced by the Official Food and Feed Controls and advised everyone to read the proposals and send in comments. APHA noted that the new training and experience requirements for POAO inspection were an issue of concern.

Mark Du Val and Doug Bloomfield thanked all those present for a full and frank discussion.